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`IPR2014-01181
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` 110797-0004-655
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`U.S. Patent No. 8,532,641 B2
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
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`SAMSUNG ELECTRONICS CO., LTD and SAMSUNG ELECTRONICS
`AMERICA, INC.,
`Petitioners
`
`v.
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`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.
`
`
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`DECLARATION OF HAYAN YOON
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`I, Hayan Yoon, make the following Declaration pursuant to 28 U.S.C. §1746:
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`1. I am an attorney at the law firm of Ropes & Gray LLP.
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`*Case Nos. IPR2014-01182 and IPR2014-01184 have been consolidated with the
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`instant proceeding. See IPR2014-01181, Paper 15; IPR2014-01182, Paper 15; and
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`IPR2014-01184, Paper 15.
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`- 1 -
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`Samsung Exhibit 1061
`Samsung v. Affinity
`IPR2014-01181
`Page 00001
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` Attorney Docket No.
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`IPR2014-01181
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`U.S. Patent No. 8,532,641 B2
`2. 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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`3. Exhibit 1026 hereto is a true and correct copy of an excerpt from “Microsoft
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`Computer Dictionary, Fourth Edition,” published by Microsoft Press, and
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`dated 1999. This document has been marked with an exhibit label and page
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`numbers on each page at the bottom right corner. However, no alterations,
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`other than these noted markings, have been made to this document.
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`4. Exhibit 1027 hereto is a true and correct copy of European Patent
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`Application Publication No. EP 1675309 filed by Gorman, which was
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`downloaded from the European Patent Office (“EPO”) Espacenet website
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`and which is a record of the EPO to which all parties have access. This
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`document has been marked with an exhibit label and page numbers on each
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`page at the bottom right corner. However, no alterations, other than these
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`noted markings, have been made to this document.
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`5. Exhibit 1028 hereto is a true and correct copy of an excerpt from “Webster’s
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`II New College Dictionary,” published by the Houghton Mifflin Company
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`and dated 1995. This document has been marked with an exhibit label and
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`page numbers on each page at the bottom right corner. However, no
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`Page 00002
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` Attorney Docket No.
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`IPR2014-01181
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`U.S. Patent No. 8,532,641 B2
`alterations, other than these noted markings, have been made to this
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`document.
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`6. Exhibit 1029 hereto is a true and correct copy of an excerpt from
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`“Dictionary of Computing, Fourth Edition” published by the Oxford
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`University Press and dated 1997. 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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`7. Exhibit 1036 hereto is a true and correct copy of an excerpt from “Merriam-
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`Webster’s Collegiate Dictionary, Tenth Edition” published by Merriam-
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`Webster, Inc. and dated 1997. 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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`8. Exhibit 1037 hereto is a true and correct copy of United States Patent No.
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`6,633,932 to Bork et al., which was downloaded from the USPTO PAIR
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`website and which is a record of the USPTO to which all parties have access.
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`This document has been marked with an exhibit label and page numbers on
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`each page at the bottom right corner. However, no alterations, other than
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`these noted markings, have been made to this document.
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`U.S. Patent No. 8,532,641 B2
`9. Exhibit 1050 hereto is a true and correct copy of United States Patent No.
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`5,884,269 to Cellier, which was downloaded from the USPTO PAIR website
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`and which is a record of the USPTO to which all parties have access. This
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`document has been marked with an exhibit label and page numbers on each
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`page at the bottom right corner. However, no alterations, other than these
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`noted markings, have been made to this document.
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`10. Exhibit 1051 hereto is a true and correct copy of an excerpt from
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`“Comprehensive Dictionary of Electrical Engineering,” published by the
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`CRC Press and IEEE Press and dated 1999. This document has been marked
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`with an exhibit label and page numbers on each page at the bottom right
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`corner. However, no alterations, other than these noted markings, have been
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`made to this document.
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`11. Exhibit 1055 hereto is a true and correct copy of the file history of
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`Reexamination Control No. 90/011,982 (ex parte reexamination of U.S.
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`Patent No. 7,634,228) from February 14, 2013 until June 10, 2014, which
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`was downloaded from the USPTO PAIR website and which is a record of
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`the USPTO to which all parties have access. This document has been
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`marked with an exhibit label and page numbers on each page at the bottom
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`right corner. However, no alterations, other than these noted markings, have
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`been made to this document.
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` Attorney Docket No.
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`IPR2014-01181
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`U.S. Patent No. 8,532,641 B2
`12. Exhibit 1056 hereto is a true and correct copy of the Non-Final Action
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`issued on June 14, 2010 in Reexamination Control Nos. 90/010,333,
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`95/001,223 and 95/001,264 (Ex Parte and Inter Partes Reexaminations of
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`U.S. Patent No. 7,324,833), which was downloaded from the USPTO PAIR
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`website and which is a record of the USPTO to which all parties have access.
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`This document has been marked with an exhibit label and page numbers on
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`each page at the bottom right corner. However, no alterations, other than
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`these noted markings, have been made to this document.
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`13. Exhibit 1058 hereto is a true and correct copy of United States Patent No.
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`6,928,468 to Leermakers, which was downloaded from the USPTO PAIR
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`website and which is a record of the USPTO to which all parties have access.
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`This document has been marked with an exhibit label and page numbers on
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`each page at the bottom right corner. However, no alterations, other than
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`these noted markings, have been made to this document.
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`14. Exhibit 1059 hereto is a true and correct copy of Exhibit 2008 in IPR2014-
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`00209 (Universal Serial Bus Specification, Revision 2.0, April 27, 2000,
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`Compaq, Hewlett-Packard, Intel, Lucent, Microsoft, NEC, Philips), which
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`was downloaded from the USPTO PTAB Trials website and which is a
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`record of the USPTO to which all parties have access. This document has
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`been marked with an exhibit label and page numbers on each page at the
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`Page 00005
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`IPR2014-01 181
`US. Patent No. 8,532,641 B2
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`Attorney Docket No.
`110797—0004—655
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`bottom right corner. However, no alterations, other than these noted
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`markings, have been made to this document.
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`15. 1 make this declaration of my own personal knowledge. If called to testify
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`as to the truth ofthe matters stated herein, 1 could and would testify
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`competently.
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`16.] declare under penalty of perjury that the foregoing is true and correct.
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`Executed this 315‘ day of August, 2015, at East Palo Alto, California.
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`’47'w,~«-\;-- _
`
`Hayan Yoon
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`Page 00006