`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`ARTESIAN HOME PRODUCTS
`and
`AMERICAN DIE & ROLLFORMING
`Petitioners,
`
`v.
`
`GUTTERGLOVE, INC.,
`Patent Owner.
`
`Case IPR2018-00030
`Patent 8,479,454 B2
`
`DECLARATION OF JOHN COSTELLO
`
`IPR2018-00030
`Petitioners Ex. 1016 p. 1
`
`
`
`I, John Costello, declare as follows:
`
`I am an attorney at law, licensed to practice in the State of California,
`
`and I am backup counsel of record for Petitioners Artesian Home Products
`
`("Artesian Home Products") and American Die & Rollforming ("ADR")
`
`(collectively "Petitioners"). I am also counsel of record in Gutterglove, Inc. v.
`
`American Die and Rollforming, Inc., et al., United States District Court for the
`
`Eastern District of California Case No. 2:16-CV-02408-WHO, which is the co-
`
`pending patent litigation arising out of the patents that are the subject of these IPR
`
`proceedings. I have personal knowledge of the facts set forth herein, except those
`
`matters stated upon information and belief which I believe to be true. If called to
`
`testify, I could and would testify competently to the contents herein.
`
`2.
`
`Exhibit 1017 is a true and correct copy of a "Superior Gutter Guards"
`
`brochure that was produced by Petitioners to Patent Owner Gutterglove's
`
`("Gutterglove") counsel at the Kutak Rock firm on March 28, 2017, in the matter
`
`Gutterglove, Inc. v. American Die and Rollforming, Inc., et al., United States
`
`District Court for the Eastern District of California Case No. 2:16-CV-02408-
`
`WHO.
`
`3.
`
`Exhibit 1018 is a true and correct redacted copy of the supplemental
`
`responses served by Artesian Home Products on July 14, 2017, to Gutterglove's
`
`counsel at the Kutak Rock firm, in response to Gutterglove's Common
`
`IPR2018-00030
`Petitioners Ex. 1016 p. 2
`
`
`
`Interrogatories Set One in the matter Gutter love, Inc. v. American Die and
`
`Rollforming, Inc., et al., United States District Court for the Eastern District of
`
`California Case No. 2:1 F-CV-024(1R-WH(1
`
`4.
`
`Exhibit 1019 is a true and correct copy of documents produced by
`
`Gutterglove's counsel at Kutak Rock in October 2017, in the matter Gutterglove,
`
`Inc. v. American Die and Rollforming, Inc., et al., United States District Court for
`
`the Eastern District of California Case No. 2:16-CV-02408-WHO. These
`
`documents were produced to my office by Kutak Rock with Bates stamps
`
`(GG003333-GG003340) and confidentiality designations on them.
`
`I declare under penalty of perjury under the laws of the United States of
`
`America that the foregoing is true and correct.
`
`John Costello
`
`Executed on this 5th day of September, 2018.
`
`2
`
`IPR2018-00030
`Petitioners Ex. 1016 p. 3
`
`
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