`AMAZON.COM, INC., AMAZON.COM
`SERVICES LLC, and AMAZON WEB
`SERVICES, INC.,
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`v.
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`Defendants.
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`Case 6:21-cv-00898-ADA Document 303 Filed 08/06/24 Page 1 of 3
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`IN THE UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`ALMONDNET, INC.,
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`Plaintiff,
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`Civil Action No. 6:21-cv-00898-ADA
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`JURY TRIAL DEMANDED
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`DECLARATION OF JEFFREY A. WARE IN SUPPORT OF
`DEFENDANTS’ OPPOSITION TO PLAINTIFF ALMONDNET, INC.’S
`OPPOSED MOTION TO ENTER FINAL JUDGMENT
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`Case 6:21-cv-00898-ADA Document 303 Filed 08/06/24 Page 2 of 3
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`I, Jeffrey A. Ware, declare as follows:
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`1.
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`I am a counsel of the law firm of Fenwick & West LLP and one of the attorneys of
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`record for Defendants Amazon.com, Inc., Amazon Services LLC, and Amazon Web Services, Inc.
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`(“Amazon”). I have personal knowledge of the facts in this declaration and, if called upon to do
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`so, could and would testify competently as to the matters set forth herein.
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`2.
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`Attached hereto as Exhibit 1 is a true and correct copy of AlmondNet’s complaint
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`in AlmondNet, Inc. et al v. Yahoo! Inc., C.A. No. 1-16-cv-01557 (E.D.N.Y. Mar. 30, 2016), Dkt.
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`1.
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`3.
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`Attached hereto as Exhibit 2 is a true and correct copy of AlmondNet’s notice of
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`patent infringement letter to Facebook, Inc., dated July 24, 2019, labeled ALMONDNET-
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`AMAZON-0003188-3191. AlmondNet sent nearly identical notice of patent infringement letters
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`to at least 40 other companies in July 2019, which it produced at ALMONDNET-AMAZON-
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`0003194-3353.
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`4.
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`After a letter dated October 25, 2019, AlmondNet ended communications with
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`Amazon.
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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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`foregoing is true and correct. Executed in Seattle, Washington on August 6, 2024.
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`/s/ Jeffrey A. Ware
`Jeffrey A. Ware
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`1
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`Case 6:21-cv-00898-ADA Document 303 Filed 08/06/24 Page 3 of 3
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`CERTIFICATE OF SERVICE
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`I hereby certify that all counsel of record who are deemed to have consented to electronic
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`service are being served with a true and correct copy of this document on August 6, 2024 via the
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`Court’s CM/ECF system per Local Rule CV 5(a)(3).
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`/s/ Jeffrey A. Ware
`Jeffrey A. Ware
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`2
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