`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SONY CORPORATION
`
`Petitioner
`v.
`
`YIS SUM RESEARCH DEVELOPMENT COMPANY
`
`OF THE HEBREW UNIVERSITY OF JERUSALEM
`
`Patent Owner
`
`Patent No. 7,477,284
`
`Issue Date: January 13, 2009
`Title: SYSTEM AND METHOD FOR CAPTURING AND VIEWING
`
`STEREOSCOPIC PANORAMIC IMAGES
`
`Inter Partes Review No. IPR2013-00327
`
`DECLARATION OF ROBERT L. GERRITY
`
`IN OPPOSITION TO JOINDER
`
`RD-2001
`
`
`
`DECLARATION OF ROBERT L. GERRITY
`
`1.
`
`I, Robert L. Gerrity, am more than twenty—one years of age, am
`
`competent to present this declaration, and have personal knowledge of the facts set
`
`forth herein.
`
`2.
`
`This declaration is given in support of patent owner Yissum Research
`
`Development Company of the Hebrew University of Jerusalem’s
`
`(“Yissum’s”)
`
`Opposition To Joinder.
`
`3.
`
`On March 29, 2012, Yissum’s real party in interest HumanEyes
`
`Technology Ltd.
`
`(“HumanEyes”)
`
`filed suit against Sony Corporation, Sony
`
`Corporation of America, Sony Electronics Inc., Sony Mobile Communications
`
`(USA) Inc., and Sony Mobile Communications AB (individually and collectively,
`
`“Sony”) in the US. District Court for the District of Delaware, HumanEyes Techs,
`
`LTD. v Sony Elecs, Inc., Sony Corp, Sony Corp. ofAmerica, Sony Mobile Comms,
`
`AB, Sony Mobile Comms.
`
`(USA), Inc., Case No. 1:12-cv-00398-GMS, alleging
`
`infringement of US. Patent Nos. 6,665,003 and 7,744,284 (“District Court
`
`Litigation” or “Litigation”).
`
`4.
`
`On April 19, 2013, Sony filed a Motion to Stay Litigation Pending
`
`Outcome of Inter Partes Review of the Patents—In-Suit (“Sony’s Motion to Stay”).
`
`5.
`
`On May 6, 2013, HumanEyes filed its Answering Brief in Opposition
`
`to Sony’s Motion to Stay (“HumanEyes Answering Brief”) (Sony-1102).
`
`6.
`
`The HumanEyes Answering Brief articulates factors that weigh
`
`heavily against a litigation stay. Among them is that Sony’s petitions for inter
`
`partes review will not resolve all issues because the petitions only address 14 of the
`
`155 claims potentially at issue in the litigation. Other factors weighing against stay
`
`pertain to the prejudice that will result to HumanEyes. As explained more fillly in
`
`the Levy-Ron Declaration (YRD-2002), delay in resolving Sony’s ongoing
`
`
`
`DECLARATION OF ROBERT L. GERRITY
`
`infringement and use of HumanEyes’ patented technology continues to harm
`
`HumanEyes’ business.
`
`7.
`
`I am counsel for HumanEyes in the Litigation and actively involved in
`
`all aspects thereof.
`
`I am familiar with the subject matter and status of issues in the
`
`Litigation.
`
`8.
`
`As of this writing, the Court in the District Court Litigation has not
`
`ruled on Sony’s Motion to Stay.
`
`9.
`
`As of this writing, no scheduling order has been entered in the District
`
`Court Litigation.
`
`10.
`
`As of this writing, there have been no rulings that limit the number or
`
`scope of claims that may be asserted as infringed in the Litigation pertaining to
`
`US. Patent Nos. 6,665,003 and 7,477,284. There has been no claim construction
`
`order in the case.
`
`Declaration
`
`I declare that all statements made herein on my own knowledge are true and
`
`that all statements made on information and belief are believed to be true, and
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`further, that these statements were made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code.
`
`Executed: July 11, 2013
`
`By:
`
`Robert
`
`. Gerrity
`
`
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