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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`CIVIL ACTION NO. 6:20-cv-00272-ADA
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`VOIP-PAL.COM, INC.,
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`Plaintiff,
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`v.
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`AMAZON.COM, INC.;
`AMAZON.COM SERVICES LLC; and
`AMAZON WEB SERVICES, INC.
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`Defendants.
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`DECLARATION OF LEWIS E. HUDNELL, III IN SUPPORT OF PLAINTIFF VOIP-
`PAL.COM’S OPPOSED MOTION FOR PARTIAL RECONSIDERATION OF CLAIM
`CONSTRUCTION ORDER
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`I, Lewis E. Hudnell, III, declare and state as follows:
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`1. I am an attorney licensed to practice law in the State of California and the, State of New York
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`and admitted to practice in this District.
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`2. I am an attorney at the Hudnell Law Group, P.C., 800 W. El Camino Real, Mountain View,
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`California 94040 representing Plaintiff VoIP-Pal.com, Inc. (“VoIP-Pal”) in the above-captioned
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`case.
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`3. I make this declaration in Support of Plaintiff VoIP-Pal.com’s Opposed Motion For Partial
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`Reconsideration of Claim Construction Order. I have personal knowledge of the facts contained
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`in this Declaration and, if called as a witness, I could and would testify competently to those
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`facts.
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`4. Attached to this declaration as Exhibit 1 is a true and correct copy of an excerpt of the
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`transcript of the February 15, 2023 Claim Construction hearing.
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`5. Attached to this declaration as Exhibit 2 is a true and correct copy of an email exchange
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`1
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`Case 6:20-cv-00272-ADA Document 89-1 Filed 03/10/23 Page 2 of 2
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`between N. Mcqueen and L. Hudnell regarding the Court’s Preliminary Constructions, dated
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`February 12, 2023.
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`6. Attached to this declaration as Exhibit 3 is a true and correct copy of the Written Opinion of
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`the International Searching Authority, Application No. PCT/CA2007/001956, dated February 20,
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`2008, excerpted from the File History of U.S. Patent No. 8,542,815.
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`7. Attached to this declaration as Exhibit 4 is a true and correct copy of U.S. Patent No.
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`9,179,005 B2, dated November 3, 2015.
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`8. Attached to this declaration as Exhibit 5 is a true and correct copy of U.S. Patent No.
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`11,171,864 B2, dated November 9, 2021.
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`9. Attached to this declaration as Exhibit 6 is a true and correct copy of WO2008052340.
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`Under 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and
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`correct.
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`Executed on this 10th day of March 2023, in Mountain View, California.
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`/s/ Lewis E. Hudnell, III
`Lewis E. Hudnell, III
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