`
`IN THE UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`RFCyber CORP.,
`
`
`Plaintiff,
`
`
`
`
`
`
`
`CASE NO.: 6:22-cv-00697-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`VISA U.S.A. Inc.,
`
`
`Defendant.
`
`v.
`
`
`
`
`
`
`
`
`
`DECLARATION OF LUCY YEN IN SUPPORT OF VISA U.S.A. INC.’S
`OPPOSED MOTION TO STAY PENDING INTER PARTES REVIEW
`
`I, Lucy Yen, declare as follows:
`
`1.
`
`I am an attorney with a pending application for admission to this Court pro hac
`
`vice and am admitted to practice in New York, California, and the District of Columbia. I am a
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`Partner at the law firm of Wilson Sonsini Goodrich and Rosati, counsel for Defendant Visa
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`U.S.A. Inc. (“Visa”) in the above-captioned matter. I provide this declaration in support of
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`Visa’s Opposed Motion to Stay Pending Inter Partes Review. Unless otherwise indicated below,
`
`the statements in this declaration are based on my personal knowledge and my review of the
`
`documents cited herein. If called to testify as a witness, I could and would competently do so
`
`under oath.
`
`2.
`
`Attached hereto as Exhibit 1 is a true and correct copy of the Petition for Inter
`
`Partes Review of claims 1-19 of U.S. Patent No. 9,189,787, IPR2022-00412, Paper 1, dated
`
`January 14, 2022.
`
`1
`
`
`
`Case 6:22-cv-00697-ADA Document 22-1 Filed 06/08/23 Page 2 of 2
`
`3.
`
`Attached hereto as Exhibit 2 is a true and correct copy of the Petition for Inter
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`Partes Review of claims 1-17 of U.S. Patent No. 9,240,009, IPR2022-00413, Paper 1, dated
`
`January 14, 2022.
`
`4.
`
`Attached hereto as Exhibit 3 is a true and correct copy of the Decision Granting
`
`Institution of the Patent Trial and Appeal Board for Inter Partes Review of claims 1-19 of U.S.
`
`Patent No. 9,189,787, IPR2022-00412, Paper 11, dated July 21, 2022.
`
`5.
`
` Attached hereto as Exhibit 4 is a true and correct copy of the Decision Granting
`
`Institution of the Patent Trial and Appeal Board for Inter Partes Review of claims 1-17 of U.S.
`
`Patent No. 9,240,009, IPR2022-00413, Paper 12, dated July 21, 2022.
`
`I declare under penalty of perjury under the laws of the United States that the foregoing is
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`true and correct to the best of my knowledge and belief after reasonable investigation. Executed
`
`this 8 day of June 2023 in New York, New York.
`
`
`
`
` /s/ Lucy Yen
`Lucy Yen
`
`
`
`2
`
`
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