`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 23-278-MN
`
`JURY TRIAL DEMANDED
`
`)))))))))
`
`PAYRANGE INC.,
`
`Plaintiff,
`
`v.
`
`CSC SERVICEWORKS, INC.,
`
`Defendant.
`
`DECLARATION OF JAMIE Y. OTTO IN SUPPORT OF PLAINTIFF PAYRANGE
`INC.’S OPPOSITION TO DEFENDANT CSC SERVICEWORKS INC.’S
`MOTION TO STAY PENDING INTER PARTES REVIEW
`
`David E. Moore (#3983)
`Bindu A. Palapura (#5370)
`Andrew M. Moshos (#6685)
`POTTER ANDERSON & CORROON LLP
`Hercules Plaza, 6th Floor
`1313 N. Market Street
`Wilmington, DE 19801
`Tel: (302) 984-6000
`dmoore@potteranderson.com
`bpalapura@potteranderson.com
`amoshos@potteranderson.com
`
`Attorneys for Plaintiff PayRange Inc.
`
`OF COUNSEL:
`
`James C. Yoon
`Ryan R. Smith
`Christopher D. Mays
`Alexander Miller
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`Tel: (650) 493-9300
`
`Jamie Y. Otto
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`953 East Third Street, Suite 100
`Los Angeles, CA 90013
`Tel: (323) 210-2900
`
`Dated: February 23, 2024
`11349399 / 23372.00001
`
`
`
`Case 1:23-cv-00278-MN Document 60 Filed 02/23/24 Page 2 of 3 PageID #: 1148
`
`I, Jamie Y. Otto, declare as follows:
`
`1.
`
`I am an attorney at law duly licensed to practice in the State of California and
`
`before this Court. I am an attorney at the firm of Wilson Sonsini Goodrich & Rosati P.C., counsel
`
`for Plaintiff PayRange Inc. (“PayRange”) in the above-captioned matter. I provide this declaration
`
`in support of Plaintiff PayRange Inc.’s Opposition to Defendant CSC ServiceWorks, Inc.’s Motion
`
`to Stay Pending Inter Partes Review. The statements in this declaration are based on my personal
`
`knowledge and my review of the documents cited herein. If called to testify as a witness, I could
`
`and would competently do so under oath.
`
`2.
`
`Attached hereto as Exhibit A is a true and correct copy of the Patent Trial and
`
`Appeal Board’s (“PTAB’s”) Decision Granting Institution of Inter Partes Review for U.S. Patent
`
`No. 8,856,045 in IPR2023-01186, dated January 19, 2024.
`
`3.
`
`Attached hereto as Exhibit B is a true and correct copy of the PTAB’s Decision
`
`Denying Institution of Inter Partes Review for U.S. Patent No. 10,438,208 in IPR2023-01187,
`
`dated January 18, 2024.
`
`4.
`
`Attached hereto as Exhibit C is a true and correct copy of the PTAB’s Decision
`
`Denying Institution of Inter Partes Review for U.S. Patent No. 10,891,608 in IPR2023-01188,
`
`dated January 24, 2024.
`
`5.
`
`Attached hereto as Exhibit D is a true and correct copy of CSC ServiceWorks,
`
`Inc.’s Petition for Inter Partes Review in IPR2023-01449, dated October 9, 2023.
`
`6.
`
`Attached hereto as Exhibit E is a true and correct copy of print out of the
`
`PayRange webpage https://shop.payrange.com/industries/laundry/?gad_source=1&gclid=
`
`Cj0KCQiAoKeuBhCoARIsAB4WxtcPKmLpXqsUBJ23YZfXXiolFYD8YJGGDYOtBzgFzaTy
`
`FW4nI7wvvPIaAm04EALw_wcB, last accessed on February 23, 2024.
`
`
`
`Case 1:23-cv-00278-MN Document 60 Filed 02/23/24 Page 3 of 3 PageID #: 1149
`
`7.
`
`Attached hereto as Exhibit F is a true and correct copy of a print out of the
`
`PayRange webpage https://www.payrange.com/laundry/, last accessed on February 23, 2024.
`
`I declare under penalty of perjury under the laws of the United States that the foregoing is
`
`true and correct to the best of my knowledge and belief after reasonable investigation. Executed
`
`this 23rd day of February 2024, in Orange County, California.
`
`/s/ Jamie Y. Otto
` Jamie Y. Otto
`
`-2-
`
`
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