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`Covered Business "Method Patent Review
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`United States Patent No. 8,061,598
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`Attorney Docket No.:
`10467"/55008-815
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`Customer No. 28120
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`Petitioner: Apple Inc.
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`Inventor: Racz et al.
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`United States Patent No.: 8,061,598
`Formerly Application No.: 13/ 012,541
`Issue Date: November 22, 2011
`Filing Date: january 24, 2011
`Former Group Art Unit: 2887
`Former lixaminer: Thien M. Le
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`l§’JlJaZ‘3!.fI'1§§l_//T115‘!
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`1301': Data Storage and Access Systems
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`MAIL STOP IJATENT BOARD
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`Patent Trial and Appeal Board
`United States Patent and Trademark Office
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`Post Office Box 1450
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`Alexandria, Virginia 22313-1450
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`DECLARATION OF MEGAN RAYMOND IN SUPPORT OF PETITION
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`FOR COVERED BUSINESS METHOD PATENT REVIEW OF
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`UNITED STATES PATENT NO. 8,061,598
`PURSUANT TO 35 U.S.C. § 321, 37 C.F.R. § 42.304
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`1, Megan 1*". 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.l*'.R.
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`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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`Apple Exhibit 1222 Page 00001
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`Apple Exhibit 1222 Page 00001
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`
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`Covered Business Method Patent Review
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`United States Patent No. 8,061,598
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`3.
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`Lixhibit 1203 hereto is a true and correct copy of "United States Patent
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`No. 5,925,127 to Arshad Ahmad, which was downloaded on October 27, 2014 from
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`the United States Patent and Trademark Office (“USPTO”) Patent i'\pp].icai:ion
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`Information Retrieval (“PAH ”) website at my request and which is a record of the
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`USPTO to which all parties have access. An exhibit label on the first page and pages
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`numbers on all pages have been added to the bottom of this document but no other
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`alterations have been made.
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`4.
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`Exhibit 1204 hereto is a true and correct copy of United States Patent
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`No. 5,940,805 to Dieter Kopp, which was downloaded on October 26, 2014 from the
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`'USPTO PAIR website at my request and which is a record of the USPTO to which all
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`parties have access. An exhibit label on the first page and pages numbers on all pages
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`have been added to the bottom of this document but no other alterations have been
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`made.
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`5.
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`Exhibit 1205 hereto is a true and correct copy of an article by Russell
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`I-Iousley and Jan Dolphin, entitled “Metering: A Pre~pay Technique,” Storage and
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`Retrieval for Image and Video Databases V, Conference Volume 3022, 527 (January
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`15, 1997) from the SPIE Digital library at my request. Page numbers and an exhibit
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`label have been added to the bottom of this document but no other alterations have
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`been made.
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`Page 00002
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`Page 00002
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`
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`Covered Business Method Patent Review
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`United States Patent No. 8,061,598
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`6.
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`Exhibit 1218 hereto is a true and correct Copy of an article by liberhard
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`von Faber, Robert Hamrnelrath, and 1+‘ranz~'Peter
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`I--ieider, entitled “The Secure
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`Distribution of Digital Contents,
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`from the 13th Annual Computer Security
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`3!‘
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`Applications Conference held on December 8-12, 1997, published by The lnstitute of
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`Electrical and Electronics Engineers, Inc., which was retrieved from the Linda Hall
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`Library of Science, Engineering and Technology, Document Services at my request.
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`Page numbers and an exhibit label have been added to the bottom of this document
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`but no other alterations have been made.
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`7.
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`liXl’1il)it 1223 hereto is a true and correct copy of the Claim Construction
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`Opinion (“Claim Construction Opinion”) from .S'm.ar2fXar/.1 LLC, er al 22. Apfle Ina, et
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`ai, Civil Action No. 6:13—cv—447', before the District Court of the Eastern District of
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`Texas, which was downloaded on October 29, 2014 from the Public Access to Court
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`Electronic Records (“PAClE7.R”) website at my reduest and is
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`a record of the
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`aforementioned District Court (Dkt. No. 229) to which all parties have access. The
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`Claim Construction Opinion contains markings at the top of each page indicating the
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`PACER filing information. An exhibit label on the first page and pages numbers on
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`all pages have been added to the bottom of this document but no other alterations
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`have been made.
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`8.
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`Exhibit 1224 hereto is a true and correct copy of the file history for
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`United States Patent No. 8,061,598 to Patrick Racz and Hermen—ard I-Iulst, which was
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`Page 00003
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`Page 00003
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`
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`Covered Business Method Patent Review
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`United States Patent No. 8,061,598
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`downloaded on October 29, 2014 at my request and which is a record of the USPTO
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`to which all parties have access. An exhibit label on the first page and pages numbers
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`on all pages have been added to the bottom of this document but no other alterations
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`have been made.
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`9.
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`l'*.lxlr1ibit 1225 hereto is a true and correct copy of United States Patent
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`No. 4,337,483 to Louis C. Guillou, which was downloaded on October 29, 2014 from
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`the US'P'l‘O PAIR website at my request and which is a record of the USPTO to
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`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
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`have been made.
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`10.
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`Exhibit 1226 hereto is a true and correct copy of United States Patent
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`No. 7,725,375 to Ian Kenneth Shepherd, which was downloaded on October 29, 2014
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`from the USPTO PAIR website at my request and which is a record of the USPTO to
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`which all parties have access. An exhibit label on the first page and pages numbers on
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`all pages have been added to the bottom of this document but no other alterations
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`have been made.
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`11.
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`Exhibit 1227 hereto is
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`a
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`true and correct copy of International
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`Publication No. \‘-C/O 95/34857, filed onjune 14, l995 by Srnith,_lames P. and Smith,
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`Edward A., and published on December 21, 1995, which was downloaded on
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`October 26, 2014 from the European Patent Off1ce’s Espacenet search page to which
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`Page 00004
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`Page 00004
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`
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`Covered Business Method Patent Review
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`United States Patent No. 8,061,598
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`all parties have access at my request. An exhibit label on the first page and pages
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`numbers on all pages have been added to the bottom of this document but no other
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`alte.rations have been made.
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`12.
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`I make this declaration of my own personal knowledge.
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`If called to
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`testify as
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`to the truth of the matters stated herein, 1 could and would testify
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`competently.
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`13.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed this 30”‘ day of October, 2014, at Washington, DC.
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`a Megan F. Eaymond
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`Page 00005
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`Page 00005
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