`
`Covered Business Method Patent Review
`
`United States Patent No. 7,334,720
`
`Attorney Docket No.:
`104677—5008—825
`
`Customer No. 28120
`
`Petitioner: Apple Inc.
`
`Inventor: Racz et al.
`
`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 Examiner: Steven S. Paik
`
`wmwwwww
`
`For: Data Storage and Access Systems
`
`MAIL STOP PATENT BOARD
`
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`
`Post Office BOX 1450
`
`Alexandria, Virginia 22313—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 F. Raymond, make the following Declaration pursuant to 28 U.S.C. §
`
`1 746:
`
`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 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
`
`
`Page 00001
`
`Apple Exhibit 1022
`
`
`
`Covered Business Method Patent Review
`
`United States Patent No. 7,334,720
`
`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 Trademark Office (“USPTO”) Patent Application
`
`Information Retrieval (“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 1005 hereto is a true and correct copy of two emails in an email
`
`string dated August 26, 2014, titled “RE: Smartflash: Meet and Confer Regarding
`
`Further Claim/Prior Art Limits”, which I received from H. Hamad on August 26,
`
`2014. 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.
`
`6.
`
`Exhibit 1018 hereto is a true and correct copy of an article by Eberhard
`
`von Faber, Robert Hammelrath, and Franz—Peter Heider, entitled “The Secure
`
`Page 00002
`
`
`Page 00002
`
`
`
`Covered Business Method Patent Review
`
`United States Patent No. 7,334,720
`
`Distribution of Digital Contents,” from the 13th 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.
`
`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 1023 hereto is a true and correct copy of the Claim Construction
`
`Opinion (“Claim Construction Opinion”) from 577747??an LLC, at 77/.
`
`77. Apple Ina, 62‘
`
`711., 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.
`
`8.
`
`Exhibit 1024 hereto is a true and correct copy of the file history for
`
`United States 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
`
`Page 00003
`
`
`Page 00003
`
`
`
`Covered Business Method Patent Review
`
`United States Patent No. 7,334,720
`
`on all pages have been added to the bottom of this document but no other alterations
`
`have been made.
`
`9.
`
`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
`
`all pages have been added to the bottom of this document but no other alterations
`
`have been made.
`
`10.
`
`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.
`
`11.
`
`Exhibit 1027 hereto is
`
`a true and correct copy of International
`
`Publication No. W0 95 / 34857, filed on June 14, 1995 by Smith,]ames P. and Smith,
`
`Edward A., and published on December 21, 1995, which was downloaded on
`
`October 26, 2014 from the European Patent Office’s Espacenet search page to which
`
`all parties have access at my request. An exhibit label on the first page and pages
`
`Page 00004
`
`
`Page 00004
`
`
`
`Covered Business Method Patent Review
`
`United States Patent No. 7,334,720
`
`numbers on all pages have been added to the bottom of this document but no other
`
`alterations have been made.
`
`12.
`
`Exhibit 1028 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 was downloaded on March
`
`11, 2014 at my request 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 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.
`
`13.
`
`Exhibit 1036 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 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.
`
`14.
`
`I have been informed that willfully false statements are punishable by
`
`fine or imprisonment, or both.
`
`I 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, I could and would testify competently.
`
`5
`
`Page 00005
`
`
`Page 00005
`
`
`
`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 “1 day of May, 2015, at Washington, DC,
`
` U-
`
`\
`.
`ro’
`Meg-1m i . Eizsrzzzond
`
`Page 00006
`
`