`Parrot, Inc. v. Drone
`Technologies, Inc.
`IPR2014-00732
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`
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`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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`l.
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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 IPR20l4-00730 and lPR20l4—O0732
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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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`E 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 prior art patents and
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`Dr. D’Andrea’s declaration, its attachments, its appendices, and its signature pages.
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`4.
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`On April 30, 2014, Prof. Raffaello D’Andrea sent scanned executed
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`signature pages to the IPR20l4—00732 (Exhibit 1011) and IPR20l4-00730 (Exhibit
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`1010) by email, with instructions to insert the signature pages into the final Version
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`of his declaration. Each signature page included his hand written signature and the
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`IPR number to which it related. A review of our files shows that the paralegal staff
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`and/or other attorneys on the team received Dr. D’Andrea’s signature pages and
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`2
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`
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`one of the members of the team saved the signature pages in a shared folder to be
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`included in the final declaration exhibit, per Dr. D’Andrea’s instructions.
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`5.
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`A review of our files also shows that prior to the receipt of the
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`signature pages, the paralegal staff and/or other attorneys on the team received Dr.
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`D’Andrea’s Curriculum Vitae and one of the members of the team saved the CV in
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`a shared folder, from which the pdf file should have been retrieved to be included
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`in the final declaration exhibit.
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`6.
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`Due to a clerical mistake during the assembly of Exhibit 1011 to the
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`petition filed in IPR2014—00732, theexecuted signature page for Exhibit 1010 in
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`IPR20l4—O0730 was erroneously inserted into Exhibit 1011 in IPR20l4—00732 in
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`lieu of Dr. D’Andrea’s signature page for Exhibit 1011 in IPR20l4—00732.
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`Additionally, Prof. Raffaello D’Andrea’s Curriculum Vitae (“Appendix B” to his
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`declaration) was inadvertently not included in Exhibit 1011 in IPR20l4—00732.
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`These errors were unintentional and were brought to my attention in January
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`before Dr. D’Andrea’s deposition.
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`7.
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`Once the errors were brought to my attention and after we received a
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`letter from Drone’s counsel regarding the signature page error,
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`I prepared a
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`corrected Exhibit 1011, which includes the correct signature page and a copy of the
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`pdf file of Dr. D’Andrea’s Curriculum Vitae at “Appendix B” to his declaration.
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`In the process of preparing the corrected exhibit, I also applied a new exhibit label
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`3
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`
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`to the front page and more easily identifiable page—numbering to the attachments to
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`the declaration. This corrected Exhibit 1011 was served on Drone’s counsel on
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`Monday, January 26, 2015.
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`4
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