`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`ALLIANCE LAUNDRY SYSTEMS LLC,
`
`Plaintiff,
`
`v.
`
`PAYRANGE INC.,
`
`Defendant.
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`C. A. No.: 24-733-MN
`
`JURY TRIAL DEMANDED
`
`DECLARATION OF SARAH E. WAIDELICH IN SUPPORT OF PLAINTIFF’S
`RULE 12(B)(6) MOTION TO DISMISS DEFENDANT’S COUNTERCLAIMS
`
`I, Sarah E. Waidelich, declare as follows:
`
`1.
`
`I am over the age of eighteen and am otherwise competent to provide this
`
`declaration. I have personal knowledge of the facts set forth in this declaration and if called as a
`
`witness, could and would testify competently to them.
`
`2.
`
`I am an attorney with Honigman LLP in Ann Arbor, Michigan. I am counsel for
`
`Plaintiff Alliance Laundry Systems LLC in this litigation.
`
`3.
`
`Attached hereto as Exhibit A is a true and correct copy of a redline comparison of
`
`Claim 11 of U.S. Patent No. 11,481,772 (“the ’772 Patent”) to Claim 1 of U.S. Patent No.
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`11,966,920 (“the ’920 Patent”).
`
`4.
`
`Attached hereto as Exhibit B is a true and correct copy of a redline comparison of
`
`Claim 1 of the ’772 Patent to Claim 1 of U.S. Patent No. 11,972,423 (“the ’423 Patent”).
`
`5.
`
`Attached hereto as Exhibit C is a true and correct copy of excerpts of PayRange
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`Inc.’s Patent Owner Preliminary Response, filed in the Post-Grant Review of the ’772 Patent
`
`before the Patent Trial and Appeal Board, captioned KioSoft Technologies, LLC v. PayRange Inc.,
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`No. PGR2023-00042 (PTAB Nov. 24, 2023).
`
`
`
`Case 1:24-cv-00733-MN Document 16 Filed 09/13/24 Page 2 of 2 PageID #: 895
`
`6.
`
`Attached hereto as Exhibit D is a true and correct copy of a chart comparing claim
`
`1 of U.S. Patent No. 10,891,608 to the allegations in PayRange’s Counterclaims.
`
`7.
`
`8.
`
`Attached hereto as Exhibit E is a true and correct copy of U.S. Patent No. 3,416,639.
`
`Attached hereto as Exhibit F is a true and correct copy of a redline comparison of
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`Claim 1 of U.S. Patent No. 10,891,614 (“the ’614 Patent”) to Claim 1 of the ’920 Patent.
`
`9.
`
`Attached hereto as Exhibit G is a true and correct copy of a redline comparison of
`
`Claim 1 of the ’614 Patent to Claim 1 of the ’423 Patent.
`
`10.
`
`I hereby declare under penalty of perjury that the foregoing statements made by me
`
`are true.
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`Executed on September 13, 2024, in Ann Arbor, Michigan.
`
`Respectfully submitted,
`
`Sarah E. Waidelich
`
`2
`
`
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