`Farmwald and RPX v. ParkerVision
`IPR2014-00948
`
`
`
`Farmwald and RPX Exhibit 1049, pg. 2
`Farmwald and RPX v. ParkerVision
`IPR2014-00948
`
`
`
`record of the Qualcomm v. ParkerVision litigation (as posted by ParkerVision on
`
`its webpage).
`
`(5)
`
`Only one reference asserted in the Qualcomm trial, Weisskopf, was
`
`relied upon in any of the IPR petitions. The manner in which Weisskopf and other
`
`prior art references were applied against the challenged claims was determined
`
`independent of Qualcomm. As matter of fact, two independent expert declarations
`
`were prepared by Dr. Asad Abidi supporting the IPR petitions.
`
`(6)
`
`I understand that counsel for the patentee, ParkerVision Inc., has
`
`suggested that there may be some connection between my participation in the IPR
`
`petitions and a licensing agreement executed between Qualcomm and my former
`
`company Rambus Inc. ("Rambus"). To the best of my knowledge, there is no
`
`connection whatsoever.
`
`I was a co-founder of Rambus but am no longer employed
`
`by them either as an employee or a consultant and I ceased being a member of the
`
`Board of Rambus in May 2013.
`
`I was generally aware of the licensing
`
`negotiations between Rambus and Qualcomm, which had been ongoing for a long
`
`time, but I had no personal involvement in those negotiations. As a courtesy, I
`
`informed the General Counsel of Rambus of my participation in the IPR petitions
`
`shortly before the actual filing of the petitions. However, there was never any
`
`discussion or even hint that the IPR petitions would or could influence the deal
`
`between Rambus and Qualcomm.
`
`Farmwald and RPX Exhibit 1049, pg. 3
`Farmwald and RPX v. ParkerVision
`IPR2014-00948
`
`
`
`(7)
`
`On or about November 9, 2013 I met with representatives of
`
`Qualcomm and informed them of my intent to pursue IPR petitions against
`
`ParkerVision patents. At that meeting I inquired whether Qualcomm's contractual
`
`relations with their technical expert used at trial, Dr. Behzad Razavi, would prevent
`
`me from potentially using Dr. Razavi to support the IPR petitions. I was
`
`subsequently informed that Qualcomm objected to Dr. Razavi serving in such a
`
`role. Other than the communications related to that meeting, I had no other
`
`communications with Qualcomm regarding the IPR petitions.
`
`(8)
`
`On or about December 9, 2013,1 retained the Law Office of James T.
`
`Bailey for the purposes of preparing and prosecuting the petitions and on or about
`
`March 26, 2014 I retained the law firm of Obion, Spivak McClelland, Maier &
`
`Neustadt, LLP for the same purpose. I personally paid all fees and expenses
`
`related to the preparation of the IPR petitions up until on or about March 21, 2014,
`
`after which those costs where shared with RPX Corporation.
`
`(9)
`
`In signing this declaration, I understand that the declaration will be
`
`filed as evidence in a contested case before the Patent Trial and Appeal Board of
`
`the United States Patent and Trademark Office. I acknowledge that I may be
`
`subject to cross examination in the case and that cross examination will take place
`
`within the United States. If and to the extent cross examination is legally required
`
`Farmwald and RPX Exhibit 1049, pg. 4
`Farmwald and RPX v. ParkerVision
`IPR2014-00948
`
`
`
`of me, I will appear for such cross examination within the United States during the
`
`time allotted for such cross examination.
`
`Farmwald and RPX Exhibit 1049, pg. 5
`Farmwald and RPX v. ParkerVision
`IPR2014-00948
`
`
`
`(10)
`
`I hereby declare that all statements made herein of my own
`
`knowledge are true and that all statements made on information and belief are
`
`believed to be true; and further that these statements were made with the
`
`knowledge that willful false statements and the like so made are punishable by fine
`
`or imprisonment, or both, under Section 1001 of Title 18 of the United States Code
`
`and that such willful false statements may jeopardize the results of these
`
`proceedings.
`
`Date: 55/£o/^*/^
`
`Dr. Michael Farmwald
`
`Farmwald and RPX Exhibit 1049, pg. 6
`Farmwald and RPX v. ParkerVision
`IPR2014-00948
`
`
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