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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
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`MAXELL, LTD.,
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`Plaintiff
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`Civil Action NO. 5:19-cv-00036-RWS
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`v.
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`APPLE INC.,
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`Defendant.
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`JURY TRIAL DEMANDED
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`DECLARATION OF DR. BENJAMIN B. BEDERSON IN SUPPORT OF APPLE INC.’S
`MOTION FOR PARTIAL SUMMARY JUDGMENT OF NON-INFRINGEMENT OF
`U.S. PATENT NOS. 10,084,991 AND 8,339,493
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`Case 5:19-cv-00036-RWS Document 389-3 Filed 07/02/20 Page 2 of 2 PageID #: 19127
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`I, Dr. Benjamin B. Bederson, declare the following:
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`1.
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`I am Professor Emeritus of Computer Science at the University of Maryland. I
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`am over the age of eighteen, and I am a citizen of the United States. I have been retained by
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`defendant Apple Inc. (“Apple”) as a technical expert on issues relating to U.S. Patent Nos.
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`6,928,306 and 10,084,991 (the “’991 Patent”). I previously submitted a Rebuttal Expert Report
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`of Dr. Benjamin B. Bederson Regarding Non-Infringement of U.S. Patent Nos. 6,928,306 And
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`10,084,991 on June 4, 2020. This report contains a true and correct statement of the non-
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`infringement opinions I have formed in this case, and the basis and reasons for them. If called to
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`testify as to this declaration or the contents of the above-referenced report, I can and would
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`testify truthfully and competently.
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`2.
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`Attached as Exhibit B is a true and correct copy of excerpts from the Rebuttal
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`Expert Report of Dr. Benjamin B. Bederson Regarding Non-Infringement of U.S. Patent Nos.
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`6,928,306 And 10,084,991, dated June 4, 2020.
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` declare under penalty of perjury under the laws of the United States of America that the
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` I
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`foregoing is true and correct.
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`Executed on June 30, 2020, in Windsor, Massachusetts.
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`______________________________
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`Dr. Benjamin B. Bederson
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`2
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