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IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Covered Business Method Patent Review
`
`United States Patent No. 8,061,598
`
`Attorney Docket No.:
`104677—5008—829
`
`Customer No. 28120
`
`Petitioner: Apple Inc.
`
`Inventor: Racz et al.
`
`United States Patent No: 8,061,598
`l*'onnerly Application No.: 13/ 012,541
`Issue Date: November 22, 2011
`
`Filing Date: January 24, 2011
`l“().E1’1’1(31‘ Group Art Unit: 2887
`Former Examiner: Thien M. Le
`
`E§‘.i<§}!5il&"‘|§§fi!f‘.~t5'J
`
`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 N0. 8,061,598
`PURSUANT TO 35 U.S.C. § 321, 3'7 C.F.R. § 42.304
`
`I, 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 & Gray LLP.
`
`I provide this Declaration in connection with the above-identified
`
`( Iovered 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
`
`(I.l*'.R.
`
`42.304. Unless otherwise stated, the facts stated in this Declaration are based
`
`on 1113-‘ pe1‘:~‘o1'121l linowledge.
`
`Apple Exhibit 1022
`
`Page 00001
`
`
`Page 00001
`
`Apple Exhibit 1022
`
`

`
`Covered Business Method Patent Review
`
`United States Patent No. 8,061,598
`
`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.
`
`lixhibit 1005 hereto is a true and correct copy of two emails in an email
`
`string dated August 26, 2014, titled “RE: Srnartflash: Meet and Confer Regarding
`
`Further Claim/ Prior Art limits”, which I received from H. I-lamid on August 26,
`
`2014.
`
`:\n 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.
`
`lixhibir 101 8 hereto is a true and correct copy of an article by liberhard
`
`Von l*'aber, Robert
`
`l-lammel1'ath_, and l*'ranz—Peter
`
`lleider, entitled “’.l‘l1e Secure
`
`Page 00002
`
`
`Page 00002
`
`

`
`Covered Business Method Patent Review
`
`United States Patent No. 8,061,598
`
`Distribution of Digital Contents,” from the 13th Annual Computer Security
`
`Applications Conference held on December 8-12, 1997, published by The Institute of
`
`lilectrical 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.
`
`7.
`
`Exhibit 1023 hereto is a true and correct copy of the Claim Construction
`
`Opinion (“Claim Construction Opinion”) from Srzzarflasb LLC, .92‘ czl
`
`22. /lppie Inc, at
`
`:11, 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
`
`PACIER 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.
`
`ltxhibit 1024 hereto is a true and correct copy of the tile history for
`
`United States Patent No. 8,061,598 to Patrick Racz and I-Iermen—ard l"lulst_, which was
`
`downloaded on October 29, 2014 at my request and which is a record of the USP'l'()
`
`to which all parties have access.
`
`..-\n exhibit label on the first page and pages numbers
`
`Page 00003
`
`
`Page 00003
`
`

`
`Covered Business Method Patent Review
`
`United States Patent No. 8,061,598
`
`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. Guiliou, 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. \‘{=”() 95/345357, filed on June 14, 1995 by Smith,james P. and Smith,
`
`lidward 1-\., and published on December 21, 1995, which was downloaded on
`
`()ctober 26, 2014 from the li.uropear1 Patent Office’s Iispacenet search page to which
`
`all parties have access at my request.
`
`1-"\n exhibit label on the first page and pages
`
`Page 00004
`
`
`Page 00004
`
`

`
`Covered Business Method Patent Review
`
`United States Patent No. 8,061,598
`
`numbers on all pages have been added to the bottom of this document but no other
`
`alterations have been made.
`
`12.
`
`Exhibit 1029 hereto is a true and correct copy of United States Patent
`
`No. 5,646,992 to Ronald Sublet, 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.
`
`Exhibit 1034 hereto is a true and correct copy of the Japanese Patent
`
`Application Publication No.
`
`I-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 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 21ll’C1‘21T.l()1”1S have been made.
`
`'14.
`
`l have been informed that willfully false statements are punishable by
`
`fine or impnsonment, or both.
`
`I make this declaration of my own personal
`
`l<nowledge, and all start.-merits are true.
`
`If called to testify as to the truth of the
`
`matters stated l'1e1‘ein._ I could and would testify competently.
`
`5
`
`Page 00005
`
`
`Page 00005
`
`

`
`Covered Business Method Patent Review
`
`United States Patent No. 8,061,598
`
`15.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Executed this ___3 day of May, 2015, at Washington, D.C.
`
`&«~v4=«,«»\/Q
`
`Megan F. Raymond
`
`Page 00006
`
`
`Page 00006

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