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`UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE
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`PATENT TRIAL AND APPEAL BOARD
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`IKEA Supply AG
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`Petitioner
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`v.
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`Everlight Electronics Co., Ltd.,
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`Patent Owner
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`Patent No. 9,640,733 to Hsieh et al. IPR Case No.: IPR2024-00972
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`Declaration of Joseph R. Klinicki
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`IKEA Supply AG
`Exhibit 1024 Page 1 of 5
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`Ex-1024 – Attorney Declaration of Joseph R. Klinicki
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`1. My name is Joseph R. Klinicki, and I am a shareholder of the law firm
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`Flaster Greenberg P.C. I have been retained by, and am counsel for, Petitioner IKEA
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`Supply AG (“ISAG”) in the above captioned proceeding. I am above the age of 18
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`and am a USPTO registered patent attorney having Registration No. 68,505.
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`2.
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`I make this declaration in support of IKEA’s petition for inter partes
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`review of U.S. Patent No. 9,640,733 (“the ’733 patent”).
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`3.
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`Attached as Exhibit 1001 (Ex-1001) is a true and correct copy of the
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`’733 patent.
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`4.
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`Attached as Exhibit 1002 (Ex-1002) is a true and correct copy of the
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`file history for the ’733 patent.
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`5.
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`Attached as Exhibit 1003 (Ex-1003) is a true and correct copy of a
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`declaration regarding the unpatentability of the claims of the ’733 patent by Dr.
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`Michael Lebby.
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`6.
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`Attached as Exhibit 1004 (Ex-1004) is a true and correct copy of U.S.
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`Patent No. 7,771,093.
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`7.
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`Attached as Exhibit 1005 (Ex-1005) is a true and correct copy of U.S.
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`Patent No. 7,462,870.
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`8.
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`Attached as Exhibit 1006 (Ex-1006) is a true and correct copy of
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`Japanese Patent Publication No. 2014-041966.
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`1
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`IKEA Supply AG
`Exhibit 1024 Page 2 of 5
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`Ex-1024 – Attorney Declaration of Joseph R. Klinicki
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`9.
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`Attached as Exhibit 1007 (Ex-1007) is a true and correct copy of
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`Certified English Translation of Japanese Patent Publication No. 2014-041966.
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`10. Attached as Exhibit 1008 (Ex-1008) is a true and correct copy of U.S.
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`Patent Publication No. 2014/0124812.
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`11. Attached as Exhibit 1009 (Ex-1009) is a true and correct copy of U.S.
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`Patent No. 7,719,024.
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`12. Attached as Exhibit 1010 (Ex-1010) is a true and correct copy of Patent
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`Owner’s Infringement Contentions and Claim Chart comparing U.S. Patent No.
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`9,640,733 to the IKEA Ledare GX53 LED Bulb in Everlight Electronics Co., Ltd. v.
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`IKEA US Retail LLC, et al., No. 6:23-cv-00481-AM-DTG (W.D. Tx. Jul. 5, 2023).
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`13. Attached as Exhibit 1011 (Ex-1011) is a true and correct copy of U.S.
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`Patent No. 7,964,943.
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`14. Attached as Exhibit 1012 (Ex-1012) is a true and correct copy of U.S.
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`Patent No. 8,415,681.
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`15. Attached as Exhibit 1013 (Ex-1013) is a true and correct copy of the
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`Preliminary Opinion in German Nullity Proceeding for EP2947705, dated February
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`14, 2024.
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`16. Attached as Exhibit 1014 (Ex-1014) is a true and correct copy of
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`machine-based English Translation of Preliminary Opinion in German Nullity
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`Proceeding for EP2947705, dated February 14, 2024.
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`2
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`IKEA Supply AG
`Exhibit 1024 Page 3 of 5
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`Ex-1024 – Attorney Declaration of Joseph R. Klinicki
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`17. Attached as Exhibit 1015 (Ex-1015) is a true and correct copy of the
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`Scheduling Order (Dkt. No. 31) issued in Everlight Electronics Co., Ltd. v. IKEA US
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`Retail LLC, et al., No. 6:23-cv-00481-AM-DTG (W.D. Tx. Jul. 5, 2023).
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`18. Attached as Exhibit 1016 (Ex-1016) is a true and correct copy of Claim
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`Construction Order issued in Everlight Electronic Co., Ltd. v. Walmart Inc., No. 23-
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`cv-000439-AM-DTG (W.D. Tx. Jun. 9, 2023), dated May 6, 2024.
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`19. Attached as Exhibit 1017 (Ex-1017) is a true and correct copy of U.S.
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`Patent No. 7,161,190.
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`20. Attached as Exhibit 1018 (Ex-1018) is a true and correct copy of U.S.
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`Patent No. 6,274,924.
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`21. Attached as Exhibit 1019 (Ex-1019) is a true and correct copy of U.S.
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`Patent No. 8,097,937.
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`22. Attached as Exhibit 1020 (Ex-1020) is a true and correct copy of U.S.
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`Patent Application Publication No. 2007/0139949.
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`23. Attached as Exhibit 1021 (Ex-1021) is a true and correct copy of U.S.
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`Patent No. 8,035,125.
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`24. Attached as Exhibit 1022 (Ex-1022) is a true and correct copy of WIPO
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`Publication No. WO2013118072A2.
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`25. Attached as Exhibit 1023 (Ex-1022) is a true and correct copy of a
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`Curriculum Vitae (CV) for Dr. Michael Lebby.
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`3
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`IKEA Supply AG
`Exhibit 1024 Page 4 of 5
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`Ex-1024 – Attorney Declaration of Joseph R. Klinicki
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`26.
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`I, Joseph R. Klinicki, do hereby declare and state, that: (1) all
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`statements made herein of my own knowledge are true; (2) all statements made
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`herein on information and belief are believed to be true; and (3) these statements
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`were made with the knowledge that willful false statements and the like so made are
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`punishable by fine, imprisonment, or both, under Section 1001 of Title 18 of the
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`United States Code.
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`Date: May 29, 2024
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`/Joseph R. Klinicki/
`Joseph R. Klinicki
`Registration No. 68,505
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`4
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`IKEA Supply AG
`Exhibit 1024 Page 5 of 5
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