`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`APPLE INC.
`Petitioner
`
`v.
`
`SIGHTSOUND TECHNOLOGIES, LLC
`Patent Owner
`______________
`
`Case CBM2013-00020
`Patent 5,191,573
`______________
`
`Before the Honorable MICHAEL P. TIERNEY, JUSTIN T. ARBES, and
`GEORGIANNA W. BRADEN,
`Administrative Patent Judges.
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`DECLARATION OF CHING-LEE FUKUDA
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`I, Ching-Lee Fukuda, make the following Declaration pursuant to 28 U.S.C. §
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`1746:
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`1.
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`2.
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`I am a partner at the law firm of Ropes & Gray LLP.
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`I provide this Declaration in connection with the above-identified
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`Covered Business Method Patent Review proceeding and Petitioner’s Reply to Patent
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`Owner SightSound Technologies LLC’s Response. Unless otherwise stated, the facts
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`stated in this Declaration are based on my personal knowledge.
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`Apple Exhibit 4266
`Apple v. SightSound Technologies
`CBM2013-00020
`Page 00001
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`
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`3.
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`Exhibit 4166 hereto is a true and correct copy of the redacted version of
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`SightSound Technologies, LLC’s Expert Report of John Snell, titled “Plaintiff
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`SightSound Technologies, LLC’s, [sic] Expert Report of John Snell on Validity,”
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`signed and dated June 5, 2013, which was downloaded at my direction from a
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`hyperlink provided to me, counsel for Apple Inc., by Arnold & Porter LLP, counsel
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`for SightSound Technologies, LLC, in SightSound Techs., LLC v. Apple Inc., No. 11-
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`01292, before the District Court of the Western District of Pennsylvania. The first
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`page of the document has an exhibit label, “Exhibit 4 – Snell 3.6.14,” at the bottom,
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`as it was used in the March 6, 2014 Deposition of John Snell in the above-identified
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`Covered Business Method Patent Review proceeding. An exhibit label on the first
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`page and pages numbers on all pages have been added to the bottom of this
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`document but no other alterations have been made.
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`4.
`
`Exhibit 4173 hereto is a true and correct copy of SightSound
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`Technologies, LLC’s Technology Tutorial, titled “Technology Tutorial SightSound
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`Technologies, LLC v. Apple, Inc. No. 2:11-cv-1192-DWA Special Master Gregory
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`Bradley October 11, 2012,” which was provided to me, counsel for Apple Inc., by
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`Arnold & Porter LLP, counsel for SightSound Technologies, LLC, at the October 11,
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`2012 technology tutorial presentation in SightSound Techs., LLC v. Apple Inc., No. 11-
`
`01292, before the District Court of the Western District of Pennsylvania. The first
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`page of the document has an exhibit label, “Exhibit 15 – Snell 3.6.14,” to the right, as
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`it was used in the March 6, 2014 Deposition of John Snell in the above-identified
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`Page 00002
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`
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`Covered Business Method Patent Review proceeding. An exhibit label on the first
`
`page and pages numbers on all pages have been added to the bottom of this
`
`document but no other alterations have been made.
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`5.
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`I make this declaration of my own personal knowledge. If called to
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`testify as to the truth of the matters stated herein, I could and would testify
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`competently.
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`6.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`
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`Executed this 21st day of March, 2014, at New York, New York.
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`
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`Ching-Lee Fukuda
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`Page 00003
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