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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`Case No. 6:22-cv-00697-ADA
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`JURY TRIAL DEMANDED
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`Plaintiff,
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`Defendant.
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`RFCYBER CORP.,
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`v.
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`VISA U.S.A. INC.,
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`DECLARATION OF RICHARD M. COWELL IN SUPPORT OF
`PLAINTIFF RFCYBER CORP.’S RESPONSE IN OPPOSITION TO
`DEFENDANT VISA U.S.A. INC.’S MOTION TO DISMISS
`RFCYBER CORP’S COMPLAINT FOR PATENT INFRINGEMENT (DKT. 7)
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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 1 is a true and correct copy of a press release entitled
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`“Visa Launches Innovative Token Service,” dated September 9, 2014,
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`taken from
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`https://usa.visa.com/about-visa/newsroom/press-releases.releaseId.9896.html.
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`Case 6:22-cv-00697-ADA Document 12-1 Filed 12/15/22 Page 2 of 2
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`5.
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`Attached hereto as Exhibit 2 is a true and correct copy of an article from
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`Businesswire entitled “Visa Introduces Visa Ready Partner Program,” dated February 22, 2013
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`taken
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`from https://www.businesswire.com/news/home/20130222005233/en/Visa-Introduces-
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`Visa-Ready-Partner-Program.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed on December 15, 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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