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` 104677-5005-804
`Customer No. 28120
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`Petitioner: Apple Inc.
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`§
`Inventor: Hair
`United States Patent No.: 5,966,440 §
`Formerly Application No.: 08/471,964 §
`Issue Date: October 12, 1999
`§
`Filing Date: June 6, 1995
`§
`Former Group Art Unit: 380
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`Former Examiner: Hoa T. Nguyen
`§
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`For: System and Method for Transmitting Desired Digital Video or Digital Audio
`Signals
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`MAIL STOP PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`Post Office Box 1450
`Alexandria, Virginia 22313-1450
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`DECLARATION OF MEGAN F. RAYMOND IN SUPPORT OF
`PETITION FOR COVERED BUSINESS METHOD PATENT REVIEW OF
`UNITED STATES PATENT NO. 5,966,440
`PURSUANT TO 35 U.S.C. § 321, 37 C.F.R. § 42.304
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`
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`I, Megan F. Raymond, 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 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 that is being requested at the
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`United States Patent and Trademark Office by Apple Inc. under 35 U.S.C. § 321, 37
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`C.F.R. § 42.304. Unless otherwise stated, the facts stated in this Declaration are based
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`on my personal knowledge.
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`Page 00001
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`3.
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`Exhibit 1310 hereto is a true and correct copy of an article entitled
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`“Audio/digital interface for the IBM PC?” from the From the News Desk section of
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`the June 4, 1984 issue of InfoWorld published by the InfoWorld Media Group, which
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`was downloaded from LexisNexis at my request. Page numbers have been added to
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`the bottom of this document and an exhibit label has been added to the top of this
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`document but no other alterations have been made.
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`4.
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`Exhibit 1317 hereto is a true and correct copy of a presentation entitled
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`“A High Speed Telecommunications Interface for Digital Audio Transmission and
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`Reception,” which bears the name Hyun Heinz Sohn and a reference to its
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`presentation at the 76th Convention 1984 October 8-11 New York AES and which
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`was retrieved from the Audio Engineering Society’s AES Convention Papers Forum
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`at (https://secure.aes.org/forum/pubs/conventions/?elib=11612 at my request.
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`Page numbers have been added to the bottom of this document and an exhibit label
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`has been added to the top of this document but no other alterations have been made.
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`5.
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`Exhibit 1324 hereto is a true and correct copy of an article entitled “The
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`Search For The Digital Recorder” from the November 12, 1984 issue of Fortune,
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`which was retrieved at my instruction from the Science, Industry and Business Library
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`located at 188 Madison Avenue, New York, NY 10016. Page numbers have been
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`added to the bottom of this document and an exhibit label has been added to the top
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`of this document but no other alterations have been made.
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`Page 00002
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`6.
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`Exhibit 1327 hereto is a true and correct copy of an article entitled “Spec
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`Sheet” from the March 1987 issue of Keyboard, which was retrieved at my instruction
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`from the United States Library of Congress, 101 Independence Avenue SE,
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`Washington, DC 20540. The article bears a Music Division Library of Congress.
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`Page numbers have been added to the bottom of this document and an exhibit label
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`has been added to the top of this document but no other alterations have been made.
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`7.
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`Exhibit 1341 hereto is a true and correct copy of the Declaration of Dr.
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`John P.J. Kelly in SightSound Techs., LLC v. Apple Inc., No. 11-01292, before the
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`District Court of the Western District of Pennsylvania, signed by John P.J. Kelly and
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`dated September 7, 2012, which was downloaded from the Public Access to Court
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`Electronic Records (“PACER”) website at my direction and is a record of the
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`aforementioned District Court (Dkt. No. 93) to which all parties have access. The
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`Declaration contains markings at the top of each page indicating the PACER filing
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`information. Page numbers have been added to the bottom of this document and an
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`exhibit label has been added to the top of this document but no other alterations have
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`been made.
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`8.
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`Exhibit 1342 hereto is a true and correct copy of an article entitled “New
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`Telerecording Method for Audio” from the October 1985 issue of Broadcast
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`Management Engineering, which was produced by counsel for SightSound Techs.,
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`LLC, the law firm of Arnold & Porter LLC, to counsel for Apple Inc., the law firm of
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`Ropes & Gray LLP, during discovery relating to SightSound Techs., LLC v. Apple Inc.,
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`Page 00003
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`No. 11-01292, before the District Court of the Western District of Pennsylvania. The
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`document, as produced, bears identification numbers CDN027185 – CDN027186
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`and a stamp from Stamford University Libraries dated November 12, 1985. The
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`document, as produced, also bears an image of a sticker marking the document as
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`“Exhibit &, Wt: M. Sohn, Date: 2.23.01, Frances A. Weinrob CSR, CRR..” Page
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`numbers have been added to the bottom of this document and an exhibit label has
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`been added to the top of this document but no other alterations have been made.
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`9.
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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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`10.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed this 5th day of May, 2013 in Washington, DC.
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` Megan F. Raymond
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`Page 00004
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