`Parrot, Inc. v. Drone
`Technologies, Inc.
`IPR2014-00730
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`I, Raffaello D’Andrea, do hereby declare and state that all statements made
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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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`herein of my own knowledge are true and correct and all statements made on
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`Dated: February ‘7 , 2015
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`United States of America.
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`1.
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`I have been retained by counsel for Petitioner as an expert witness in
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`the above—captioned proceeding and in IPR2014-00732.
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`1 previously prepared
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`declarations that have been submitted in support of Parrot’s IPR petitions in both
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`proceedings.
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`2.
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`I recently learned while preparing for my deposition in this matter that
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`in my declaration submitted in this proceeding my CV, which is clearly referred to
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`within my declaration as “Appendix B,” was missing.
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`I understand this was the
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`result of errors in the process of assembling the declaration into an exhibit prior to
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`Petitioner’s counsel’s filing of the IPR petition. Although this inadvertent clerical
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`error resulted in the omission of my CV from my declaration, I intended for my
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`CV to be included with my declaration when it was originally assembled in
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`April/May 2014.
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`I understand this matter can be corrected by submitting a
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`corrected version of the exhibit that included my declaration, Exhibit 1010, which
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`Petitioner’s counsel has now prepared.
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`3.
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`I have reviewed the corrected version of Exhibit 1010 in the instant
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`IPR (IPR2014-00730) and I confirm that in its corrected form it now includes the
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`copy of my CV that I originally intended to be attached to my declaration in
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`April/May 2014.