`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SONY CORPORATION
`Petitioner
`
`v.
`
`Patent ofYISSUM RESEARCH DEVELOPMENT COMPANY OF THE
`HEBREW UNIVERSITY OF JERUSALEM
`Patent Owner
`
`Case IPR2013-00219 (SCM) 1
`Patent 7,477,284
`Title: SYSTEM AND METHOD FOR CAPTURING AND VIEWING
`STEREOSCOPIC PANORAMIC IMAGES
`
`Before SALLY C. MEDLEY, KARL D. EASTHOM, and
`JAMES B. ARPIN, Administrative Patent Judges.
`
`DECLARATION OF WILLIAM NELSON
`SUBMITTED UNDER 37 C.F.R. §42.64(2)
`
`1 The IPR2013-00327 proceeding has been joined with this proceeding.
`
`1
`
`Petition for Inter Partes Review
`of U.S. Pat. No. 7,477,284
`IPR2013‐00219
`EXHIBIT
`Sony‐
`
`
`
`DECLARATION OF WILLIAM NELSON
`IPR2013-00219 (Patent 7,477,284)
`
`I, William Nelson, do hereby make the following declaration:
`
`1. I am a partner ofTensegrity Law Group, LLP, located at 555 Twin Dolphin
`
`Dr., Suite 360, Redwood Shores, CA 94065. Along with my colleagues, I
`
`served as counsel of record for HumanEyes Technologies, Ltd.
`
`("HumanEyes"), Complainant in the International Trade Commission
`
`investigation No. 337-TA-842, captioned "In the Matter of Certain Cameras
`
`and Mobile Devices, Related Software and Firmware, and Components
`
`Thereof and Products Containing the Same" (the "ITC Investigation").
`
`HumanEyes is the exclusive licensee, with rights to enforce, of U.S. Patent
`
`Nos. 6,665,003, and 7,477,284, at issue in Case IPR2013-00218 and Case
`
`IPR2013-00219. Petitioner Sony was the Respondent in the ITC
`
`Investigation.
`
`2. Exhibit YRD-2012 was produced by Sony in the course of discovery in the
`
`Course of the ITC Investigation. For that reason, Exhibit YRD-2012 bears
`
`"Bates" production numbers SONY842ITC_00260537-260579. Attached as
`
`Exhibit A to this Declaration is a transmittal letter dated August 29, 2012
`
`from Sony, transmitting the production range including YRD-2012. YRD-
`
`20 12 is an English translation of the Asahi reference (Exhibit 1010 ).
`
`
`
`DECLARATION OF WILLIAM NELSON
`IPR2013-00219 (Patent 7,477,284)
`
`3. Exhibit YRD-2013 was produced by Sony in the course of discovery in the
`
`Course of the ITC Investigation. For that reason, Exhibit YRD-2013 bears
`
`"Bates" production numbers SONY842ITC _ 00260414-260422. Attached as
`
`Exhibit A to this Declaration is a transmittal letter dated August 29, 2012
`
`from Sony, transmitting the production range including YRD-2013. YRD-
`
`2013 is a certified English translation of the Kawakita reference (Exhibit
`
`1003).
`
`I declare under penalty of perjury that the forgoing is true and correct.
`
`Dated April, 25, 2014
`
`
`
`
`
`Ajita Shukla
`Direct 212.908.6436
`AShukla@Kenyon.com
`
`One Broadway
`New York, NY 10004-1007
`212.425.7200
`Fax 212.425.5288
`
`VIA FEDEX
`
`Megan Nelson
`Tensegrity Law Group LLP
`555 Twin Dolphin Drive, Suite 360
`Redwood Shores, CA 94065
`Email: HumanEyes@tensegritylawgroup.com
`
`August 29, 2012
`
`Mareesa Frederick
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`Email: mareesa.frederick@usitc.gov
`
`
`
`
`Re:
`
`
`
` In the Matter of Certain Cameras and Mobile Devices, Related Software and
` Firmware, and Components Thereof and Products Containing the Same,
`Inv. No. 337-TA-842
`
`Dear Counsel:
`
`Enclosed please find a disc containing Respondents Sony Corporation, Sony Corporation of
`America, Sony Electronics Inc., Sony Mobile Communications AB, and Sony Mobile
`Communications (USA) Inc.’s production documents bearing bates numbers
`SONY842ITC_00260220 - SONY842ITC_00261135.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
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`
`
`
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`
`
`Best regards,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Enclosure
`cc: Counsel of Record (via email, without enclosure)
`
`
`
`
`
`
`
`
`
`
`
`Ajita Shukla
`
`
`
`
`
`
`
`New York Washington, DC Silicon Valley www.kenyon.com
`
`
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