`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GOOGLE INC.
`Petitioner
`
`v.
`
`ALFONSO CIOFFI, MEGAN ELIZABETH ROZMAN,
`MELANIE ANN ROZMAN, AND MORGAN LEE ROZMAN
`Patent Owners
`
`Patent No. RE43,528
`
`DECLARATION OF DANIEL CALLAWAY
`
`Google - Exhibit 1021, cover
`
`
`
`I, Daniel C. Callaway, make the following declaration in support of several
`
`petitions by Google Inc. for covered business method patent review of U.S. Patent
`
`No. RE43,500 (the “’500 Reissue”); U.S. Patent No. RE43,528 (the “’528
`
`Reissue”); U.S. Patent No. RE43,529 (the “’529 Reissue”); and U.S. Patent No.
`
`RE43,103 (the “’103 Reissue”):
`
`1.
`
`I am an attorney with the law firm of Farella Braun + Martel LLP. I
`
`am one
`
`of the attorneys representing Google Inc. in the related lawsuit pending in
`
`the United States District Court for the Eastern District of Texas and entitled
`
`Alfonso Cioffi and The Estate of Allen Rozman v. Google Inc., Case Number 2:13-
`
`cv-103 (JRG/RSP). Unless otherwise stated, the facts stated in this declaration are
`
`based on my personal knowledge.
`
`2.
`
`The document submitted with the Google petitions and identified as
`
`Exhibit 1005 is a true and correct copy of the Amended Complaint for Patent
`
`Infringement in the related lawsuit.
`
`3.
`
`The document submitted with the Google petitions and identified as
`
`Exhibit 1010 is a true and correct copy of the Patent Local Rule 4-3 Joint Claim
`
`Construction and Prehearing Statement in the related lawsuit. The exhibits to that
`
`document have been excluded.
`
`4.
`
`The document submitted with the Google petitions and identified as
`
`Exhibit 1011 is a true and correct copy of the Plaintiffs Reply Memorandum In
`
`1
`
`Google - Exhibit 1021, page 1
`
`
`
`Support of Opening Claim Construction Brief in the related lawsuit.
`
`5. The document submitted with the Google petitions and identified as
`
`Exhibit 1012 is a true and correct copy of the Claim Construction Memorandum
`
`and Order in the related lawsuit.
`
`6.
`
`The document submitted with the Google petitions and identified as
`
`Exhibit 1013 is a true and correct copy of excerpts from the transcript of the
`
`deposition of El. E. Dunsmore, dated June 17, 2014, in the related lawsuit.
`
`7.
`
`The document submitted with the Google petitions and identified as
`
`Exhibit 1014 is a true and correct copy of excerpts from the transcript of the
`
`deposition of EE. E. Dunsmore, dated October 10, 2016, in the related lawsuit.
`
`8.
`
`The document submitted with the Google petitions and identified as
`
`Exhibit 1015 is a true and correct copy of excerpts from the Expert Declaration of
`
`ETE. Dunsmore in the pending lawsuit.
`
`9.
`
`The document submitted with the Google petitions and identified as
`
`Exhibit 1016 is a true and correct copy of excerpts from the Expert Report of
`
`EE.E. Dunsmore in the pending lawsuit.
`
`10.
`
`The document submitted with the Google petitions and identified as
`
`Exhibit 1017 is a true and correct copy of excerpts from the transcript of the
`
`deposition of Alfonso Cioffi, dated June 26, 2014, in the related lawsuit.
`
`11. The document submitted with the Google petitions and identified as
`
`2
`
`Google - Exhibit 1021, page 2
`
`
`
`Exhibit 1018 is a true and correct copy of excerpts from the transcript of deposition
`
`of Alfonso Cioffi, dated November 7, 2014, in the related lawsuit.
`
`12. The document submitted with the Google petitions and identified as
`
`Exhibit 1019 is a true and correct copy of an excerpt from a book entitled
`
`Microsoft Press Computer Dictionary (5th ed. 2002).
`
`13. The document submitted with the Google petitions and identified as
`
`Exhibit 1020 is a true and correct copy of the Joint Notice of Agreed Construction
`
`in the related lawsuit.
`
`14. The document submitted with the Google petitions and identified as
`
`Exhibit 1032 is a declaration of Steven M. Bellovin, Ph.D. Attached as Exhibit A
`
`to Dr. Bellovin’s declaration is a paper entitled “Building a Secure Web Browser.”
`
`The document submitted with the Google petitions and identified as Exhibit 1026
`
`is the same paper. Attached as Exhibit B to Dr. Bellovin’s declaration is a paper
`
`entitled “Sub-Operating Systems: A New Approach to Application Security” and
`
`certain “front matter” from printed conference proceedings. The document
`
`submitted with the Google petitions and identified as Exhibit 1025 is the same
`
`paper.
`
`I declare that all statements made herein of my own knowledge are true and
`
`that all statements made on information and belief are believed to be true; and
`
`further that these statements were made with the knowledge that willful false
`
`3
`
`Google - Exhibit 1021, page 3
`
`
`
`statements and the like so made are punishable by fine or imprisonment, or both,
`
`under Section 1001 of Title 18 of the United States Code.
`
`..............Dania/CUallawdyv..
`
`4
`
`Google - Exhibit 1021, page 4
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