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`MAXELL, LTD.,
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`v.
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`APPLE INC.,
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
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`Plaintiff,
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`Case No. 5:19-cv-00036-RWS
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`JURY TRIAL DEMANDED
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`Defendant.
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`DECLARATION OF TIFFANY A. MILLER IN SUPPORT OF
`MAXELL, LTD.’S SUR-REPLY IN OPPOSITION TO APPLE INC.’S
`RENEWED MOTION TO STAY PENDING DETERMINATION OF INTER PARTES
`REVIEW OF THE PATENTS-IN-SUIT
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`I, Tiffany A. Miller, hereby declare and state as follows:
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`1.
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`I am an attorney at Mayer Brown LLP, counsel for Plaintiff Maxell, Ltd.
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`(“Maxell”) in the above-captioned lawsuit. I submit this declaration in support of Maxell’s Sur-
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`Reply in Opposition to Apple Inc.’s (“Apple”) Renewed Motion to Stay Pending Determination
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`of Inter Partes Review of the Patents-in-Suit. I have personal knowledge of the statements
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`herein, and, if called to do so, I could and would testify competently as to the same.
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`2.
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`Attached as Exhibit EE is a true and correct copy of Petitioner’s Notice of
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`Appeal for IPR2020-00203, filed on August 5, 2020.
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`3.
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`Attached as Exhibit FF is a true and correct copy of Petitioner’s Notice of Appeal
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`for IPR2020-00407, filed on August 27, 2020.
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`4.
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`Attached as Exhibit GG is a true and correct copy of Petitioner’s Notice of
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`Appeal for IPR2020-00408, filed on August 27, 2020.
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`1
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`PUBLIC VERSION
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`PUBLIC VERSION
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`Case 5:19-cv-00036-RWS Document 530-1 Filed 09/04/20 Page 2 of 2 PageID #: 28002
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`5.
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`Attached as Exhibit HH is a true and correct copy of Petitioner’s Notice of
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`Appeal for IPR2020-00409, filed on August 27, 2020.
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`6.
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`Attached as Exhibit II is a true and correct copy of Petitioner’s Request for
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`Rehearing Under 37 C.F.R. § 42.71(D) for IPR2020-00201, filed on July 6, 2020.
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`7.
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`Attached as Exhibit JJ is a true and correct copy of the Complaint for
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`Declaratory and Injunctive Relief filed by Apple Inc., Cisco Systems, Inc., Google LLC, and
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`Intel Corporation in the Northern District of California on August 31, 2020 (Case No. 5:20-cv-
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`6128).
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`8.
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`Attached as Exhibit KK is a true and correct copy of transcript excerpts from the
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`Deposition of Kenji Nakamura, taken on February 21, 2020.
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`I declare under penalty of perjury under the laws of the United States of America that the
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`above is true and correct and that this Declaration was executed on September 2, 2020 in
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`Washington, D.C.
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`Dated: September 2, 2020
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`By:
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`_______________________
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`Tiffany A. Miller
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`2
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`PUBLIC VERSION
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