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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 REPLY
`IN SUPPORT OF ITS OPPOSED MOTION TO SEVER NON-SELECTED PATENTS
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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. (“Maxell”)
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`in the above-captioned lawsuit. I submit this declaration in support of Maxell’s Reply in Support
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`of its Opposed Motion to Sever Non-Selected Patents. 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 D is a true and correct copy of Defendant Apple Inc.’s
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`Identification of Narrowed Prior Art Invalidity Challenges, dated February 8, 2021.
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`3.
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`Attached as Exhibit E is a true and correct copy of an e-mail sent from Tiffany
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`Miller to Michael Jay on January 28, 2021.
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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 March 8, 2021 in Washington,
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`D.C.
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`1
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`Case 5:19-cv-00036-RWS Document 650-1 Filed 03/08/21 Page 2 of 2 PageID #: 33153
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`Dated: March 8, 2021
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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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