Case IPR2016-00497
`U.S. Patent No. 6,111,506
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`Filed on behalf of Patent Owner IRIS Corporation Berhad
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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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`
`
`
`
`
`______________________
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`DEPARTMENT OF JUSTICE
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`Petitioner
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`v.
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`IRIS CORPORATION BERHAD
`
`Patent Owner
`
`_____________________
`
`
`
`Case IPR2016-00497
`U.S. Patent No. 6,111,506
`
`
`____________________
`
`DECLARATION OF NEVILLE CRAMER
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`I, NEVILLE CRAMER, hereby declare and state as follows:
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`PROTECTIVE ORDER MATERIAL
`
`IRIS
`EXHIBIT 2032 PAGE 1
`DOJ v. IRIS
`IPR 2016-00497
`
`
`
`U.S. Patent No. 6,111,506
`
`
`Filed on behalf of Patent Owner IRIS Corporation Berhad
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
` _______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`______________________
`
`DEPARTMENT OF JUSTICE
`
`Petitioner
`
`v.
`
`IRIS CORPORATION BERHAD
`
`Patent Owner
`
`_____________________
`
`
`
`Case IPR2016-00497
`U.S. Patent No. 6,111,506
`
`
`____________________
`
`DECLARATION OF NEVILLE CRAMER
`
`
`I, NEVILLE CRAMER, hereby declare and state as follows:
`
`PROTECTIVE ORDER MATERIAL
`
`IRIS
`EXHIBIT 2032 PAGE 1
`DOJ v. IRIS
`IPR 2016-00497
`
`
`
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`1. I reside in Orlando, Florida. A copy of my Curriculum Vitae
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`(“CV”) is attached to this declaration as Exhibit 2035.
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`2. As more specifically set forth in my CV, I was employed by the
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`United States Immigration and Naturalization Service (hereinafter “INS”)
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`from 1976 until my retirement in 2002. My last position with the Service,
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`from 1996 until retirement was as Special Agent-in-Charge, Overseas
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`Enforcement Unit, INS.
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`
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`3. Sometime in 1999 I was contacted by our Forensic Document Lab
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`and was told that there was something “funny” about some of the Malaysian
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`passports that were being presented to immigration officers at various points
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`of entry into the United States. I was asked to investigate.
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`
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`4. During the course of my investigation I learned that Malaysia had
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`recently began using what they referred to as “electronic passports”, that is,
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`passports equipped with features designed to prevent fraudulent alteration on
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`the one hand, while enabling more convenient and expeditious re-entry into
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`Malaysia for legitimate Malaysian passport holders, without sacrificing
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`security, on the other hand.
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`5. As part of my investigation I traveled to Kuala Lumpur, Malaysia’s
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`capital, where I met with local immigration officials as well as with
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`technical and managerial staff of the Malaysian company, IRIS Corporation,
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`PROTECTIVE ORDER MATERIAL
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`IRIS
`2
`EXHIBIT 2032 PAGE 2
`DOJ v. IRIS
`IPR 2016-00497
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`the company that I was told had invented the method of manufacturing the
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`electronic passport that enabled it to work to the satisfaction of the
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`Malaysian government. IRIS was also the company that had been awarded a
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`contract by the Malaysian Government to manufacture the Malaysian
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`passport inlays containing the electronic chip and antenna.
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`6. I was impressed by what I had seen and therefore arranged for INS
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`to conduct a pilot program of its own in the United States to test the efficacy
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`of the fraud protection features of the Malaysian electronic passport.
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`7. In furtherance of this pilot project INS purchased several electronic
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`passport readers from IRIS corporation and installed these at several U.S.
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`international airports where holders of Malaysian passports might be
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`expected to enter this country. In addition we purchased, for examination
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`and testing, sample passports containing my photo and personal details that
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`had been manufactured for us by IRIS.
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`8. The pilot project was a success. During the course of the
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`implementation of this project, altered Malaysian passports were detected
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`and arrests by immigration officials were made at several U.S. airports. The
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`altered passports were detected when the U.S. immigration officials
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`compared the photograph on the passport’s face page with the image stored
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`on the passport’s electronic chip. For decades criminals have been quite
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`PROTECTIVE ORDER MATERIAL
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`IRIS
`3
`EXHIBIT 2032 PAGE 3
`DOJ v. IRIS
`IPR 2016-00497
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`successful in altering valid passport face pages by substituting photographs,
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`altering printed biographical data or changing information located in the
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`document’s Machine Readable Zone or “MRZ”, (the bar coded area located
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`at the bottom of the passport’s face page). However, with the invention of
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`the electronic passport, individuals attempting to alter data have found it to
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`be nearly impossible to change passport face page data and then match it
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`exactly with the corresponding digital information stored on the passport’s
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`electronic chip.
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`9. As the Special Agent-in-Charge, Overseas Enforcement Unit of
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`INS, I presented these findings and demonstrated the electronic passport to
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`Bush Administration personnel. Following that, in September of 2002,
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`shortly before my retirement, I met with a White House staffer to discuss
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`possible U.S. implementation of electronic passports. His response was that
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`electronic passports were “useless”.
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`10. Not long after my retirement, America not only turned to
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`electronic passports as the best method for securing our travel document and
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`protecting it against fraud and alteration, but in addition, our government
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`mandated use of electronic passports as a condition precedent to a country’s
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`participation in the United States visa waiver program.
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`PROTECTIVE ORDER MATERIAL
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`IRIS
`4
`EXHIBIT 2032 PAGE 4
`DOJ v. IRIS
`IPR 2016-00497
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`11. When it came time for the U.S. Government to contract with
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`outside vendors to manufacture the inlays for this new U.S. electronic
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`passport, however, after having benefited from the aforementioned pilot
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`project as well as from the technical information that IRIS corporation
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`shared with me and my colleagues, the U.S. Government did not purchase
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`the inlays from the Malaysian company, IRIS. Nor did it purchase these
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`inlays from any American company. The contract for the manufacture of
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`U.S. electronic passport inlays went to Smartrac Technology Ltd.
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`Smartrac’s manufacturing facilities for these inlays was located in Thailand.
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`12. The letters attached to my declaration as Exhibits 2003, 2011, and
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`2036 were written by me during the course of my employment as a Special
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`Agent-in-Charge, Overseas Enforcement Unit of the INS. Exhibit 2011, a
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`July 18, 2002 letter I had written to the Director General of Immigration
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`Malaysia accurately reported to Malaysian immigration the detection of
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`altered passports and the subsequent arrests referred to in paragraph 8 above.
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`13. Exhibit 2012 to this declaration is a July 5, 2007 article published
`by the electronic edition of the Malaysian newspaper New Straits Times.
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`This article quotes me accurately and I state from personal knowledge that
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`the contents of that article, with which I am familiar, are true and correct.
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`PROTECTIVE ORDER MATERIAL
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`IRIS
`5
`EXHIBIT 2032 PAGE 5
`DOJ v. IRIS
`IPR 2016-00497
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`PROTECTIVE ORDER MATERIAL
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`IRIS
`EXHIBIT 2032 PAGE 6
`DOJ v. IRIS
`IPR 2016-00497
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