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`AGIS SOFTWARE DEVELOPMENT, LLC,
`
`
`Plaintiff,
`
`v.
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`§
`Case No. 2:17-cv-513-JRG
`§
`(LEAD CASE)
`§
`
`§
`
`§
`§
`JURY TRIAL DEMANDED
`§
`§
`§
`§
`
`
`
`DECLARATION OF SHAHAR HAREL IN SUPPORT OF
`PLAINTIFF AGIS SOFTWARE DEVELOPMENT, LLC’S
`OPENING CLAIM CONSTRUCTION BRIEF
`
`Shahar Harel, hereby declares as follows:
`
`
`HUAWEI DEVICE USA INC., ET AL.,
`
`
`Defendants.
`
`1.
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`I am an attorney at the law firm of Brown Rudnick LLP, counsel for Plaintiff
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`AGIS Software Development, LLC (“Plaintiff”). I am admitted to practice before this Court. I
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`submit this declaration in support of Plaintiff AGIS Software Development, LLC’s Opening
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`Claim Construction Brief. I am familiar with the facts set forth herein.
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`2.
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`The exhibits attached to this declaration may contain annotations and/or excerpts
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`of the originals.
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`3.
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`Attached hereto as Exhibit A is a true and correct copy of U.S. Patent No.
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`8,213,970.
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`4.
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`Attached hereto as Exhibit B is a true and correct copy of U.S. Patent No.
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`9,408,055.
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`5.
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`Attached hereto as Exhibit C is a true and correct copy of U.S. Patent No.
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`9,445,251.
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`
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`
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`Case 2:17-cv-00513-JRG Document 165-2 Filed 07/26/18 Page 2 of 3 PageID #: 6265
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`
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`6.
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`9,467,838.
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`Attached hereto as Exhibit D is a true and correct copy of U.S. Patent No.
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`7.
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`Attached hereto as Exhibit E is a true and correct copy of US Patent No.
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`9,749,829.
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`8.
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`Attached hereto as Exhibit F is a true and correct copy of annotated excerpts of
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`Google LLC’s Petition for Inter Partes Review of U.S. Patent 8,213,970, Google LLC v. AGIS
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`Software Development, LLC, Case No. IPR2018-01079, Paper 2 (P.T.A.B., May 15, 2018).
`
`9.
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`Attached hereto as Exhibit G is a true and correct copy of annotated excerpts of
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`Apple Inc.’s Inter Partes Review of U.S. Patent 8,213,970, Apple Inc. v. AGIS Software
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`Development, LLC, Case No. IPR2018-000821, Paper 1 (P.T.A.B., March 22, 2018).
`
`10.
`
`Attached hereto as Exhibit H is a true and correct copy of the Declaration
`
`Dr. Jaime G. Carbonell.
`
`11.
`
`Attached hereto as Exhibit I is a true and correct copy of an annotated excerpts of
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`Apple Inc. v. AGIS Software Development, LLC, Case No, IPR 2018-000821, Ex. 1002
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`(P.T.A.B., March 22, 2018).
`
`12.
`
`Attached hereto as Exhibit J is a true and correct copy of an annotated excerpt of
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`Google LLC v. AGIS Software Development, LLC, Case No, IPR 2018-01079, Ex. 1003
`
`(P.T.A.B., May 15, 2018).
`
`13.
`
`Attached hereto as Exhibit K is a true and correct copy of annotated excerpts from
`
`the file history of U.S. Patent No. 8,126,441 including a February 23, 2011 Amendment and
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`Response to Office Action.
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`14.
`
`Attached hereto as Exhibit L is a true and correct copy of U.S. Patent No.
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`8,125,441.
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`
`
`2
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`
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`Case 2:17-cv-00513-JRG Document 165-2 Filed 07/26/18 Page 3 of 3 PageID #: 6266
`
`
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`15.
`
`Attached hereto as Exhibit M is a true and correct copy of annotated excerpts
`
`from the file history of U.S. Patent No. 9,445,251 including a November 13, 2015 Amendment
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`and Response to Office Action.
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`16.
`
`Attached hereto as Exhibit N is a true and correct copy of annotated excerpts from
`
`the file history of U.S. Patent No. 9,445,251 including a December 10, 2015 Office Action.
`
`17.
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`Attached hereto as Exhibit O is a true and correct copy of annotated excerpts from
`
`the file history of U.S. Patent No. 9,445,251 including a January 26, 2016 Amendment and
`
`Response to Office Action.
`
`18.
`
`Attached hereto as Exhibit P is a true and correct copy of Apple Inc. v. AGIS
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`Software Development, LLC, Case No. IPR 2018-00818, Paper No. 1 (P.T.A.B., March 22,
`
`2018).
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`19.
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`Attached hereto as Exhibit Q is a true and correct copy of Appendix 1 to the
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`Claim Construction brief.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed this 25th day of July, 2018.
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` /s/ Shahar Harel
` Shahar Harel
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`3
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