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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`CASE NO. 6:21-cv-00665-ADA
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`JURY TRIAL DEMANDED
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`
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`CASE NO. 6:21-cv-00667-ADA
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`JURY TRIAL DEMANDED
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`
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`CASE NO. 6:21-cv-00668-ADA
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`JURY TRIAL DEMANDED
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`VOIP-PAL.COM, INC.,
`
`Plaintiff,
`
`v.
`
`META PLATFORMS, INC. and
`WHATSAPP LLC,1
`
`Defendants.
`
`
`VOIP-PAL.COM, INC.,
`
`v.
`
`GOOGLE LLC,
`
`Plaintiff,
`
`Defendant.
`
`
`VOIP-PAL.COM, INC.,
`
`Plaintiff,
`
`v.
`
`AMAZON.COM, INC., et al.,
`
`Defendants.
`
`
`1 Defendants have filed a notice of name change and unopposed motion to correct the docket in
`Case No. 6:21-cv-00665-ADA.
`
`
`
`
`
`Case 6:21-cv-00667-ADA Document 37-1 Filed 03/14/22 Page 2 of 4
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`
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`CASE NO. 6:21-cv-00672-ADA
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`JURY TRIAL DEMANDED
`
`
`
`CASE NO. 6:21-cv-00674-ADA
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`JURY TRIAL DEMANDED
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`VOIP-PAL.COM, INC.,
`
`Plaintiff,
`
`v.
`
`VERIZON COMMUNICATIONS, INC.,
`et al.,
`
`Defendants.
`
`
`VOIP-PAL.COM, INC.,
`
`Plaintiff,
`
`v.
`
`T-MOBILE USA, INC.,
`
`Defendant.
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`
`
`DECLARATION OF ROBERT W. UNIKEL IN SUPPORT OF
`DEFENDANTS’ OPENING CLAIM CONSTRUCTION BRIEF
`
`I, Robert W. Unikel, declare as follows:
`
`1.
`
`I am an attorney with the law firm Paul Hastings LLC and counsel for Defendant
`
`Google LLC (“Google”). I have personal knowledge of the facts contained in the declaration and,
`
`if called upon to do so, I could and would testify competently to the matters set forth herein.
`
`2.
`
`Attached hereto as Exhibit 1 is a true and correct copy of U.S. Patent No. 8,630,234
`
`(issued Jan. 14, 2014).
`
`3.
`
`Attached hereto as Exhibit 2 is a true and correct copy of U.S. Patent No.
`
`10,880,721 (issued Dec. 29, 2020)
`
`2
`
`
`
`Case 6:21-cv-00667-ADA Document 37-1 Filed 03/14/22 Page 3 of 4
`
`
`
`4.
`
`Attached hereto as Exhibit 3 is a true and correct copy of U.S. Patent Application
`
`No. 13/056,277, Reply to Non-Final Office Action with Amendment (dated May, 24, 2013),
`
`bearing the Bates range VOP0008173 - VOP0008211.
`
`5.
`
`Attached hereto as Exhibit 4 is a true and correct copy of U.S. Patent Application
`
`No. 13/056,277, Information Disclosure Statement (dated Sept. 13, 2013), bearing the Bates range
`
`VOP0008080.
`
`6.
`
`Attached hereto as Exhibit 5 is a true and correct copy of Wikipedia, “Roaming,”
`
`http://en.wikipedia.org/wiki/Roaming (accessed July 16, 2013), cited in U.S. Patent Application
`
`No. 13/056,277, Information Disclosure Statement (dated Sept. 13, 2013).
`
`7.
`
`Attached hereto as Exhibit 6 is a true and correct copy of excerpts from Andy
`
`Valdar, Understanding Telecommunications Networks,
`
`bearing
`
`the Bates
`
`range
`
`VOP_RBR0009420 - VOP_RBR0009421.
`
`8.
`
`Attached hereto as Exhibit 7 is a true and correct copy of excerpts from Federal
`
`Standard 1037C, “Telecommunications: Glossary of Telecommunication Terms” (Aug. 7, 1996),
`
`prepared by the National Communications System Technology and Standards Division and
`
`bearing the Bates range DEFS-VOIP-2021-CC-00000046 - DEFS-VOIP-2021-CC-00000057.
`
`9.
`
`Attached hereto as Exhibit 8 is a true and correct copy of excerpts from Microsoft
`
`Computer Dictionary (5th ed. 2002), bearing the Bates range DEFS-VOIP-2021-CC-00000058 -
`
`DEFS-VOIP-2021-CC-00000065.
`
`10.
`
`Attached hereto as Exhibit 9 is a true and correct copy of excerpts from Althos
`
`Publishing, Wireless Encyclopedia (2007), bearing the Bates range DEFS-VOIP-2021-CC-
`
`00000085 - DEFS-VOIP-2021-CC-00000087.
`
`3
`
`
`
`Case 6:21-cv-00667-ADA Document 37-1 Filed 03/14/22 Page 4 of 4
`
`
`
`11.
`
`Attached hereto as Exhibit 10 is a true and correct copy of U.S. Patent Application
`
`No. 14/035,806, Information Disclosure Statement (filed Dec. 23, 2013), bearing the Bates range
`
`VOP0007738-VOP0007744.
`
`12.
`
`Attached hereto as Exhibit 11 is a true and correct copy of WIPO International
`
`Patent Application Publication No. WO 01/89145 A2 (published Nov. 22, 2001).
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed this 11th
`
`day of March, 2022 in Chicago, Illinois.
`
`
`
`
`/s/ Robert W. Unikel
`Robert W. Unikel
`
`
`
`4
`
`
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