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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`TELETRAC INC.,
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`NAVMAN WIRELESS NORTH AMERICA, LTD.
`GEOTAB INC., AND
`TV MANAGEMENT INC., DIBIA GPS NORTH AMERICA
`Petitioners,
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`V.
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`PERDIEM CO., LLC.
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`Patent Owner
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`Case IPR2016-TBA
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`U.S. Patent 8,717,166
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`DECLARATION OF VIVEK GANTI, ESQ
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`TELETRAC 1013
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`1
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`1.
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`I, Vivek A. Ganti, resident of Atlanta, GA, hereby declare as follows:
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`2.
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`On information and belief, Exhibits 1001-1012 are true and accurate
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`copies of the original documents, as shown in the table below:
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`
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`U.S. Patent No. 7,327,258 (“Fast”)
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`U.S. Provisional Patent App. No. 60/542,208 (“Fast
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`Provisional”)
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`Discrete Wireless’s Marcus GPS Fleet Management
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`A n u lication Product Brochure (“Marcus”)
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`Office Action (Feb. 11, 2016)
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`3. On information and belief, the correspondence address for the attorney of
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`record for U.S. Patent 8,717,166 is:
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`Robert S. Babayi
`Address: 3208 Q. Street, NW
`Washington DC 20007
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`4. In the related district court litigations PerdiemCo, LLC. v. Omnivations II,
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`LLC DIBEA Fleetronix, Case No. 2:15-cv-00729; PerdiemCo, LLC. v.
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`thingtech LLC, Case No. 2:15-cv-01218; PerdiemCo, LLC. v.
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`2
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`LiveViewGPS, Inc., Case No. 2:15-cv-01219; PerdiemCo LLC v. TV
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`Management, Inc. dfbfa GPS North America, Case No. 2:15-cv-01217;
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`PerdiemCo, LLC. v. Teletrac, Inc. et al; Case No. 2:15-cv-00730;
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`PerdiemCo LLC v. Geotab Inc. et al, Case No. 2:15-cv-00726; Perdiem Co
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`LLC v. GPS Logic, LLC; Case No. 2:15-cv-01216; PerdiemCo, LLC. v.
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`Industrack LLC, Case No. 2: 1 5-cv-00727, pending in the Eastern District of
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`Texas, Patent Owner is represented by the law firm Quinn Emanuel
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`Urquhart & Sullivan, LLP whose correspondence address is:
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`Quinn Emanuel Urquhart & Sullivan, LLP
`777 6th Street NW 11th floor
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`Washington, D.C. 20001-3706
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`. On May 16, 2016, Patent Owner’s litigation counsel, Alan Whitehurst of the
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`firm Quinn Emanuel Urquhart & Sullivan, LLP, represented that Patent
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`Owner’s litigation counsel agrees to accept service on behalf of Patent
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`Owner of all IPR petitions directed to Patent Owner’s patents that are at
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`issue in the district court litigations identified above. Mr. Whitehurst also
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`represented that Patent Owner consents to electronic service via email.
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`.
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`I hereby declare under penalty of perjury under the laws of the United States
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`of America that the foregoing is true and correct, and that all statements
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`made of my own knowledge are true and that all statements made on
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`information and belief are believed to be true. I understand that willful false
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`3
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`statements and the like are punishable by fine or imprisonment, or both (18
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`U.S.C. § 1001).
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`Executed on May 19, 2016
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`
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`Vivek Ganti
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`4
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