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`Apple Exhibit 4255
`Apple v Sightsound Technologies
`CBM2013-00020
`Page 00001
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`Apple Exhibit 4255
`Apple v Sightsound Technologies
`CBM2013-00020
`Page 00001
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`I, Jeffrey Robbin, declare:
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`1.
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`I am employed by Apple Inc. (“Apple”) as Vice President, iTunes and
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`Apple TV.
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`I am over the age of 18, I have personal knowledge of the facts set forth
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`herein, and I am competent to testify regarding these facts.
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`2.
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`In my current capacity at Apple, my responsibilities include overseeing
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`the development of the {Fumes client and setting product direction. The iTunes client
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`is the software that runs on Microsoft Windows or (Mac) OS X computers and iOS
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`devices that, in addition to other functions, provides users with access to the iTunes
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`Store.
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`3.
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`I began working at Apple as an intern in 1992 and returned full time in
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`1993. In 1997, I left Apple and later started the company SoundStep.
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`\While at
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`Soundstcp, I, along with Bill Kincaid and David Heller, developed the Software
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`product Sound_]an1 MP, a music player product for the Mac. Soundjam MP, among
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`other things, allowed users to play music, transfer music from their computers to MP3
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`players, create playlists, and transfer music from CDs to their computers and convert
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`to MP3 format.
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`4.
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`In September 2000, Apple acquired SoundStep, and I returned to Apple
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`as part of the acquisition. I was employed as an engineer to Continue my work on
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`Soundjam MP, which was the predecessor product to iTunes.
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`I was responsible,
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`along with Mr. Kincaid and H1‘. Heller, for the development of the iTunes client.
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`iTunes commercially launched in January 2001.
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`414025883
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`5.
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`Prior to March 2002, I became involved in developing a music purchase
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`service for Apple, which became the iTunes Music Store, currently known as the
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`iTunes Store.
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`6.
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`I was one of the leaders of the initial development team for the iTunes
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`Music Store. An internal demonstration version of the iTunes Music Store was
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`available by the end of 2002. The iTunes Music Store officially launched on April 23,
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`2003.
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`7.
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`The iTunes client and iTunes Music Store include many technological
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`features developed by Apple. One example is the “Genius” feature, which, among
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`other functions, implements a sophisticated algorithm to provide recommendations
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`based on past purchases. Apple has been granted U.S. patents on rnany inventions
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`relating to the iTunes Music Store, including user interface technology, playlist
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`management, presentation of media on a device, secure access to content, and
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`assigning ratings. For example, Apple patents for which I am one of the named
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`inventors include US. Patent No. 7,853,893 relating to a graphical user interface for
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`searching, browsing, previewing, and/ or purchasing media items; US. Patent No.
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`6,728,729 relating to accessing media across networks; U.S. Patent No. 7,765,326
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`relating to improved interac1ion between a host computer and a media player; U.S.
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`Patent No. 7,797,446 relating to automatic updating of playlists; US. Patent No.
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`7,827,259 relating to selecting and presenting media items at a media device; U.S.
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`Patent No. 7,844,498 relating to interacting with an online media store to obtain a
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`media asset bundle; US. Patent No. 7,895,661 relating to secure access to content
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`within media files; US. Patent No. 7,958,441 relating to management of playlists; and
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`U.S. Patent No. 8,046,369 relating to assigning ratings to media assets. Apple also has
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`been granted many other patents, for which I am not a named inventor, for
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`innovative features of the iTunes client and iTunes Store.
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`8.
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`To my recollection, I had not heard of, nor was I aware of, any
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`SightSound entity or any services offered by any Sightfaound entity before 2003.
`
`I
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`also have no recollection of any communication from either Tom ‘Weyer or Mark
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`Gavini (now Marco Mazzoni) relating to SightSound or to the concept of electronic
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`purchase of digital audio or video signals over telecommunication lines. Nor am I
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`aware of anyone in the development team for the launch of the iTunes Music Store,
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`including Mr. Heller, who knew anything about SightSound or its services prior to
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`2003, or had such communication from either Mr. Weyer or Mr. Gavini (now Mr.
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`Mazzoni). As one of the leaders of the development team for the iTunes Music Store,
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`if anyone had heard of Sightsound or received any information about SightSound that
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`related to the {fumes Music Store, I believe I would have been aware of it.
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`9.
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`I am informed that Sigl1tSound is alleging in this proceeding—more than
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`10 years after Apple developed and launched the iTunes Music Store—~that Apple
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`developed the iTunes client and iTunes Music Store by copying from SightSound.
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`Based on my knowledge and experience as a key member of the development team
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`for the iTunes client and the iTunes Music Store, that allegation is utterly false. Apple.
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`developed those technologies based on the predecessor product Soundjam MP that it
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`acquired in September 2000, and based on the significant innovative work done at
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`Apple to make commercially viable the idea—prevalent in the industry since the mid-
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`1980s——that it would be desirable to sell music and video files over computer
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`networks. Apple’s work on this project was both innovative and pioneering, which
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`helps to explain why Apple became the market leader so soon after its launch of the
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`iTunes Music Store. Based on my core involvement in this project, and my extensive,
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`sustained interaction with all of the other team members in developing the iTunes
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`ecosystem, Apple did not copy anything from any SightSound entity.
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`I declare under penalty of perjury under the laws of the United States of
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`America that the foregoing is true and correct.
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`Dated: March A, 2014
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`E
`
`Jeffrey Robbin
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`4I402588_2
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