I, Thom Kidrin, make the following Declaration pursuant to 28 U.S.C. § 1746:
`
`1. I currently reside at 11 Royal Road, Brookline, Massachusetts. I am the
`
`current President and Chief Executive Officer of Worlds, Inc., and have
`
`been so since 1997.
`
`2. I am providing this Declaration in connection with the pending Inter Partes
`
`review proceedings currently instituted against five U.S. Patents owned by
`
`Worlds, Inc.
`
`3. Unless otherwise stated, the facts presented in this Declaration are based on
`
`my personal knowledge.
`
`4. I was the President and Chief Executive Officer of a company that acquired
`
`Worlds, Inc. (formerly Knowledge Adventure Worlds) on December 3,
`
`1997.
`
`5. At the time of acquisition, the physical documents and assets of Worlds, Inc.
`
`included:
`
`a. All corporate documents, PC’s, hard drives and back up source code
`
`repositories.
`
`b. I took possession of these assets by Federal Express and UPS
`
`shipping, as well as by hand delivery on my trips to the San Francisco
`
`offices of Worlds, Inc.
`
`IPR2015-01264, -01268, -01269, -01319, -01321, -01325
`EX. 2018
`Page 1 of 5
`
`
`
`1. I currently reside at 11 Royal Road, Brookline, Massachusetts. I am the
`
`current President and Chief Executive Officer of Worlds, Inc., and have
`
`been so since 1997.
`
`2. I am providing this Declaration in connection with the pending Inter Partes
`
`review proceedings currently instituted against five U.S. Patents owned by
`
`Worlds, Inc.
`
`3. Unless otherwise stated, the facts presented in this Declaration are based on
`
`my personal knowledge.
`
`4. I was the President and Chief Executive Officer of a company that acquired
`
`Worlds, Inc. (formerly Knowledge Adventure Worlds) on December 3,
`
`1997.
`
`5. At the time of acquisition, the physical documents and assets of Worlds, Inc.
`
`included:
`
`a. All corporate documents, PC’s, hard drives and back up source code
`
`repositories.
`
`b. I took possession of these assets by Federal Express and UPS
`
`shipping, as well as by hand delivery on my trips to the San Francisco
`
`offices of Worlds, Inc.
`
`IPR2015-01264, -01268, -01269, -01319, -01321, -01325
`EX. 2018
`Page 1 of 5
`
`
`
`6. Upon acquiring Worlds, Inc., I also took possession of the software code
`
`libraries from Conor Laffan, Controller of Worlds, Inc., via a Federal
`
`Express package. I understand that Conor Laffan has testified in this matter
`
`that these libraries reflected regular tape backups of Worlds software,
`
`including Worlds Chat, AlphaWorlds, and Ace and Gamma software
`
`engines. This matches the representations that were made to me upon
`
`acquiring Worlds, Inc.
`
`7. Currently, code is stored on backup tapes given to me by Conor Laffan on
`
`December 3, 1997, upon the formal date of closing of the acquisition of
`
`Worlds Inc.
`
`8. This code accurately reflects the code that was implemented as Worlds Chat.
`
`I know and understand this to be true because of the declaration provided by
`
`Conor Laffan in this matter. This was also confirmed to me by former
`
`Worlds employee Bo Adler, one of the named inventors and an employee of
`
`Worlds Inc. after the acquisition.
`
`9. I provided copies of this code to Ron Britvich of Placerville, California, on
`
`or around November 8, 2010. Mr. Britvich is currently engaged as a
`
`consultant to Worlds, Inc., and as part of that engagement I asked him to
`
`evaluate certain portions of this code.
`
`IPR2015-01264, -01268, -01269, -01319, -01321, -01325
`EX. 2018
`Page 2 of 5
`
`
`
`10. My understanding is that Mr. Britvich is submitting his own declaration in
`
`this matter, and that his declaration and testimony is based upon his review
`
`of the code I provided to him.
`
`11. On February 18, 2016, I contacted the New York Public Library by
`
`telephone and ordered an authentic copy of the following article:
`
`a. Title: Talking blowfish to enliven the internet
`
`b. Author: Sandberg, Jared
`
`c. Journal: The Wall Street Journal
`
`d. Citation: April 3, 1995
`
`e. Inclusive Pages: B2
`
`12. In response, I received an email message on February 18, 2016, from
`
`copies@nypl.org, subject: NYPL Interlibrary & Document Services Order
`
`(Ex. 2031). This exhibit is a true and accurate copy of the email message
`
`received by me.
`
`a. This email message confirmed my order.
`
`b. I received the ordered article from the New York Public Library
`
`(copies@nypl.org) by electronic delivery in pdf format (Ex. 2022).
`
`c. The attached Ex. 2022 is a true and accurate copy of the file delivered
`
`to me by the New York Public Library, in response to my order
`
`described above.
`
`IPR2015-01264, -01268, -01269, -01319, -01321, -01325
`EX. 2018
`Page 3 of 5
`
`
`
`13. I understand that the team responsible for developing the Worlds Chat
`
`program included David Leahy, Judith Challinger, Mitra Ardon, and Bo
`
`Adler. These are the four named inventors of the patents-at-issue. These co-
`
`inventors are no longer employed by Worlds, Inc. Judith Challinger and
`
`Mitra Ardon have not been employed by Worlds, Inc. since before I
`
`acquired the company. David Leahy and Bo Adler were employed by
`
`Worlds, Inc. for a period of time after the acquisition, but have not been
`
`employed by Worlds, Inc. since around 2004.
`
`a. I attempted to contact each of the four named inventors for assistance
`
`in defending against this inter partes review. I was unable to contact
`
`Mitra Ardon and Judith Challinger. I was able to contact David Leahy
`
`and Bo Adler, but they were unwilling or unable to assist in this
`
`defense due to their current employment situations.
`
`b. However, Ron Britvich was an employee of Worlds, Inc. (then
`
`Knowledge Adventure Worlds) during the time from January 30, 1995
`
`to April 24, 1995, and observed working demonstrations of Worlds
`
`Chat from the inventors during this time. I was also able to obtain
`
`testimony from Dave Marvit, who oversaw the Worlds Chat team at
`
`Worlds, Inc. from January 1995 until at least April 1995. Because I
`
`was able to obtain testimony from these people having first-hand
`
`IPR2015-01264, -01268, -01269, -01319, -01321, -01325
`EX. 2018
`Page 4 of 5
`
`
`
`knowledge of the Worlds Chat development, I believed this was better
`
`evidence than compelled testimony from unwilling witnesses.
`
`14. I make this declaration of my own personal knowledge, and declare under
`
`penalty of perjury under the laws of the United States of America that the
`
`foregoing is true and correct.
`
`
`
`Executed on this 15th day of March, 2016, at Brookline, Massachusetts.
`
`
`
`Thom Kidrin
`
`
`
`IPR2015-01264, -01268, -01269, -01319, -01321, -01325
`EX. 2018
`Page 5 of 5
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
