`Case 1:19-cv-11586-FDS Document 379 Filed 04/13/22 Page 1 of 2
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`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MASSACHUSETTS
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`PHILIPS NORTH AMERICA LLC,
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`Plaintiff,
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`V.
`FITBIT, INC.,
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`Civil Action No. 1:19-cv-11586-FDS
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`Defendant.
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`DECLARATION OF DR. THOMAS MARTIN IN SUPPORT OF
`PLAINTIFF’S MOTION FOR PARTIAL SUMMARY JUDGMENT
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`I, Thomas Martin, declare as follows:
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`1.
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`I makethis declaration in support of Philips North America LLC’s Motion for
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`Partial Summary Judgmentof Direct Infringement and No Invalidity of iFit Prior Art.
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`2.
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`I have personal knowledge of the facts set forth herein and,if called to testify in
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`this matter, could and would testify to the following.
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`3.
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`Attached as Exhibit A is a true and correct copy of the report I submitted in this
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`case titled “Amended Expert Report of Tom Martin Concerning Infringement”, dated December
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`12, 2021, previously filed in this matter as Docket No. 342-1.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Date:April 13,2022
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`is Bows [ Jo.
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`Dr. Thomas L. Martin, Ph.D
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`4893-5973-3531
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`peel
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`Case 1:19-cv-11586-FDS Document 379 Filed 04/13/22 Page 2 of 2
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing document was filed
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`with the Court through the ECF system and that a copy will be electronically served on
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`registered participants as identified on the Notice of Electronic Filing.
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`4893-5973-3531
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`By: /s/ John W. Custer
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`2
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