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`RFCYBER CORP.,
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`v.
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`APPLE INC.,
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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-00916-ADA
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`JURY TRIAL DEMANDED
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`§
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`Plaintiff,
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`Defendant.
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`DECLARATION OF RICHARD M. COWELL IN SUPPORT OF
`PLAINTIFF RFCYBER CORP.’S
`RESPONSIVE CLAIM CONSTRUCTION BRIEF
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`
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`I, Richard M. Cowell, hereby declare as follows:
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`1.
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`I have personal knowledge of the facts set forth in this declaration. I am competent
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`to testify as to all matters stated, and I am not under any legal disability that would in any way
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`preclude me from testifying.
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`2.
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`I am Counsel with the law firm of Fabricant LLP and counsel of record for Plaintiff
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`RFCyber Corp. in this matter.
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`3.
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`The exhibits attached to this declaration may contain annotations and/or excerpts
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`of the originals.
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`4.
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`Attached hereto as Exhibit A is a true and correct copy of a document entitled
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`Dictionary of Banking and Finance third edition, bearing Bates numbers RFC-APPLE00000048
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`through RFC-APPLE00000051.
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`
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`Case 6:21-cv-00916-ADA Document 54-1 Filed 05/10/22 Page 2 of 2
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`5.
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`Attached hereto as Exhibit B is a true and correct copy of a document entitled
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`Newton’s Telecom Dictionary bearing Bates Nos. RFC-APPLE00000052 through RFC-
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`APPLE00000054.
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`6.
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`Attached hereto as Exhibit C is a true and correct copy of Paper No. 1, Petition for
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`Inter Partes Review of U.S. Patent No. 9,189,787 in Apple Inc. v. RFCyber Corp., IPR2022-
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`00412, dated January 14, 2022.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed on May 10, 2022 in Cranford, New Jersey.
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`/s/ Richard M. Cowell
` Richard M. Cowell
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`2
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