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`Docket No.: 0100157-00244
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`Inventors: DAVID A. FARBER
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`AND RONALD D. LACHMAN
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`Inter Partes Review of Patent No.:
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`6,415,280
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`IPR Control Number: IPR2013-00083
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`Filed:
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`Title:
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`April 1, 1999
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`Issued:
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`July 2, 2002
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`IDENTIFYING AND REQUESTING DATA IN A NETWORK USING
`IDENTIFIERS WHICH ARE BASED ON THE CONTENT OF THE
`DATA
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`Commissioner for Patents
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`P.O.’Box 1450
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`Alexandria, VA 22313—1450
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`DECLARATION OF CYNTHIA ,VREELAND IN SUPPORT OF MOTION
`FOR ADMISSION PRO HAC, VICE
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`1, Cynthia Vreeland, declare as follows:
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`1.
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`I have been practicing law for over twenty years, and have been practicing
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`in the field of intellectual property, and particularly, patent litigation, for more than
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`fifteen years.
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`2.
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`I am a member in good standing of the Bar of the State of Massachusetts
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`and the Bar of the State of Texas, and am admitted to practice before the United States
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`Courts of Appeal for the First, Fourth, and Federal Circuits, the United States District
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`Court for the District of Massachusetts, the United States Court for the Eastern District’of
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`Texas and all Massachusetts State and Texas State courts.
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`3.
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`My Massachusetts Bar membership No. is 635143 and my Texas Bar
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`membership No. is 20625150.
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`ActiveUS 107441134v.1
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`EMCVMW 1038
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`Docket No.: 0100157—00244
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`4.
`I have been in private practice for over twenty years, and litigating patent cases
`for over fifteen years. Several ofthese patent litigations concerned patent office rules and
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`regulations. For example, I represented American Superconductor Corporation before the trial
`court in an interference proceeding in American Superconductor Corp. v. Massachusetts Institute
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`of Technology No. 1:01—cv-11477-EFH, in the District of Massachusetts.
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`5.
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`I have never been suspended, disbarred, sanctioned or cited for contempt by any
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`court or administrative body.
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`6.
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`I have never had a court or administrative body deny my application for
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`admission to practice,
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`7.
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`I have read and will comply with Office Patent Trial Practice guide and the
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`Board’s Rules of Practice for Trials, as set forth in Part 42 of the C.F.R.
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`8.
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`I
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`I agree to be subject to the United States Patent and Trademark Office Code of
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`Professional Responsibility set forth in 37 CPR. §§ 10.20 et. seq. and disciplinary jurisdiction
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`under 37 CPR. § 11.19(a).
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`9.
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`.
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`In the past three years, I have not appeared pro hac vice in any proceedings before
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`the United States Patent and Trademark Office.
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`10.
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`I am familiar with the subject matter at issue in this proceeding. I am counsel in
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`PersonalWeb Technologies LLC v. EMC Corporation and VMware, Inc, No. 6:11-cv—00660—
`LED, ED. Tex. (served on Dec. 16, 2011), which is related to and involves the same patents at
`issue in this proceeding.
`I
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`.
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`11.
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`,
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`I have represented EMC Corporation in multiple patent—related matters since
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`2003, including confidential patent—related analysis, and the following United States District
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`Courtcases: EMC v. Hewlett—Packard, No. 4:00—cv—40188-NMG in the District of
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`ActiveUS 107441134v.1
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`Docket No.: 0100157-00244
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`Massachusetts, Equifax, Inc. v. Verid, Inc. No. 1:06-0v—02404—TCB in the Northern District of
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`Georgia, and EMC v. BetaNet, LLC, N0. 1:10—cv—11593—RGS in the District of Massachusetts.
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`12.
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`I am familiar with the technology at issue in this proceeding from the prior work
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`described above.
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`13.
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`I hereby declare that all statements made herein of my own knowledge are true
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`and that all statements made on information-and belief are believed to be true; and further that
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`these statements are made with the knowledge that willful false statements and the like are
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`punishable by fine, imprisonment, or both, under Section 1001 of Title 18 of the United States
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`Code.
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`Respectfully Submitted,
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`Cynthia D. Vreeland
`WILMER CUTLER PICKERING HALE
`AND DORR LLP
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`60 State Street
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`Boston, MA 02109
`cynthia.vreeland@wilmerhalecom
`Tel: 617—526-6148
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`Fax: 617-526—5000
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`March 26, 2013
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