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Attorney Docket No.
`
`
`IPR2014-01181
`
` 110797-0004-655
`
`
`U.S. Patent No. 8,532,641 B2
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`SAMSUNG ELECTRONICS CO., LTD and SAMSUNG ELECTRONICS
`AMERICA, INC.,
`Petitioners
`
`v.
`
`AFFINITY LABS OF TEXAS, LLC
`Patent Owner
`______________
`
`Case IPR2014-01181*
`Patent 8,532,641 B2
`______________
`
`Before the Honorable KEVIN F. TURNER, LYNNE E. PETTIGREW, and
`JON B. TORNQUIST, Administrative Patent Judges.
`
`
`
`DECLARATION OF HAYAN YOON
`
`
`I, Hayan Yoon, make the following Declaration pursuant to 28 U.S.C. §1746:
`
`1. I am an attorney at the law firm of Ropes & Gray LLP.
`
`
`*Case Nos. IPR2014-01182 and IPR2014-01184 have been consolidated with the
`
`instant proceeding. See IPR2014-01181, Paper 15; IPR2014-01182, Paper 15; and
`
`IPR2014-01184, Paper 15.
`
`
`
`- 1 -
`
`Samsung Exhibit 1061
`Samsung v. Affinity
`IPR2014-01181
`Page 00001
`
`

`
` Attorney Docket No.
`
`
`IPR2014-01181
`
` 110797-0004-655
`
`
`U.S. Patent No. 8,532,641 B2
`2. I provide this Declaration in connection with the above-identified Inter
`
`Partes Review proceeding and Petitioners’ Reply to Patent Owner Affinity
`
`Labs of Texas, LLC’s Response. Unless otherwise stated, the facts stated in
`
`this Declaration are based on my personal knowledge.
`
`3. Exhibit 1026 hereto is a true and correct copy of an excerpt from “Microsoft
`
`Computer Dictionary, Fourth Edition,” published by Microsoft Press, and
`
`dated 1999. This document has been marked with an exhibit label and page
`
`numbers on each page at the bottom right corner. However, no alterations,
`
`other than these noted markings, have been made to this document.
`
`4. Exhibit 1027 hereto is a true and correct copy of European Patent
`
`Application Publication No. EP 1675309 filed by Gorman, which was
`
`downloaded from the European Patent Office (“EPO”) Espacenet website
`
`and which is a record of the EPO to which all parties have access. This
`
`document has been marked with an exhibit label and page numbers on each
`
`page at the bottom right corner. However, no alterations, other than these
`
`noted markings, have been made to this document.
`
`5. Exhibit 1028 hereto is a true and correct copy of an excerpt from “Webster’s
`
`II New College Dictionary,” published by the Houghton Mifflin Company
`
`and dated 1995. This document has been marked with an exhibit label and
`
`page numbers on each page at the bottom right corner. However, no
`
`
`
`- 2 -
`
`Page 00002
`
`

`
` Attorney Docket No.
`
`
`IPR2014-01181
`
` 110797-0004-655
`
`
`U.S. Patent No. 8,532,641 B2
`alterations, other than these noted markings, have been made to this
`
`document.
`
`6. Exhibit 1029 hereto is a true and correct copy of an excerpt from
`
`“Dictionary of Computing, Fourth Edition” published by the Oxford
`
`University Press and dated 1997. This document has been marked with an
`
`exhibit label and page numbers on each page at the bottom right corner.
`
`However, no alterations, other than these noted markings, have been made to
`
`this document.
`
`7. Exhibit 1036 hereto is a true and correct copy of an excerpt from “Merriam-
`
`Webster’s Collegiate Dictionary, Tenth Edition” published by Merriam-
`
`Webster, Inc. and dated 1997. This document has been marked with an
`
`exhibit label and page numbers on each page at the bottom right corner.
`
`However, no alterations, other than these noted markings, have been made to
`
`this document.
`
`8. Exhibit 1037 hereto is a true and correct copy of United States Patent No.
`
`6,633,932 to Bork et al., which was downloaded from the USPTO PAIR
`
`website and which is a record of the USPTO to which all parties have access.
`
`This document has been marked with an exhibit label and page numbers on
`
`each page at the bottom right corner. However, no alterations, other than
`
`these noted markings, have been made to this document.
`
`
`
`- 3 -
`
`Page 00003
`
`

`
` Attorney Docket No.
`
`
`IPR2014-01181
`
` 110797-0004-655
`
`
`U.S. Patent No. 8,532,641 B2
`9. Exhibit 1050 hereto is a true and correct copy of United States Patent No.
`
`5,884,269 to Cellier, which was downloaded from the USPTO PAIR website
`
`and which is a record of the USPTO to which all parties have access. This
`
`document has been marked with an exhibit label and page numbers on each
`
`page at the bottom right corner. However, no alterations, other than these
`
`noted markings, have been made to this document.
`
`10. Exhibit 1051 hereto is a true and correct copy of an excerpt from
`
`“Comprehensive Dictionary of Electrical Engineering,” published by the
`
`CRC Press and IEEE Press and dated 1999. This document has been marked
`
`with an exhibit label and page numbers on each page at the bottom right
`
`corner. However, no alterations, other than these noted markings, have been
`
`made to this document.
`
`11. Exhibit 1055 hereto is a true and correct copy of the file history of
`
`Reexamination Control No. 90/011,982 (ex parte reexamination of U.S.
`
`Patent No. 7,634,228) from February 14, 2013 until June 10, 2014, which
`
`was downloaded from the USPTO PAIR website and which is a record of
`
`the USPTO to which all parties have access. This document has been
`
`marked with an exhibit label and page numbers on each page at the bottom
`
`right corner. However, no alterations, other than these noted markings, have
`
`been made to this document.
`
`
`
`- 4 -
`
`Page 00004
`
`

`
` Attorney Docket No.
`
`
`IPR2014-01181
`
` 110797-0004-655
`
`
`U.S. Patent No. 8,532,641 B2
`12. Exhibit 1056 hereto is a true and correct copy of the Non-Final Action
`
`issued on June 14, 2010 in Reexamination Control Nos. 90/010,333,
`
`95/001,223 and 95/001,264 (Ex Parte and Inter Partes Reexaminations of
`
`U.S. Patent No. 7,324,833), which was downloaded from the USPTO PAIR
`
`website and which is a record of the USPTO to which all parties have access.
`
`This document has been marked with an exhibit label and page numbers on
`
`each page at the bottom right corner. However, no alterations, other than
`
`these noted markings, have been made to this document.
`
`13. Exhibit 1058 hereto is a true and correct copy of United States Patent No.
`
`6,928,468 to Leermakers, which was downloaded from the USPTO PAIR
`
`website and which is a record of the USPTO to which all parties have access.
`
`This document has been marked with an exhibit label and page numbers on
`
`each page at the bottom right corner. However, no alterations, other than
`
`these noted markings, have been made to this document.
`
`14. Exhibit 1059 hereto is a true and correct copy of Exhibit 2008 in IPR2014-
`
`00209 (Universal Serial Bus Specification, Revision 2.0, April 27, 2000,
`
`Compaq, Hewlett-Packard, Intel, Lucent, Microsoft, NEC, Philips), which
`
`was downloaded from the USPTO PTAB Trials website and which is a
`
`record of the USPTO to which all parties have access. This document has
`
`been marked with an exhibit label and page numbers on each page at the
`
`
`
`- 5 -
`
`Page 00005
`
`

`
`IPR2014-01 181
`US. Patent No. 8,532,641 B2
`
`Attorney Docket No.
`110797—0004—655
`
`bottom right corner. However, no alterations, other than these noted
`
`markings, have been made to this document.
`
`15. 1 make this declaration of my own personal knowledge. If called to testify
`
`as to the truth ofthe matters stated herein, 1 could and would testify
`
`competently.
`
`16.] declare under penalty of perjury that the foregoing is true and correct.
`
`Executed this 315‘ day of August, 2015, at East Palo Alto, California.
`
`’47'w,~«-\;-- _
`
`Hayan Yoon
`
`Page 00006

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