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United States Patent No.: 7,149,511
`Inventors: Edward F. Bachner III,
`John Major, Xin Du
`Formerly Application No.: 09/652,734
`Issue Date: December 12, 2006
`Filing Date: August 31, 2000
`Former Group Art Unit: 2617
`Former Examiner: Keith Ferguson
`









`
`Attorney Docket No.:
`110797-0020-651
`Customer No.: 28120
`
`Petitioners: SAMSUNG
`ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS
`AMERICA, INC., and APPLE
`INC.
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`For: WIRELESS INTELLIGENT PERSONAL SERVER
`
`MAIL STOP PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`Post Office Box 1450
`Alexandria, Virginia 22313-1450
`
`
`
`
`
`
`
`
`DECLARATION OF SHARON LEE IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW OF
`UNITED STATES PATENT NO. 7,149,511
`
`
`
`-1-
`
`Samsung Exhibit 1011 Page 00001
`
`

`
`I, Sharon Lee, make the following Declaration pursuant to 28 U.S.C § 1746:
`
`1.
`
`2.
`
`I am an attorney at the law firm of Ropes & Gray LLP.
`
`I provide this Declaration in connection with the above-identified
`
`Inter Partes Review proceeding that is being requested at the United States Patent
`
`and Trademark Office by Samsung Electronics Co., Ltd., Samsung Electronics
`
`America, Inc., and Apple Inc. under 35 U.S.C. §§ 311-319, 37 C.F.R. § 42. Unless
`
`otherwise stated, the facts stated in this Declaration are based on my personal
`
`knowledge.
`
`3.
`
`Exhibit 1008 hereto is a true and correct copy of excerpts from “The
`
`Authoritative Dictionary of IEEE Standards Terms, Seventh Edition,” which was
`
`published by Standards Information Network IEEE Press in 2000 and was obtained
`
`from the library at Weil, Gotshal & Manges LLP’s Washington, D.C. office and
`
`David DesRosier, counsel for Petitioner Apple Inc. on February 10, 2016. An
`
`exhibit label on the first page and page numbers on all pages have been added to
`
`the bottom of this document and highlighting has been added to this document but
`
`no other alterations have been made.
`
`4.
`
`Exhibit 1028 hereto is a true and correct copy of Rosetta-Wireless
`
`Corporation’s Local Patent Rule 2.2 Initial Infringement Contentions in Rosetta-
`
`Wireless Corp. v. Samsung Elecs. Co. Ltd. et al., No. 1:15-cv-10605 (E.D. Tex.),
`
`dated January 20, 2016, which I received via e-mail on January 20, 2016 from
`
`
`
`
`-2-
`
`Page 00002
`
`

`
`Travis Anderson-Hamilton, Business Development Analyst at Kobre & Kim LLP,
`
`which is counsel for Rosetta-Wireless Corporation in the aforementioned case. An
`
`exhibit label on the first page and page numbers on all pages have been added to
`
`the bottom of this document but no other alterations have been made.
`
`5.
`
`Attached to Exhibit 1029 hereto as Exhibit D is a true and correct
`
`copy of a letter from David Valentine-Elam of OCLC, which I received via e-mail
`
`on February 3, 2016 from Jois Henry, staff member in OCLC’s legal department.
`
`Page numbers on all pages have been added to the bottom of this document but no
`
`other alterations have been made.
`
`6.
`
`Attached to Exhibit 1029 hereto as Exhibit E is a true and correct
`
`copy of the OCLC FirstSearch record for “Windows CE Developer’s Handbook”
`
`by Terence Goggin, which was retrieved at my direction from OCLC FirstSearch
`
`on February 2, 2016. Page numbers on all pages have been added to the bottom of
`
`this document but no other alterations have been made.
`
`7.
`
`Attached to Exhibit 1029 hereto as Exhibit F is a true and correct copy
`
`of excerpts of the publication “Windows CE Developer’s Handbook” by Terence
`
`A. Goggin, which was published by Sybex Inc. in 1999 and obtained from the
`
`George Mason University Library at my direction and which was copied at my
`
`direction on or about February 7, 2016. Page numbers on all pages have been
`
`added to the bottom of this document but no other alterations have been made.
`
`
`
`
`-3-
`
`Page 00003
`
`

`
`8.
`
`Attached to Exhibit 1029 hereto as Exhibit H are excerpts of a true
`
`and correct copy of the publication “Essential Windows CE Application
`
`Programming” by Robert Burdick, which was published by John Wiley & Sons,
`
`Inc. in 1999 and obtained from the Library of Congress at my direction and which
`
`was copied at my direction on or about February 8, 2016. Page numbers on all
`
`pages have been added to the bottom of this document but no other alterations have
`
`been made.
`
`9.
`
`Attached to Exhibit 1029 hereto as Exhibit J is a true and correct copy
`
`of the OCLC FirstSearch record for “Essential Windows CE Application
`
`Programming” by Robert Burdick, which was retrieved at my direction from
`
`OCLC FirstSearch on February 2, 2016. Page numbers on all pages have been
`
`added to the bottom of this document but no other alterations have been made.
`
`10. Attached to Exhibit 1029 hereto as Exhibit L are excerpts of a true
`
`and correct copy of the publication “Essential Windows CE Application
`
`Programming” by Robert Burdick, which was published by John Wiley & Sons,
`
`Inc. in 1999 and obtained from the North Carolina State University Library at my
`
`direction and which was copied at my direction on February 8, 2016. Page
`
`numbers on all pages have been added to the bottom of this document but no other
`
`alterations have been made.
`
`
`
`
`-4-
`
`Page 00004
`
`

`
`11. Attached to Exhibit 1029 hereto as Exhibit O is a true and correct
`
`copy of the OCLC FirstSearch record for “Programming Microsoft Windows CE”
`
`by Douglas M. Boling, which was retrieved at my direction from OCLC
`
`FirstSearch on February 2, 2016. Page numbers on all pages have been added to
`
`the bottom of this document but no other alterations have been made.
`
`12. Exhibit 1030 hereto is a true and correct copy of the publication
`
`“Windows CE Developer’s Handbook” by Terence A. Goggin, which was
`
`published by Sybex Inc. in 1999 and obtained from the Library of Congress at my
`
`direction and which was copied at my direction on or about February 8, 2016. An
`
`exhibit label on the first page and page numbers on all pages have been added to
`
`the bottom of this document but no other alterations have been made.
`
`13. Exhibit 1031 hereto is a true and correct copy of the publication
`
`“Essential Windows CE Application Programming” by Robert Burdick, which was
`
`published by John Wiley & Sons, Inc. in 1999 and obtained from the George
`
`Mason University Library at my direction and which was copied at my direction on
`
`or about February 7, 2016. An exhibit label on the first page and page numbers on
`
`all pages have been added to the bottom of this document but no other alterations
`
`have been made.
`
`14. Exhibit 1032 hereto is a true and correct copy of the publication
`
`“Programming Microsoft Windows CE” by Douglas Boling, which was published
`
`
`
`
`-5-
`
`Page 00005
`
`

`
`by Microsoft Press in 1998 and obtained from the North Carolina State University
`
`Library at my direction and which was copied at my direction on or about February
`
`7, 2016. An exhibit label on the first page and page numbers on all pages have
`
`been added to the bottom of this document but no other alterations have been
`
`made.
`
`15.
`
`I have been warned that willful false statements and the like are
`
`punishable by fine or imprisonment, or both. I make this declaration of my own
`
`personal knowledge, and all statements are true. If called to testify as to the truth
`
`of the matters stated herein, I could and would testify competently.
`
`16.
`
`I declare under penalty of perjury that the foregoing IS true and
`
`correct.
`Executed on this /2+11
`day ofFebruary, 2016 at Washington, D.C.
`
`~ ·
`
`har Lee
`
`-6-
`
`Page 00006

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