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`IPR2016-00418
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`PATENT NO. 8,155,342
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
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`TOYOTA MOTOR CORPORATION
`Petitioner
`v.
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`BLITZSAFE TEXAS, LLC
`Patent Owner
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`Patent No. 8,155,342
`Issue Date: April 10, 2012
`Title: MULTIMEDIA DEVICE INTEGRATION SYSTEM
`__________________________________________________________________
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`DECLARATION OF IRA MARLOWE
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`Case No. IPR2016-00418
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` IPR2016-00418, EX. 2004
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` Blitzsafe Texas, LLC, Patent Owner
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`1
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`I, Ira Marlowe, declare as follows:
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`IPR2016-00418
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`PATENT NO. 8,155,342
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`1. I am the named inventor of U.S. Patent No. 8,155,342 (the ’342 Patent).
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`2. I am also the named inventor of three U.S. Patent Applications to which the
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`’342 Patent claims priority: U.S. Patent Appl. No. 11/071,667 (the ’667
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`Application), 10/732,909 (the ’909 Application), and 10/316,961 (the ’961
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`Application). The ’961 Application, which was filed on December 11, 2002,
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`ultimately issued as U.S. Patent No. 7,489,786.
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`3. From the early-1980’s to the present, I have been working as the CEO and
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`president of Blitzsafe, a company that designs, manufactures, and sells
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`aftermarket car audio/video equipment.
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`4. I have been working in the field of car audio video interfaces since the mid-
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`1990’s and I have invented many types of interfaces that connect aftermarket
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`devices to car audio/video systems, several of which are described and
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`claimed in the ’786 Patent, the ’342 Patent and the applications set forth
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`above.
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`2
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`IPR2016-00418
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`PATENT NO. 8,155,342
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`5. Specifically with regard to the ’667 Application, the application was filed on
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`March 3, 2005. I conceived of the inventions set forth in the ’667
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`Application prior to March 3, 2005, and at least as early as the end of
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`January of 2005.
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`6. At least as early as January of 2005, I had retained my patent attorneys, Mr.
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`Mike Friscia and Mr. Mark Nikolsky to draft the ’667 Application.
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`7. Exhibit M1 to this Declaration is a true and accurate copy of an email I had
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`received from Mr. Friscia’s assistant Ms. Janelle Fava. The email attaches a
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`draft patent application that was an initial draft of the ’667 Application,
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`8. I note that this initial draft included Figure 10, which I had conceived of,
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`reproduced below.
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`IPR2016-00418
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`PATENT NO. 8,155,342
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`9.
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`10. From February 8 until March 3, I continued to exchange correspondence
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`with Mr. Friscia and Mr. Nikolsky, and we worked diligently to file the ’667
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`Application. Below is a description of our efforts to file the ’667
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`Application during that period.
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`11. After I received the February 8 communication I worked to supply
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`additional information regarding the names and models of chips to include in
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`the application, and it was my understanding that Mr. Nikolsky and
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`Mr. Friscia continued to work to revise the ’667 Application.
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`IPR2016-00418
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`PATENT NO. 8,155,342
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`12. Between February 8 and February 16, Mr. Nikolsky and I had additional
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`communications regarding the application.
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`13. On February 16, I sent Mr. Nikolsky an email with code portions describing
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`the command conversion between the iPod and the Ford OEM environment.
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`I had designed these code portions prior to my communication with
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`Mr. Nikolsky, and I provided them for addition to the application. A true
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`and correct copy of this February 16 email is attached as exhibit M2 to this
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`Declaration.
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`14. Between February 8 and February 18, I also had discussions with
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`Mr. Nikolsky and Mr. Friscia regarding an additional features of the ’667
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`Application. It was my understanding that between February 8 and February
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`18, Mr. Nikolsky and Mr. Friscia were incorporating those ideas into the
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`’667 Application.
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`15. On February 18, 2005, I received a revised draft of the ’667 Application
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`from Mr. Nikolsky via email. A true and accurate copy of the February 18,
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`2005 email is attached as Exhibit M3 to this Declaration. As reflected in the
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`email correspondence, this draft included the additional code portions I had
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`sent to Mr. Nikolsky on February 16 along with a new Figure 16. I note that
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`IPR2016-00418
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`PATENT NO. 8,155,342
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`this Figure 16 relates to a feature I referred to as “fast navigation.”
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`After receiving Mr. Nikolsky’s draft on February 18, 2005, I reviewed the
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`draft and provided comments regarding a typographical change to the
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`figures along with a list of chips for inclusion in the application. A true and
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`correct copy of my email to Mr. Nikolsky on February 18, 2005 is attached
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`as Exhibit M4 to this Declaration.
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`16. On February 25, 2005, I received en email from Mr. Nikolsky and
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`Mr. Friscia that attached what Mr. Nikolsky referred to as a “final draft” of
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`the ’667 Application. A true and accurate copy of the February 25 email is
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`attached as exhibit M5 to this Declaration.
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`17. Although the February 25 email purported to be a final draft, after receiving
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`the draft, I had additional discussions with Mr. Nikolsky regarding additions
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`to the application
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`18. On March 1, 2005, Mr. Nikolsky and Mr. Friscia sent me an email attaching
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`Figure 17 of the ’667 Application. A true and correct copy of the March 1,
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`2005 email is attached as exhibit M6 to this Declaration.
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`19. On March 2, 2005, I received an email from Mr. Nikolsky entitled “Final
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`draft – CIP patent application.” A true and accurate copy of this email is
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`attached as exhibit M7 to this Declaration. This email attached the final
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`’667 Application, as well as a declaration and power of attorney. I signed
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`IPR20 16-0041 8
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`PATENT NO. 8,155,342
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`the declaration and power of attorney that same day, and it is my
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`understanding that the ’667 Application was filed the Very next day on
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`March 3, 2005.
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`I declare that all statements made herein of my own knowledge are true and
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`that all statements made on information and belief are believed to be true,
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`and further that these statements were made with the knowledge that willful
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`false statements
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`and the like
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`so made
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`are punishable by fine or
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`imprisonment, or both, under Section 1001 of Title 18 of the United States
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`Code.
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`Dated: 7/50 Z’//4
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`Ira Marlowe
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