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Petition for Inter Partes Review
`U.S. Patent No. 6,809,490
`
`
`
`UNITED STATES PA TENT AND TRADEMARK OFFICE
`
`__________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________
`
`Shenzhen Silver Star Intelligent Technology Co., Ltd.
`
`Petitioner
`
`
`
`v.
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`
`
`iRobot Corporation
`
`Patent Owner
`
`__________
`
`Case: Unassigned
`
`U.S. Patent No. 6,809,490
`___________
`
`
`DECLARATION OF JULIE JAGER
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`
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`
`
`
`
`

`

`Petition for Inter Partes Review
`U.S. Patent No. 6,809,490
`
`I, Julie Jager, do hereby declare as follows:
`
`1. I am a paralegal at Arch & Lake LLP, attorneys for Petitioner. I make this declaration
`
`based on personal knowledge.
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`2. Exhibit 1001 is a copy of U.S. Patent No. 6,809,490, the patent that is the subject of the
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`present Petition.
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`3. Exhibit 1002 is the Prosecution File History of U.S. Patent No. 6,809,490.
`
`4. Exhibit 1003 is a copy of ITC COMPLAINT for Investigation filed with United States
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`International Trade Commission on April 18, 2017.
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`5. Exhibit 1004 is a copy of the complaint filed with United States District Court for the
`
`District of Massachusetts on April 17, 2017.
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`6. Exhibit 1005 is a copy of Certified Translation of JPH11212642A.
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`7. Exhibit 1006 is a copy of PCT application of WO0004430A1.
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`8. Exhibit 1007 is a copy of U.S. Patent 6,574,536.
`
`9. Exhibit 1008 is a copy of PCT application of WO9303399A1.
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`10. Exhibit 1009 is the Dictionary Definition of Encounter.
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`11. Exhibit 1010 is a copy of PCT application of WO0038025A1.
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`12. Exhibit 1011 is a copy of translated German application of DE19849978A1.
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`13. Exhibit 1012 is a copy of U.S. Patent 5,204,814.
`
`14. Exhibit 1013 is a copy of U.S. Patent 6,076,025.
`
`15. Exhibit 1014 is a copy of Japanese application of JPH11212642A.
`
`16. Exhibit 1015 is a copy of German application of DE19849978A1.
`
`17. Exhibit 1016 is a copy of “Sensors for Mobile Robots – Theory and Application” by H.R.
`
`Everett, Wellesley, MA, 1995.
`
`

`

`Petition for Inter Partes Review
`U.S. Patent No. 6,809,490
`
`18. Exhibit 1017 is a copy of “Where am I? Sensors and Methods for Mobile Robot
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`Positioning” by J. Borenstein, H.R. Everett and L. Feng, University of Michigan, Ann
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`Arbor, MI, April 1996
`
`19. Exhibit 1018 is a copy of “Mobile Robots – Inspiration to Implementation” by J.L. Jones
`
`and A. M. Flynn, Wellesley, MA, 1st Edition, 1993.
`
`20. Exhibit 1019 is a copy of “Sweep Strategies for a Sensory-Driven, Behavior-Based
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`Vacuum Cleaning Agent” by K.L. Doty and R.R. Harrison, AAAI Technical Report FS-
`
`93-03, AAAI 1993 Fall Symposium Series – Instantiating Real-World Agents, Oct. 1993
`
`(“AAAI Article”).
`
`21. Exhibit 1020 is a copy of Declaration of Dr. Mingshao Zhang, Ph.D.
`
`22. Exhibit 1021 is a copy of Respondents’ opening claim construction brief, Certain Robotic
`
`Vacuum Cleaning Devices and Components Thereof Such as Spare Parts, Inv. No. 337-
`
`TA-1057.
`
`23. Exhibit 1022 is a copy of Complainant’s reply claim construction brief, Certain Robotic
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`Vacuum Cleaning Devices and Components Thereof Such as Spare Parts, Inv. No. 337-
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`TA-1057.
`
`24. Exhibit 1023 is a copy of Joint Claim Construction Chart, Certain Robotic Vacuum
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`Cleaning Devices and Components Thereof Such as Spare Parts, Inv. No. 337-TA-1057.
`
`25. Exhibit 1024 is a copy of Markman hearing transcript, Certain Robotic Vacuum Cleaning
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`Devices and Components Thereof Such as Spare Parts, Inv. No. 337-TA-1057.
`
`26. Exhibit 1025 is a copy of Construing terms of the asserted patents (November 9, 2017),
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`Certain Robotic Vacuum Cleaning Devices and Components Thereof Such as Spare
`
`Parts, Inv. No. 337-TA-1057.
`
`

`

`27. Exhibit 1026 is a copy of U.S. Patent 6,493,612.
`
`Petition for Inter Partes Review
`U.S. Patent No. 6,809,490
`
`
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`
`
`
`
`April 9, 2018
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`/Julie Jager/
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`Julie Jager
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`

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