Case 4:23-cv-01147-ALM Document 22-9 Filed 05/23/24 Page 1 of 5 PageID #: 460
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`Exhibit F
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`Case 4:23-cv-01147-ALM Document 22-9 Filed 05/23/24 Page 2 of 5 PageID #: 461
`Case 4:23-cv-00092-ALM Document 2@-2 Filed 05/23/24 Page 2 of 8 PagelD #: 363
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`Exhibit 10
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`Case 4:23-cv-01147-ALM Document 22-9 Filed 05/23/24 Page 3 of 5 PageID #: 462
`Case 4:23-cv-00092-ALM Document 22-9 Filed 05/23/24 Page 2 of 34 PagelD #: 862
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMANDIVISION
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`R2 Solutions LLC,
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`Plaintiff,
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`v.
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`Civil Action No, 4:21-cv-00092
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`TARGET CORPORATION, a
`Defendant.
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`DECLARATION OF ERIC LUCAS
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`|.MynameisEricLucas.IamthePresidentofR2SolutionsLLC.Tamalsothe
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`Z.
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`I am more than 18 years of age, and I am competent to make this Declaration.I
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`have personal knowledge ofthe facts contained in this Declaration, and I am competentto testify
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`on the matters set forth below.
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`-
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`R2 Solutions LLCis a limited liability company incorporated in Texas. Paul F.
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`Reidy formed and incorporated R2 Solutions LLC in 2016 and served as its Managing Member.
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`4,
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`R2 Solutions LLC wasincorporated with a principal place of business in Austin,
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`Texas. Mr. Reidy resided in Austin, Texas at that time, and hestill resides in Austin, Texas
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`today.
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`5;
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`Mr. Reidyis the President of Excalibur IP, LLC andheld thatrole at least as early
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`as 2020, whenI participated in discussions with him regarding the acquisition of his ownership
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`interest in R2 Solutions LLC.
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`1 of 3
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`Case 4:23-cv-01147-ALM Document 22-9 Filed 05/23/24 Page 4 of 5 PageID #: 463
`Case 4:23-cv-00097-ALM Document 20-9 Filed 05/22/22 Page 4 of 4 PagelD # 463
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`6.
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`OnApril 25, 2020, Acacia Research Group LLCacquiredall of Mr. Reidy’s
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`ownership interest in R2 Solutions LLC, and R2 Solutions LLChassince had a place of business
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`located at 6136 Frisco Square Blvd., Suite 400, Frisco, TX 75034.
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`7
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`OnApril 27, 2020, ExcaliburIP, LLC entered into a patent sale agreement with
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`R2 Solutions LLC. This acquisition included the assignmentall rights, title, and interest in, and
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`to, a large patent portfolio (the “Excalibur Portfolio”) to R2 Solutions LLC, The Excalibur
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`Portfolio includes U.S. Patent Nos. 8,190,610 (“the ’°610 patent”), 8,341,157 (“the ’157 patent”),
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`and 7,698,329 (‘the ’329 patent”). I understand that the ’610 patent, ’157 patent, and °329 patent
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`are the subjectof litigation between R2 Solutions LLC and Target Corporation.
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`8.
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`In the process of R2 Solutions LLC acquiring the ExcaliburPortfolio, I came to
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`understand that Excalibur IP, LLC licensed the Excalibur Portfolio to numerous companies
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`between May 2016, when Excalibur IP, LLC acquired the patents in the Excalibur Portfolio from
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`Yahoo!, and April 2020, when R2 Solutions LLC acquired the Excalibur Portfolio. During the
`period ofits ownership, Excalibur IP, LLC licensed the Excalibur Portfolio iii
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`licenses, except for iii were negotiated and consummated withoutlitigation.
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`9.
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`The ’610 patent, ’157 patent, and °329 patent were includedin the license
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`agreements that Excalibur IP, LLC consummated.
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`10.
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`Since R2 Solutions LLC acquired the Excalibur Portfolio, it has continued to
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`commercialize the patents withoutlitigation. Within the past year, R2 Solutions LLC negotiated
`and consummated licensing agreements for the Excalibur Portfolio withPo
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`EE 2rnong others.
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`Case 4:23-cv-01147-ALM Document 22-9 Filed 05/23/24 Page 5 of 5 PageID #: 464
`Case 4:23-cv-00092-ALM Document 20-9 Filed 05/23/24 Page 8 of 8 PagelD #: 864
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`i.
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`R2 Solutions LLC currently works to license the Excalibur Portfolio—including
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`the °610 patent, °157 patent, and ’329 patent—to dozens of other companies withoutthe
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`necessity oflitigation, R2 Solutions’soft licensing efforts are extensive and ongoing.
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`I declare under penalty ofperjury that the statements made in this Declaration are based
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`on my own knowledgeandthat all opinions given are my own.
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`Dated: May 19, 2021
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`Eric Lucas
`President, R2 Solutions LLC
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`3 of 3
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