`Samsung v. Affinity
`IPR2014-01181
`Page 00001
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`IPR20l 4-0] 181
`U.S. Patent No. 8,532,641 B2
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`Attorney Docket No.
`110797—O004~655
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`2.
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`I provide this Declaration in connection with the above—identified Inter
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`Partes Review proceeding and Petitioners’ Reply to Patent Owner Affinity
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`Labs of Texas, LLC’s Response. Unless otherwise stated, the facts stated in
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`this Declaration are based on my personal knowledge.
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`. Exhibit 1030 hereto is a true and correct copy of an article entitled
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`“Compatibility of FM Hybrid In-Band On—Channel (IBOC) System for
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`Digital Audio Broadcasting,” by Brian Kroeger and Paul Peyla, published by
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`IEEE Transactions on Broadcasting in December 1997, which was
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`downloaded from the IEEE official website,
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`http://ieeexpilore.ieee.org/xpl/login.j sp‘?tp=&arnumber=664025&ui%3
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`A%2F%2Fieeexplore.ieee.org%2Fiel3%2Fl l%2F14549%2F00664025_.pgl_f
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`%3Farnumber%3D664025. Page numbers and an exhibit label have been
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`added to the bottom of this document but no other alterations have been
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`made.
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`. Exhibit 1032 hereto is a true and correct copy of an excerpt from “Principles
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`of Digital Audio, Fourth Edition” by Ken C. Pohlmann, published by
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`McGraw—Hill, with a copyright date of 2000, which was retrieved from the
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`Library of Congress at my request. This document has been marked with an
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`exhibit label and page numbers on each page at the bottom right corner.
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`Page 00002
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`IPR2014—01 181
`U.S. Patent No. 8,532,641 B2
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`Attorney Docket No.
`_ 110797-0004-655
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`However, no alterations, other than these noted markings, have been made to
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`this document.
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`. Exhibit1033 hereto is a true and correct copy of the definition for “CD-
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`Quality” from the Oxford English Dictionary (“www.oed.com”), that I
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`retrieved on August 28, 2015. This document has been marked with an
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`exhibit label and page numbers on each page at the bottom right corner.
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`However, no alterations, other than these noted markings, have been made to
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`this document.
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`. Exhibit 1034 hereto is a true and correct copy of an article entitled “A DSP
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`Powered Solid State Audio System,” by Jason Kridner et al., published by
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`IEEE International Conference on Acoustics, Speech, and Signal Processing
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`in 1999, which was downloaded from the IEEE official website,
`
`http://ieeexplore.ieee.org/xpl/logiggj sp?tp:&arnumber=758393&url=http%3
`
`A%2F%2Fieeexplore.ieee.o1:g%2Fxpls%2Fab§___alljsp%3Farnumber%3D75
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`8393. Page numbers and an exhibit label have been added to the bottom of
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`this document but no other alterations have been made.
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`. Attached as Exhibit 1035 is a true and correct copy of an article entitled
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`“Intellectual Property Protection Systems and Digital Watermarking,” by
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`Jack Lacy et al., published in Optics Express Vol. 3, No. 12 on December 7,
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`1998, which was downloaded from the Optical Society website,
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`Page 00003
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`IPR2014-01 181
`U.S. Patent No. 8,532,641 B2
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`Attorney Docket No.
`110797-0004-655
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`hwttps://www.osa,publishing.org/oe/tulltext.cfm?uri=oe-3-12-478&id=63348.
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`Page numbers and an exhibit label have been added to the bottom of this
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`document but no other alterations have been made.
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`.4 Exhibit 1040 hereto is a true and correct copy of a document titled
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`“BluetoothW Whitepaper,” by AU-System, dated January 2000, which was
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`downloaded from
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`www.roggewecknet/ugloads/media/Bluetooth Handougp_df. Page numbers
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`and an exhibit label have been added to the bottom of this document but no
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`other alterations have been made.
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`. Exhibit 1042 hereto is a true and correct copy of an article entitled “Ericsson
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`Demonstrates Bluetooth at CeBIT ’99 [March 18],” by the Mobile Internet
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`Community, dated March 1999, which was downloaded from the Mobile
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`Internet Community’s website,
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`http://www.mobic.com/oldnews/9903/ericsson__demonstrates_bluetooth .ht
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`m, on August 28, 2015. Page numbers and an exhibit label have been added
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`to the bottom of this document but no other alterations have been made.
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`10.Exhibit 1044 hereto is a true and correct copy of an article entitled “CTIA
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`Wireless 2000 View From The Floor — Day 2,” by Wireless Developer
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`Network, which was downloaded from the Wireless Developer Network
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`website,
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`Page 00004
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`lPR2014—01 181
`US. Patent No. 8,532,641 B2
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`Attorney Docket No.
`l10797—0004—655
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`httpI//www.wirelessdeVnet.com/channeIs/wireless/features/ctia 2.html, on
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`August 28, 2015. Page numbers and an exhibit label have been added to the
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`bottom of this document but no other alterations have been made.
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`1 1.Exhibit 1047 hereto is a true and correct copy of “Bluetooth Protocol
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`Architecture Version 1.0,” published by the Bluetooth SIG and dated 1999,
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`which was downloaded from http2//srohittripod.com/bluetooth sec.pdf.
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`Page numbers and an exhibit label have been added to the bottom of this
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`document but no other alterations have been made.
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`12.Exhibit 1052 hereto is a true and correct copy of an article entitled “NTT
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`DoCoMo To Offer Mobile Music Downloads,” by William Auckerman,
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`published by lnternetNews.co1n on October 8, 1999, which was downloaded
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`from the IntemetNews.com website, httpfiwww.ir1ternetnews.com/ec-
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`news/articlephp/214471/NTT+'DoCoMo+To+Offer+Mo, on August 28,
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`201 5. Page numbers and an exhibit label have been added to the bottom of
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`this document but no other alterations have been made.
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`l3.Exhibit 1053 hereto is a true and correct copy of an article entitled “Sony
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`and Liquid Audio Integrate Internet Music Delivery Systems,” published by
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`Sony on January 6, 2000, which was downloaded from the Sony website,
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`http://www.sony.net/Sonylnfo/News/Press Archive/200001/00-01 1 1B/, on
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`Page 00005
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`IPR2014-01 181
`U.S. Patent No. 8,532,641 B2
`
`Attorney Docket No.
`1 lO797—0004—655
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`August 28, 2015. Page numbers and an exhibit label have been added to the
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`bottom of this document but no other alterations have been made.
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`14. I make this declaration of my own personal knowledge. If called to testify
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`as to the truth of the matters stated herein, I could and would testify
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`competently.
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`15.1 declare under penalty of perj ury that the foregoing is true and correct.
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`Executed this 31“ day of August, 2015, at New York, New York.
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`Richard Moncrief
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`Page 00006