`
`1, Lawrence P. G. Forsley, hereby state as follows:
`
`1.
`
`2.
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`I am over the age of 18 and am competent to make this declaration.
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`I have personal knowledge of the matters stated herein.
`
`.
`
`I currently live in San Diego, California.
`
`I am currently a Research Associate in the
`
`Nuclear Engineering Teaching Laboratory at the University of Texas, Austin and am the
`
`Senior Vice President and Chief Technical Officer of the Global Energy Corporation- I
`
`am also the President of JWK International Corporation.
`
`I taught in the College of Engineering and in the College of Arts and Sciences at the
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`University of Rochester, in Rochester, NY where I was a group leader at the Laboratory
`
`for Laser Energetics, at the University of Rochester.
`
`.
`
`I was a Forth language and system developer and had been using it for Laser Fusion
`
`research since 1978. The University of Rochester developed its own version called
`
`URTH, or University of Rochester Forth.
`
`Consequently, between 1981 and 1999 I chaired or co-chaired twenty conferences related
`
`to the Forth programming language.
`
`I founded the not-for-profit Institute for Applied Forth Research, Inc. in Rochester, NY in
`
`1983 to further promote the Forth programming system and to run Conferences held at
`
`the University of Rochester; at Ryerson University in Toronto, Ontario, Canada; Johns
`
`Hopkins University in Laurel, MD and in Leningrad, Soviet Union.
`
`Specifically, in 1996 I organized and chaired the 1996 Open Systems Conference held in
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`Toronto, Canada at Ryerson Polytechnic University (referred to herein as the “1996
`
`Rochester Forth Conference”).
`
`Petitioner First Data - Exhibit 1013 - Page 1
`
`
`
`10.
`
`ll.
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`12.
`
`13.
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`14.
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`The 1996 Rochester Forth Conference was held from June 19, 1996 through June 22,
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`1996 and was hosted by the Institute for Applied Forth Research, Inc. The 1996
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`Rochester Forth Conference was open to the public for any interested persons to attend.
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`As part of the 1996 Rochester Forth Conference, subject matter corresponding to a paper
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`entitled “The Europay Open Terminal Architecture — A Forth-based Token System for
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`Payment Terminals” (referred to herein as the “OTA Paper") was presented by its
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`authors.
`
`As per the standard procedure following such a conference I chaired, I collected the
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`conference papers corresponding to the presentations at the 1996 Rochester Forth
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`Conference for publication and distribution as part of the conference proceedings.
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`Following collection of the papers, the Institute for Applied Forth Research, Inc. served
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`as the publisher and type set each paper to be included in the Conference Proceedings of
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`the 1996 Rochester Forth Conference, including the OTA Paper.
`
`The Conference Proceedings of the 1996 Rochester Forth Conference were sent to the
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`printer by December of 1996 with the intention of publication and distribution by early
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`January 199?.
`
`Publically available publication dates of January 1, 1997 (as indicated in Exhibit A) and
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`January 28, 1997 (as indicated in Exhibit B) (ISBN-13: 9780914593164) are indicative
`
`of the printing and publication of the Conference Proceedings of the 1996 Rochester
`
`Forth Conference, including the OTA Paper, occurring, at the latest, by the end of
`
`January 1997.
`
`Petitioner First Data - Exhibit 1013 - Page 2
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`
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`15. As per The Institute for Applied Forth Research, Inc.’s standard procedure, the
`
`Conference Proceedings of the 1996 Rochester Forth Conference would have been
`
`publically distributed in multiple ways within a month of printing and publication:
`
`16. First, the Conference Proceedings of the 1996 Rochester Forth Conference would have
`
`been distributed to over fifty attendees of the 1996 Rochester Forth Conference. Such
`
`distribution would have included a copy of the Conference Proceedings of the 1996
`
`Rochester Forth Conference being mailed to the attendees either directly by The Institute
`
`for Applied Forth Research or by a fulfillment house used for distributing the Conference
`
`Proceedings of the 1996 Rochester Forth Conference. As per standard procedure, such
`
`distribution would have occurred within a month of publication, thus by the end of
`
`February 1997 at the latest. A list of attendees to the 1996 Rochester Forth Conference
`
`who would have received copies of the Proceedings is attached as Exhibit E.
`
`17. Second, over one hundred copies of the Conference Proceedings of the 1996 Rochester
`
`Forth Conference would have been received by the Institute for Applied Forth Research
`
`for distribution to members of the public starting in February 1997 at the latest.
`
`18. As per The Institute for Applied Forth Research, Inc.’s usual procedures, the availability
`
`of Conference Proceedings of the 1996 Rochester Forth Conference were made known
`
`through advertising in “Forth Dimensions” a publication focusing on applications of the
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`Forth computing language.
`
`19. The advertising in “Forth Dimensions” was intended to alert readers to: the occurrence of
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`the 1996 Rochester Forth Conference, and contact information for reaching me, and the
`
`Institute for Applied Forth Research, Inc. Through contacting myself or my staff at the
`
`Petitioner First Data - Exhibit 1013 - Page 3
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`
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`Institute a copy of the Conference Proceedings of the 1996 Rochester Forth Conference
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`could be obtained.
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`20. A true and correct copy of an exemplary advertisement for the 1996 Rochester Forth
`
`Conference from “Forth Dimensions" is attached as Exhibit C.
`
`21. Further, The Institute for Applied Forth Research, Inc. maintained a mailing list of over
`
`three hundred persons and institutions who had previously attended conferences, bought
`
`the Institute’s publications, or expressed a general interest in the Institute to apprise them
`
`of publications available for purchase. As such, all members of the mailing list would
`
`have been notified of the availability of Conference Proceedings of the 1996 Rochester
`
`Forth Conference for purchase.
`
`22. Third, commencing no later than February 1997, copies of the Conference Proceedings of
`
`the 1996 Rochester Forth Conference were distributed or sold to vendors for their
`
`customers or for resale to the general public. An example of this would be sales to
`
`Mountain View Press, who would purchase 5 - 20 copies at a time for resale. Similarly,
`
`we would have given additional copies to Conference sponsors for their own distribution-
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`23. A true and correct excerpt of the Conference Proceedings from the 1996 Rochester Forth
`
`Conference, which includes the OTA Paper, is attached as Exhibit D.
`
`Petitioner First Data - Exhibit 1013 - Page 4
`
`
`
`I declare under penalty of perj ury that the forgoing Declaration is true and correct.
`
`Date: Apri 1 3 0 1
`
`2 0 14
`
`Location (C ityfstate): San Diego, CA
`
`1/
`ya‘
`K7,?’
`/
`
`32";-.-9~'1T‘#?—"
`{
`->
`\— — —
`
`Digitally signed by Lawrence Forsley
`DN: cn=Lawrence Forsley. o=JwK International
`Corporation, ou, emai|=|pgfors|ey@ao|.com, c=US
`Date: 2014.04.30 13:41 :30 -o7'oo'
`
`Lawrence P. G. Forsley
`
`Petitioner First Data - Exhibit 1013 - Page 5
`
`
`
`EXHIBIT A
`
`Petitioner First Data - Exhibit 1013 - Page 6
`
`
`
`4/30/2014
`
`1996 Rochester FORTH Conference: Open Systems, June 19-22, 1996, Ryerson
`
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`University, Toronto, Ontario, Canada
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`1996 Rochester FORTH Conference:
`
`Open Systems, June 19-22, 1996, Ryerson Polytechnic
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`http://boo|G.g oog |e.com/bools/about/1 996_Rochester_FORTH_Conference. html ?i d= Oi 2rAAAACAA.J
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`Petitioner First Data - Exhibit 1013 - Page 7
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`4/30/2014
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`1996 Rochester FORTH Conference: Open Systems, June 19-22, 1996, Ryerson
`
`- Google Books
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`http://boo|G.g oog|e.com/books/about/1996_Rochester_FORTH_Conference.htm|?id= Oi2rAAAACAAJ
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`Petitioner First Data - Exhibit 1013 - Page 8
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`2/2
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`EXHIBIT B
`
`Petitioner First Data - Exhibit 1013 - Page 9
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`
`
`4/30/2014
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`1996 Rochester Forth Conference: Open Systems, June 19-22, 1996, Ryerson Polytechnic University, Toronto, Ontario, Canada by Rochester 4th Applicati . ..
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`Product Details
`ISBN-13: 9780914593164
`Publisher: Institute For Applied Forth Research
`Publication date: 1/28/1997
`Pages: 118
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`Related Subjects
`Protocols & Standards - Computer Networks
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`1996 Rochester Forth Conference: Open Systems, June 19-22, 1996, Ryerson Polytechnic University, Toronto, Ontario, Canada by Rochester 4th Applicati . ..
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`Petitioner First Data - Exhibit 1013 - Page 11
`http://vwwv.barnesandnob|e.com/w/1996- rochester-forth-conference- rochester-4th-appl i cati ons-conference-staf/1 0041 50969?ean= 9780914593164
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`EXHIBIT C
`
`Petitioner First Data - Exhibit 1013 - Page 12
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`
`
`$10
`
`Volume XW, Number 6
`
`March 1996 APT!"-'
`
`FORT
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`D
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`I M E
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`N
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`S
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`I
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`0
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`N
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`S
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`
`
`The Institute for Applied Forth Research, Inc.
`Announces the 16th Annual
`1996 Rochester Forth Conference
`
`on Open Systems
`
`June 19 — 22, 1996
`Ryerson Polytechnic University
`Toronto, Ontario, Canada
`
`Call for Papers
`The 1996 Rochester Forth Conference on Open Systems is hosted by the Institute for Applied
`Forth Research, Inc. in conjunction with the Southern Ontario Forth Interest Group and
`McMaster University. The Rochester Conference will again provide a forum for researchers,
`developers, and vendors to present the latest practical results dealing with open systems. The
`conference seeks original papers relevant to the design, development, implementation, and
`use of open systems. Conference topics include:
`
`0 Open Firmware Standard / Open Boot”
`0 Scripting Languages
`0 Distributed Computing
`0 Plug and Play” Systems
`0 SGML and HTML
`
`0 Educational Issues
`
`0 Java”
`
`Other areas of interest are Forth programming standards, embedded systems, real—time
`systems, and the use of Forth for scientific and engineering applications.
`
`Important Dates
`February 1, 1996
`May 1, 1996
`
`Deadline for an extended abstract
`Deadline for the camera-ready copy of final paper
`
`Please send all manuscripts to the Program Chairman.
`Additional information will be posted on the world-wide web as it becomes available:
`http:/ /maccs.dcss.mcmaster.ca / ~ns/ 96roch.html
`Facilities Chair: B.]. Rodriguez
`
`Erggram gfihair
`Nicholas Solntseff
`Dept. of Computer Science 8: Systems
`McMaster University
`Hamilton, Ontario
`Canada L85 4K1
`ns@maccs.dcss.mcmaster.ca
`
`gfignfgrgngg Infgrrnatign
`Lawrence P.G. Forsley, General Chair
`Institute for Applied Forth Research, Inc.
`Box 1261
`Annandale, Virginia 2003
`fax: 703-256-3873
`phone: 716-235-0168
`lforsley@jwk.com
`
`Petitioner First Data - Exhibit 1013 - Page 14