`
`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 REPLY BRIEF IN SUPPORT OF ITS
`PARTIAL RULE 12(B)(6) MOTION TO DISMISS PAYRANGE’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 J is a true and correct copy of excerpts of the hearing
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`before the Patent Trial and Appeal Board in the Post-Grant Review of U.S. Patent No. 10,891,614,
`
`captioned KioSoft Technologies, LLC v. PayRange Inc., No. PGR2021-00093 (PTAB September
`
`16, 2022), Paper No. 37.
`
`4.
`
`Attached hereto as Exhibit K is a true and correct copy of excerpts of an Office
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`Action for Patent Application No. 18/197,070, now U.S. Patent No. 11,972,423 (“the ’423
`
`Patent”), dated September 27, 2023.
`
`
`
`Case 1:24-cv-00733-MN Document 28 Filed 11/25/24 Page 2 of 2 PageID #: 1616
`
`5.
`
`Attached hereto as Exhibit L is a true and correct copy of excerpts of an Office
`
`Action for Patent Application No. 18/197,071, now U.S. Patent No. 11,966,920 (“the ’920
`
`patent”), dated August 16, 2023.
`
`6.
`
`Attached hereto as Exhibit M is a true and correct copy of the Applicant’s response
`
`to the September 27, 2023 Office Action for the ’423 Patent, dated November 15, 2023.
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`7.
`
`Attached hereto as Exhibit N is a true and correct copy of the Applicant’s response
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`to the August 16, 2023 Office Action for the ’920 Patent, dated November 15, 2023.
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`8.
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`I hereby declare under penalty of perjury that the foregoing statements made by me
`
`are true.
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`Executed on November 25, 2024, in Ann Arbor, Michigan.
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`Respectfully submitted,
`
`Sarah E. Waidelich
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`2
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