`
`Covered Business Method Patent Review
`
`United States Patent No. 8,118,221
`
`Attorney Docket No.:
`104677-5008-813
`
`Customer No. 28120
`
`Petitioner: Apple Inc.
`
`Inventor: Racz et al.
`
`United States Patent No: 8,118,221
`liormerly Application No.: 12X943,872
`Issue Date: February 21, 2012
`Filing Date: November 10, 2010
`Former Group Art Unit: 2887
`Former l'ilxaminer: Thien M. I c
`
`wmwwmmw
`
`Data Storage and Access Systems
`
`MAIL STOP PA’I‘ENT BOARD
`
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`
`Post Office Box 1450
`
`Alexandria, Virginia 22313-1450
`
`DECLARATION OF MEGAN F. RAYMOND IN SUPPORT OF
`
`PETITION FOR COVERED BUSINESS METHOD PATENT REVIEW OF
`
`UNITED STATES PATENT NO. 8,118,221
`PURSUANT TO 35 U.S.C. S 321, 37 C.F.R. § 42.304
`
`1, Megan F. Raymond, make the following Declaration pursuant to 28 U.S.C. §
`
`1746:
`
`l.
`
`2.
`
`I am an attorney at the law firm of Ropes & Gray LL13.
`
`I provide this Declaration in connection with the above—identified
`
`Covered Business Method Patent Review proceeding that is being requested at the
`
`United States Patent and Trademark Office by Apple Inc. under 35 U.S.C. § 321, 37
`
`C.l-*'.R. § 42.304. Unless otherwise stated, the facts stated in this Declaration are based
`
`on my personal knowledge.
`
`Apple Exhibit 1223 Page 00001
`
`Apple Exhibit 1223 Page 00001
`
`
`
`Covered Business Method Patent Review
`
`United States Patent No. 8,118,221
`
`3.
`
`Exhibit 1210 hereto is a true and correct copy of United States Patent
`
`No. 5,940,805 to Dieter Kopp, which was downloaded on October 26, 2014 from the
`
`United States Patent and Trademark Office
`
`(“USPTO”) Patent Application
`
`Information Retreival (“PAIR”) website at my request and which is a record of the
`
`USPTO to which all parties have access. 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.
`
`4.
`
`Exhibit 1219 hereto is
`
`a true and correct copy of International
`
`Publication No. 990 95/345357, filed onjune 14, 1995 by Smitl1,]a1nes P. and Smith,
`
`Edward 31., and published on December 21, 1995, which was downloaded at my
`
`request on October 26, 2014 from the European Patent Office’s Espacenet search
`
`page to which all parties have access. 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.
`
`5.
`
`lilxhibit 1220 hereto is a true and correct copy of an article by 'Iiberhard
`
`yon Faber, Robert
`
`I-Iammelrath, and Franz-Peter
`
`I-l'eider, entitled “The Secure
`
`Distribution of Digital Contents,” from the 13th Annual Computer Security
`
`Applications Conference held on December 8-12, 1997, published by The Institute of
`
`l'fllectrical and Electronics Engineers, Inc, which was retrieved from the Linda Hall
`
`Library of Science, [Engineering and Technology, Document Services at my request.
`
`Page 00002
`
`Page 00002
`
`
`
`Covered Business Method Patent Review
`
`United States Patent No. 8,118,221
`
`Page numbers and an exhibit label have been added to the bottom of this document
`
`but no other alterations have been made.
`
`6.
`
`Exhibit 1230 hereto is a true and correct copy of the Claim Construction
`
`Opinion (“Claim Construction Opinion”) from Smarflarli LLC, at at a Appfe Imu, er
`
`a1, Civil Action No. 6:13—cv—447, before the District Court of the Eastern District of
`
`Texas, which was downloaded on October 29, 2014 from the Public Access to Court
`
`Electronic Records (“PACER”) website at my request and is a record of the
`
`aforementioned District Court (Dkt. No. 229) to which all parties have access. The
`
`Claim Construction Opinion contains markings at the top of each page indicating the
`
`PACER filing information. 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.
`
`7.
`
`Exhibit 1231 hereto is a true and correct copy of United States Patent
`
`No. 4,337,483 to Louis C. Guillou, which was downloaded on October 29, 2014 from
`
`the USPTO PAIR website at my request and which is a record of the USPTO to
`
`which all parties have access. 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.
`
`8.
`
`Exhibit 1232 hereto is a true and correct copy of United States Patent
`
`No. 7,725,375 to Ian Kenneth Shepherd, which was downloaded on October 29, 2014
`
`from the USPTO PAIR website at my request and which is a record of the USPTO to
`
`Page 00003
`
`Page 00003
`
`
`
`Covered Business Method Patent Review
`
`United States Patent No. 8,118,221
`
`which all parties have access. 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.
`
`9.
`
`Exhibit 1233 hereto is a true and correct copy of United States Patent
`
`No. 5,925,127 to Arshad Ahmad, which was downloaded on October 27, 2014 from
`
`the USPTO PAIR website at my request and which is a record of the USPTO to
`
`which all parties have access. 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.
`
`10.
`
`I make this declaration of my own personal knowledge.
`
`If called to
`
`testify as
`
`to the truth of the matters stated herein,
`
`1 could and would testify
`
`competently.
`
`11.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`.lixecuted this 30th day of October, 2014, at Washington, DC.
`
`Megan 14'. Raymond
`
`Page 00004
`
`Page 00004
`
`