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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`RFCyber CORP.,
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`Plaintiff,
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`v.
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`VISA U.S.A. Inc.,
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`Defendants.
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`CASE NO.: 6:22-cv-00697-ADA
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`DECLARATION OF LUCY YEN IN SUPPORT OF DEFENDANT’S
`OPENING CLAIM CONSTRUCTION BRIEF
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`I, Lucy Yen, declare as follows:
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`1.
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`I am an attorney admitted to this Court pro hac vice and admitted to practice in
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`New York, California, and the District of Columbia. I am an attorney at the law firm of Wilson
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`Sonsini Goodrich and Rosati, counsel for Defendant Visa U.S.A. Inc. (“Visa”) in the above-
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`captioned matter. I provide this declaration in support of Visa’s Opening Claim Construction
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`Brief. Unless otherwise indicated below, the statements in this declaration are based on my
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`personal knowledge and my review of the documents cited herein. If called to testify as a
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`witness, I could and would competently do so under oath.
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`2.
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`Attached hereto as Exhibit 1 is a true and correct copy of the Merriam-Webster’s
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`Pocket Dictionary (1995) bearing bates numbers VISA_USA_00009145 –
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`VISA_USA_00009148.
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`-1-
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`Case 6:22-cv-00697-ADA Document 41-2 Filed 08/21/23 Page 2 of 2
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`3.
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`Attached hereto as Exhibit 2 is a true and correct copy of the Random House
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`Webster’s College Dictionary (2000) bearing bates numbers VISA_USA_00009158 –
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`VISA_USA_00009164.
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`4.
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`Attached hereto as Exhibit 3 is a true and correct copy of an excerpt to the patent
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`prosecution history for Application No. 11/534,653, the Response to 1st OA (RCE), dated
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`September 7, 2011, bearing bates numbers RFC00001013 – RFC00001024.
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`5.
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`Attached hereto as Exhibit 4 is a true and correct copy of an excerpt to the patent
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`prosecution history for Application No. 11/534,653, the Application, dated September 24, 2006,
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`bearing bates numbers RFC00000802 – RFC00000833.
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`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
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`this 21st day of August 2023 in New York, New York.
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` /s/ Lucy Yen
`Lucy Yen
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`-2-
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