`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`AMAZON.COM, INC., AMAZON.COM, LLC,
`AMAZON WEB SERVICES, INC., BAZAARVOICE, INC., AND
`GEARBOX SOFTWARE, LLC.,
`Petitioners,
`v.
`ZITOVAULT, LLC,
`Patent Owner
`____________
`Case IPR2016-00021
`Patent 6,484,257
`____________
`
`DECLARATION OF EMILY E. TOOHEY IN SUPPORT OF PATENT
`OWNER’S RESPONSE
`
`Zitovault - Ex. 2010
`Amazon v. Zitovault
`IPR2016-00021
`
`
`
`I, Emily E. Toohey, make the following Declaration pursuant to 28 U.S.C. §
`
`1746:
`
`1.
`
`I am a Litigation Paralegal at the law firm of Davidson Berquist
`
`Jackson & Gowdey, LLP.
`
`2.
`
`I provide this Declaration in connection with the above—identified
`
`Inter Partes Review. Unless otherwise stated, the facts stated in this declaration
`
`are based on my personal knowledge.
`
`3.
`
`Exhibit 2003 is a true and correct copy of Internetworking with
`
`TCP/IP, Vol. 1, Principles, Protocols and Architecture, Chapter 11 with Glossary of
`
`Terms, Douglas C. Corner, 1991. An exhibit label on the first page has been added
`
`to the bottom of the document but no other alterations have been made.
`
`4.
`
`Exhibit 2005 is a true and correct copy of Internetworking with
`
`TCP/IP, Vol. 1, Principles, Protocols and Architecture, Chapter 12, Douglas C.
`
`Comer, 1991. An exhibit label on the first page has been added to the bottom of
`
`the document but no other alterations have been made.
`
`5.
`
`Exhibit 2006 is a true and correct copy ofthe Transcript of Deposition
`
`of Dr. Aviel Rubin dated July 22, 2016 taken in IPR2016-00021. An exhibit label
`
`has been added to the bottom of the Transcript but no other alterations have been
`
`made.
`
`
`
`6.
`
`Exhibit 2008 is a true and correct copy of a press release from
`
`Imperito Networks dated December 10, 2001 entitled Imperito Networks Wins the
`
`SC Magazine Hot Pick of 2001 Award With Perfect Five Star Review of
`
`InstantVPN 1.5.
`
`I downloaded a copy of the press release from
`
`https://web.archive.org/web/20020810153157/http://www.imperito.com/release_l
`
`2l0200l.html. An exhibit label on the first page has been added to the bottom of
`
`the press release but no other alterations have been made.
`
`7.
`
`Exhibit 2009 is a true and correct copy of a press release from
`
`Verisign from 2008 entitled Managed VPN Service Into Australia And New
`
`Zealand.
`
`I downloaded a copy of the press release from
`
`http://web.archive.org/web/20091 013005240/http://wWw.p1wire.com.au/pdf/verisi
`
`gn—australia—launches—imperito—s—safesecure-access-managed-vpn-service-into-
`
`australia—and—new—zealand. An exhibit label on the first page has been added to the
`
`bottom of the press release but no other alterations have been made.
`
`8.
`
`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.
`
`
`
`
`
`15
`
`32E E 3I I i
`
`9.
`
`I declare under penalty of perjuiy that the foregoing is true and
`
`correct.
`
`Executed this 8”‘ day of August, 2016, at McLean, Virginia.
`
`5
`
`
`'1/E.T 1'1
`=
`K/I mi}
`00 e}/MW}
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