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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.
`
`Petitioner
`
`V.
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`SIGHTSOUND TECHNOLOGIES, LLC
`Patent Owner
`
`Case CBM2013—00020
`
`Patent 5,191,573
`
`Before the Honorable MICHAEL P. TIERNEY, JUSTIN ’1‘. ARBES, and
`GEORGIANNA W. BRADEN,
`Administrafim Patentfudger.
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`DECLARATION OF MEGAN F. RAYMOND
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`I, Megan F. Raymond, make the following Declaratiori 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 an attorney 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 Apple’s
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`Opposition to Patent Owner SightSound 'l‘cchnologies LLC’s Motion for Additional
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`Discovery under 37 CFR § 42.224(a). Unless otherwise stated, the facts stated in this
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`Declaration are based on my personal knowledge.
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`Apple Exhibit 4156
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`Apple V. Sightsound Technologies
`CBM2013-00020
`
`Page 00001
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`Apple Exhibit 4156
`Apple v. Sightsound Technologies
`CBM2013-00020
`Page 00001
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`
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`3.
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`Exhibit 4148 is a true and correct copy of the cover sheet of the Expert
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`Report of Dr. john P. J. Kelly Regarding Non-Infringement of United States Patent
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`Nos. 5,191,573 and 5,966,440. Page numbers and an exhibit label have been added to
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`the bottom of this document but no other alterations have been made.
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`4.
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`Exhibit 4149 is a true and correct copy of the September 24, 2007 article
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`Virgin Digital Shuts Down, which was retrieved from wwwlcchhivecom at my
`
`direction on November 22, 2013. Page numbers and an exhibit label have been added
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`to the bottom of this document but no other alteratious have been made.
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`5.
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`Exhibit 4150 is a true and correct copy of the january 13, 2007 article
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`AOL, Now Focused on Free, Sells Its Paid Music Service, which was retrieved from
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`www.mytimescom at my direction on November 22, 2013. Page numbers and an
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`exhibit label have been added to the bottom of this document but no other alterations
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`have been made.
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`6.
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`Exhibit 4151 is a true and correct copy of the August 10, 2011 article
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`Walmart Closing Online Music Store, which was retrieved from physorg at my
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`direction on November 22, 2013. Page numbers and an exhibit label have been added
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`to the bottom of this document but no other alterations have been made.
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`7.
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`Exhibit 4152 is a true and correct copy of the article ITunes’ Success
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`Revolutionizes Music Business, which was retrieved from wwwleadertelegramcom at
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`Page 00002
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`Page 00002
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`
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`my direction on November 22, 2013. Page numbers and an exhibit label have been
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`added to the bottom of this document but no other alterations have been made.
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`8.
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`Exhibit 4153 is a true and correct copy of the May 5, 2003 press release
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`entitled iTunes Music Store Sells Over One Million Songs in First Week, which was
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`retrieved from wwwapplecom at my direction on November 22, 2013. Page
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`numbers and an exhibit label have been added to the bottom of this document but no
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`other alterations have been made.
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`9.
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`Exhibit 4154 is a true and correct copy of the April 26, 2013 email from
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`Sean Callagy to David Cohen, carbon copying attorneys at Ropes & Gray LLP. Page
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`numbers and an exhibit label have been added to the bottom of this document, but
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`no other alterations have been made.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed this 22nd day of November, 2013, at Washington, DC.
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`
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`Megan F. Raymond
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`Page 00003
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`Page 00003
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