`Parrot, Inc. v. Drone
`Technologies, Inc.
`IPR2014-00730
`
`
`
`1, Deborah A. Skolaski, do hereby declare and state, that all statements made
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`herein of my own knowledge are true and correct and all statements made on
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`information and belief are believed to be true and correct; and further that the
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`statements were made with the knowledge that willful false statements and the like
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`so made are punishable by fine or imprisonment, or both, under the laws of the
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`United States of America.
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`Dated: February 9, 2015
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`
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`1.
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`I am a Senior Litigation Paralegal for Osha Liang LLP (“the Firm”),
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`and I work as the lead paralegal assigned to IPR2014—00730 and IPR2014-00732
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`in the Firm.
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`2.
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`I worked on the filing of the petition in the above—cited IPRs along
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`with another paralegal who is no longer at our firm. We finalized and processed
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`for filing and filed the IPR petition and its exhibits, which included correcting
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`typographical errors and formatting where necessary, assembling and marking the
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`exhibits, and electronically filing the IPR petitions and their exhibits on PRPS.
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`3.
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`During the time leading up to the filing of the IPR petition and its
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`exhibits, the paralegal staff and/or other attorneys on the team collected the pdf
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`files that would eventually be assembled into the final exhibits in various shared
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`folders on our system at the firm. These materials included, among other things,
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`Prof. Raffaello D’Andrea’s Curriculum Vitae, which was supposed to be attached
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`to Prof. D’Andrea’s declaration as “Appendix B” in the final exhibit. A review of
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`our files shows that the paralegal staff and/or other attorneys on the team received
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`Prof. D’Andrea’s Curriculum Vitae and one of the members of the team saved the
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`CV in a shared folder, from which the pdf file should have been retrieved to be
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`included in the final declaration exhibit.
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`4.
`
`Due to a clerical mistake during the assembly of Exhibit 1010,
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`although we had the pdf file of Prof. D’Andrea’s Curriculum Vitae (Appendix B)
`
`2
`
`
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`to his declaration, that file was inadvertently not included in Exhibit 1010 for the
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`Petition for Inter Partes Review of US. Patent No. 7,584,071 (“the Petition”; Paper
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`No. 1). This error was unintentional and was brought to my attention in January,
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`2015 before Prof. D’Andrea’s deposition.
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`5.
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`Once the error was brought to my attention and after we received a
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`letter from Drone’s counsel regarding a clerical error in another exhibit in the
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`related proceeding, IPR2014—00732 (Exhibit 1011), I prepared a corrected Exhibit
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`1010, which includes the copy of the pdf file of Prof. D’Andrea’s Curriculum
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`Vitae at “Appendix B” to his declaration. In the process of preparing the corrected
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`exhibit, I also applied a new exhibit label to the front page and more easily
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`identifiable page-numbering to the attachments to the declaration. This corrected
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`Exhibit 1010 was served on Drone’s counsel on Monday, January 26, 2015.
`
`3
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`
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