`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.
`
`Petitioner
`
`V.
`
`CONTENTGUARD HOLDINGS, INC.
`Patent Owner
`
`Patent No. 7,774,280
`Issued: August 10, 2010
`Filed: October 4, 2004
`
`Inventors: Nguyen, er al.
`Title: System and Method for Managing Transfer of Rights Using Shared
`State Variables
`
`Inter Partes Review No. IPR 2015-00354
`
`DECLARATION OF JACKELINE TORRES IN SUPPORT OF
`
`CONTENTGUARD HOLDINGS, INC.’S
`
`UNOPPOSED MOTION TO CORRECT FILING DATE OF PATENT
`
`OWNER’S PRELIMINARY RESPONSE
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`
`P.O. Box 1450
`
`Alexandria, Virginia 22313-1450
`
`Patent Owner ContentGuard, Inc. - Exhibit 2029, p. 1
`
`Patent Owner ContentGuard, Inc. - Exhibit 2029, p. 1
`
`
`
`I, J ackeline Torres, declare:
`
`1.
`
`I am a legal assistant at the law firm of Fitch, Even, Tabin & Flannery
`
`LLP.
`
`I make this declaration in support of ContentGuard Holdings,
`
`Inc.’s
`
`Unopposed Motion to Correct Filing Date of Patent Owner’s Preliminary Response
`
`based on my own personal knowledge. If called as a witness, I could and would
`
`testify competently to the facts in this declaration.
`
`2.
`
`I have electronically filed several papers using the Patent Review
`
`Processing System (“PRPS”) and I am well versed in uploading and submitting
`
`documents to PRPS.
`
`3.
`
`On April 6, 2015,
`
`I was directed to file six separate Preliminary
`
`Responses on behalf of ContentGuard Holdings, Inc. (“CG”),
`
`including CG’s
`
`Preliminary Response and supporting exhibits
`
`for
`
`IPR20l5—O0354.
`
`I was
`
`authorized to file using the e—filing credentials of lead counsel, Timothy P.
`
`Maloney.
`
`4.
`
`At the time I began to file CG’s Preliminary response for IPR20l5-
`
`00354, I had already electronically submitted five of the six Preliminary Responses
`
`due on April 6.
`
`I completed the submission of the fifth Preliminary Response
`
`(CBM20l5—0OO40) by 11:55 p.m. Eastern Time,
`
`as
`
`shown on the “My
`
`Correspondence” section of Mr. Maloney’s PTAB Trials Portal webpage. A true
`
`and correct copy of the “My Correspondence” section of Mr. Maloney’s PTAB
`
`Patent Owner ContentGuard, Inc. - Exhibit 2029, p. 2
`
`Patent Owner ContentGuard, Inc. - Exhibit 2029, p. 2
`
`
`
`Trials Portal webpage is attached as Exhibit 2030.
`
`5.
`
`At the time of making the fifth filing, I also had on my computer the
`
`electronic files for the sixth and final filing that evening, CG’s Preliminary
`
`Response
`
`and supporting exhibits
`
`for
`
`IPR20l5-00354.
`
`Immediately after
`
`completing the fifth filing,
`
`I
`
`turned my attention to the sixth filing. At
`
`approximately 11:56 p.m. Eastern Time on April 6,
`
`I began uploading CG’s
`
`Preliminary Response using PRPS. After the Preliminary Response was uploaded,
`
`I proceeded to upload each of the eight exhibits, Exhibits 2001-2008.
`
`(The
`
`Preliminary Response and Exhibits 2001-2008 are collectively referred to as the
`
`“Response.”) After PRPS completed its upload of each file, it displayed an active
`
`link for each file, indicating to me that the file had been successfully uploaded.
`
`6.
`
`At approximately 11:58 p.m. Eastern Time, the links for all of these
`
`files were displayed,
`
`indicating to me that all had been successfully uploaded.
`
`Having completed the upload process, I clicked on the “Submit” button. I believe
`
`that I did so by 1 1:58 p.m., and certainly no later than 11:59 pm. Eastern Time.
`
`7.
`
`After I clicked the “Submit” button, PRPS displayed a progress wheel,
`
`indicating that the submission of the uploaded documents was in progress. The
`
`progress wheel rotated for approximately 1-2 minutes, after which time PRPS
`
`displayed a Party Filing Notice. The Party Filing Notice indicated that
`
`the
`
`Response had been accorded a filing date of April 7, 2015. A true and correct copy
`
`Patent Owner ContentGuard, Inc. - Exhibit 2029, p. 3
`
`Patent Owner ContentGuard, Inc. - Exhibit 2029, p. 3
`
`
`
`of the Party Filing Notice is attached as Exhibit 2031.
`
`8.
`
`To investigate the timing of the filing,
`
`I
`
`accessed the “My
`
`Correspondence” section on Mr. Maloney’s PTAB Trials Portal account. The My
`
`Correspondence section indicated that Response was dated April 7, 2015, at
`
`12:00 a.m. (Ex. 2030.)
`
`I declare under penalty of perjury that the foregoing is true and correct, and
`
`that this declaration was executed in Chicago, Illinois on April 16, 2015.
`
`Dated: April 16, 2015
`
`Patent Owner ContentGuard, Inc. - Exhibit 2029, p. 4
`
`Patent Owner ContentGuard, Inc. - Exhibit 2029, p. 4
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