`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`ONE WORLD TECHNOLOGIES, INC.,
`D/B/A TECHTRONIC INDUSTRIES POWER EQUIPMENT
`Petitioner,
`
`v.
`
`CHERVON (HK) LIMITED,
`Patent Owner.
`
`Case Nos. IPR2020-00883, IPR2020-00884, IPR2020-00885, IPR2020-00886,
`IPR2020-00887, and IPR2020-00888
`
`U.S. Patent Nos. 9,060,463, 9,596,806, 9,648,805, 9,826,686, 9,986,686, and
`10,070,588
`
`DECLARATION OF MICHAEL CLANCY IN SUPPORT
`OF PATENT OWNER’S PRELIMINARY RESPONSES
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Chervon (HK) Limited
`Exhibit 2004 - Page 1
`
`
`
`I, Michael Clancy, declare as follows:
`
`1. My name is Michael Clancy. I am Chief Executive Officer of Chervon
`
`North America and I am submitting this declaration in support of Chervon
`
`(HK) Limited’s Preliminary Responses submitted in the above IPR
`
`proceedings.
`
`2.
`
`Around April 20, 2020, I spoke on the phone with Lee Sowell, President of
`
`the Outdoor Products Division of Techtronic Industries Co. Ltd.
`
`3. Mr. Sowell and I discussed the co-pending litigation, Chervon (HK)
`
`Limited, and Chervon North America, Inc. v. One World Tech., Inc., and
`
`Techtronic Indus. Co. Ltd., and Homelite Consumer Prods., Inc., Case No.
`
`1:19-cv-01293-LPS (D. Del.) (the “District Court Litigation”).
`
`4. Mr. Sowell explained that “TTI” has prepared and will soon be filing a
`
`series of IPR petitions to challenge the validity of the claims of the patents
`
`at issue in the District Court Litigation. Mr. Sowell proposed that “TTI”
`
`would not file any IPR Petitions against the patents at issue in the District
`
`Court Litigation if Chervon would agree to dismiss the litigation claims
`
`against all of the named defendants in the District Court Litigation, i.e.,
`
`Techtronic Industries Co. Ltd., One World Technologies, Inc., and
`
`Homelite Consumer Products, Inc.
`
`5.
`
`I understood that Mr. Sowell was acting and negotiating on behalf of all of
`
`
`
`2
`
`Chervon (HK) Limited
`Exhibit 2004 - Page 2
`
`
`
`the named defendants in the District Court Litigation, i.e., Techtronic
`
`Industries Co. Ltd., One World Technologies, Inc., and Homelite Consumer
`
`Products, Inc. I also understood that TTI controlled whether any and all of
`
`the named defendants in the District Court Litigation, i.e., Techtronic
`
`Industries Co. Ltd., One World Technologies, Inc., and Homelite Consumer
`
`Products, Inc., would file IPR Petitions against the patents at issue in the
`
`District Court Litigation.
`
`I hereby declare that all statements made herein of my own knowledge are true
`
`and that all statements made on information and belief are believed to be true; and further
`
`that these statements are made with the knowledge that willful false statements and the
`
`like so made are punishable by fine or imprisonment, or both, under Section 1001 of
`
`Title 18 of the United States Code and that such willful false statements may jeopardize
`
`the validity of the patents at issue.
`
`
`Dated: August 10, 2020
`
`
`Respectfully submitted,
`
`/_______________ /
`Michael Clancy
`
`
`
`3
`
`Chervon (HK) Limited
`Exhibit 2004 - Page 3
`
`
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