`
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________________
`
`
`
`
`
`
`
`GLOBAL TEL*LINK CORPORATION
`Petitioner
`
`v.
`
`SECURUS TECHNOLOGIES, INC.
`Patent Owner
`
`___________________
`
`IPR2015-01219 (U.S. Patent No. 8,626,118)
`___________________
`
`
`
`DECLARATION OF BRIAN D. OLIVER
`
`Mail Stop “Patent Board”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`GTL 1024
`GTL v. Securus
`IPR2015-01219
`
`
`
`
`
`I, Brian D. Oliver, hereby declare and state:
`
`1.
`
`I am the Chief Executive Officer of Global Tel*Link Corporation
`
`(“GTL”).
`
`2.
`
`GTL is governed by a Board of Directors, including several members
`
`who are also employees of American Securities.
`
`3.
`
`In my position as CEO, I have participated in negotiations related to
`
`disputes between Securus Technologies, Inc. (“Securus”) and GTL.
`
`4.
`
`I reviewed Mr. Smith’s and Mr. Reinhold’s Declarations which
`
`purport to discuss settlement discussions or negotiations that occurred in
`
`September 2013 and April 2014. (Ex. 2006, 2011.) The statements contained in
`
`those Declarations do not accurately reflect our discussions and improperly
`
`disclose confidential settlement negotiations that the parties had agreed to keep
`
`confidential pursuant to Federal Rules of Evidence Rule 408.
`
`5.
`
`Any settlement offers must be reviewed and ratified by GTL’s Board
`
`of Directors. Although I do not recall the exact phrasing I used in the two meetings
`
`referenced by Mr. Smith and Mr. Reinhold, I have no authority to reach an
`
`agreement, and therefore, I believe that I communicated to them that any
`
`settlement offers had to be reviewed and approved by GTL’s Board. At no time did
`
`I ever state that any settlement offers had to be reviewed and approved by
`
`American Securities Board.
`
`
`
`- 1 -
`
`
`
`6.
`
`I hereby declare that all statements made herein of my own
`
`knowledge are true and that all statements made on information and belief are
`
`believed to be true; and further that these statements were made with the
`
`knowledge that willful false statements and the like so made are punishable by fine
`
`or imprisonment, or both, under Section 1001 of Title 18 of the United States
`
`Code.
`
`
`
`Dated: ______________
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`_________________
`
` Brian D. Oliver
`
`- 2 -
`
`
`
`
`
`
`
`
`
`1, Brian D. Oliver, hereby declare and state:
`
`1.
`
`I am the Chief Executive Officer of Global Tel*Link Corporation
`
`(GCGTI-I9!) .
`
`2.
`
`GTL is governed by a Board of Directors, including several members
`
`who are also employees of American Securities.
`
`3.
`
`In my position as CEO, I have participated in negotiations related to
`
`disputes between Securus Technologies, Inc. (“Securus”) and GTL.
`
`4.
`
`I reviewed Mr. Smith’s and Mr. Reinhold’s Declarations which
`
`purport to discuss settlement discussions or negotiations that occurred in
`
`September 2013 and April 2014. (Ex. 2006, 2011.) The statements contained in
`
`those Declarations do not accurately reflect our discussions and improperly
`
`disclose confidential settlement negotiations that the parties had agreed to keep
`
`confidential pursuant to Federal Rules of Evidence Rule 408.
`
`5.
`
`Any settlement offers must be reviewed and ratified by GTL’s Board
`
`of Directors. Although I do not recall the exact phrasing I used in the two meetings
`
`referenced by Mr. Smith and Mr. Reinhold, I have no authority to reach an
`
`agreement, and therefore, I believe that I communicated to them that any
`
`settlement offers had to be reviewed and approved by GTL’s Board. At no time did
`
`I ever state that any settlement offers had to be reviewed and approved by
`
`American Securities Board.
`
`
`
`6.
`
`I hereby declare that all statements made herein of my own
`
`knowledge are true and that all statements made on information and belief are
`
`believed to be true; and further that these statements were made with the
`
`knowledge that willful false statements and the like so made are punishable by fine
`
`or imprisonment, or both, under Section 1001 of Title 18 of the United States
`
`Code.
`
`Dated: %i 351i ‘bf
`
`'<§_~.;<J, 04;.
`
`Brian D. Oliver
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