throbber
Filed on behalf of Microsoft Corporation
`
`By: John D. Vandenberg (Reg. No. 31,312)
`
`john.vandenberg@klarquist.com
`Stephen J. Joncus (Reg. No. 44,809)
`stephen.joncus@klarquist.com
`Klarquist Sparkman LLP
`One World Trade Center, Suite 1600
`121 S.W. Salmon Street
`Portland, Oregon 97204
`Telephone: (503) 595-5300
`Facsimile: (503) 595-5301
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`MICROSOFT CORPORATION
`Petitioner
`
`v.
`
`PROXYCONN, INC.
`Patent Owner
`
`____________
`
`Case IPR2012-00026 (TLG)
`Patent 6,757,717 B1
`
`____________
`
`DECLARATION OF MUNG TAM AS SUPPLEMENTAL
`EVIDENCE IN RESPONSE TO PROXYCONN, INC.’S
`OBJECTIONS TO PETITIONER’S EXHIBITS 1001-1018
`
`

`

`Case IPR2012-00026
`Patent 6,757,717
`
`
`
`I, Mung Tam, declare as follows:
`
`1.
`
`I am over 18 years of age, a paralegal employed by Klarquist
`
`Sparkman, LLP, lead counsel for Petitioner Microsoft Corporation, and I make this
`
`declaration based on my own knowledge, personal experience, and belief. If called
`
`upon, I can competently testify to the facts stated in this declaration.
`
`2.
`
`This declaration is submitted as supplemental evidence, pursuant to 37
`
`C.F.R. § 42.64(b)(2), in support of the instituted inter partes review, Microsoft
`
`Corporation v. Proxyconn, Inc., Case No. IPR2012-00026 (TLG), and in response
`
`to Proxyconn Inc.’s Objections to Petitioner’s Exhibits 1001-1018.
`
`3.
`
`On September 18, 2012, Microsoft Corporation filed a Petition for
`
`Inter Partes Review of U.S. Patent No. 6,757,717 (“IPR2012-00026”). Filed
`
`concurrently with Microsoft’s Petition were Exhibits 1001-1018.
`
`4.
`
`Exhibit 1008 is a true and correct copy of a Microsoft Corporation
`
`document titled “[MS-RDC] – v20120705, Remote Differential Compression
`
`Algorithm Specification,” dated July 5, 2012. This document was referenced in
`
`Exhibit 1009, pages 12-23, and is a business record maintained in the ordinary
`
`course of Microsoft’s business.
`
`5.
`
`Exhibit 1009 is a true and correct copy of Defendant Microsoft
`
`Corporation’s Response to Plaintiff Proxyconn Inc.’s First Set of Interrogatories
`
`Declaration Of Mung Tam
`As Supplemental Evidence In Response
`To Proxyconn, Inc.’s Objections To Petitioner’s Exhibits 1001-1018
`
`Page 1
`
`

`

`Case IPR2012-00026
`Patent 6,757,717
`
`
`with supporting Exhibits A-B and E, dated July 25, 2012. Exhibits C-D have been
`
`omitted. Microsoft served these interrogatory responses on July 25, 2012 in the
`
`concurrent litigation, Proxyconn Inc. v. Microsoft Corporation, et al., Case No. SA
`
`CV11-1681 DOC (JPRx) [consolidated with Case Nos. SA CV11-1682 DOC
`
`(JPRx), SA CV11-1683 DOC (JPRx), and SA CV11-1684 DOC (JPRx)], pending
`
`in the U.S. District Court for the Central District of California (the “’717
`
`Concurrent Litigation”). Exhibit 1019 is a true and correct copy of the verification
`
`of the interrogatory responses, signed by Microsoft representative David M.
`
`Howard on August 13, 2012.
`
`6.
`
`Exhibit 1010 is a true and correct copy of Microsoft’s Supplemental
`
`Exhibit E to Defendants’ Supplemental Interrogatory Response, dated August 15,
`
`2012. Microsoft served these supplemental interrogatory responses on August 15,
`
`2012 in the ’717 Concurrent Litigation.
`
`7.
`
`Exhibit 1011 is a true and correct copy of Plaintiff Proxyconn Inc.’s
`
`Objections and Responses to Defendant Microsoft Corporation’s First Set of
`
`Interrogatories, dated September 4, 2012. Proxyconn served these interrogatory
`
`objections and responses on Microsoft on September 4, 2012 in the ’717
`
`Concurrent Litigation.
`
`Declaration Of Mung Tam
`As Supplemental Evidence In Response
`To Proxyconn, Inc.’s Objections To Petitioner’s Exhibits 1001-1018
`
`Page 2
`
`

`

`Case IPR2012-00026
`Patent 6,757,717
`
`8.
`
`Exhibit 1012 is a true and correct copy of Plaintiff Proxyconn Inc.'s
`
`Second Amended Consolidated Complaint for Patent Infringement and supporting
`
`Exhibit B, dated July 16, 2012. Exhibit A has been omitted. Proxyconn filed this
`
`complaint in the '717 Concurrent Litigation, as Docket No. 77, and a notice was
`
`emailed via the court's ECF system on July 17, 2012.
`
`I declare under penalty of perjury of the laws of the United States that the
`
`foregoing is true and correct.
`
`Executed this 18th day of January, 2013 in Portland, Oregon.
`
`Mung
`
`Declaration Of Mung Tam
`As Supplemental Evidence In Response
`To Proxyconn, Inc.'s Objections To Petitioner's Exhibits 1001-1018
`
`Page 3
`
`

`

`Case IPR2012-00026
`Patent 6,757,717
`
`
`
`Certificate of Service in Compliance With 37 C.F.R. § 42.6(e)(4)
`
`The undersigned certifies that a complete copy of this Declaration of Mung
`
`Tam as Supplemental Evidence in Response to Proxyconn, Inc.’s Objections to
`
`Petitioner’s Exhibits 1001-1018 was served on the official correspondence address
`
`for the U.S. Patent No. 6,757,717 shown in PAIR and the attorneys of record for
`
`Plaintiff in this proceeding and in the concurrent litigation matter:
`
`MATTHEW L. CUTLER
`BRYAN K. WHEELOCK
`DOUGLAS A. ROBINSON
`HARNESS, DICKEY & PIERCE, PLC
`7700 BONHOMME, SUITE 400
`ST. LOUIS, MO 63105
`
`GENE SCOTT
`PATENT LAW & VENTURE GROUP
`36 EXECUTIVE PARK, SUITE #110
`IRVINE, CALIFORNIA 92614
`
`MARC A. FENSTER
`ANDREW D. WEISS
`RUSS AUGUST & KABAT
`12424 WILSHIRE BOULEVARD, 12TH FLOOR
`LOS ANGELES, CALIFORNIA 90025
`
`via EXPRESS MAIL, on January 18, 2013.
`
`
`
`
`
`By /John D. Vandenberg/
`
`John D. Vandenberg, Reg. No. 31,312
`One World Trade Center, Suite 1600
`121 S.W. Salmon Street
`Portland, Oregon 97204
`Telephone: (503) 595-5300
`Facsimile: (503) 595-5301
`
`CERTIFICATE OF SERVICE
`
`
`
`Page 1
`
`

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket