Case 5:18-md-02834-BLF Document 608-11 Filed 06/18/20 Page 1 of 10
`
`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 PERSONAL WEB TECHNOLOGIES,
`LLC, ET AL., PATENT LITIGATION
`
`AMAZON.COM, INC. and AMAZON WEB
`SERVICES, INC.,
`Plaintiffs,
`
`v.
`
`PERSONALWEB TECHNOLOGIES, LLC,
`and LEVEL 3 COMMUNICATIONS, LLC,
`Defendants.
`
`CASE NO.: 5:18-cv-00767-BLF
`CASE NO.: 5:18-cv-05619-BLF
`DECLARATION OF DR. SAMUEL H.
`RUSS IN SUPPORT OF PERSONALWEB
`TECHNOLOGIES, LLC’S OPPOSITION
`TO MOTION OF AMAZON.COM, INC.,
`AMAZON WEB SERVICES, INC., AND
`TWITCH INTERACTIVE, INC. FOR
`ATTORNEY FEES AND COSTS
`
`Date: August 6, 2020
`Time:
`9:00 a.m.
`Courtroom 3, 5th Floor
`Dept.:
`Judge: Hon. Beth Labson Freeman
`
`PERSONALWEB TECHNOLOGIES, LLC
`and LEVEL 3 COMMUNICATIONS, LLC,
`Counterclaimants,
`
`v.
`AMAZON.COM, INC. and AMAZON WEB
`SERVICES, INC.,
`Counterdefendants.
`
`PERSONALWEB TECHNOLOGIES, LLC, a
`
`DECLARATION OF DR. SAMUEL H. RUSS ISO PWEB’S OPPOSITION TO MOTION OF
`AMAZON AND TWITCH INTERACTIVE, INC. FOR ATTORNEY FEES AND COSTS
`
`CASE NO: 5:18-MD-02834-BLF
`CASE NO: 5:18-CV-00767-BLF
`CASE NO: 5:18-CV-05619-BLF
`
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`Case 5:18-md-02834-BLF Document 608-11 Filed 06/18/20 Page 2 of 10
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`Texas limited liability company, and
`LEVEL 3 COMMUNICATIONS, LLC, a
`Delaware limited liability company
`Plaintiffs,
`
`v.
`TWITCH INTERACTIVE, INC. a Delaware
`corporation,
`Defendant.
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`DECLARATION OF DR. SAMUEL H. RUSS ISO PWEB’S OPPOSITION TO MOTION OF
`AMAZON AND TWITCH INTERACTIVE, INC. FOR ATTORNEY FEES AND COSTS
`
`CASE NO: 5:18-MD-02834-BLF
`CASE NO: 5:18-CV-00767-BLF
`CASE NO: 5:18-CV-05619-BLF
`
`

`

`Case 5:18-md-02834-BLF Document 608-11 Filed 06/18/20 Page 3 of 10
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`I, Dr. Samuel H. Russ, declare as follows:
`1.
`I have personal knowledge of the facts contained in this declaration and unless
`otherwise stated, if called a witness I could and would competently testify thereto.
`2.
`I submit this declaration in support of PersonalWeb Technologies, LLC’s
`(“PersonalWeb”) Opposition to Motion of Amazon.com, Inc., Amazon Web Services, Inc., and
`Twitch Interactive, Inc. for Attorney Fees and Costs.
`3.
`I received a Ph.D. in Electrical Engineering in 1991 and a Bachelor of Science degree
`in 1986 in electrical engineering, both from Georgia Institute of Technology. Since 2007, I have
`been on the faculty of the Electrical and Computer Engineering Department at the University of
`South Alabama. I have significant education, work, and academic experience since 1991 in the field
`of computer networking and content delivery over the internet and other networks. For example, I
`have managed the development of cable set-top boxes, developed pioneering home-networking
`technology (including a coaxial networking system that won an Engineering and Technology
`Emmy® Award in 2015), and taught classes in embedded systems and cryptography. Several of my
`published papers involve the delivery of video over in-home Internet-based wireless and wired
`networks. I am very familiar with HTTP protocol, having both studied it and worked with it over 25
`years.
`
`I am intimately familiar with how to construe patent claims, including claims that are
`4.
`under review by the United States Patent and Trademark Office and the federal courts, and how prior
`art may affect the validity of a patent. I have served as an expert witness in 33 patent infringement
`matters for both patent owners and alleged infringers, in litigation, in Inter Partes Reviews, in
`covered business method reviews, and at the International Trade Commission. I have also testified
`in both depositions and trials in numerous matters in which I have always qualified as an expert
`witness. Attached hereto as Exhibit 1 is a true and correct copy of my curriculum vitae, which
`details my experience more extensively and also provides a list of the patent cases on which I have
`served as an expert witness.
`5.
`I was retained by counsel for PersonalWeb in early October 2017 in connection with
`evaluating and providing my expert opinion as to whether patents in PersonalWeb’s patent portfolio,
`
`1
`DECLARATION OF DR. SAMUEL H. RUSS ISO PWEB’S OPPOSITION TO MOTION OF
`AMAZON AND TWITCH INTERACTIVE, INC. FOR ATTORNEY FEES AND COSTS
`
`CASE NO: 5:18-MD-02834-BLF
`CASE NO: 5:18-CV-00767-BLF
`CASE NO: 5:18-CV-05619-BLF
`
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`Case 5:18-md-02834-BLF Document 608-11 Filed 06/18/20 Page 4 of 10
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`commonly referred to as the “True Name” patents, were infringed by various website operators, and
`whether the patent claims potentially infringed were valid over the prior art. The technology
`involved in the potential infringement I was asked to study is similar to the technologies involved in
`my prior expert engagements discussed above.
`6.
`My initial task was to evaluate and provide my expert opinion regarding how various
`prior art cited in post-grant proceedings affected the validity of various claims in the True Name
`patents, including claims 38 and 42 of U.S. Patent No. 5,978,791 (the ’791 patent); claims 20, 69 and
`71 of U.S. Patent No. 7,802,310 (the ’310 Patent); claims 25-36 and 166 of U.S. Patent No.
`8,099,420 (the ’420 Patent); claims 10 and 11 of U.S. Patent No. 6,928,442 (the ’442 patent); and
`claims 46-56 of U.S. Patent No. 7,945,544 (the ’544 patent) (collectively, “claims under review”).
`7.
`I began this initial task by reviewing the claims under review, as well as the common
`specification of the True Name patents, and in connection with these assignments, I had primary
`communications with Sandeep Seth, a patent litigation attorney retained by PersonalWeb and
`additionally with Dr. Brian Siritzky, a patent prosecution attorney with a Ph.D. in computer science
`who had written the True Name patents. Aided by these two individuals, I reviewed and analyzed
`the prosecution history of the patents and the post-grant proceedings involving them. I also reviewed
`and analyzed prior constructions issued by various federal district courts and the Patent Trial and
`Appeal Board in connection with the True Name patents.
`8.
`The reexamination and inter-partes review proceedings I particularly focused on in
`my review included IPR2013-00596, and the Federal Circuit’s decision in Pers. Web Techs., LLC v.
`Apple, Inc., 848 F.3d 987 (Fed. Cir., 2017); IPR2013-00082; IPR2013-00084; IPR2013-00087;
`Reexam Control No. 90/013,487; Reexam Control No. 90/020,091; Reexam Control No.
`90/020,102; IRP2014-00058; IPR2014-00066; and IPR2014-00979.
`9.
`I reviewed the disclosures and operation of certain prior art references considered in
`the post-grant proceedings. The prior art references I particularly focused on included U.S. Patent
`No. 5,649,196 (“Woodhill”), U.S. Patent No. 4,845,715 (“Francisco”), U.S. Patent No. 7,359,881
`(“Stefik”), U.S. Patent No. 6,135,646 (“Kahn”) and non-patent references including “FWKCS
`Contents-Signature System Version 1.22” (“Kantor”), “Scalable, Secure, and Highly Available
`
`2
`DECLARATION OF DR. SAMUEL H. RUSS ISO PWEB’S OPPOSITION TO MOTION OF
`AMAZON AND TWITCH INTERACTIVE, INC. FOR ATTORNEY FEES AND COSTS
`
`CASE NO: 5:18-MD-02834-BLF
`CASE NO: 5:18-CV-00767-BLF
`CASE NO: 5:18-CV-05619-BLF
`
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`Case 5:18-md-02834-BLF Document 608-11 Filed 06/18/20 Page 5 of 10
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`Distributed File Access” (“Satyanarayanan”), and a newsgroup post by Albert Langer (“Langer”). I
`analyzed True Name patent claims that had been invalidated in these proceedings, the rulings, and
`their relationship to the claims under review.
`10.
`Through my extensive review and analysis of the foregoing, I formed conclusions and
`opined about the validity of the claims under review. Specifically, I did not find the art I reviewed
`anticipated these claims or rendered them obvious. I wrote up my opinions and sent them in letter
`form setting forth my analysis and the basis of my conclusions to PersonalWeb’s counsel on January
`3, 2018.
`Another one of my assignments for PersonalWeb and its counsel was to analyze
`11.
`whether the True Name patents under review were infringed by certain website operators who
`PersonalWeb suspected of infringing one or more of the claims under review through two forms of
`infringement. In the first form of infringement, PersonalWeb suspected website operators were
`practicing a form of cache-control by sending their webpage files to browsers in HTTP 200 message
`wherein the website operators were adding an ETag header using a content-based value for the ETag
`and also adding max-age values in the cache-control header of such messages. The second form of
`infringement added the use of content-based fingerprints in the filenames of asset files that were
`listed in the webpage index files sent by the website operator.
`12.
`I examined certain optional cache control features of the HTTP 1.1 protocol
`implemented, for example, the Amazon S3 file storage and service platform in connection with its
`service of certain webpage files. In particular, I studied which website operators added to an HTTP
`200 response to a GET request for a webpage file the following two headers: (1) an ETag header
`with a content based-ETag value; and (2) a cache-control header with a “max-age” directive. I also
`determined that the website operator, by adding these two headers (neither of which were included in
`HTTP version 1.0 or required by HTTP version 1.1) to the HTTP 200 message: (a) set an original
`time period the file’s content was permitted to be cached/used and, after that original time period had
`expired; and (b) required the recipient to check whether it was still permitted to use that cached
`content by sending a conditional HTTP GET request with the ETag in an “If-None-Match” header.
`13.
`I further determined that the website operator: (a) extended the permitted time for the
`
`3
`DECLARATION OF DR. SAMUEL H. RUSS ISO PWEB’S OPPOSITION TO MOTION OF
`AMAZON AND TWITCH INTERACTIVE, INC. FOR ATTORNEY FEES AND COSTS
`
`CASE NO: 5:18-MD-02834-BLF
`CASE NO: 5:18-CV-00767-BLF
`CASE NO: 5:18-CV-05619-BLF
`
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`Case 5:18-md-02834-BLF Document 608-11 Filed 06/18/20 Page 6 of 10
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`content to be used after the original time period had expired but the file’s content had not changed by
`comparing the received ETag with its current ETag for that file and, if they matched, sending an
`HTTP 304 response; (b) declined to extend the permitted time for the cached content to be used after
`its original permitted time period had expired and the file’s content had changed by comparing the
`received ETag with its current ETag for that file and, if they did not match, sending the new content
`in a new HTTP 200 response with a new max-age header and new ETag header; and (c) authorized
`the cache to access the new content instead of the old content for a new time period set by the new
`max-age value in the new HTTP 200 response.
`14.
`I also examined certain features of Ruby on Rails webserver architecture platform
`(“RoR”). In particular, I studied how that platform inserted a content-based fingerprint into the
`filename of a webpage asset file within a mechanism called the “asset pipeline.” I looked at how the
`fingerprint in the filename could be used for cache-control to (1) provide a new index file to the
`cache when the content of one or more asset file named in the index file had changed and (2) inform
`the cache exactly which previously cached asset file had new content that needed to be obtained.
`15.
`In performing my analysis, in addition to Mr. Seth and Dr. Siritzky, I worked with
`and relied on a team of computer engineers employed by patent litigation consulting company
`Patbak to compile infringement evidence reflecting which of the suspected website operators were
`sending webpage files in HTTP 200 messages that added content-based values into ETag headers
`and max-age directives in cache-control headers, and which of the suspected website operators were
`also inserting fingerprints in the filenames of their asset files. I formulated an understanding of
`which of the website operators who were ultimately sued by PersonalWeb in January 2018 had
`practiced these specific forms of cache-control during the relevant time period.
`16.
`In the pre-suit investigation, I and Patbak conducted a heuristic analysis to determine
`whether a website used RoR, S3, or both, in which we looked at several markers in webpages
`archived on archive.org as indicative, but not conclusive, of the use of RoR or S3 in serving that
`webpage at the time it was archived. We also consulted public websites that analyze websites to
`determine what software was used to create the website.
`17.
`If a combination of the markers met a certain threshold, we determined it was very
`
`4
`DECLARATION OF DR. SAMUEL H. RUSS ISO PWEB’S OPPOSITION TO MOTION OF
`AMAZON AND TWITCH INTERACTIVE, INC. FOR ATTORNEY FEES AND COSTS
`
`CASE NO: 5:18-MD-02834-BLF
`CASE NO: 5:18-CV-00767-BLF
`CASE NO: 5:18-CV-05619-BLF
`
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`Case 5:18-md-02834-BLF Document 608-11 Filed 06/18/20 Page 7 of 10
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`likely that website was using RoR or S3, respectively. I examined all of the websites operated by the
`defendants sued in January 2018, and all of them met the heuristics for determining if the site used
`RoR, and the heuristics for determining if the site used S3.
`18.
`This heuristic analysis used industry accepted techniques to determine the likelihood
`that a particular website used RoR and/or served webpage assets with Amazon S3, and we only
`determined websites to be likely to be infringing if these industry accepted techniques showed a very
`high likelihood that the website used RoR or Amazon S3.
`19. My investigation also included reviewing claim constructions issued by U.S. District
`Court Judge Leonard Davis and U.S. District Court Judge Rodney Gilstrap.
`20.
`In my claim construction review, I noted that Judge Davis had ruled that the term
`“licensed” did not require construction and was not limited to any particular form of license, and did
`not necessarily have to be for the requested content, and otherwise, that the term did not require
`construction. I based this on my review of the order from PersonalWeb Technologies, LLC. v.
`Amazon.com.Inc., et al, Case No. 6:11-cv-00658, Dkt. 140, pp. 25-26. (“While there must be a
`license to a file, there is no further restriction on what type of license is necessary. For example,
`there is no disclaimer stating that a license must be to a specific file, or whether it could be to a
`series of files, or whether it could be even broader than that. Further, there is no language in the
`specification mandating a particular level of specificity of license. There is also no limiting language
`about the nature in which a license must be issued. Accordingly, while a party must have a license to
`access a particular file, there is no restriction on precisely how that license grants access to the file.”)
`21.
`In reviewing Judge Gilstrap’s claim constructions, I noted that he construed “license”
`to mean “valid rights to content” and “authorized” as “compliant with a valid license.” I reviewed
`these constructions and formed an opinion that there was infringement in light of them.
`22.
`Ultimately, I delivered infringement opinions to PersonalWeb’s counsel in the form
`of claim charts for each website operator for which I had formed an infringement opinion. Attached
`as Exhibit 2 is a true and correct copy of the list of each of the website operators for which I
`provided an infringement opinion in the form of a claim chart. I delivered these charts between
`January 8, 2018 and January 19, 2018. Attached as Exhibit 3 is a true and correct copy of a
`
`5
`DECLARATION OF DR. SAMUEL H. RUSS ISO PWEB’S OPPOSITION TO MOTION OF
`AMAZON AND TWITCH INTERACTIVE, INC. FOR ATTORNEY FEES AND COSTS
`
`CASE NO: 5:18-MD-02834-BLF
`CASE NO: 5:18-CV-00767-BLF
`CASE NO: 5:18-CV-05619-BLF
`
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`Case 5:18-md-02834-BLF Document 608-11 Filed 06/18/20 Page 8 of 10
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`representative chart from my Airbnb opinion, which details my opinion of how each claim element
`was met, and which is the same format as the opinions I provided for the other website operators
`listed in Exhibit 2.
`23.
`In my factual review, I determined that the servers used by the accused website
`operator were programmed to provide file content in HTTP 200 messages with two specific headers
`not required by the HTTP/1.1 specification (RFC 2616): the ETag header, which provided a value
`that could be used for several purposes, but served as a “validator”; and a cache-control header
`directive called “max-age” which specified the amount of time (in seconds) that the recipient (e.g. a
`browser) was authorized/permitted/licensed to cache and access the content after it received the
`HTTP 200 message. (Ex. 2, ’310 Chart, p. 4.) Neither of these header types existed in the HTTP/1.0
`version of the HTTP specification. I also determined that the servers were programmed to generate
`an MD5 hash value for the ETag. (Ex. 2, ’310 Chart, pp. 3, 8.) The use of such a content-based
`ETag like an MD5 hash is also not a requirement of the HTTP/1.1 specification nor is it even
`disclosed in the HTTP/1.1 specification, which leaves open to the user the choice of what to use as
`an ETag.
`I also determined that the recipients of such HTTP 200 messages were programmed,
`24.
`in accordance with the HTTP/1.1 specification, to cache and use the content and store its URL, max-
`age, received time and ETag. (Ex. 2, ’310 Chart, pp. 4-5.) I further determined that the recipient was
`programmed, when it wished to again access the cached file content, to determine whether a max-
`age value existed for that content. If so, the recipient was programmed to check the current time
`against the time the HTTP 200 message had been received, and determine whether the difference in
`seconds exceeded the max-age value. (RFC 2616, Sections 13.2.3, 13.2.4, 14.9.3.) If the difference
`did not exceed the max-age value, the recipient was programmed to access the cached content.
`(RFC 2616, Section 13.1.1.) If the difference did exceed the max-age value, the recipient was
`programmed not to immediately access the cached content. (RFC 2616, Section 13.3.) Instead, it was
`programmed to first send the ETag it had for that URL in a conditional GET request with an If-
`None-Match header and await a response. (Ex. 2, ’310 Chart, pp. 5, 6, 10; RFC 2616, Sections 13.3,
`13.3.3, 13.3.4, 14.26.)
`
`6
`DECLARATION OF DR. SAMUEL H. RUSS ISO PWEB’S OPPOSITION TO MOTION OF
`AMAZON AND TWITCH INTERACTIVE, INC. FOR ATTORNEY FEES AND COSTS
`
`CASE NO: 5:18-MD-02834-BLF
`CASE NO: 5:18-CV-00767-BLF
`CASE NO: 5:18-CV-05619-BLF
`
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`Case 5:18-md-02834-BLF Document 608-11 Filed 06/18/20 Page 9 of 10
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`I also determined the server, also in accordance with the HTTP/1.1 specification, was
`25.
`programmed to compare the ETag value received in the conditional GET request with the current
`ETag values it had for the URL specified in the conditional GET request. (Ex. 2, ’310 Chart, pp. 4,
`9, 10.) If there was a match with any of the ETag values it had for that URL, the server was
`programmed to not send the requested file but rather was programmed to instead send an HTTP 304
`message. (Ex. 2, ’310 Chart, pp. 4, 5, 10.)
`26.
`I also determined that the recipient was programmed to access the cached file content
`if it received the 304 response. (Ex. 2, ’310 Chart, pp. 4-5, 10.) Later, if the recipient wished to again
`access the file, it was programmed to compare the current time with the time it had received the 304
`response and, as above, see if the difference exceeded the max-age value. If not, the recipient was
`programmed to access the cached content for that file. If so, it was programmed to again send a
`conditional GET request with the ETag value it had for that URL and an If-None-Match header and
`await a response. (Ex. 2, ’310 Chart, p. 10.)
`27.
`Conversely, at the server, if the ETag in the conditional GET request did not match
`any of the ETags for the URL of the requested file, then the server was programmed to send the file
`content the server had stored for the URL (which would be different from the content in the
`recipient’s cache because the MD5 ETags did not match) in an HTTP 200 response that again
`included a cache-control header with a max-age value for the new content, and an ETag header with
`the MD5 hash value for the new content (which would be different from the ETag for the content in
`the recipient’s cache because the content in the recipient’s cache is different from the content in the
`new HTTP 200 response). (Ex. 2, ’310 Chart, p. 10.)
`28. When the recipient received the HTTP 200 response, it was programmed to not use
`the previously cached content for the file; rather, it was programmed to cache and use the new
`content and to store the time it was received, its ETag, and max-age value. (Ex. 2, ’310 Chart, p. 10.)
`When the recipient was called upon to access that new content, it was programmed to go through the
`same procedure outlined above to determine whether it was permitted to access the content again or
`whether it had to send the conditional GET request and await a response before accessing the
`content.
`
`7
`DECLARATION OF DR. SAMUEL H. RUSS ISO PWEB’S OPPOSITION TO MOTION OF
`AMAZON AND TWITCH INTERACTIVE, INC. FOR ATTORNEY FEES AND COSTS
`
`CASE NO: 5:18-MD-02834-BLF
`CASE NO: 5:18-CV-00767-BLF
`CASE NO: 5:18-CV-05619-BLF
`
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`Case 5:18-md-02834-BLF Document 608-11 Filed 06/18/20 Page 10 of 10
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`I formed the good faith belief that this programmed cache-control method fell
`29.
`squarely within the claim limitations requiring a determination of whether a data item was
`authorized/unauthorized or licensed/unlicensed because it: (a) granted permission to a recipient to
`cache and access specifically identified content for a specific period of time; (b) required the
`recipient to revalidate access rights after the permitted time has expired; (c) used the MD5 values in
`deciding whether to extend such access rights or not; and (d) if the access rights were not extended,
`sent new content with permission to access the new content for a specified period of time, which also
`terminated the access rights to the previously cached content since no extension of the permitted
`time to access that content existed in that scenario.
`30.
`In sum, based upon my expertise, work, review and analysis, I was of the opinion that
`the claims under review were valid and that the suspected website operators that were going to be
`sued by PersonalWeb infringed the asserted claims of the patents-in-suit in the website operator
`cases that were subsequently filed.
`I declare under penalty of perjury under the laws of the United States of America that the
`foregoing is true and correct.
`Executed on June 18, 2020 in Mobile, Alabama.
`
`/s/ __
`Dr. Samuel H. Russ
`
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`DECLARATION OF DR. SAMUEL H. RUSS ISO PWEB’S OPPOSITION TO MOTION OF
`AMAZON AND TWITCH INTERACTIVE, INC. FOR ATTORNEY FEES AND COSTS
`
`CASE NO: 5:18-MD-02834-BLF
`CASE NO: 5:18-CV-00767-BLF
`CASE NO: 5:18-CV-05619-BLF
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`26
`27
`28
`
`