`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`ALLIANCE LAUNDRY SYSTEMS LLC,
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`Plaintiff,
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`v.
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`PAYRANGE INC.,
`
`Defendant.
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`)
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`C. A. No.: 24-733-MN
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`JURY TRIAL DEMANDED
`
`DECLARATION OF SARAH E. WAIDELICH
`IN SUPPORT OF ALLIANCE LAUNDRY SYSTEMS LLC’S
`PARTIAL MOTION TO DISMISS PAYRANGE’S AMENDED COUNTERCLAIMS
`
`I, Sarah E. Waidelich, declare as follows:
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`1.
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`I am over the age of eighteen and am otherwise competent to provide this
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`declaration. I have personal knowledge of the facts set forth in this declaration and if called as a
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`witness, could and would testify competently to them.
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`2.
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`I am an attorney with Honigman LLP in Ann Arbor, Michigan. I am counsel for
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`Plaintiff Alliance Laundry Systems LLC in this litigation.
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`3.
`
`Attached hereto as Exhibit A is a true and correct copy of a redline comparison of
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`the claims of U.S. Patent No. 11,481,772 (“the ’772 Patent”) to the asserted claims of U.S. Patent
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`No. 11,966,920 (“the ’920 Patent”).
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`4.
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`Attached hereto as Exhibit B is a true and correct copy of a redline comparison of
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`the claims of the ’772 Patent to the asserted claims of U.S. Patent No. 11,972,423 (“the ’423
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`Patent”).
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`5.
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`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
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`1
`
`
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`Case 1:24-cv-00733-MN Document 23 Filed 10/25/24 Page 2 of 2 PageID #: 1502
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`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).
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`6.
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`Attached hereto as Exhibit D is a true and correct copy of a redline comparison of
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`claim 1 of the ’920 Patent and claims 13 and 15 of the ’920 Patent.
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`7.
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`Attached hereto as Exhibit E is a true and correct copy of a redline comparison of
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`claim 1 of the ’423 Patent and claims 13 and 15 of the ’423 Patent.
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`8.
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`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.
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`9.
`
`Attached hereto as Exhibit G is a true and correct copy of a redline comparison of
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`Claim 1 of the ’614 Patent to Claim 1 of the ’423 Patent.
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`10.
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`Attached hereto as Exhibit H is a true and correct copy of excerpts of the Notice of
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`Allowance for the ’920 Patent dated January 26, 2024.
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`11.
`
`Attached hereto as Exhibit I is a true and correct copy of excerpts of the Notice of
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`Allowance for the ’423 Patent dated December 20, 2023.
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`12.
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`I hereby declare under penalty of perjury that the foregoing statements made by me
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`are true.
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`Executed on October 25, 2024, in Ann Arbor, Michigan.
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`Respectfully submitted,
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`Sarah E. Waidelich
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`2
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