`EXHIBIT B
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`Additional Support for Belief That Relevant Technical Documents Have Not Been Produced
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`Category
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`Additional Support
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`Schematics Not Produced
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`Incomplete Schematics
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`Documents Describing
`Cellular Functionalities
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`Requirements
`Specifications
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`A job listing at Apple for “RF Requirements Engineer” at
`https://jobs.apple.com/en-us/details/200082891/rf-
`requirements-engineer confirms that one of the tasks of such an
`engineer is to “Generate product specific RF Requirements
`Specifications insuring that functional and performance
`requirements are fully vetted and consistent with overall
`product definition and design goals.” Apple has not produced
`RF Requirements Specifications.
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`PUBLIC VERSION
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`Case 5:19-cv-00036-RWS Document 198-2 Filed 02/19/20 Page 2 of 2 PageID #: 8557
`EXHIBIT B
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`Apple runs a webpage describing tests Apple conducts to test
`the battery performance of its devices, including tests
`performed on the CDMA network and streaming videos,
`features implicated in the ’193, ’991, and ’493 Patents. See
`https://www.apple.com/iphone/battery.html
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`Publicly available documents confirm the presence of Apple’s
`testing labs where they conduct numerous tests on their devices
`prior to their release. See
`https://www.vox.com/2014/9/25/11631290/inside-apples-
`secret-testing-labs-where-phones-are-bent-all-day-long; see
`also https://www.independent.co.uk/life-style/gadgets-and-
`tech/features/apple-iphone-privacy-security-park-interview-
`federighi-a8925291.html
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`Testing Documents
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`PUBLIC VERSION
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