`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GEOTAB INC., AND
`TV MANAGEMENT INC., D/B/A GPS NORTH AMERICA
`Petitioners,
`
`V.
`
`PERDIEM CO., LLC.
`
`Patent Owner
`
`DECLARATION OF STEVEN G. HILL
`
`GEOTAB Ex. 1015
`GEOTAB EX. 1015
`
`1
`
`
`
`1.
`
`My name is Steven G. Hill.
`
`I am over the age of twenty—one and
`
`competent to testify in this matter. The statements made herein as based on my
`
`own personal knowledge.
`
`2.
`
`I am a founding partner of the law firm Hill, Kertscher & Wharton,
`
`LLP (“HKW”) and counsel to the Petitioners. HKW is counsel to the joint defense
`
`group consisting of Teletrac —Navman Wireless, Geotab, Inc. and Telular, Inc. for
`
`purposes of preparing and bringing five petitions for inter partes review (IPR)
`
`against patents owned by Per Diem. The patent numbers are 8,223,012, 8,493,207,
`
`8,717,166, 9,003,499, and 9,071,931.
`
`3.
`
`As part of my work on the IPR petitions, I was responsible for
`
`gathering the funds from the participants in the IPR petitions to be used to offset
`
`the IPR filing fees. Toward that end, I collected 1/3 of the filing fees from each of
`
`Teletrac-Navman, Geotab and Telular.
`
`4.
`
`Attached as Exhibit A hereto is a true and correct copy of a
`
`confirmation of wire from Telular, Inc. showing that Telular wired 1/3 of the
`
`monies used for the IPR filings.
`
`5.
`
`At the outset of the engagement by the joint defense group, the
`
`arrangement regarding payment of HKW’s legal fees was originally that each of
`
`Teletrac-Navman, Geotab and Telular would pay 1/3 of our fees relating to the
`
`2
`
`
`
`IPRs. After Teletrac-Navman settled with PerDiem and terminated its
`
`participation in the IPRs, the arrangement became that Geotab and Telular would
`
`split HKW’s fees evenly.
`
`6.
`
`At no time prior to September 2016 when PerDiem raised the question
`
`of whether SkyBitz, Inc. is an RPI was I ever aware of SkyBitz, Inc. SkyBitz has
`
`not participated in, has not funded or offered to fund any of the IPR proceedings.
`
`I hereby declare under penalty of perjury under the laws of the United States
`
`of America that the foregoing is true and correct, and that all statements made of
`
`my own knowledge are true and that all statements made on information and belief
`
`are believed to be true. I understand that willful false statements and the like are
`
`punishable by fine or imprisonment, or both (18 U.S.C. § 1001).
`
`Executed on November 1, 2016
`
`/4/4
`
`Steven G. Hill
`
`3
`
`
`
`Exhibit A
`Exhibit A
`
`4
`
`
`
`TU 770-953-I353
`
`HILLKERTSCHERHHQRTDN
`7769531358
`RECEIVED 85/15/2016 34:85
`FRUH BANK OF AHERICA
`IGHAVIE |437EST 7237952A
`PAGE I OF
`
`I
`
`Bankofmnerica .%,.
`42/-'
`
`Bank of America, N.A.
`wire Transfer Services
`
`Date:
`iE-MAY-2015
`Time wire
`Account:
`
`Comileted: 15:35 ET
`
`HILL KERTSCHER & WHARTDN LLP
`IOLTA
`335B RIUERWOUD PKWY SE STE BEE
`HTLANTA, GA
`3fl339-3351
`Attn: SAMANTHA SHUB
`
`05
`
`Please Contact us at Bflfl.729.9473 Option 2 if you have any questions about
`this wire transfer. Thank you for using Bank of America wire Transfer
`Services.
`
`The following wire was credited today in the amount of USD:‘
`
`Transaction Ref:
`Sender's Ref:
`Service Ref:
`man:
`
`2fliEfl5iEBfl34i2ii
`2@iEi37ifl345BB
`lal.7i2l2I4E
`2131 sosi 51.1 377131 CflEl2ifl4EIZ|5l 51 saerroa
`
`Originator:
`
`Sending Bank:
`
`Beneficiary:
`
`TELULAR coaponanou —
`OPERATING ACCOUNT
`zoo s. WHCKER DRIVE
`some moo
`SILICON VALLEY BANK -
`SANTA cmaa, ca
`HILL xsnrscnsn wnanoon LLP IOLTA -
`129:2: ave or AMERICAS
`NEW mar
`mnema
`
`Payment Details:
`
`INVOICE ZZBBBGPSNA
`Clii-1RGES:0UR
`
`mom
`
`CONFIDENTIALITY NOTICE: This Fax transmittal is a confidential communication. If
`
`the reader of this message is not the intended recipient or an agent responsible for
`delivering it to the Intended reclplent. you are hereby notified that you have received
`this document in error and that any review, dissemination, distribution or copying of
`this transmittal is strictly prohibited. If you have received this communication in
`error, please notify this office and Immediately delete this message and all of its
`attachments, if any.
`
`5
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