IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Covered Business Method Patent Review
`
`United States Patent No. 8,794,516
`
`Attorney Docket No.:
`104677-5008-832
`
`Customer No. 28120
`
`Petitioner: Apple Inc.
`
`Inventor: Racz et al.
`
`United States Patent No.: 8,794,516
`Formerly Application No; 13 / 483,754
`Issue Date: August 5, 2014
`Filing Date: April 3, 2012
`liorrner Group Art Unit: 2887
`Iiormer Iixaminer: Thien M. I .e
`
`E5‘.~(§iE=§‘}'.§5I§§£fl.&_".n
`
`Data Storage and Access Systems
`
`i\-IAIL STOP PA'I".L‘IN'1‘ BOARD
`
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`
`Post Office Box 1450
`
`Alexandria, Virginia 2231 3—1450
`
`DECLARATION OF MEGAN F. RAYMOND IN SUPPORT OF
`
`PETITION FOR COVERED BUSINESS METHOD PATENT REVIEW OF
`
`UNITED STATES PATENT NO. 8,794,516
`PURSUANT TO 35 U.S.C. § 321, 37 C.F.R. § 42.304
`
`1, 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 8: Gray LLP.
`
`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 1022
`
`Page 00001
`
`Apple Exhibit 1022
`Page 00001
`
`
`
`Covered Business Method Patent Review
`
`United States Patent No. 8,794,516
`
`Attorney Docket No.:
`104677-5008-832
`
`Customer No. 28120
`
`Petitioner: Apple Inc.
`
`Inventor: Racz et al.
`
`United States Patent No.: 8,794,516
`Formerly Application No; 13 / 483,754
`Issue Date: August 5, 2014
`Filing Date: April 3, 2012
`liorrner Group Art Unit: 2887
`Iiormer Iixaminer: Thien M. I .e
`
`E5‘.~(§iE=§‘}'.§5I§§£fl.&_".n
`
`Data Storage and Access Systems
`
`i\-IAIL STOP PA'I".L‘IN'1‘ BOARD
`
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`
`Post Office Box 1450
`
`Alexandria, Virginia 2231 3—1450
`
`DECLARATION OF MEGAN F. RAYMOND IN SUPPORT OF
`
`PETITION FOR COVERED BUSINESS METHOD PATENT REVIEW OF
`
`UNITED STATES PATENT NO. 8,794,516
`PURSUANT TO 35 U.S.C. § 321, 37 C.F.R. § 42.304
`
`1, 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 8: Gray LLP.
`
`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 1022
`
`Page 00001
`
`Apple Exhibit 1022
`Page 00001
`
`
`
`Covered Business Method Patent Review
`
`United States Patent No. 8,794,516
`
`3.
`
`Exhibit 1003 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 Tradernarlr Office (“USP’l‘O”) 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 1004 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 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.
`
`5.
`
`Exhibit 1018 hereto is a true and correct copy of an article by Eberhard
`
`V()I1 Faber, Robert I-lammelrath, and l*‘ranz—Peter Heider, entitled “The Secure
`
`Distribution of Digital Contents,” from the
`
`13"‘ Annual Computer Security
`
`Applications Conference held on December 8-12, 1997, published by The Institute of
`
`Electrical and Electronics Engineers, Inc, which was retrieved from the Linda Hall
`
`Library of Science, Engineering and Technology, Document Services at my request.
`
`Page numbers and an exhibit label 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. 8,794,516
`
`6.
`
`liixhibit 1023 hereto is a true and correct copy of the Claim Construction
`
`Opinion (“Claim Construction Opinion”) from Swarzflasb LLC, ez‘ a!. at Apple Inc., at
`
`ad, 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 (Dkr. 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 1024 hereto is a true and correct copy of the file history for
`
`United Statics Patent No. 8,061,598 to Patrick Racz and Hermen—ard Hulst, which was
`
`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.
`
`8.
`
`Exhibit 1025 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
`
`Page 00003
`
`
`
`Covered Business Method Patent Review
`
`United States Patent No. 8,794,516
`
`all pages have been added to the bottom of this document but no other alterations
`
`have been made.
`
`9.
`
`Exhibit 1026 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
`
`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 1027 hereto is
`
`a
`
`true and correct copy of International
`
`Publication No. W0 95/ 34857, filed on june 14, 1995 by Srnith,_lames P. and Smith,
`
`l-Edward A, and published on December 21, 1995, which was downloaded on
`
`October 26, 2014 from the European Patent Offiee’s Espacenet search page to which
`
`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.
`
`11.
`
`Exhibit 1028 hereto is a true and correct copy of the Japanese Patent
`
`Application Publication No.
`
`l-I10-269289 filed on March 26, 1997 by Sony
`
`Corporation, and published on October 9, 1998, which was downloaded on March
`
`11, 2014 at my request from the liuropean 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
`
`4
`
`Page 00004
`
`
`
`Covered Business Method Patent Review
`
`United States Patent No. 8,794,516
`
`translation provided by Multiling 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.
`
`12.
`
`Exhibit 1036 hereto is a true and correct copy of United States Patent
`
`No. 5,646,992 to Ronald Subler, which was downloaded on November 16, 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.
`
`13.
`
`l" have been informed that willfully false statements a.r.e punishable by
`
`fine or
`
`imprisonment, or both.
`
`1 make this declaration of my own personal
`
`knowledge, and all statements are true.
`
`If called to testify as to the truth of the
`
`matters stated herein, 1 could and would testify competently.
`
`14.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Executed this 4th day of May, 2015, at Washington, DC.
`.n-.
`‘I
`
`Page 00005
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