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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.:
`104677—5008—829
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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
`l*'onnerly Application No.: 13/ 012,541
`Issue Date: November 22, 2011
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`Filing Date: January 24, 2011
`l“().E1’1’1(31‘ Group Art Unit: 2887
`Former Examiner: Thien M. Le
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`E§‘.i<§}!5il&"‘|§§fi!f‘.~t5'J
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`For: Data Storage and Access Systems
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`MAIL STOP PATENT 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 N0. 8,061,598
`PURSUANT TO 35 U.S.C. § 321, 3'7 C.F.R. § 42.304
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`I, 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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`( Iovered 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.
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`321, 37
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`(I.l*'.R.
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`42.304. Unless otherwise stated, the facts stated in this Declaration are based
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`on 1113-‘ pe1‘:~‘o1'121l linowledge.
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`Apple Exhibit 1022
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`Page 00001
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`Page 00001
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`Apple Exhibit 1022
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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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`Exhibit 1003 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 Application
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`Information Retrieval (“PAIR”) 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 1004 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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`lixhibit 1005 hereto is a true and correct copy of two emails in an email
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`string dated August 26, 2014, titled “RE: Srnartflash: Meet and Confer Regarding
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`Further Claim/ Prior Art limits”, which I received from H. I-lamid on August 26,
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`2014.
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`:\n exhibit label on the first page and pages numbers on all pages have been
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`added to the bottom of this document but no other alterations have been made.
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`6.
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`lixhibir 101 8 hereto is a true and correct copy of an article by liberhard
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`Von l*'aber, Robert
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`l-lammel1'ath_, and l*'ranz—Peter
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`lleider, entitled “’.l‘l1e Secure
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`Page 00002
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`Page 00002
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`Covered Business Method Patent Review
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`United States Patent No. 8,061,598
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`Distribution of Digital Contents,” from the 13th Annual Computer Security
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`Applications Conference held on December 8-12, 1997, published by The Institute of
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`lilectrical 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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`Exhibit 1023 hereto is a true and correct copy of the Claim Construction
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`Opinion (“Claim Construction Opinion”) from Srzzarflasb LLC, .92‘ czl
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`22. /lppie Inc, at
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`:11, 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 (“PACER”) website at my request and is 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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`PACIER 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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`ltxhibit 1024 hereto is a true and correct copy of the tile history for
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`United States Patent No. 8,061,598 to Patrick Racz and I-Iermen—ard l"lulst_, which was
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`downloaded on October 29, 2014 at my request and which is a record of the USP'l'()
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`to which all parties have access.
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`..-\n exhibit label on the first page and pages numbers
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`Page 00003
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`Page 00003
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`Covered Business Method Patent Review
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`United States Patent No. 8,061,598
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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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`Exhibit 1025 hereto is a true and correct copy of United States Patent
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`No. 4,337,483 to Louis C. Guiliou, which was downloaded on October 29, 2014 from
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`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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`10.
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`Exhibit 1026 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 1027 hereto is
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`a true and correct copy of International
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`Publication No. \‘{=”() 95/345357, filed on June 14, 1995 by Smith,james P. and Smith,
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`lidward 1-\., and published on December 21, 1995, which was downloaded on
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`()ctober 26, 2014 from the li.uropear1 Patent Office’s Iispacenet search page to which
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`all parties have access at my request.
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`1-"\n exhibit label on the first page and pages
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`Page 00004
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`Page 00004
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`Covered Business Method Patent Review
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`United States Patent No. 8,061,598
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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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`12.
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`Exhibit 1029 hereto is a true and correct copy of United States Patent
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`No. 5,646,992 to Ronald Sublet, which was downloaded on November 16, 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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`13.
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`Exhibit 1034 hereto is a true and correct copy of the Japanese Patent
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`Application Publication No.
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`I-I10-269289 filed on March 26, 1997 by Sony
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`Corporation, and published on October 9, 1998, which was downloaded on March
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`11, 2014 at my request from the European Patent Office’s Espacenet search page to
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`which all parties have access, and which is accompanied by a true and correct copy of
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`a translation of the text of that document and a declaration of accuracy regarding that
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`translation provided by MultiLing Corporation. An exhibit label on the first page and
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`pages numbers on all pages have been added to the bottom of this document but no
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`other 21ll’C1‘21T.l()1”1S have been made.
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`'14.
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`l have been informed that willfully false statements are punishable by
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`fine or impnsonment, or both.
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`I make this declaration of my own personal
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`l<nowledge, and all start.-merits are true.
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`If called to testify as to the truth of the
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`matters stated l'1e1‘ein._ I could and would testify competently.
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`5
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`Covered Business Method Patent Review
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`United States Patent No. 8,061,598
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`15.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed this ___3 day of May, 2015, at Washington, D.C.
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`&«~v4=«,«»\/Q
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`Megan F. Raymond
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`Page 00006
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