`
`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
`
`____________
`
`
`Patent 6,757,717 B1
`
`____________
`
`DECLARATION OF SEAN-MICHAEL RILEY
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF CLAIMS 6, 7, 9, 11, 12 and 14 OF U.S. PATENT NO. 6,757,717
`
`Page 1 of 5
`
`
`
`
`
`
`I, Sean-Michael Riley, declare as follows:
`
`1.
`
`I am over 18 years of age, a paralegal employed by Klarquist
`
`Sparkman, LLP, counsel for Petitioner Microsoft Corporation, and I make this
`
`declaration based on my own knowledge, personal experience and belief; and if
`
`called upon can testify competently thereto.
`
`2.
`
`I make this declaration in support of Microsoft Corporation’s Second
`
`Petition for Inter Partes Review of Claims 6, 7, 9, 11, 12 and 14 of U.S. Patent No.
`
`6,757,717 (“Petition”). This declaration is filed concurrently with Microsoft’s
`
`Petition as Exhibit 1011.
`
`3.
`
`Filed concurrently with Microsoft’s Petition as Exhibit 1001 is a true
`
`and correct copy of Appendix A, which is a claim chart mapping the claims to
`
`prior art references HTTP DRP, Mattis and Yohe.
`
`4.
`
`Filed concurrently with Microsoft’s Petition as Exhibit 1002 is a true
`
`and correct copy of U.S. Patent No. 6,757,717, entitled “System and Method for
`
`Data Access,” issued June 29, 2004, with Certificate of Correction, issued Aug. 14,
`
`2012.
`
`5.
`
`Filed concurrently with Microsoft’s Petition as Exhibit 1003 is a true
`
`and correct copy of Arthur van Hoff, John Giannandrea, Mark Hapner, Steve
`
`Carter, and Milo Medin, “The HTTP Distribution and Replication Protocol,” W3C
`
`Note, http://www.w3.org/TR/NOTE-drp-19970825.html, Aug. 1997
`
`Page 1
`
`Page 2 of 5
`
`
`
`
`
`6.
`
`Filed concurrently with Microsoft’s Petition as Ex. 1004 is a true and
`
`correct copy of United States Patent No. 6,292,880, entitled “Alias-Free Content-
`
`Indexed Object Cache,” issued Sept. 18, 2001.
`
`7.
`
`Filed concurrently with Microsoft’s Petition as Ex. 1005 is a true and
`
`correct copy of U.S. Patent Application No. 09/060886, filed Apr. 15, 1998, issued
`
`as U.S. Patent No. 6,292,880.
`
`8.
`
`Filed concurrently with Microsoft’s Petition as Ex. 1006 is a true and
`
`correct copy of U.S. Patent No. 5,835,943, “Apparatus and Method for Increased
`
`Data Access in a Network File Oriented Caching System,” issued Nov. 10, 1998.
`
`9.
`
`Filed concurrently with Microsoft’s Petition as Ex. 1007 is a true and
`
`correct copy of U.S. Patent Application No. 08/888,311, filed July 3, 1997, issued
`
`as U.S. Patent No. 5,835,943.
`
`10. Filed concurrently with Microsoft’s Petition as Ex. 1008 is a true and
`
`correct copy of Tim Berners-Lee, “W3C Staff Note on HTTP Distribution and
`
`Replication Protocol Submission,”
`
`http://www.w3.org/Submission/1997/10/Comment.html, Aug. 28, 1997. This note
`
`was a response to the W3C Note of Ex. 1003.
`
`11. Filed concurrently with Microsoft’s Petition as Ex. 1009 is a true and
`
`correct copy of Tim Berners-Lee, “Acknowledged Submissions to W3C,”
`
`http://web.archive.org/web/19980213220701/http:/www13.w3.org/Submission/,
`
`Page 2
`
`Page 3 of 5
`
`
`
`
`
`Feb. 13, 1998. This exhibit was downloaded from a “Wayback Machine” Web
`
`archived site dated Feb. 13, 1998, and references the August 1997, W3C Note of
`
`Ex. 1003.
`
`12. Filed concurrently with Microsoft’s Petition as Ex. 1010 is a true and
`
`correct copy of Michael A. Goulde, “Network Caching Guide, Optimizing Web
`
`Content Delivery,” Patricia Seybold Group, March 1999.
`
`13. Filed concurrently with Microsoft’s Petition as Ex. 1011 is a true and
`
`correct copy of Simon Spero, “HTTP-NG Architectural Overview,”
`
`http://web.archive.org/web/19970606013159/http://www.w3.org/Protocols/HTTP-
`
`NG/http-ng-arch.html. This exhibit was downloaded from a “Wayback Machine”
`
`Web archived site dated June 6, 1997.
`
`14. Filed concurrently with Microsoft’s Petition as Ex. 1012 is a true and
`
`current copy of Proxyconn, Inc. and Microsoft Corporation’s Joint Stipulation
`
`Requesting Stay of Case Pending Inter Partes Review filed November 2, 2012.
`
`15. Filed concurrently with Microsoft’s Petition as Ex. 1013 is a true and
`
`correct copy of the Expert declaration of Professor Darrell D. E. Long in Support
`
`of Microsoft’s Petition for Inter Partes Review of Claims 6, 7, 9, 11, 12 and 14 of
`
`U.S. Patent No. 6,757,717.
`
`I declare under penalty of perjury of the laws of the United States that the
`
`foregoing is true and correct.
`
`Page 3
`
`Page 4 of 5
`
`
`
`Executed this ~~day of January, 2013 in Portland, Oregon.
`
`_.-
`✓!~f
`Sean-Michael 'ley
`
`Page 4
`
`Page 5 of 5
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`
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