`
`BEFORE THE PA'I‘ENT TRIAL AND APPEAL BOARD
`
`APPLE INC.
`
`Petitioner
`
`v.
`
`SIGHTSOUND TECHNOLOGIES, LLC
`Patent Owner
`
`Case CBM2013-00023
`
`Patent 5,966,440
`
`Before the Honorable MICHAEL P. TIERNEY, JUSTIN T. ARBES, and
`GEORGIANNA W. BRADEN,
`Admifiirz‘raz’z’ve Patefltjudgeu‘.
`
`DECLARATION OF MEGAN F. RAYMOND
`
`I, Megan F. Raymond, make the following Declaration pursuant to 28 U.S.C. §
`
`1746:
`
`1.
`
`2.
`
`I am an attorney at the law firm of Ropes & Gray LLP.
`
`I provide this Declaration in connection with the above-identified
`
`Covered Business Method Patent Review proceeding and Petitioner Apple’s
`
`Opposition to Patent Owner SightSound Technologies LLC’S Motion for Additional
`
`Discovery under 37 CFR § 42.224(a). Unless otherwise stated, the facts stated in this
`
`Declaration are based on my personal knowledge.
`
`Apple Exhibit 4357
`
`Apple V. SightSound Technologies
`CBM2013-00023
`
`Page 00001
`
`Apple Exhibit 4357
`Apple v. SightSound Technologies
`CBM2013-00023
`Page 00001
`
`
`
`3.
`
`Exhibit 4349 is a true and correct copy of the cover sheet of the Expert
`
`Report of Dr. John P. J. Kelly Regarding Non-Infringement of United States Patent
`
`Nos. 5,191,573 and 5,966,440. Page numbers and an exhibit label have been added to
`
`the bottom of this document but no other alterations have been made.
`
`4.
`
`Exhibit 4350 is a true and correct copy of the September 24, 2007 article
`
`Virgin Digital Shuts Down, which was retrieved from wwwtechhivecom at my
`
`direction on November 22, 2013. Page numbers and an exhibit label have been added
`
`to the bottom of this document but no other alterations have been made.
`
`5.
`
`Exhibit 4351 is a true and correct copy of the January 13, 2007 article
`
`AOL, Now Focused on Free, Sells Its Paid Music Service, which was retrieved from
`
`wwwnytimescom at my direction On November 22, 2013. Page numbers and an
`
`exhibit label have been added to the bottom of this document but no other alterations
`
`have been made.
`
`6.
`
`Exhibit 4352 is a true and correct copy of the August 10, 2011 article
`
`Walmart Closing Online Music Store, which was retrieved from physorg at my
`
`direction on November 22, 2013. Page numbers and an exhibit label have been added
`
`to the bottom of this document but no other alterations have been made.
`
`7.
`
`Exhibit 4353 is a true and correct copy of the article ITunes’ Success
`
`Revolutionizes Music Business, which was retrieved from wwwleadertelegramcom at
`
`Page 00002
`
`Page 00002
`
`
`
`my direction on November 22, 2013. Page numbers and an exhibit label have been
`
`added to the bottom of this document but no other alterations have been made.
`
`8.
`
`Exhibit 4354 is a true and correct copy of the May 5, 2003 press release
`
`entitled iTunes Music Store Sells Over One Million Songs in First Week, which was
`
`retrieved from www.apple.com at my direction on November 22, 2013. Page
`
`numbers and an exhibit label have been added to the bottom of this document but no
`
`other alterations have been made.
`
`9.
`
`Exhibit 4355 is a true and correct copy of the April 26, 2013 email from
`
`Sean Callagy to David Cohen, which was received by attorneys at Ropes & Gray LLP.
`
`Page numbers and an exhibit label have been added to the bottom of this document,
`
`but no other alterations have been made.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Executed this 22nd day of November, 2013, at Washington, DC.
`
`1...
`
`
`Megan F. Raymond
`
`Page 00003
`
`Page 00003
`
`
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