UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MICROSOFT CORPORATION,
`Petitioner
`
`v.
`
`BRADIUM TECHNOLOGIES LLC,
`Patent Owner
`
`CASE IPR2016-00448
`Patent 7,908,343
`
`
`
`
`
`
`
`
`
`
`
`
`
`DECLARATION OF OLENA IEREGA
`IN SUPPORT OF PATENT OWNER’S RESPONSE TO THE PETITION
`FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,908,343
`
`
`
`
`Exhibit 2060
`Bradium Technologies LLC - patent owner
`Microsoft Corporation - petitioner
`IPR2016-00448
`1
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MICROSOFT CORPORATION,
`Petitioner
`
`v.
`
`BRADIUM TECHNOLOGIES LLC,
`Patent Owner
`
`CASE IPR2016-00448
`Patent 7,908,343
`
`
`
`
`
`
`
`
`
`
`
`
`
`DECLARATION OF OLENA IEREGA
`IN SUPPORT OF PATENT OWNER’S RESPONSE TO THE PETITION
`FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,908,343
`
`
`
`
`Exhibit 2060
`Bradium Technologies LLC - patent owner
`Microsoft Corporation - petitioner
`IPR2016-00448
`1
`
`
`
`DECLARATION OF OLENA IEREGA
`
`
`I, Olena Ierega, make the following declaration under penalty of perjury:
`
`
`1. My name is Olena Ierega. I am an attorney at Andrews Kurth Kenyon
`
`LLP.
`
`2.
`
`I have personal knowledge regarding the preparation of the exhibits
`
`described below.
`
`3.
`
`Exhibit 2012 is a true and correct copy of a three-page document
`
`produced by Petitioner in the litigation between Petitioner and Patent Owner,
`
`Bradium Technologies LLC v. Microsoft Corporation, Case No. 15-cv-031 (D.
`
`Del.) (Feb. 3, 2016), with the Bates Numbers MSFT-BRAD-0044914 – 0044916.
`
`I have personally downloaded this document from the production site of the
`
`abovementioned litigation on or about October 28, 2016.
`
`4.
`
`Exhibit 2013 is a true and correct copy of an eleven-page document
`
`produced by Petitioner in the litigation between Petitioner and Patent Owner,
`
`Bradium Technologies LLC v. Microsoft Corporation, Case No. 15-cv-031 (D.
`
`Del.) (Feb. 3, 2016), with the Bates Numbers MSFT-BRAD-0044917 – 0044927.
`
`I have personally downloaded this document from the production site of the
`
`abovementioned litigation on or about October 28, 2016. Document, identified as
`
`Exhibit 2013, on its face is dated, September, 2005.
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`
`
`
`
`
`
`2
`
`2
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`
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`DECLARATION OF OLENA IEREGA
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`5.
`
`Exhibit 2016 is a true and correct printed copy of an internet webpage
`
`entitled “The Global Innovation 1000: Top 29 R&D Spenders 2005-2015” that I
`
`downloaded from the URL http://www.strategyand.pwc.com/global/home/what-
`
`we-hink/innovation1000/top-20-rd-spenders-2015 on or about October 26, 2016.
`
`6.
`
`Exhibit 2017 is a true and correct printed copy of a screenshot I took
`
`of the internet webpage entitled “Microsoft's expenditure on research and
`
`development from 2002 to 2016 (in million U.S. dollars)” that is available at the
`
`URL https://www.statista.com/statistics/267806/expenditure-on-research-and-
`
`development-by-the-microsoft-corporation/. I took the screen shot of this webpage
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`on or about October 31, 2016.
`
`7.
`
`Exhibit 2018 is a true and correct printed copy of an internet webpage
`
`entitled “Convergence in North American Automotive Industry” that I downloaded
`
`from the URL http://www.frost.com/srch/catalog-
`
`search.do?search_paths%5B%5D=&sortBy=R&searchType=sub&queryText=3D
`
`VU&rd_submit=Go, on or about October 31, 2016. The webpage, identified as
`
`Exhibit 2018, is dated, December 15, 2008.
`
`8.
`
`Exhibit 2021 is a true and correct printed copy of an internet webpage
`
`entitled “3DVU Launches Navi2Go for BlackBerry, the First 3D Picture
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`Navigation, in Anticipation of the Bold” that I downloaded from the URL
`
`http://www.directionsmag.com/pressreleases/3dvu-launches-navi2go-for-
`
`
`
`3
`
`3
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`
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`DECLARATION OF OLENA IEREGA
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`blackberry-the-first-3d-picture-navigation-in-ant/115362, on or about November 1,
`
`2016. The webpage, identified as Exhibit 2021, is dated, July 11, 2008.
`
`9.
`
`Exhibit 2030 is a true and correct printed copy of an internet webpage
`
`entitled “FlyOver Visual MAPTM Technology the first 3D aerial imagery Map to
`
`enriched Kenwood’s new HDD car navigation system” that I downloaded from the
`
`URL http://www.silicomventures.com/newsletter_10_29_02/FlyOver.htm, on or
`
`about November 1, 2016. The webpage, identified as Exhibit 2030, is dated,
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`October 6, 2002.
`
`10. Exhibit 2031 is a true and correct printed copy of a screenshot that I
`
`have taken of the internet webpage entitled “3DVU Image Navigation fuels
`
`Kenwood Systems in Japan” that I downloaded from the URL
`
`https://www.youtube.com/watch?v=3btUNuCYM6M, on or about November 7,
`
`2016.
`
`11. Exhibit 2032 is a true and correct printed copy of an internet webpage
`
`entitled “FlyOver 2nd generation Visual MAPÂTechnology fuel Kenwood new
`
`Theater Navi – with 3D aerial imagery map” that I located at the URL
`
`http://www.prweb.com/releases/2004/02/prweb103763.htm, on or about October
`
`31, 2016.
`
`12. Exhibit 2038 is a true and correct printed copy of an article entitled
`
`“Daewoo introduces 3DVU’s Visual Map Navigation Technology” from June
`
`
`
`4
`
`4
`
`
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`DECLARATION OF OLENA IEREGA
`
`
`2006 GIS Development: Asia Pacific: The Monthly Magazine on Geographic
`
`Information Science, Vol. 10, Issue 6, page 9. I downloaded this article from the
`
`URL https://www.geospatialworld.net/wp-
`
`content/uploads/magazine/925d04_apJune2006.pdf, on or about October 31, 2016.
`
`13. Exhibit 2039 is a true and correct printed copy of an internet webpage
`
`entitled “Daewoo to Showcase 3DVU’s Visual Map Navigation Technology at the
`
`Busan International Motor Show, Korea” that I downloaded from the URL
`
`http://www.theautochannel.com/news/2006/04/30/005219.html, on or about
`
`November 1, 2016.
`
`14. Exhibit 2042 is a true and correct printed copy of a screenshot that I
`
`caused to be taken of the internet webpage entitled “Navi2Go in Action” that is
`
`located at the URL https://www.youtube.com/watch?v=rTGnselwJbM. The screen
`
`shot was taken on or about November 7, 2016.
`
`15. Exhibit 2044 is a true and correct printed copy of an internet webpage
`
`entitled “Navi2Go – 3D Image Navigation System on Mobile Phone” that I
`
`downloaded from the URL
`
`http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=2&ved=0a
`
`hUKEwjXiODdn_zPAhVG9YMKHamADQYQFggjMAE&url=http%3A%2F%2
`
`Ftechnode.com%2F2008%2F12%2F03%2Fnavi2go-%25E2%2580%2593-3d-
`
`
`
`5
`
`5
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`
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`DECLARATION OF OLENA IEREGA
`
`
`image-navigation-system-on-mobile-phone%2F&usg=AFQjCNEKfI-
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`lLbA7ehvu7X1hc7e-ImGPvQ, on or about October 31, 2016.
`
`16. Exhibit 2045 is a true and correct printed copy of an internet webpage
`
`entitled “3DVU announces Way2Go 3D mobile mapping” that I downloaded from
`
`the URL https://www.cnet.com/news/3dvu-announces-way2go-3d-mobile-
`
`mapping/, on or about November 1, 2016.
`
`17. Exhibit 2046 is a true and correct printed copy of an internet webpage
`
`entitled “3DVU Releases the Ultimate Game-Changer in Mobile Navigation,
`
`Navi2Go Two-for-One” that I downloaded from the URL
`
`http://www.directionsmag.com/pressreleases/3dvu-releases-the-ultimate-game-
`
`changer-in-mobile-navigation-navi2go-two-fo/116777, on or about October 31,
`
`2016.
`
`18. Exhibit 2047 is a true and correct printed copy of an internet webpage
`
`entitled “3DVU Enhancing Over 80 Million Nokia Phones With Navi2Go, the
`
`Only 3D Virtual World Mobile Navigation” that I downloaded from the URL
`
`http://www.directionsmag.com/pressreleases/3dvu-enhancing-over-80-million-
`
`nokia-phones-with-navi2go-the-only-3d-virtua/116005, on or about October 31,
`
`2016.
`
`19. Exhibit 2048 is a true and correct printed copy of an internet webpage
`
`entitled “3DVU’s Mobile Navigation Best Seller on Sprint’s shop” that I
`
`
`
`6
`
`6
`
`
`
`DECLARATION OF OLENA IEREGA
`
`
`downloaded from the URL
`
`http://www.directionsmag.com/pressreleases/3dvu146s-mobile-navigation-best-
`
`seller-on-sprint146s-shop/115112, on or about October 31, 2016.
`
`20. Exhibit 2049 is a true and correct printed copy of an internet webpage
`
`entitled “Navi2Go: the Ultimate Killer Navigation Application?” that I
`
`downloaded from the URL
`
`http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&ved=0a
`
`hUKEwiBrNmJmfzPAhWp1IMKHQWeCMgQFggcMAA&url=http%3A%2F%2
`
`Fwww.vccafe.com%2F2008%2F11%2F12%2Fnavi2go-the-ultimate-killer-
`
`navigation-
`
`application%2F&usg=AFQjCNH0entf5GH_owuOqqrUNRcEpj9hTA&bvm=bv.13
`
`6811127,d.amc, on or about October 31, 2016.
`
`21. Exhibit 2054 is a true and correct printed copy of an internet webpage
`
`entitled “3D GPS Navigation On Your BlackBerry” that I downloaded from the
`
`URL http://www.berryreview.com/2008/07/08/3d-gps-navigation-on-your-
`
`blackberry/, on or about September 28, 2016.
`
`22. Exhibit 2055 is a true and correct printed copy of an internet webpage
`
`entitled “3DVU signed up with Orange UK for off-board nav solution” that I
`
`downloaded from the URL http://www.gpsbusinessnews.com/3DVU-signed-up-
`
`
`
`7
`
`7
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`
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`DECLARATION OF OLENA IEREGA
`
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`with-Orange-UK-for-off-board-nav-solution_a776.html, on or about September 28,
`
`2016.
`
`23. Exhibit 2057 is a true and correct printed copy of an internet webpage
`
`entitled “TerraVision (/projects/terravision/)” that I downloaded from URL
`
`https://sourceforge.net/projects/terravision/files/stats/timeline?dates=2002-08-
`
`02+to+2016-10-13, setting the Date Range field to 2002-08-02 to 2016-10-13, on
`
`or about November 7, 2016.
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`24. Exhibit 2058 is a true and correct printed copy of an internet webpage
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`entitled “TerraVision Open Sourced” that I downloaded from URL
`
`https://sourceforge.net/p/terravision/news/?source=navbar, on or about November
`
`7, 2016.
`
`25. Exhibit 2059 is a true and correct printed copy of an internet webpage
`
`entitled “Bing Map Tile System” that I downloaded from URL
`
`https://msdn.microsoft.com/en-us/library/bb259689.aspx, on or about November 7,
`
`2016.
`
`26. Exhibit 2063 is a true and correct printed copy of an internet webpage
`
`entitled “3DVU and Infoterra Signed a Memorandum of Understanding” that I
`
`downloaded from URL
`
`http://www.prweb.com/releases/2005/09/prweb284722.htm, on or about November
`
`6, 2016.
`
`
`
`8
`
`8
`
`
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`DECLARATION OF OLENA IEREGA
`
`
`27. Exhibit 2066 is a true and correct printed copy of an internet webpage
`
`entitled “Visualization System for SRI’s Digital Earth Proposal” that I downloaded
`
`from URL http://www.ai.sri.com/digital-earth/proposal/visualization-system.html,
`
`on or about November 3, 2016.
`
`28. Exhibit 2067 is a true and correct printed copy of an internet webpage
`
`entitled “Next Generation Internet (NGI) Initiative” that I downloaded from URL
`
`https://www.nitrd.gov/PUBS/talks/pdf-13Jun97/strawn.pdf, on or about November
`
`3, 2016.
`
`29. Exhibit 2069 is a true and correct copy of video that I caused to be
`
`downloaded of the YouTube internet webpage entitled “3DVU YouTube Video:
`
`Navi2Go in Action” that is located at the URL
`
`https://www.youtube.com/watch?v=rTGnselwJbM. The video was downloaded on
`
`or about November 4, 2016.
`
`30. Exhibit 2070 is a true and correct copy of video that I caused to be
`
`downloaded of the YouTube internet webpage entitled “3DVU YouTube Video:
`
`3DVU Image Navigation fuels Kenwood Systems in Japan” that is located at the
`
`https://www.youtube.com/watch?v=3btUNuCYM6M. The video was downloaded
`
`on or about November 4, 2016.
`
`I hereby declare that all statements made herein of my own knowledge are
`
`true; that all statements made on information and belief are believed to be true; and
`
`
`
`9
`
`9
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`
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`DECLARATION OF OLENA IEREGA
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`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 18 U.S.C. 1001 and that such willful false statements may jeopardize the
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`Validity of the application or any patent issued thereupon.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`,
`1
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`M
`
`A ,.~r
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`Executed on this 7 day of November, 2016 in New York, NY.
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`/[K/M
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