`Petitioner
`
`V.
`
`Paragon BioTeck, Inc.,
`Patent Owner.
`
`Case PGR2015-00011
`Patent 8,859,623
`
`___.___:_____._.:___
`
`DECLARATION OF M. SAWAYA
`
`Document Number: 3327905
`
`Exhibit 1024, Page 1 Of 5
`
`Exhibit 1024, Page 1 of 5
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`
`
`I, Michael Sawaya, do hereby declare and state, that all statements made
`
`herein of my own knowledge are true and that all statements made on
`
`information and belief are believed to be true; and further that these
`
`statements were made with the knowledge that Wlllflll false statements and the
`
`like so made are punishable by fine or imprisonment, or both, under Section
`
`1001 of Title 18 of the United States Code.
`
` Dated: 02/57’6/'1”/'6
`
`
`
`Michael Sawaya, Esq.
`
`Exhibit 1024, Page 2 of 5
`
`Exhibit 1024, Page 2 of 5
`
`
`
`1, Michael Sawaya, declare as follows:
`
`information publicly available.
`
`4.
`
`As a privately held corporation, Altaire does not publish or
`
`otherwise make available the minutes ofits board meetings. Nor does it publish
`
`its by-laws or other procedures related to board decision making or voting. It
`
`certainly does not publish or otherwise make available internal discussions
`
`regarding strategic operation and planning ofthe corporation.
`
`Exhibit 1024, Page 3 of 5
`
`Exhibit 1024, Page 3 of 5
`
`
`
`5.
`
`Saw Aque as a privately held corporation also maintains the
`
`confidentiality of its board meetings. It does not publish or otherwise make
`
`available the minutes ofboard meetings, the procedures related to strategic
`decision-making, or methods or results ofvoting. This information is not
`
`currently publicly available. Furthermore, Saw Aque does not publish or make
`
`available internal financial information, such as the valuation confidentially held
`
`assets.
`
`6.
`
`The release ofthis confidential information would significantly
`
`negatively impact both Altaire and Saw Aque.
`
`7.
`
`The redacted testimony reflects, among other things,
`
`information Altaire has maintained as confidential and not made publicly
`
`available. In particular, the testimony discusses high level strategic business
`
`p1am1ing and decision-making information. The disclosure ofthis information
`
`could significantly negatively affect negotiations between Altaire and other
`
`parties. Furthermore, as the information pertains to ownership interests, strategic
`
`decision-making, and confidential agreements, the testimony could potentially
`affect the valuation of Altaire.
`
`Exhibit 1024, Page 4 of 5
`
`Exhibit 1024, Page 4 of 5
`
`
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`stated above with respect to Altaire. In particular, certain portions ofExh. 2034
`
`refer to internal financial valuation of confidential assets. The disclosure of such
`
`would not only affect the value ofthe asset, but could additionally affect the
`
`valuation of Saw Aque.
`
`9.
`
`For the above reasons, the highly confidential information of
`
`Altaire and Saw Aque should not be made public.
`
`Exhibit 1024, Page 5 of 5
`
`Exhibit 1024, Page 5 of 5
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