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`1. I currently reside at 815 24th Ave, SF CA 94121. I am providing this
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`Declaration in connection with the pending Inter Partes review proceedings
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`currently instituted against certain U.S. Patents owned by Worlds, Inc.
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`2. Unless otherwise stated, the facts presented in this Declaration are based on
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`my personal knowledge.
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`3. In 1995, I served as the Vice President of Production at Knowledge
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`Adventure Worlds.
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`4. From January 1995 until December 1995, I oversaw the team responsible for
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`developing and maintaining the Worlds Chat program. This team included
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`David Leahy, Judith Challinger, Mitra Ardon, and Bo Adler.
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`5. During January 1995, the Worlds Chat team was working on the problem of
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`crowd control in the virtual world experience. At the time, servers and
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`computers (clients) possessed significantly limited processing power and
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`memory, and networks transferred data at slow rate. These limitations
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`hindered the potential size of a virtual world, since too many avatars on a
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`screen could bog down the system, either in the transmission of
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`position/orientation updates from the server to the clients, or in graphics
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`processing by the clients.
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`IPR2015-01264, -01268, -01269, -01319, -01321, -01325
`EX. 2027
`Page 1 of 4
`
`
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`6. After Ron Britvich joined Worlds, Inc. on January 30, 1995, he occasionally
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`traveled to San Francisco, CA to collaborate with the team developing the
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`Worlds Chat program, and on occasion members of the Worlds Chat team
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`traveled to his home in Carlsbad, CA, where Ron worked. These visits were
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`to collaborate on the development of Worlds Chat and the ActiveWorlds
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`customizable virtual world that Ron was developing.
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`7. On April 3, 1995, the Wall Street Journal published an article about Worlds
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`Chat. The article was entitled, “Talking Blowfish to Enliven the Internet.”
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`This article accurately described the Worlds Chat experience at that time,
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`and I specifically recall speaking with the article’s author, Jared Sandberg,
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`about Worlds Chat in an interview prior to the publication of that article. I
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`also recall that a copy of Worlds Chat was provided to Mr. Sandberg for
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`testing purposes prior to him writing the article. Attached as Exhibit 2022 is
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`a true and accurate copy of Mr. Sandberg’s Wall Street Journal article
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`published on April 3, 1995.
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`8. This company’s goal was to make Worlds Chat available for public release
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`and download no later than April 1, 1995. The goal was to allow users to
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`experience Worlds Chat from their homes. This date was important because
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`it represented the Worlds company’s one-year anniversary. The Worlds
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`Chat team did not meet this deadline, however.
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`IPR2015-01264, -01268, -01269, -01319, -01321, -01325
`EX. 2027
`Page 2 of 4
`
`
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`9. From April 11, 1995 until April 25, 1995, the Worlds Chat team worked on
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`a daily basis, including weekends, to debug and improve the code for
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`Worlds Chat. This included sending members of the Worlds Chat team to
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`Seattle, where Mitra Ardon was located, to improve the Ace software engine
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`on which Worlds Chat was built. Ace required this update in order to fully
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`support the Worlds Chat client-server protocol that was written by the
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`Worlds Chat programming team. Additionally, the team needed additional
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`time to add features to Worlds Chat, including the “whisper” function that
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`allowed one-to-one chat communications.
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`10. On April 23, 1995, Worlds Chat was made publicly available for download
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`from an anonymous ftp site.
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`11. On or about April 23, 1995, Knowledge Adventure Worlds changed its name
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`to Worlds, Inc.
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`12. On April 25, 1995, Worlds, Inc. publicly announced the availability of
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`Worlds Chat for download from Worlds’ webpage (kaworlds.com). This
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`announcement was made by press release through Business Wire.
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`13. Attached as Exhibit 2021 is a true and accurate copy of the Press Release
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`issued by Worlds, Inc. on April 25, 1995.
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`14. To the best of my recollection, the statements in the Press Release were
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`accurate at the time they were made.
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`IPR2015-01264, -01268, -01269, -01319, -01321, -01325
`EX. 2027
`Page 3 of 4
`
`
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`15. I make this declaration of my own personal knowledge, and declare under
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`penalty of perjury under the laws of the United States of America that the
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`foregoing is true and correct.
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`Executed on this 15th day of March, 2016, at San Francisco, CA.
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`
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`_________________________
`David Marvit
`
`IPR2015-01264, -01268, -01269, -01319, -01321, -01325
`EX. 2027
`Page 4 of 4
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