IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Covered Business Method Patent Review
`
`United States Patent No. 7,334,720
`
`Attorney Docket No.:
`1046'/7—5008—817
`
`Customer No. 28120
`
`Petitioner: Apple Inc.
`
`Inventor: Racz et a1.
`
`United States Patent No.: 7,334,720
`Formerly Application No; 11 /336,758
`Issue Date: February 26, 2008
`Filing Date: January 19, 2006
`Former Group Art Unit: 2876
`Former Hxaminer: Steven S. Pail-;
`
`Q.’}'_‘3E§1f§iE&_".I1.?"-2’/"’JE§’:
`
`For: Data Storage and Access Systems
`
`MAI] 1 STOP I-”A'l‘EN’1‘ BOARD
`
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`
`Post Office Box 1450
`
`Alexandiia, Virginia 2231 3~1450
`
`DECLARATION OF MEGAN RAYMOND IN SUPPORT OF PETITION
`
`FOR COVERED BUSINESS METHOD PATENT REVIEW OF
`
`UNITED STATES PATENT NO. 7,334,720
`PURSUANT TO 35 U.S.C. § 321, 37 C.F.R. § 42.304
`
`1, Megan 1*". Raymond, make the following Declaration pursuant to 28 U.S.C. §
`
`1746:
`
`1.
`
`2.
`
`I am an attorney at the law firm of Ropes 8: Gray L] ,1’.
`
`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.F.R. § 42.304. Unless otherwise stated, the facts stated in this Declaration are based
`
`on my personal knowledge.
`
`Apple Exhibit 1222 Page 00001
`
`Apple Exhibit 1222 Page 00001
`
`
`
`Covered Business Method Patent Review
`
`United States Patent No. 7,334,720
`
`Attorney Docket No.:
`1046'/7—5008—817
`
`Customer No. 28120
`
`Petitioner: Apple Inc.
`
`Inventor: Racz et a1.
`
`United States Patent No.: 7,334,720
`Formerly Application No; 11 /336,758
`Issue Date: February 26, 2008
`Filing Date: January 19, 2006
`Former Group Art Unit: 2876
`Former Hxaminer: Steven S. Pail-;
`
`Q.’}'_‘3E§1f§iE&_".I1.?"-2’/"’JE§’:
`
`For: Data Storage and Access Systems
`
`MAI] 1 STOP I-”A'l‘EN’1‘ BOARD
`
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`
`Post Office Box 1450
`
`Alexandiia, Virginia 2231 3~1450
`
`DECLARATION OF MEGAN RAYMOND IN SUPPORT OF PETITION
`
`FOR COVERED BUSINESS METHOD PATENT REVIEW OF
`
`UNITED STATES PATENT NO. 7,334,720
`PURSUANT TO 35 U.S.C. § 321, 37 C.F.R. § 42.304
`
`1, Megan 1*". Raymond, make the following Declaration pursuant to 28 U.S.C. §
`
`1746:
`
`1.
`
`2.
`
`I am an attorney at the law firm of Ropes 8: Gray L] ,1’.
`
`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.F.R. § 42.304. Unless otherwise stated, the facts stated in this Declaration are based
`
`on my personal knowledge.
`
`Apple Exhibit 1222 Page 00001
`
`Apple Exhibit 1222 Page 00001
`
`
`
`Covered Business Method Patent Review
`
`United States Patent No. 7,334,720
`
`3.
`
`Exhibit 1203 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 United States Patent and Trademark Office (“USl’T()”) Patent Application
`
`Information Removal (“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.
`
`lixhibit 1204 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
`
`USPTO "PAIR website at my request and which is a record of the USl~"l‘O 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.
`
`Exhibit 1205 hereto is a true and correct copy of an article by Russell
`
`I--lousley and Jan Dolphin, entitled “Metering: A Pre—pay Technique,” Storage and
`
`Retrieval for Image and Video Databases V, Conference Volume 3022, 527 Oanuary
`
`15, 1997) from the SPII-I Digital Library at my request. 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.
`
`Page 00002
`
`
`
`Covered Business Method Patent Review
`
`United States Patent No. 7,334,720
`
`6.
`
`l_"xhibit 1218 hereto is a true and co.r.r.ect copy of an article by Eberhard
`
`V011 Faber, Robert Hammelrath, and Franz—Peter Heider, entitled “The Secure
`
`Distribution of Digital Contents,” from the 13th Annual Computer Security
`
`Applications Conference held on December 8—l2, 1997, published by The lnstitute of
`
`Electrical and l_“.lectronics lingineers, Inc, which was retrieved from the Linda Hall
`
`Library of Science, Engineering and Technology, Document Services at my request.
`
`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.
`
`lixhibit 1223 hereto is a true and correct copy of the Claim Construction
`
`Opinion (“Claim Construction Opinion”) from 5mazj!7%z.rfr LLC, .92‘ al :2. Apple Im:., at
`
`.52./., Civil Action No. 6:l3—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 (“PAC]_iR”) 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.
`
`8.
`
`Exhibit 1224 hereto is a true and correct copy of the file history for
`
`United States Patent No. 8,061,598 to Patrick Racz and Hermenward I-lulst, which was
`
`Page 00003
`
`
`
`Covered Business Method Patent Review
`
`United States Patent No. 7,334,720
`
`downloaded on October 29, 2014 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.
`
`9.
`
`Exhibit 1225 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.
`
`10.
`
`Exhibit 1226 hereto is a true and correct copy of United States Patent
`
`No. 7,725,375 to lan 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
`
`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.
`
`11.
`
`Exhibit 1227 hereto is
`
`a true and correct copy of International
`
`Publication No. WO 95/34857, filed onjune 14, 1995 by Srr1ith,James P. and Smith,
`
`Edward A., and published on December 21, 1995, which was downloaded on
`
`October 26, 2014 from the liuropean Patent Off1ce’s lispacenet search page to which
`
`Page 00004
`
`
`
`Covered Business Method Patent Review
`
`United States Patent No. 7,334,720
`
`all parties have access at my request. 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.
`
`12.
`
`Exhibit 1228 hereto is a true and correct copy of the Japanese Patent
`
`Application Publication No. H10—269289 filed on March 26, 1997 by Sony
`
`Corporation, and published on October 9, 1998, which I downloaded on March 11,
`
`2014 from the European Patent Office’s Espacenet search page to which all parties
`
`have access, and which is accompanied by a true and correct copy of a translation of
`
`the text of that document and a declaration of accuracy regarding that translation
`
`provided by l\/Iultiliing Corporation. 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.
`
`13.
`
`lixliibit 1236 hereto is a true and correct copy of United States Patent
`
`No. 5,646,992 to Ronald J. Subler, which was downloaded on November 16, 2014
`
`from the USPTO PAIR website at my request and which is a record of the USP'l'O 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.
`
`14.
`
`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.
`
`Page 00005
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`
`
`Covered Business Method Patent Review
`
`United States Patent No. 7,334,720
`
`15.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Executed this 17"‘ day of November, 2014, at \5C/’ash’1ngt()n, D.C.
`
`6
`
`F. Raymond
`
`Page 00006
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