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`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`Case No. 6:21-cv-955-ADA
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`JURY TRIAL DEMANDED
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`Case No. 6:21-cv-1101-ADA
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`JURY TRIAL DEMANDED
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`Case No. 6:21-cv-1104-ADA
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`JURY TRIAL DEMANDED
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`AIRE TECHNOLOGY LTD.,
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`SAMSUNG ELECTRONICS CO., LTD. and
`SAMSUNG ELECTRONICS AMERICA, INC.,
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`AIRE TECHNOLOGY LTD.,
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`APPLE INC.
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`AIRE TECHNOLOGY LTD.,
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`GOOGLE LLC,
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`Plaintiff,
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`Defendants.
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`Plaintiff,
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`Defendant.
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`Plaintiff,
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`v.
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`v.
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`v.
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`Defendant.
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`DECLARATION OF DREW B. HOLLANDER IN SUPPORT OF PLAINTIFF AIRE
`TECHNOLOGY LTD.’S RESPONSIVE CLAIM CONSTRUCTION BRIEF
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`Case 6:21-cv-01101-ADA Document 34 Filed 06/09/22 Page 2 of 4
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`I, Drew B. Hollander, hereby declare under the penalty of perjury as follows:
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`1.
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`I am an attorney at Russ August & Kabat LLP, counsel of record for Aire
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`Technology Ltd. (“Aire”). I am one of the attorneys responsible for representing Aire in this
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`matter. I have personal knowledge of all facts stated in this declaration and if called as a witness,
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`could and would competently testify to these facts. I respectfully submit this declaration in support
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`of Aire’s responsive claim construction brief.
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`2.
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`Attached hereto as Exhibit 1 is a true and correct copy of Samsung’s Petition for
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`Inter Partes Review for U.S. Patent No. 8,174,360, IPR2022-00874.
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`3.
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`Attached hereto as Exhibit 2 is a true and correct copy of Examiner Non-Final
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`Rejection, dated June 9, 2009, filed in the prosecution of U.S. Patent No. 8,174,360 (U.S. Patent
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`App. No. 10-565,732).
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`4.
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`Attached hereto as Exhibit 3 is a true and correct copy of Examiner Non-Final
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`Rejection, dated January 5, 2010, filed in the prosecution of U.S. Patent No. 8,174,360 (U.S. Patent
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`App. No. 10-565,732).
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`5.
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`Attached hereto as Exhibit 4 is a true and correct copy of the definition of
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`“measuring device” from The Free Dictionary.
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`6.
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`Attached hereto as Exhibit 5 is a true and correct copy of the definition of
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`“measuring device” from The Mnemonic Dictionary.
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`7.
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`Attached hereto as Exhibit 6 is a true and correct copy of the definition of
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`“measuring device” from Vocabulary.com Dictionary.
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`8.
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`Attached hereto as Exhibit 7 is a true and correct copy of the definition of
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`“measuring device” from The Fine Dictionary.
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`1
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`Case 6:21-cv-01101-ADA Document 34 Filed 06/09/22 Page 3 of 4
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`9.
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`Attached hereto as Exhibit 8 is a true and correct copy of Chapter 8 of “Handbuch
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`der Chipkarten” (“Chip Card Manual”), W. Rankl, W. Effing, 3rd edition, 1999.
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`10.
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`Attached hereto as Exhibit 9 is a true and correct copy of Applicant Remarks, dated
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`March 30, 2011, filed in the prosecution of U.S. Patent No. 8,205,249 (U.S. Patent App. No. 10-
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`531,259).
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`11.
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`Attached hereto as Exhibit 10 is a true and correct copy of Applicant Remarks,
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`dated May 27, 2010, filed in the prosecution of U.S. Patent No. 8,205,249 (U.S. Patent App. No.
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`10-531,259).
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`12.
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`Attached hereto as Exhibit 11 is a true and correct copy of Applicant Remarks and
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`Amendments, dated May 18, 2009, filed in the prosecution of U.S. Patent No. 8,205,249 (U.S.
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`Patent App. No. 10-531,259).
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`13.
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`Attached hereto as Exhibit 12 is a true and correct copy of the Declaration of Dr.
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`Hugh Smith in Support of Aire’s Responsive Claim Construction Brief, dated June 9, 2022.
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`14.
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`Attached hereto as Exhibit 13 is a true and correct copy of the Declaration of Dr.
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`Michael Brogioli in Support of Aire’s Responsive Claim Construction Brief, dated June 9, 2022.
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`Executed on this 9th day of June, 2022 in New York, NY.
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`/s/ Drew B. Hollander
`Drew B. Hollander
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`2
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`Case 6:21-cv-01101-ADA Document 34 Filed 06/09/22 Page 4 of 4
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`CERTIFICATE OF SERVICE
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`I certify that this document is being served upon counsel of record for Defendants on June
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`9, 2022 via electronic service.
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`/s/ Brett Cooper
` Brett Cooper
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