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`Case 5:18-md-02834-BLF Document 551-1 Filed 10/25/19 Page 1 of 12
`
`MICHAEL A. SHERMAN (SBN 94783)
`masherman@stubbsalderton.com
`JEFFREY F. GERSH (SBN 87124)
`jgersh@stubbsalderton.com
`SANDEEP SETH (SBN 195914)
`sseth@stubbsalderton.com
`WESLEY W. MONROE (SBN 149211)
`wmonroe@stubbsalderton.com
`STANLEY H. THOMPSON, JR. (SBN 198825)
`sthompson@stubbsalderton.com
`VIVIANA BOERO HEDRICK (SBN 239359)
`vhedrick@stubbsalderton.com
`STUBBS, ALDERTON & MARKILES, LLP
`15260 Ventura Blvd., 20th Floor
`Sherman Oaks, CA 91403
`Telephone:
`(818) 444-4500
`Facsimile:
`(818) 444-4520
`Attorneys for PersonalWeb Technologies, LLC
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`CASE NO.: 5:18-md-02834-BLF
`IN RE PERSONALWEB TECHNOLOGIES,
`LLC, ET AL., PATENT LITIGATION
`_______________________________________
`PERSONALWEB TECHNOLOGIES, LLC, a
`Texas limited liability company, and
`LEVEL 3 COMMUNICATIONS, LLC,
`a Delaware limited liability company,
`Plaintiffs,
`
`v.
`TWITCH INTERACTIVE, INC. a Delaware
`corporation,
`
`Defendant.
`
`Case No.: 5:18-cv-05619-BLF
`
`DECLARATION OF ERIK DE LA
`IGLESIA IN SUPPORT OF
`PERSONALWEB TECHNOLOGIES,
`LLC’S NON-OPPOSITION TO TWITCH
`INTERACTIVE, INC. MOTION FOR
`SUMMARY JUDGEMENT OF
`NONINFRINGEMENT AND PARTIAL
`OPPOSITION TO MOTION TO
`EXCLUDE TESTIMONY OF ERIK DE LA
`IGLESIA
`
`Trial Date: March 16, 2020
`
`DECLARATION OF
`ERIK DE LA IGLESIA
`
`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-05619-BLF
`
`

`

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`DECLARATION OF ERIK DE LA IGLESIA
`I, Erik de la Iglesia, declare as follows:
`I am over the age of eighteen (18) and make this declaration of my own personal
`1.
`knowledge, under penalty of perjury.
`I have been retained as an independent expert witness by the law firm of Stubbs
`2.
`Alderton & Markiles, LLP on behalf of PersonalWeb Technologies, LLC (“PersonalWeb”) to
`testify as a technical expert in lawsuits concerning U.S. Patent No. 6,928,442 (“‘442 Patent”), U.S.
`Patent No. 7,802,310 (“‘310 Patent”), and U.S. Patent No. 8,099,420 (“‘420 Patent”) (collectively,
`“the Asserted Patents”), the lawsuits including In re PersonalWeb Technologies, LLC, et al.,
`Patent Litigation, Case No.: 5:18-md-02834-BLF (Northern District of California) and
`PersonalWeb Technologies, LLC v. Twitch Interactive, Inc., Case No. 5:18-cv-05619-BLF
`(Northern District of California). I refer to Twitch Interactive, Inc. as “Twitch” in this declaration.
`On August 23, 2019, I submitted my report summarizing my findings regarding
`3.
`infringement by Twitch. For at least all the reasons summarized in that report, it is my opinion that
`Twitch’s web server met certain limitations of each of claim 20 of the ’310 patent, claims 25, 26,
`27, 32, 34, 35, 36, and 166 of the ’420 patent, and claims 10 and 11 of the ’442 patent. I understand
`from counsel that PersonalWeb is withdrawing certain portions of my August 23 report. A true
`and correct copy of my August 23 report with the redactions is attached hereto as Exhibit 1, which
`I verify under penalty of perjury.
`The asserted patent claims relate to controlling the distribution of files in a network
`4.
`of computers. Requests for content or access to content are permitted or not permitted by the
`system using specific methods that include the use of content-based identifiers. This subject
`matter includes the protocols used to transfer those files, technology such as caching to accelerate
`distribution and the configuration of such caching to optimize efficiency using content-based
`identifiers.
`While the evidence of the claim limitations and my analysis are detailed in my
`5.
`report, I will address in this declaration certain specific points raised by Twitch in its summary
`judgment motion that relates to:
`
`
`
`DECLARATION OF
`ERIK DE LA IGLESIA
`
`1
`
`
`
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`CASE NO: 5:18-cv-05619-BLF
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`Case 5:18-md-02834-BLF Document 551-1 Filed 10/25/19 Page 3 of 12
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`a.
`
`b.
`
`c.
`
`How Twitch used MD5 ETags that were generated by applying the MD5 hash
`algorithm to the content and only the content of a Twitch webpage file to determine
`whether or not to send a message that permitted browsers to keep using cached
`version of that webpage file after the original permitted time to use that cached
`version has expired;
`How Twitch used MD5 ETags to determine whether or a file at a browser was a
`copy of the current version of a webpage file in making the decision of (a); and
`How Twitch compared an MD5 ETag sent in a conditional GET request from a
`browser to see if it matched one of a plurality of stored ETags in making the
`determinations of (a) and (b).
`More particularly, as I explain below, Twitch servers sent Twitch webpage file
`6.
`content in HTTP 200 messages with MD5 ETags and max-age values set by Twitch. By doing
`so, the Twitch server instructed browsers operating under the HTTP 1.1 protocol how long they
`were permitted to use the file content without having to first check back with Twitch whether
`they may still continue to use the content after their permitted use of the content has expired.
`After the permitted time to use the content has expired, the browser sent a conditional GET
`request to which it must receive an HTTP 304 response to continue to access and use the cached
`file content.
`If the browser instead received from a Twitch server an HTTP 200 response to the
`7.
`conditional GET request, it used the content provided in the 200 response instead of the
`previously cached content. Moreover, the Twitch servers used MD5 ETags (i.e., ETag values
`generated by applying the MD5 hash algorithm to the file content and only the file content) in
`making the decision whether or not to continue to permit the browsers’ access to the previously
`cached file content or to provide new file content for the browser to access and use instead of the
`previously cached file content.
`The MD5 ETags informed the Twitch server whether a copy of the current version
`8.
`of the webpage file was already cached (present) at the browser or whether a copy of the current
`version needed to be provided. If a copy of the current version was determined to be already
`
`
`
`DECLARATION OF
`ERIK DE LA IGLESIA
`
`2
`
`
`
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`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-05619-BLF
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`

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`present at the browser, Twitch sent the HTTP 304 message permitting the browser to continue
`accessing the cached copy. If the file at the browser was determined to be a copy of the current
`file version, the Twitch server sent the HTTP 200 message for the browser to access instead of
`the previously cached version. By using this system of HTTP 304 and 200 messages, Twitch
`controlled how long browsers accessed Twitch’s webpage file content and what webpage file
`content they accessed.
`I will now address Twitch’s three summary judgment arguments that are not based
`9.
`upon the Court’s construction of “unauthorized or unlicensed.”
`Claim 20 of the ’310 patent recites, in relevant part:
`10.
`based at least in part on said content-dependent name of said
`particular data item, the first device (A) permitting the content to be
`provided to or accessed by the at least one other computer if it is not
`determined that the content is unauthorized or unlicensed,
`otherwise, (B) if it is determined that the content is unauthorized or
`unlicensed, not permitting the content to be provided to or accessed
`by the at least one other computer.
`The evidence that I have reviewed shows that Twitch’s webpage servers each
`11.
`made a determination to permit or not permit content to be provided to or accessed by a client,
`such as a browser, based at least on part on an MD5 ETag value, which is a content-dependent
`name of said particular data item. The Twitch servers operated during the relevant infringement
`time period in accordance with the HTTP 1.1 protocol, RFC 2616. Specifically, the servers
`communicated with connected computers communicate via messages, including but not limited
`to those specified in RFC 2616 regarding GET requests (“HTTP GET requests”) (e.g., Sec. 9.3),
`conditional GET requests (“HTTP conditional GET requests”) with If-None-Match Headers (e.g.,
`Sec. 14.9.4), ETags (e.g., Sec. 14.19), 304 messages (“HTTP 304 messages”) (e.g., Sec. 10.3.5),
`200 messages (“HTTP 200 messages”) (e.g., Sec. 10.2.1), and cache control directives (e.g., Secs.
`13.1, 13.2, 13.3.2-4, 14.9, 14.21, 14.26) to implement cache control including in instructing
`browsers when they were allowed to re-use previously cached content or had to use instead use
`
`
`
`DECLARATION OF
`ERIK DE LA IGLESIA
`
`3
`
`
`
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`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-05619-BLF
`
`

`

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`newly provided content.
`HTTP 1.1 provides a mechanism for using ETags to instruct clients (such as
`12.
`browsers) whether or not file content stored in their caches may continue to be used to fulfill
`requests for content after their original permitted time to use the content has expired. More
`particularly, HTTP 1.1 allowed website operators to send the file content in an HTTP 200 message
`with an “ETag” value for that content and a “max-age” value (i.e., a permitted time to use the
`content) and force a browser to check back with the server before using that content after the
`permitted time had expired. If a requested file is served along with a max-age caching directive
`and an ETag value, the client browser cache will store the file, the max-age and the ETag. As
`long as the file’s age in the cache is less than the max-age, the client cache will reuse the file for
`future requests. (RFC 2616 @ 51-52). However, after the permitted time to use the content has
`been exceeded, conditional GETs must be used to revalidate that the client is permitted to keep
`using the cached file content for some extended period of time.
`The evidence I reviewed confirmed that, during the relevant time period, Twitch
`13.
`servers used content-based ETags that were generated by applying the MD5 hash algorithm to
`the content, and only the content, of the associated file. My evidentiary review also confirmed
`that the servers sent the MD5 ETag along with the file content and cache control directives in
`HTTP 200 messages and subsequently compared such MD5 ETags sent by clients (e.g. browsers
`and intermediate cache servers) in conditional GET requests with the current ETag values for the
`requested file stored at the server.
`The following source code that Twitch’s server used compared the ETag sent by
`14.
`a browser in a conditional GET request with a value for a data item stored at the server:
`if (ngx_strncmp(start, etag->data, etag->len) != 0).
`(PERSONALWEB106919, at line 193.)
`If the server processing the conditional GET request verified that the ETag sent
`15.
`in the “If-None-Match” request header of the conditional GET request matched the current MD5
`ETag value of the requested file, the server then made a determination to permit a browser to keep
`using and accessing the cached content when it sent a 304 NOT MODIFIED message to the
`
`
`
`DECLARATION OF
`ERIK DE LA IGLESIA
`
`4
`
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`
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`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-05619-BLF
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`

`

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`browser, which was accomplished by the following code:
`r->headers_out.status = NGX_HTTP_NOT_MODIFIED;
`r->headers_out.status_line.len = 0;
`r->headers_out.content_type.len = 0;
`ngx_http_clear_content_length(r);
`ngx_http_clear_accept_ranges(r);
`(PERSONALWEB106919, at lines 94-98.)
`This capability relied on the fact that the server’s MD5 ETag value for that file
`16.
`was updated when that file’s content changed. RFC 2616 does not describe the generation of
`ETag validators or require the use of content-based ETags that changed only when the content
`itself changed but rather distinguishes weak from strong validators by requiring that strong
`validators change whenever the underlying file changed. (RFC 2616 @ 54-57)
`17. When the Twitch server responding to the conditional GET request did not find
`there to be an MD5 ETag match, it made a determination not to permit a browser to keep using
`and accessing the cached content and sent an HTTP 200 OK response with new content for the
`browser to use and access instead of previously cached content in accordance with the HTTP
`protocol specification RFC 2616. Twitch’s witness, James Richard, also provided extensive
`testimony confirming my analysis of Twitch’s processing of HTTP conditional GET requests
`containing content-based ETags and sending 200 and 304 responses. (See James Richard Dep.
`Tr. (10/1/19), at pps. 9-21, 33-35, 38-39.)
`Claim 25 of the ’420 patent recites, in relevant part:
`18.
`(C) based at least in part on said ascertaining in step (B), selectively
`allowing a copy of the particular sequence of bits to be provided to or
`accessed by or from at least one of the computers in a network of
`computers, wherein a copy of the sequence of bits is not to be provided
`or accessed without authorization, as determined, at least in part, based
`on whether or not said first content-dependent name of the particular
`sequence of bits corresponds to one of the plurality of identifiers.
`
`
`
`DECLARATION OF
`ERIK DE LA IGLESIA
`
`5
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`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-05619-BLF
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`The evidence I have reviewed shows that Twitch’s servers selectively allowed a
`19.
`copy of a particular sequence of bits (a data item) to be accessed by a computer in a network,
`namely, a computer running a web browser. The Twitch servers stored many data items to which
`MD5 ETag identifiers had been assigned. The source code discussed above determined whether
`the MD5 ETag identifier sent by a browser in a conditional GET request matched one of a
`plurality of identifiers. ((PERSONALWEB106919, at line 193.) When the server found a match,
`it determined that the file content at the browser was a copy of the file content at the server and
`allowed the browser to keep accessing the cached copy when it sent an HTTP 304 Not Modified
`response. (PERSONALWEB106919, at lines 94-98.) When the server did not find a match, it
`made a determination not to allow a browser to keep accessing cached content when it sent an
`HTTP 200 OK response with new content, which the browser would then use instead of cached
`content in accordance with the HTTP protocol specification RFC 2616.
`20. Claim 166 of the ’420 patent recites, in relevant part:
`(a2) selectively permit the particular data item to be made available for
`access and to be provided to or accessed by or from at least some of the
`computers in a network of computers, wherein the data item is not to
`be made available for access or provided without authorization, as
`resolved based, at least in part, on whether or not at least one of said
`one or more content-dependent digital identifiers for said particular
`data item corresponds to an entry in one or more databases, each of said
`one or more databases comprising a plurality of identifiers, each of said
`identifiers in each said database corresponding to at least one data item
`of a plurality of data items, and each of said identifiers in each said
`database being based, at least in part, on at least some of the data in a
`corresponding data item.
`The evidence I reviewed shows that Twitch’s servers selectively permitted access
`21.
`to a data item to be accessed by a computer in a network, namely, a computer running a web
`browser, for the same reasons as I just discussed. The evidence supporting this limitation of claim
`
`
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`DECLARATION OF
`ERIK DE LA IGLESIA
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`166 of the ’420 patent is the same as for the limitation in claim 25 of the ’420 patent discussed
`above.
`
`22.
`
`Claim 11 of the ’442 patent recites, in relevant part:
`A method as in claim 10 further comprising: allowing the file to be
`provided from one of the computers having an authorized or
`licensed copy of the file.
`The evidence I have reviewed shows that Twitch servers allowed a file to be
`23.
`provided from the server when the file’s content had changed. Specifically, the server determined
`whether the MD5 ETag sent by a client (e.g. a browser) in an HTTP conditional GET request
`matched the current MD5 ETag value for the file at the server. When the server did not find a
`match, the server generated an HTTP 200 OK response with the new file content for the browser
`to use instead of cached content in accordance with the HTTP protocol specification RFC 2616.
`This description of how the Twitch servers meet this specific claim limitations is
`24.
`consistent with the plain and ordinary meaning of “allow” and “permit.”
`Twitch servers processed conditional GET request having MD5 ETags, which are
`25.
`content-based names for the requested file, received from clients during the relevant time period.
`As part of that processing, the Twitch server either allowed/permitted the browser to keep using
`the cached file content or made new file content available for access based on a comparison of
`the MD5 ETag sent in the request with the current MD5 ETag value for the file.
`I do not read, and do not believe any person of ordinary skill in the art would read,
`26.
`any of the claims to require that the system must “prevent” access forever. In the “back” button
`example provided by Twitch, no request for a file is sent to the server, so it cannot be said that
`the server did or did not prevent the cache content to be viewed as the server is not involved that
`transaction. Similarly, Twitch’s example of offline viewing of pages is irrelevant because offline
`viewing by definition likewise does not involve communications with the server.
`Asserted claim 10 [and dependent claim 11] of the ‘442 patent requires:
`27.
`“determining, using at least the name, whether a copy of the data file is present on at least one of
`said computers.” Twitch asserts that this limitation is not met because “ETags are not used to
`
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`DECLARATION OF
`ERIK DE LA IGLESIA
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`locate files in the accused Twitch website or to determine if they are present.” [Dkt. 542 at pg.
`11 (PDF at 14 of 16)]
`In making this argument, Twitch appears to mistake my analysis. I do not assert
`28.
`that ETags were used to “locate files in the accused Twitch website.” The accused ETags were
`used by Twitch servers to determine whether various Twitch webpage files in browser caches are
`copies of various Twitch webpage files at Twitch webpage servers. When Twitch determined
`that a file at the browser cache is a copy of the file at the server, Twitch sent an HTTP 304 message
`instructing the browser to keep using the cached copy for some extended time period. And,
`conversely, when Twitch determined that a copy of the file at the Twitch server was not already
`present at the browser cache, Twitch sent an HTTP 200 message to provide the browser with an
`actual copy of the current version. The ETag was used to match content in order to determine
`whether that content was present at a given location, i.e., to determine whether a copy was present.
`By merely receiving an ETag in a conditional GET request and not doing anything
`29.
`further with it, Twitch could not know whether a copy of a given file located at the server was
`also present at the browser cache. It was necessary for Twitch to compare the content-based ETag
`with another ETag to determine whether the file located at the browser is actually a copy of the
`file located at the server, i.e., that the content of the file at the browser cache is a copy of the
`content of the file at the server. Indeed, without this determination, Twitch would not have known
`whether to send the HTTP 304 (extending the permitted time that the browser can use the cached
`copy of the file) or rather to send an HTTP 200 message with a copy of the current version of the
`file.
`
`All Twitch can determine with just the URI is that a file having that URI is located
`30.
`at a given computer, not whether that file is a copy of another file. This is the point of using the
`MD5 ETags—the URI and MD5 ETag are both needed to determine whether the file at the
`browser cache has the same content as the file at the webpage server, i.e., only when both the URI
`and the ETag received in the conditional GET request match the URI and ETag at the server, does
`Twitch determine that the file at the browser cache is an actual copy of the file at the server. Only
`when the two files have the same content is one a “copy” of the other.
`
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`DECLARATION OF
`ERIK DE LA IGLESIA
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`I understand Twitch cites my report as support for the proposition that, “ETags are
`31.
`not used to identify, locate or retrieve files.” [Br. at p. 11, Dkt. 542 at pdf 14/16]. However,
`neither claim 10 nor claim 11 requires retrieving files. Nowhere do I make a statement that an
`ETag does not identify the file or is not used to locate a copy of a file. To the contrary, the ETag
`must identify the file content so that it can be used to determine whether a current copy of a given
`file is already present at browser or must be provided. I explain this is paragraph 112 of my
`report:
`
`The Twitch web servers receive the conditional GET request and
`compare the ETag value obtained in the request with stored ETag
`values to determine whether the received ETag value matches the
`current ETag value for the content of the object referenced in the
`request.
`Claim 25 recites: “ascertaining whether or not said first content-dependent name
`32.
`for the particular sequence of bits corresponds to one of a plurality of identifiers.” This language
`does not require that the first content-dependent name is compared to more than one of a plurality
`of identifiers. It only requires that it be ascertained whether or not the content-dependent name
`corresponds to one of the plurality of identifiers.
`Similarly, claim 166 recites, “whether or not at least one of said one or more
`33.
`content-dependent digital identifiers for said particular data item corresponds to an entry in one or
`more databases, each of said one or more databases comprising a plurality of identifiers.” Again,
`this language does not require that a content-dependent digital identifier be compared to more than
`one of a plurality of identifiers in a database, only that it be ascertained whether or not it
`corresponds to one of the entries in the database, which Twitch server’s did as per my source code
`analysis set forth above.
`I reserve all rights to supplement this declaration in response to additional
`34.
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`DECLARATION OF
`ERIK DE LA IGLESIA
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`9
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`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-05619-BLF
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`Case 5:18-md-02834-BLF Document 551-1 Filed 10/25/19 Page 11 of 12
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`discovery, newly discovered documents, and/or reports by other experts.
`Executed this October 25, 2019 in Mountain View, California.
`
`Erik de la Iglesia
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`DECLARATION OF
`ERIK DE LA IGLESIA
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`10
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`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-05619-BLF
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`Case 5:18-md-02834-BLF Document 551-1 Filed 10/25/19 Page 12 of 12
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`EXHIBIT 1
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`EXHIBIT 1
`FILED UNDER SEAL
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`FILED UNDER SEAL
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`