throbber
Thomas Engellenner
`Pepper Hamilton LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02110
`(617) 204-5100 (telephone)
`(617) 204-5150 (facsimile)
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., and
`SAMSUNG TELECOMMUNICATIONS AMERICA, LLC,
`and
`LG ELECTRONICS, INC., LG ELECTRONICS U.S.A., INC., and LG
`ELECTRONICS MOBILECOMM U.S.A., INC.
`Petitioners
`
`v.
`
`BLACK HILLS MEDIA, LLC
`Patent Owner
`___________________
`
`Case No. IPR2014-00737
`Case No. IPR2015-00334
`U.S. Patent 8,050,652
`___________________
`
`EXHIBIT 2013A
`
`
`By:
`
`
`
`
`
`
`
`
`
`
`
`
`
`

`
`As authorized by the Board in an e-mail dated February 20, 2015, Patent
`
`IPR2014-00737
`Patent 8,050,652
`
`
`
`Owner hereby submits Exhibit 2013A, which contains the attachments (i.e.,
`
`Exhibits 1-4) that were inadvertently omitted from the Declaration of Ivan
`
`Zatkovich (Exhibit 2013) filed with the Patent Owner Response on February 4,
`
`2015.
`
`Counsel for Petitioners have been consulted and do not object to this filing.
`
`Respectfully submitted,
`By: /Thomas Engellenner/
`Thomas Engellenner, Reg. No. 28,711
`Pepper Hamilton LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02110
`(617) 204-5100 (telephone)
`(617) 204-5150 (facsimile)
`Attorney for Patent Owner
`
`Dated: February 23, 2014
`
`
`
`
`
`1
`
`

`
`IPR2014-00737
`Patent 8,050,652
`
`CERTIFICATE OF SERVICE
`
`
`
`
` I
`
`
`
`
`areister@cov.com
`gdischer@cov.com
`
` hereby certify that on February 23, 2015, a true and accurate copy of this paper,
`EXHIBIT 2013A, was served on the following counsel for Petitioners Samsung
`Electronics Co., Ltd. et al. and Petitioners LG Electronics, Inc., et al., via email:
`
`Andrea G. Reister
`Gregory S. Discher
`Covington & Burling LLP
`
`dori.hines@finnegan.com
`
`Dori Johnson Hines, Esq.
`jonathan.stroud@finnegan.com
`
`Jonathan R. Stroud, Esq.
`Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
`
`By: /Thomas Engellenner/
`Thomas Engellenner, Reg. No. 28,711
`Pepper Hamilton LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02110
`(617) 204-5100 (telephone)
`(617) 204-5150 (facsimile)
`Attorney for Patent Owner
`
`2
`
`
`
`Dated: February 23, 2015
`
`
`
`

`
`
`
`
`
`EXHIBIT 1
`
`EXHIBIT 1
`
`BHM EX. 2013A
`
`BHM Ex. 2013A
`
`

`
`EXHIBIT 1
`
`CURRICULUM VITAE AND TESTIMONIAL HISTORY
`
`
`
`Ivan Zatkovich
`
`301 W. Platt Street, #365  Tampa, FL 33606  (813) 601-8142  ivanzat@ecompconsultants.com
`
`Ivan Zatkovich has over 28 years’ experience in computer science, computer networks,
`digital circuit design, and software engineering. Mr. Zatkovich is the principal consultant
`with eComp Consultants, a technology consulting firm specializing in intellectual property
`consulting for telecommunications, computer related technology, eCommerce and Network
`Communication protocol. Mr. Zatkovich has over 10 years’ experience providing expert
`testimony for patent litigation and software contract disputes in Telecommunications and
`computer technology, providing expert reports, depositions, and trial testimony.
`
`Mr. Zatkovich has designed and developed Network Communications systems,
`Telecommunication applications, and high speed computer peripherals and streaming
`media, as well as, Geolocation, Graphical Information Systems (GIS), Geographic CAD
`and mapping systems. He has also participated in ISO and ANSI standard committees for
`disk and video devices. Ivan has testified on cases involving, Remote control of Video
`signal controllers, channel switching for Video on Demand, and Media Streaming network technology.
`
`
`Managed 6 to 35 member teams. Software development, systems
`Integration, critical path management, PMP/CMM methodologies.
`Commercial and high volume content websites, streaming media, web
`marketing and personalization, search engine optimization, Storefront,
`fulfillment systems, B2B/B2C portals, ERP/supply chain. (Warner
`Brothers, Caldwell Banker, AAA Travel, Pro Marine)
`Computer Telephony Integration (CTI) since 1984. Call Center, IVR,
`ACD, VoIP, and Unified Messaging (Verizon, Bell Canada, PTT
`Netherlands, and Mercury Communications).
`
`Developed early Ethernet signal collision detection, High speed parallel
`and serial communication drivers, analog to digital signal processing for
`peripheral and device control. (Digital Equipment Corporation, Tanning
`Technology).
`Expert testimony and damage assessment for ecommerce litigation,
`internet & software copyright, telecommunications. Over 24 cases
`providing expert reports, depositions, & trial testimony.
`
`Director / Project
`Manager
`Internet,
`ecommerce,
`Streaming media
`
`13 years
`
`12 years
`
`Telecommunications 11 years
`
`Communications &
`Signal processing
`
`7 years
`
`Expert Witness
`
`11 years
`
`
`
`
`
`Education:
`
`
`
`B. S. Computer Science
` Minor in E.E. digital circuit design
`Master’s study and thesis in Computer Networks 1981
` Results published in Byte Magazine
`
` 1980
`
`
`
`
`
`University of Pittsburgh
`
`University of Pittsburgh
`
`
`
`BHM Ex. 2013A
`
`

`
`Sample Cases:
`
`Nature of Case:
`Nature of Engagement:
`
`GeoTag, Inc v. Frontier Communications Corp. et al.
`Jurisdiction:
`U.S. District Court, Eastern District of Texas
`Client:
`Macy’s, Genesco, AGCO Corp., The Rockport Company, LLC., Hennes &
`Mauritz LP (H&M), Gander Mountain Company, Godiva Chocolatier, DSW,
`National Interlock Systems
`Patent Litigation
`Testifying Expert regarding e-Commerce, Geo location, store locator
`based technology. Provided Non Infringement Reports for multiple
`defendants.
`ABC v. ENC, CISCO, et.al.
`Jurisdiction:
`U.S. District Court, Southern District of Texas
`Client:
`ABC
`Nature of Case:
`Patent Litigation
`Nature of Engagement:
`Remote control & communication for Video Streaming, Video & TV signal
`controllers. Provide Infringement reports and invalidity rebuttal reports
`and deposition.
`Represented by:
`Dunlap Codding and Smyser Kaplan & Veselka
`Zamora Radio LLC v. Last.fm, Pandora, CBS Radio, et.al.
`Jurisdiction:
`U.S. District Court, SOUTHERN DISTRICT OF FLORIDA
`Client:
`Zamora Radio
`Nature of Case:
`Patent Litigation
`Nature of Engagement:
`Testifying expert on streaming players and on-demand media control vs.
`broadcast (forward only) media control.
`Represented by:
`Ward & Olivo
`VTran Media v. Cox Communication, et.al.
`Jurisdiction:
`U.S. District Court, Eastern District of Pennsylvania
`Client:
`VTran
`Nature of Case:
`Patent Litigation
`Nature of Engagement:
`Expertise in Video on Demand, DVR, Cable box interfaces, Channel
`determination, signal control. Provide report on patent non-Infringement
`and Invalidity.
`
`
`eBay (Skype) v. IDT Communications
`Client:
`IDT as defendant in complaint and plaintiff in counterclaim
`Nature of case:
`Voice Over IP, Patent Litigation
`Nature of engagement:
`Testifying expert for Network address resolution, data routing, and VoIP
`session initiation.
`Representing:
`Holland & Hart followed by Girardi|Keese
`TGIP v. AT&T, IDT, et.al.
`Jurisdiction:
`U.S. District Court, Eastern Texas
`Client:
`IDT Corporation
`Nature of Case:
`Patent Litigation
`Nature of Engagement:
`Expertise in Cell phone provisioning and activation, Wireless transaction
`communication. Provided report on non-Infringement and Invalidity.
`Deposition.
`Finnegan, Henderson, Farabow, Garrett & Dunner, L.L.P.
`
`Represented by:
`
`
`BHM Ex. 2013A
`
`

`
`Professional Experience:
`
`Fund Leader
`
`Vaud Advisors - Social Media Technology Fund
`Direct research and assessment of social media companies for venture capital investment.
`
`
`
` New York, NY
`
`
`
`2013 - Present
`
`
`
`2000 - Present
`
`2007- 2008
`
`
`
`Principal Consultant
`eComp Consultants
`
`Tampa, FL
`
`
`
`Provide consulting on design and development of software product development, and ecommerce
`technology. Provide technology consulting and expert support for telecommunications, internet,
`and ecommerce applications in the areas of:
` Patent portfolio evaluation, market valuation, identification of potential prior art,
`and licensing opportunities.
`Independent consulting for Alcatel-Lucent (AT&T Bell Labs) to review,
`recommend, and rate Alcatel’s extensive Patent portfolio specifically in the area
`of telecommunications and web-based ecommerce.
` Patent litigation consulting for telecommunications and internet technology
`patents.
` Software contract and due diligence consulting for disputes involving custom
`software projects.
`Internet publishing and copyright consulting for web content management and
`licensing.
` Commercial websites, search engine, and web marketing strategies.
`
`
`
`Sample clients include: Alcatel-Lucent, LogicLink, NWI Corp, Jones Day, Finnegan
`Henderson, Fish & Richardson, Cozen O’Connors, Morrison Foerster
`
`Global Web Markets Manager
`Smith & Nephew Inc.
`
`Clearwater, FL
`
`Smith & Nephew is a global manufacturer of medical, wound, orthopedic, and surgical supplies.
`Smith & Nephew has facilities in 33 countries and maintains 35 websites for different product areas
`and country marketing.
` Design the S&N Corporate web architecture for all intranet, extranet, and Internet
`sites.
` Direct a staff of web professionals in developing and managing 35 individual S&N
`web sites maintained in the US and 14 countries for both S&N clients and internal
`users.
` Manage and maintain the 650 domains currently owned by Smith & Nephew
` Optimize search engine ranking and website meta tagging.
` Develop corporate technology and IT standards and policies including:
` Create Web hosting agreements and IT service contracts (SLAs)
` Define Web development standards
` Research page ranking, redirection, and domain optimization strategies.
`
`2002 – 2007
`
`eBusiness Director
`Eva-Tone Inc
`
`Clearwater, FL
`
`BHM Ex. 2013A
`
`

`
`
`
`1999 to 2002
`
`
`
`
`1996 –1999
`
`
`
`
`
`
`Eva-Tone is a $45M commercial multimedia company specializing in ecommerce and marketing
`solutions, media and content customization, order processing and fulfillment, print & web
`publishing, CD & DVD manufacturing.
` Set strategic direction of client service offerings in ecommerce and Content Management.
` Designed and Implement High Volume web publishing system.
` Projects proposed and delivered include:
`o McGraw-Hill – Enterprise Content Management and automated Web publishing
`system.
`o ProMarine USA – B2B storefront, complex part search, order processing and
`fulfillment.
`o Resource Rabbit – Sales collateral manager. This system retrieves user
`preferences and client profile information to generate customized electronic
`presentations and brochures.
`o AAA Travel – CRM sales collateral system, instant customized brochures, print-
`on-demand.
`
`eBusiness Engagement Manager
`Tanning Technology and IMRGlobal
`
`Tanning Technology is an international systems integrator specializing in network infrastructure
`and channel integration for financial markets and the insurance industry. Proposed and managed
`eBusiness and Internet infrastructure projects focused on client and user personalization, data
`mining, and web marketing practices.
`
`Client web engagements proposed and managed:
` Eckerd Pharmacy – Developed eBusiness and web marketing for personalized client web
`content.
` GEICO – Developed a personalized policyholder web service that uses clients’ account
`history and demographics to customize product literature for cross-sell & up-sell
`opportunities.
` Hartford Insurance – Integrated 3 tier online claims processing & subrogation with legacy
`systems
` Citicorp Bank – Designed mortgage and loan payment system; managed sale of loan
`contracts
` Smith Barney – Developed remote access network infrastructure & wireless PDA financial
`system
` Medwerks – Created medical insurance clearinghouse, MDs centrally process insurance
`payments
`
`Director of Network & Customer Support
`Utility Partners, Inc.
`
`Tampa, FL
`
`Utility Partners developed and customized utility company software for scheduling service
`appointments, assigning and routing mobile workforce (field technicians), and dispatching and
`coordinating resources during power outages.
` Managed client engagement leads for development of client customizations and
`standardization of product features.
` Setup client support department to manage UP’s growing client and product base.
`This department:
`o Provided Network and IT management for over 800 customer users
`o Created a 24x7 Helpdesk for Utility dispatch centers and IT departments
`
`BHM Ex. 2013A
`
`

`
`o Developed system and network monitors for real-time client system monitoring
`o Received trouble calls & provided live client support for the following
`applications:
`
` MobileUP – Mobile Workforce Dispatcher
` TroubleUP – Power outage manager
` Smartnom – Web Gas Auction System for private gas auctions
` CAS – Customer Appointment and Call Center application
`
`
`
`Project Manager: Telecom Software
`GTE Data Services (currently Verizon)
` Tampa, FL
`GTE was an $8B Telecommunications company and formed the Commercial Services division to
`customize their telephone business software to sell to other telephone companies internationally.
` Managed large product implementations for Telecom billing, service order, and Switch
`management.
` Developed Service manager, an early videotext hypermedia application for online ordering
`of Telecom equipment and services.
` Specific projects managed:
`o Mercury Communication – setup Service Bureau to bill their new
`intelligent network services.
`o PTT Netherlands – managed $5M inter-carrier billing project for PTT
`Netherlands
`o Bell Canada – developed Pricing Plan & Table Management system
`o Deutsche Telekom – designed and developed a German billing
`prototype system.
`o Received GTE personal best award.
`
`Software Engineer / Technical Lead
`Digital Equipment Corp.
`
`Maynard, MA
`
`As Technical Lead, led the development of manufacturing automation and control software.
`Projects Included:
` Supply Chain, CAD/CAM – Designed system to retrieve parts information from
`circuit board CAD design. Developed a parts ordering system based on expected
`volumes.
` Pick & place automation – Automatically program IC insertion machines.
`Develop system to determine IC insertion order, generate machine instructions,
`and download program to machine.
`As Software Engineer for embedded controllers and video subsystems, designed and
`developed PDP-11 operating system and device drivers.
` Enhanced high-speed DecNet drivers for Synch, Asynch, and Parallel communications.
` Designed/developed disk firmware and drivers for floppy & Winchester disks.
` Developed Hypermedia and Windows Manager for PRO-350 microcomputer.
` Developed and enhanced video controller firmware and layered graphics system for PRO-
`350.
` Developed Computer Telephony Integration (CTI) product for telephone answering
`machines.
`
`
`1987-1996
`
`
`
`1980 – 1987
`
`
`
`
`Technical Tools & Environments:
`
` Unix, Windows, NT, Microsoft .NET, C#, C/C++, VB, Assembler
`Java, Java script, JSP, IBM Websphere, Microsoft Commerce engine, Blue Martini
`
`
`BHM Ex. 2013A
`
`

`
`
`
`SQL, Oracle, Foxpro, DB2, Crystal Reports, Active-Reports, MQ Series, Tuxedo, Documentum, Interwoven
`
`Certifications & Publications:
`
`Industry Speaker: Internet Publishing standards (Momentum conference)
`
` Department of Justice: Proposal for internet forensics technology
`IBM Websphere – Certified ecommerce Solutions Expert
`
` Byte Magazine – Published Network Design articles
` Sync Magazine – Published Programming Techniques and Tutorials
`IEEE SigGraph – Presented ICGS Computer Graphic Standards for IEEE SigGraph conference.
`
` CMM & PMP – Project management methodologies
`ISO and ANSI – On International ISO and National ANSI Committees for Disk and Media format standards
`
`
`
`
`Testimonial History:
`
`Within the past five years, I have testified and/or provided expert services in the following matters (the underlined
`party identifies which party I was retained by):
`
`• Bid For Position v. AOL, Google, Microsoft, MIVA, et.al. 2:07-cv-582 JBF/TEM (E.D. VA 2010)
`(settled 2008)
`Expert for Defendant MIVA on Patent Invalidity for Internet Search Engine technology. Provided
`expert invalidity report regarding the auctioning of keywords in paid searches.
`
` •
`
` Imhoff Associates v America’s Criminal Defense (S.D. CA) (settled 2009)
`Expert for Defendant ACD for accused Internet Search Engine mis-direction (fraud). Provided
`expert consulting and identified the unintentional actions of the defendant which caused the search
`mis-direction.
`
` •
`
` Zamora v. CBS Radio et.al. 09-20940-CIV-MORENO (S.D. FL 2010) (settled 2010)
`Last.fm, Ltd., CBS Radio, Inc., CBS Corp., Slacker, Inc., Pandora Media, Inc., Rhapsody America LLC,
`Realnetworks, Inc., DKCM, Inc., AOL, LLC, Accuradio, LLC, Yahoo! Inc. and Soundpedia, Inc.
`Expert for Plaintiff on Patent Infringement for Internet Radio Technology. Provided expert report
`and deposition regarding the use of streaming media and Web Radio players.
`
` •
`
` Nuance v. Tellme (a Microsoft subsidiary) C.A. No. 06-105-slr (S.D. Del 2009) (settled 2010)
`Expert for Defendant on Speech Recognition software. Provided expert report and deposition on
`non-infringement and invalidity for speech recognition used in automated phone directories.
`
` •
`
` TGIP, Inc. v. AT&T Corp, IDT., 512 F. Supp. 2d 727 (E.D. Tex. 2007) (settled 2007).
`Expert for Defendant on non-infringement. Patent and prior art dispute concerning call processing
`center and service provisioning in which I analyzed telephone network, call processing center, and
`call routing patents; developed detailed non-infringement chart; and rebutted plaintiff’s expert.
`
`• Swapalease, Inc. v. Sublease Exchange.com, Inc., 1:07 CV 00045-SSB (S.D. Ohio 2007) (Pending)
`Expert for Plaintiff on infringement. Patent and prior art dispute concerning commercial auto lease
`web site. Expert infringement report, testified at Markman Hearing.
`
` •
`
` Ronald A. Katz v. DHL Express, 2:2007 CV 02192 (N.D. Cal.)
`Patent infringement dispute concerning call processing center and call routing patents. Developed
`non-infringement reports and deposed.
`
`
`
`BHM Ex. 2013A
`
`

`
`• Ronald A. Katz v. Cox Communications, 2:2007 CV 02299 (N.D. Cal.)
`Patent infringement dispute concerning call processing center and call routing patents. Developed
`non-infringement reports and deposed.
`
` •
`
` Ronald A. Katz v. Earthlink, 2:2007 CV 02325 (N.D. Cal.). Patent infringement dispute concerning
`call processing center and call routing patents. Developed non-infringement reports and deposed.
`
` •
`
` Ronald A. Katz v. Fifth Third Bank, 2:2007 CV 04960 (N.D. Cal.)
`Patent infringement dispute concerning call processing center and call routing patents. Developed
`non-infringement reports and deposed.
`
` •
`
` Ronald A. Katz v. Huntington National Bank, 2:2007 CV 04960 (N.D. Cal.)
`Patent infringement dispute concerning call processing center and call routing patents. Developed
`non-infringement reports and deposed.
`
` •
`
` Ronald A. Katz v. Echostar, 2:2007 CV 06222 (N.D. Cal.) (pending)
`Patent infringement dispute concerning call processing center and call routing patents. Developed
`non-infringement reports and deposed.
`
` •
`
` ABC v. ENC, CISCO, WebEx communications, et.al., H-06-1032 (S.D. TX.)
`Patent infringement dispute concerning computer remote control, remote command processing, and
`remote communication. Developed non-infringement and invalidity rebuttal reports and deposed.
`
` •
`
` Logiclink v. Keylink, CV07-1056-DOC(MLGx) (C.D. Cal.)
`Patent infringement dispute concerning eCommerce for Kiosks for Hotel Business centers.
`Developed infringement report and invalidity rebuttal report. Trial Testimony.
`
` •
`
` eBay v. IDT corp, IDT 4:08-cv-4015-HFB (W.D. Ark) (settled 2010)
`Patent infringement. Perform analysis of Voice Over IP providers and prior art candidates; provide
`non-infringement (suit) and infringement (counter suit) expert reports.
`
` •
`
` i2 Technologies, Inc. v. Oracle Corporation, 6:09-CV-194-LED (E.D. Tex)
`Patent infringement, Testifying expert for Supply Chain Management software, Manufacturing
`Automation, and Sales projection system software. Provide infringement and Invalidity rebuttal.
`
` •
`
` IslandIP Inc. v. Deutsche Bank Corporation, 1:09-cv-04673-VM (S.D. NY)
`Patent infringement, Testifying expert for Financial Transaction, Omnibus account consolidation and
`settlement for Banks and Broker Dealers. Provide infringement and Invalidity rebuttal reports.
`
` •
`
` 3M Future Africa (PTY) LTD v. The Standard Bank of South Africa LTD, MTN Group Limited and MTN
`Mobile Money SA (PTY) LTD, Case #: Patent 2002/2337 (South African High Court)
`Patent infringement, testifying expert for Online Payments Security. Provide infringement, validity
`and trial support.
`
` •
`
` Cohen v. US, 07-154-C (U.S. District Court of Federal Claims )
`Copyright infringement testifying expert for Cohen. US Government FEMA distributed copy
`righted documents without Cohen's knowledge or approval. Provide expert report, damages and
`deposition.
`
` •
`
` SFA v. 1-800-Flowers, et.al, 6:2009-cv-00340-LED (E.D. Tex)
`• SFA v. Barnes & Noble, et.al, 6:2011-cv-00399-LED (E.D. Tex)
`
`BHM Ex. 2013A
`
`

`
`1-800-Flowers.com, Inc.,The Plow & Hearth, Inc., including D/B/A Wind & Weather, Inc.
`The Popcorn Factory, Inc., Winetasting Network, Inc., The Children's Group, Inc.,
`Problem Solvers, Inc., Barnes & Noble, Inc., Barnesandnoble.com LLC, Blockbuster, Inc.,
`BUILD-A-BEAR WORKSHOP, INC., CDW Corporation
`GameStop, Corp., GameStop, Inc., GameStop.com, Inc., Gander Mountain Company,
`Overton's, Inc., J & R Electronics, Inc., Newegg, Inc., Newegg.com, Inc.
`Northern Tool & Equipment Company, Inc., Northern Tool and Equipment Catalog Co.
`Office Depot, Inc., Omaha Steaks International, Inc., OmahaSteaks.com, Inc.
`The Timberland Company, Tupperware Brands Corporation, Tupperware.com, Inc.
`Patent infringement, for Computerized Sales Force Automation System. Testifying expert for joint
`invalidity (9 defendants) and non-infringement (5 defendants).
`
` •
`
` Bloom v. Intuative, 06 CV 6301 (S.D. NY)
`Software contract dispute, testifying expert concerning Document Management and Publishing for
`Pharmaceuticals and Regulatory agencies. Comparison of product features and software reuse.
`
` •
`
` Dallal v. New York Times, 1:2003-cv-10065 (S.D. NY) (settled 2008)
`Testifying Expert, Deposition, for Web Copyright. Provided expertise in standard media publishing
`practices, content licensing, and web content customization.
`
` •
`
` LATimes v. Software AG, 2:2007-cv-01289-SVW-JWJ (C.D. Cal.) (settled 2008)
`Testifying Expert in Network & Database Software licensing dispute. Prepared expert report and
`deposition on software licensing practices.
`
` •
`
` Bear Creek Technologies v. Verizon Services Corp., 1:11-cv-00880-TSE -JFA (E.D. Virginia)(pending)
`Testifying Expert, provided infringement and invalidity of VoIP related patents.
`
` •
`
` Cequint v. Apple, 1:2011-cv-01224 (Wilmington) (pending)
`Testifying Expert. Performed code review of Cequint’s City ID Software product to determine if
`and how they are practicing the key limitations of the patents-in-suit focused on Caller ID, CND
`Messages, City, State lookups, WAP interfaces, Database synchronicity (automatic update of
`database), Display of incoming caller information and Call Answer and set-up code..
`
`• Tel-tron Corporation v. Stanley Security Solutions d/b/a Stanley Healthcare Solutions, 6:2011-cv-01448 (M.D. Florida)
`Testifying Expert regarding network systems for displaying data relating to emergency call systems.
`
` •
`
` Microsoft v 5R Processors, LTD. and Thomas Drake, 3:12-cv-00263-slc, (W.D. Wisconsin)
`Testifying Expert. Evaluate the Microsoft Windows Professional XP OEM Licensing Agreement
`and Microsoft Refurbished PC Licensing Guidelines and opine on 5R adherence.
`
` •
`
` Walker Digital, LLC v. Fandango, Inc., et al.,1:11-cv-00313-SLR (Delaware)
`Facebook Inc., Fandango, Inc., Expedia, Inc., Amazon.com, Inc., American Airlines, Inc., eBay Inc., and
`Zappos.com, Inc.
`Testifying Expert regarding e-commerce, shopping carts, e-marketing, and the promotion of
`financial products such as credit and debit cards for retail, business-to-business (“B2B”), and
`financial industries. Provided Infringement (Amazon, Expedia, Zappos) Reports and Invalidity
`Rebuttal Report.
`
`
`
`• Trialcard v. P.S.K.W. & Associates, 3:11-cv-05693-FLW-TJB (NewJersey)
`
`BHM Ex. 2013A
`
`

`
`Testifying Expert for patent re-exam concerning eCommerce technology based on a method of
`dispensing, tracking, and managing pharmaceutical products by communicatively linking prescribers
`and pharmacies to a central computing system
`
` •
`
` Catalina Marketing Corporation v. Coupons, Inc., JAMS Reference No. 11000654507 (San Francisco)
`Testifying Expert to analyze the following Coupons systems, Microsite System & Brandcaster™
`System and determine if either system is an “Infringing Capable System”. Provided Expert Report
`and Mediation Trial support.
`
` •
`
` AKH Co., Inc. v. The Reinalt-Thomas Corp. & Southern California Discount Tire Co., Inc., SACV10-1626 CJC
`Testifying Expert regarding trademark infringement & cybersquatting. Provided Expert Report and
`deposition.
`
` •
`
` Soverain v. Euromarket Design, et al. 6:12-cv-00145-LED (E.D. Texas) (pending)
`Testifying Expert regarding e-commerce systems/online shopping carts technology.
`
`• e-LYNXX Corporation v. InnerWorkings, Inc., et al. 1:10-CV-2535 (M.D. PA)
`InnerWorkings, Standard Register, Cirqit.com and R.R. Donnelley & Sons Co.
`Testifying Expert regarding supply chain, custom print jobs, matching job requirements to vendors
` technology. Provided Infringement, Invalidity and Non Infringement Rebuttal Reports and deposition.
`
`• Joao Bock Transaction Services v. USAmeribank, et al,. 8:11-cv-00887-MSS-TGW (Tampa)
`USAmeribank, Everbank and BankFirst
`Testifying Expert regarding secure transactions on electronic financial accounts.
`
` •
`
` Lodsys v. Brother Intl Group et al., 2:11-cv-90(JRG) (E.D. Texas)
`Brother Intl Corp, Canon U.S.A., Inc., Hewlett-Packard Company, Hulu, LLC, Lenovo (United States) Inc.
`Lexmark International, Inc., Motorola Mobility, Inc., Novell, Inc., Samsung Electronics Co., LTD.,
`Samsung Electronics America, Inc., Samsung Telecommunications America, LLC, Trend Micro Incorporated
`Testifying Expert regarding interactive media enabling CRM technology. Provided Invalidity
`Rebuttal Reports and deposition testimony.
` Progressive v. State Farm, et al. CBM2012-00003, CBM2013-00004
`State Farm Insurance, Hartford Insurance, Liberty Mutual Insurance, Safeco Insurance, Ohio Casualty Insurance,
`Open Seas Solutions, Octo Telematics
`Testifying Expert regarding e-Commerce and vehicle telematics systems. Provided Patent Re-exam
`Declarations.
`
` •
`
` •
`
` Black Hills Media, LLC v. Samsung, et al. [ITC case] (pending)
`Samsung, LG, Panasonic, Toshiba, Sharp
`Testifying Expert regarding Google Latitude running on smartphones and smart phones running
`software which can direct the streaming of content between, for example, a laptop and a TV or Blu-
`ray player. Providing device analysis and code review, Infringement Reports and Rebuttal Reports.
`
` •
`
` Rembrandt Social Media, LP v. Facebook, Inc. and ADDTHIS, Inc., 1:13cv158 (TSE/TRJ) (Virginia)
`Testifying Expert regarding social media user content and 3rd party interaction -the diary page and
`"Like" feature. Provided Non Infringement Report and deposition.
`
`• GeoTag, Inc v. Frontier Communications Corp. et al. [Multiple cases] (pending)
`Macy’s, Genesco, AGCO Corp., The Rockport Company, LLC., Hennes & Mauritz LP (H&M), Gander
`Mountain Company, Godiva Chocolatier, DSW, National Interlock Systems
`
`BHM Ex. 2013A
`
`

`
`Testifying Expert regarding e-Commerce, Geo location, store locator based technology. Provided
`Non Infringement Reports for multiple defendants.
`
` •
`
` CareerFairs.com v. United Business Media, LLC, et al., 11-20329-CIV-KING (S.D. Florida)
`Testifying Expert regarding videoconferencing, virtual career fairs technology.
`
`• Transauction LLC v. eBay Patent 7343339 3:2009cv03705 (N.D. CA)
`Expert regarding computerized electronic auction payment systems.
`
`
`
`• Ameranth v. Six Continents Hotels
`Testifying Expert regarding Internet Advertising & Website Technology. Expert Report and deposition.
`
`• Carolina Power & Light Company v. Aspect Software 5:08-cv-00449-BO (E.D. NC)
`Testifying Expert in telecommunications technology.
`
` •
`
` Dominion v. Aspect Software, 3:08-cv-00737-REP (Virginia)
`Testifying Expert in telecommunications and IVR call processing. Provided expert declaration and testimony.
`
`• ComplementSoft v. SAS Institute, 12-C-7372 (N.D. IL)
`Expert regarding software development tools, database manipulation, SAS programming.
`
`• Moricz v. Google, 10-cv-01240-RSL (Seattle)
`Expert regarding use of deep search methodology. Claim Contruction support.
`
`• Media Rights Technologies v. Capital One, et al., 1:13cv476-AJT/TRJ (Virginia)
`Expert regarding secure internet Banking System technology USPatent# 7316033.
`
` •
`
` CertusView v. S&N, 2:13-cv-346 (MSD) (LRL) (Virginia)
`Testifying Expert regarding geolocation. U.S. PATENT # 8,265,344, 8,290,204, 8,340,359, 8,407,001,
`AND 8,532,341
`
` •
`
` Bright Edge v SearchMetrics, 3:14cv-01009 WHO (San Francisco)
`Testifying Expert regarding search optimization, USPatent# 8478700, USPatent# 8478746.
`
` •
`
` Black Hills Media, LLC v. Sonos, 2:14-CV-00486 SJO (PJWx) (California Western Division)
`Testifying Expert regarding delivery of stored and streaming audio content over wide-area and local
`area networks. U.S. PATENT # 6,757,517, 7,236,739, 7,742,740 and 6,826,283
`
`
`BHM Ex. 2013A
`
`

`
`
`
`
`
`EXHIBIT 2
`
`EXHIBIT 2
`
`BHM EX. 2013A
`
`BHM Ex. 2013A
`
`

`
`Manual (English)
`
`1
`
`m3po
`
`18.05.00
`
`BHM Ex. 2013A
`
`

`
`CE Declaration of conformity
`
`This product is in conformity with prevailing EU guidelines. A valuation of conformity has been carried
`out, as stipulated in EU guidelines.
`
`Company:
`
`Product:
`
`TerraTec Electronic GmbH · Herrenpfad 38 · D-41334 Nettetal · Germany
`
`MP3-CD-Player m3po
`
`According to Low-Voltage Guideline 73/23/EU The following norm has been observed:
`
`EN 60 065: 1993
`
`According to Electromagnetic Sociability Guideline 89/336/EU, the following norms have been observed:
`EN 55 013: 1990 · EN 55 020-1: 1995
`
`(incorporating EN 55 013: 1991 + 1995)
`
`The company holds the following documentation available on request:
`• Manual
`Testing documents
`•
`• Other technical documentation
`
`Nettetal, 26.04.2000
`
`TerraTec® ProMedia, SoundSystem Gold, SoundSystem Maestro, SoundSystem Base1, AudioSystem
`EWS®64, SoundSystem DMX, phono PreAMp, XLerate, Base2PCI, TerraTec 128iPCI, TerraTV+, m3po,
`WaveSystem, MIDI Smart and MIDI Master Pro are trademarks of TerraTec® Electronic GmbH Nettetal.
`
`Any soft and hardware referred to in this manual is generally also registered trademarks of their respec-
`tive owners. They are governed by the usual laws.
`
`©TerraTec® Electronic GmbH, 1994-2000. All rights reserved (18.05.00).
`
`All texts and diagrams were created with the greatest care. TerraTec Electronic GmbH and its authors can
`not be held responsible for incorrect information and its consequences. Technical information in this
`document may be subject to change without prior notice.
`
`All texts in this documentation are protected by copyright laws. All rights are reserved. No part of this
`document may be reproduced as photocopies, microfilm or any other procedure or as computer language
`/ document without the author’s permission. The rights of reproduction in presentation and media are
`also reserved.
`
`2
`
`m3po
`
`BHM Ex. 2013A
`
`

`
`Contents
`
`Box contents........................................................................................................................... 5
`
`Setup, maintenance and safety directions. ............................................................................. 6
`
`Welcome.................................................................................................................................8
`
`Unpack and go! The quick-start tour.......................................................................

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