`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`§
`
`§
`Case No. 6:21-cv-00984-ADA
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`JURY TRIAL DEMANDED
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`§
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`§
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`v.
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`APPLE INC.,
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`Defendant.
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`Case 6:21-cv-00984-ADA Document 73-1 Filed 07/13/22 Page 1 of 2
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`JAWBONE INNOVATIONS, LLC,
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`Plaintiff,
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`DECLARATION OF PETER LAMBRIANAKOS IN SUPPORT OF
`JAWBONE INNOVATIONS, LLC’S
`SUR-REPLY CLAIM CONSTRUCTION BRIEF
`
`I, Peter Lambrianakos, hereby declare as follows:
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`1.
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`I have personal knowledge of the facts set forth in this declaration. I am competent
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`to testify as to all matters stated, and I am not under any legal disability what would in any way
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`preclude me from testifying.
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`2.
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`I am a Partner at the law firm of Fabricant LLP and counsel of record for Plaintiff
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`Jawbone Innovations, LLC, in this matter.
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`3.
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`The exhibits attached to this declaration may contain annotations and/or excerpts
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`of the originals.
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`4.
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`Attached hereto as Exhibit C is a true and correct copy of excerpts from the redacted
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`version of Samsung’s Responsive Claim Construction Brief dated July 5, 2022 in Jawbone
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`Innovations, LLC v. Samsung Electronics Co., Ltd., et al., Case No. 2:21-cv-00186-JRG (E.D.
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`Tex.).
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`Case 6:21-cv-00984-ADA Document 73-1 Filed 07/13/22 Page 2 of 2
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed on July 13, 2022 in Mantoloking, New Jersey.
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`/s/ Peter Lambrianakos
` Peter Lambrianakos
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`2
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`
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