`
`In the Inter Partes Review of:
`
`Trial Number: To Be Assigned
`
`U.S. Patent No. 6,978,346
`
`Filed:
`
`December 29, 2000
`
`Issued: December 20, 2005
`
`Inventor(s): Sung-Hoon Baek, Joon-
`Bae Kim, Yong-Youn Kim
`
`Assignee: Electronics and
`Telecommunications Research Institute
`
`Title: Apparatus For Redundant
`Interconnection Between Multiple Hosts
`And RAID
`
`Mail Stop Inter Partes Review
`Commissions for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`Panel: To Be Assigned
`
`DECLARATION OF TODD M. FRIEDMAN
`
`IBM-Oracle 1003
`Page 1 of 3
`
`
`
`I, Todd M. Friedman, do hereby declare as follows:
`
`I am an attorney at the law firm of Kirkland & Ellis LLP, 601 Lexington
`
`Avenue, New York, New York 10022, and serve as counsel for Petitioners
`
`International Business Machines Corporation ("IBM") and Oracle America,
`
`Inc. ("Oracle"). I submit this declaration in support of IBM and Oracle’s
`
`Petition for Inter Partes Review Under 37 C.F.R. § 42.100 of U.S. Patent
`
`No. 6,978,346 ("Petition"). I am over twenty-one years of age and not under
`
`any legal disability. I have personal knowledge of the following facts and, if
`
`called as a witness, could and would testify competently thereto.
`
`Attached hereto as Exhibit 1004 is a true and correct copy of U.S. Pat. No.
`
`6,978,346 ("the ’346 Patent").
`
`Attached hereto as Exhibit 1005 is a true and correct copy of U.S. Pat. No.
`
`6,070,251 to Chong ("Chong US").
`
`Attached hereto as Exhibit 1006 is a true and correct copy of Japanese Pat.
`
`No. JPH11120092A to Chong ("Chong JP").
`
`Attached hereto as Exhibit 1007 is a true and correct copy of a certified
`
`translation of Chong JP.
`
`Attached hereto as Exhibit 1008 is a true a correct copy of selected excerpts
`
`from the Prosecution History of the ’346 patent, U.S. Appl. No. 09/753,245.
`
`o
`
`o
`
`o
`
`o
`
`°
`
`IBM-Oracle 1003
`Page 2 of 3
`
`
`
`7.
`
`I hereby declare under penalty of perjury under the laws of the United States
`
`of America that the foregoing is true and correct, and that all statements
`
`made of my own knowledge are true and that all statements made on
`
`information and belief are believed to be true. I understand that willful false
`
`statements are punishable by fine or imprisonment or both.
`
`See 18 U.S.C.
`
`§ 1001.
`
`Date: June 18,
`
`2014
`
`Respectfully submitted,
`
`/s/Todd M. Friedman
`Todd M. Friedman
`Reg. No. 42,559
`todd.friedman@kirkland.com
`Kirkland & Ellis LLP
`601 Lexington Avenue
`New York, NY 10022
`Telephone: (212) 446-4800
`Facsimile: (212) 446-4900
`
`Attorneys for Petitioners International
`Business Machines Corporation and
`Oracle America, Inc.
`
`2
`
`IBM-Oracle 1003
`Page 3 of 3
`
`
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