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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS CO., LTD.
`Petitioner,
`
`v.
`
`BLACK HILLS MEDIA, LLC
`Patent Owner.
`
`Case IPR2014-00717
`Patent No. 6,108,686
`
`DECLARATION OF MR. SUNGIL CHO
`
` DC: 5436543-6
`
`Samsung v. Black Hills Media
`IPR2014-00717
`SAMSUNG EX. 1009
`
`i
`
`
`
`Inter Partes Review
`U.S. Pat. No. 6,108,686
`
`
`I, Sungil Cho, hereby declare and state as follows:
`
`IPR2014-00717
`
`1. I am currently employed by Samsung Electronics Co., Ltd. in the position of
`
`Director. I have been in this position for one and a half years, and I have
`
`been employed by Samsung Electronics Co., Ltd. for ten years.
`
`2. In my role as Director, my responsibilities include the coordination and
`
`supervision of outside counsel in the preparation, review, and filing of
`
`petitions for inter partes review of third party patents. In particular, I was
`
`responsible for coordinating with and supervising Covington & Burling LLP
`
`(“Covington”) in the preparation, review, and filing of petitions for inter
`
`partes review (“IPR”) (referred to collectively as “the Petitions”) of the
`
`following U.S. Patents that have been asserted by Black Hills Media, LLC
`
`against Samsung in International Trade Commission (ITC Inv. No. 337-TA-
`
`882) and/or District Court (Black Hills Media, LLC v. Samsung Elecs. Co.
`
`Ltd., et al., No. 2:13-cv-00379) litigation :
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`6,108,686;
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`6,618,593;
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`7,835,689;
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`7,917,082;
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`8,028,323;
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`8,045,952;
`- 1 -
`
`
`
`
`
`Inter Partes Review
`U.S. Pat. No. 6,108,686
`
`
` 8,050,652;
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`8,214,873; and
`
`8,230,099.
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`IPR2014-00717
`
`3. The Petitions identify Samsung Electronics Co., Ltd. as the Petitioner, and
`
`identify Samsung Electronics Co., Ltd., Samsung Electronics America, Inc.,
`
`and Samsung Telecommunications America, LLC (collectively “Samsung”)
`
`as real parties-in-interest.
`
`4. In coordinating and supervising the preparation, review, and filing of the
`
`Petitions, I have knowledge of the individuals who received drafts of the
`
`Petitions, and of the individuals who were involved in substantive
`
`preparation, review, and filing of the Petitions. Samsung did not engage,
`
`coordinate with, or communicate with any outside counsel or representatives
`
`other than Covington in connection with the preparation, review, and filing
`
`of the Petitions.
`
`5. Samsung did not send any drafts of any of the Petitions to Google or any
`
`counsel or representatives of Google. Samsung also did not authorize or
`
`instruct Covington to send drafts of any of the Petitions to Google or any
`
`counsel or representatives of Google.
`
`
`
`- 2 -
`
`
`
`Inter Partes Review
`U.S. Pat. No. 6,108,686
`
`
`6. Substantive input was not received from Google or any counsel or
`
`IPR2014-00717
`
`representatives of Google regarding the preparation, review or filing of any
`
`of the Petitions. Neither Google nor any counsel or representatives of
`
`Google provided any direction to, or control of, Samsung in the preparation,
`
`review, or filing of the Petitions.
`
`7. Samsung did not receive any funding or monetary contributions from
`
`Google or any counsel or representatives of Google for the preparation,
`
`review, or filing of the Petitions.
`
`8. Samsung has paid and is paying all of Covington’s fees with respect to the
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`preparation, review, and filing of the Petitions and the resulting IPR
`
`proceedings. Samsung also has paid and is paying all of Covington’s fees
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`with respect to the proceeding before the International Trade Commission
`
`instituted based on Black Hills Media, LLC’s complaint (ITC Inv. No. 337-
`
`TA-882) and the action that Black Hills Media, LLC filed in the Eastern
`
`District of Texas (Black Hills Media, LLC v. Samsung Elecs. Col, Ltd., et
`
`al., No. 2:13-cv-00379).
`
`
`
`- 3 -
`
`
`
`Inter Partes Review
`
`US. Pat. No. 6,108,686
`
`IPR2014-00717
`
`I hereby declare that all statements made herein of my own knowledge are true and
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`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 willfiil false
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`statements and the like so made are punishable by fine or imprisonment, or both,
`
`under § 1001 of Title 18 of the United States Code.
`
`Dated: Segamw/W <9, 570“;
`
`Respectfully submitted,
`
`By
`
`/
`
`/M
`
`Sungil C o
`
`
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