throbber
Inter Partes Review
`United States Patent No. 8,532,641
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`§ Attorney Docket No.:
`United States Patent No.: 8,532,641
`§
`110797-0004-658
`Inventors: Russell W. White,
`§ Customer No. 28120
`Kevin R. Imes
`Formerly Application No.: 13/673,391 § Petitioners:
`Issue Date: Sept. 10, 2013
`§
`Samsung Electronics Co., Ltd.;
`Filing Date: Nov. 9, 2012
`§
`Samsung Electronics America, Inc.
`Priority Date: March 28, 2000
`§
`
`
`§
`Former Group Art Unit: 2646
`§
`Former Examiner: Erika Washington
`§
`
`§
`
`§
`
`For: SYSTEM AND METHOD FOR MANAGING MEDIA
`
`MAIL STOP PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`Post Office Box 1450
`Alexandria, Virginia 22313-1450
`
`
`
`
`
`
`
`
`
`
`DECLARATION OF HAYAN YOON IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW OF
`UNITED STATES PATENT NO. 8,532,641
`
`I, Hayan Yoon, make the following Declaration pursuant to 28 U.S.C. § 1746:
`
`1.
`
`2.
`
`I am an attorney at the law firm of Ropes & Gray LLP.
`
`I provide this Declaration in connection with the above-identified Inter
`
`Partes Review proceeding that is being requested at the United States Patent and
`
`Trademark Office (“USPTO”) by the above-identified petitioners under 35 U.S.C. §§
`
`311-319 and 37 C.F.R. § 42. Unless otherwise stated, the facts stated in this
`
`Declaration are based on my personal knowledge.
`
`
`
`- 1 -
`
`Samsung Ex. 1334 p. 1
`
`

`

`3.
`
`Exhibit 1301 hereto is a true and correct copy of United States Patent
`
`No. 8,532,641 to White et al., which was downloaded from the USPTO Patent
`
`Application Information Retrieval (“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.
`
`Exhibit 1302 hereto is a true and correct copy of the file history for
`
`United States Patent No. 8,532,641 to White 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.
`
`5.
`
`Exhibit 1303 hereto is a true and correct copy of United States Patent
`
`Publication No. 2006/0262103 filed by Hu 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.
`
`6.
`
`Exhibit 1304 hereto is a true and correct copy of the file history for
`
`United States Application No. 11/438,016 filed by Hu et al., which was downloaded
`
`
`
`- 2 -
`
`Samsung Ex. 1334 p. 2
`
`

`

`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.
`
`7.
`
`Exhibit 1305 hereto is a true and correct copy of United States Patent
`
`Publication No. 2004/0214525 filed by Ahn 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.
`
`8.
`
`Exhibit 1306 hereto is a true and correct copy of International
`
`Publication No. WO 02/096137 filed by Ahn et al., which was downloaded from the
`
`World Intellectual Property Organization (“WIPO”) PatentScope website and which
`
`is a record of the WIPO 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.
`
`9.
`
`Exhibit 1309 hereto is a true and correct copy of United States Patent
`
`No. 6,845,398 to Galensky 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
`
`
`
`- 3 -
`
`Samsung Ex. 1334 p. 3
`
`

`

`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 1311 hereto is a true and correct copy of the file history for
`
`United States Patent No. 7,953,390 to White 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.
`
`11. Exhibit 1312 hereto is a true and correct copy of the Institution
`
`Decision dated May 20, 2014 in Case IPR 2014-00209 (Inter Partes Review of U.S.
`
`Patent No. 7,953,390), which was downloaded from the USPTO Patent Review
`
`Processing System (“PRPS”) 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.
`
`12. Exhibit 1313 hereto is a true and correct copy of the Institution
`
`Decision dated May 20, 2014 in Case IPR 2014-00212 (Inter Partes Review of U.S.
`
`Patent No. 7,953,390), which was downloaded from the USPTO PRPS website and
`
`which is a record of the USPTO to which all parties have access. This document has
`
`
`
`- 4 -
`
`Samsung Ex. 1334 p. 4
`
`

`

`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 1314 hereto is a true and correct copy of the Action Closing
`
`Prosecution issued on June 12, 2014 in Reexamination Control Nos. 95/001,262 and
`
`90/011,254 (inter partes and ex parte reexaminations of U.S. Patent No. 7,187,947),
`
`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 1315 hereto is a true and correct copy of the Patent Trial and
`
`Appeal Board decision dated June 30, 2014 in Appeal No. 2014-002024 and the
`
`Action Closing Prosecution dated August 18, 2011 in Reexamination Control No.
`
`95/001,281 (inter partes reexamination of U.S. Patent No. 7,634,228), 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.
`
`15. Exhibit 1316 hereto is a true and correct copy of a document titled
`
`“Specification of the Bluetooth System v1.0 B, Vols. 1 & 2” by Telefonaktiebolaget
`
`
`
`- 5 -
`
`Samsung Ex. 1334 p. 5
`
`

`

`LM Ericsson et al., dated December 1, 1999, which was submitted by Patent Owner
`
`Affinity Labs of Texas, LLC during prosecution of United States Patent No.
`
`8,532,641 and produced by Affinity Labs of Texas, LLC in Affinity Labs of Texas, LLC
`
`v. Samsung Electronics Co., Ltd et al., No. 3:14-cv-3030 (NDCA), marked with bates
`
`numbers AFFLT0293229-AFFLT0294750. This document has been additionally
`
`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.
`
`16. Exhibit 1317 hereto is a true and correct copy of the Institution
`
`Decision dated February 12, 2013 in Case CBM2012-00003, which was downloaded
`
`from the USPTO PRPS 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.
`
`17. Exhibit 1318 hereto is a true and correct copy of the file history for
`
`United States Patent No. 7,187,947 to White 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.
`
`
`
`- 6 -
`
`Samsung Ex. 1334 p. 6
`
`

`

`18. Exhibit 1319 hereto is a true and correct copy of the file history for
`
`United States Patent No. 7,324,833 to White 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.
`
`19. Exhibit 1320 hereto is a true and correct copy of the file history for
`
`United States Patent No. 7,778,595 to White 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.
`
`20. Exhibit 1321 hereto is a true and correct copy of the file history of
`
`Reexamination Control No. 95/001,263 (inter partes reexamination of U.S. Patent No.
`
`7,486,926) from December 6, 2011 until April 11, 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.
`
`
`
`- 7 -
`
`Samsung Ex. 1334 p. 7
`
`

`

`21. Exhibit 1322 hereto is a true and correct copy of an excerpt from “IBM
`
`DICTIONARY OF COMPUTING,” compiled and edited by George McDaniel,
`
`published by McGraw-Hill Inc., and dated 1994. 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.
`
`22. Exhibit 1323 hereto is a true and correct copy of the Institution
`
`Decision dated Jan. 30, 2015 in Case IPR2014-01184 (Inter Partes Review of U.S.
`
`Patent No. 8,532,641), which was downloaded from the USPTO PRPS 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.
`
`23. Exhibit 1324 hereto is a true and correct copy of the Institution
`
`Decision dated Jan. 30, 2015 in Case IPR2014-01181 (Inter Partes Review of U.S.
`
`Patent No. 8,532,641), which was downloaded from the USPTO PRPS 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.
`
`
`
`- 8 -
`
`Samsung Ex. 1334 p. 8
`
`

`

`24. Exhibit 1325 hereto is a true and correct copy of the Institution
`
`Decision dated Jan. 30, 2015 in Case IPR2014-01182 (Inter Partes Review of U.S.
`
`Patent No. 8,532,641), which was downloaded from the USPTO PRPS 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.
`
`25. Exhibit 1326 hereto is a true and correct copy of the Nokia “After Sales
`
`Technical Documentation RAE/RAK-1N Series CARK Installation Guide,” dated
`
`August
`
`1996
`
`and
`
`downloaded
`
`from
`
`http://www.shema.ru/cd/mob/2/data/nokia%209000i.pdf on February 26, 2015.
`
`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.
`
`26. Exhibit 1327 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.
`
`
`
`- 9 -
`
`Samsung Ex. 1334 p. 9
`
`

`

`27. Exhibit 1328 hereto is a true and correct copy of the web page of
`
`http://tech-insider.org/mobile/research/1997/0910-b.html, titled “Nokia 9000i and
`
`9000il,” dated 1998 and accessed on February 26, 2015. 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.
`
`28. Exhibit 1329 hereto is a true and correct copy of United States Patent
`
`No. 6,211,649 to Matsuda, 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.
`
`
`
`29. Exhibit 1330 hereto is a true and correct copy of a manual for the
`
`Motorola RAZR V3i GSM wireless phone, titled “Motomanual RAZR V3i GSM,”
`
`dated
`
`2006
`
`and
`
`downloaded
`
`from
`
`http://www.motorola.com/mdirect/manuals/V3i_9504A48O.pdf, on February 25,
`
`2015. 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 -
`
`Samsung Ex. 1334 p. 10
`
`

`

`30. Exhibit 1331 hereto is a true and correct copy of a printed version of the
`
`archived web page of http://www.gsmarena.com/motorola_razr_v3i-1352.php
`
`accessed through the December 20, 2005 archive of http://web.archive.org,
`
`specifically,
`
`https://web.archive.org/web/20051220091300/http://www.gsmarena.com/motorol
`
`a_razr_v3i-1352.php, on February 24, 2015. This document refers to “Motorola
`
`RAZR V3i – Full Phone Specifications.” 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.
`
`31. Exhibit 1332 hereto is a true and correct copy of United States Patent
`
`No. 7,123,936 to Rydbeck, 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.
`
`32.
`
`I make this declaration of my own personal knowledge. If called to
`
`testify as to the truth of the matters stated herein, I could and would testify
`
`competently.
`
`33.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`
`
`- 11 -
`
`Samsung Ex. 1334 p. 11
`
`

`

`Executed this 27rd day of February, 2015 in East Palo Alto, CA.
`
`W H
`
`ayan Yoon
`
`
`
`-12-
`
`Samsung Ex. 1334 p. 12
`
`Samsung Ex. 1334 p. 12
`
`

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