`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
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`Attorney Docket No.:
`110797-0020-651
`Customer No.: 28120
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`Petitioners: SAMSUNG
`ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS
`AMERICA, INC., and APPLE
`INC.
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`For: WIRELESS INTELLIGENT PERSONAL SERVER
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`MAIL STOP PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`Post Office Box 1450
`Alexandria, Virginia 22313-1450
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`DECLARATION OF SHARON LEE IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW OF
`UNITED STATES PATENT NO. 7,149,511
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`Samsung Exhibit 1011 Page 00001
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`I, Sharon Lee, make the following Declaration pursuant to 28 U.S.C § 1746:
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`1.
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`2.
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`I am an attorney at the law firm of Ropes & Gray LLP.
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`I provide this Declaration in connection with the above-identified
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`Inter Partes Review proceeding that is being requested at the United States Patent
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`and Trademark Office by Samsung Electronics Co., Ltd., Samsung Electronics
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`America, Inc., and Apple Inc. under 35 U.S.C. §§ 311-319, 37 C.F.R. § 42. Unless
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`otherwise stated, the facts stated in this Declaration are based on my personal
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`knowledge.
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`3.
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`Exhibit 1008 hereto is a true and correct copy of excerpts from “The
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`Authoritative Dictionary of IEEE Standards Terms, Seventh Edition,” which was
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`published by Standards Information Network IEEE Press in 2000 and was obtained
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`from the library at Weil, Gotshal & Manges LLP’s Washington, D.C. office and
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`David DesRosier, counsel for Petitioner Apple Inc. on February 10, 2016. An
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`exhibit label on the first page and page numbers on all pages have been added to
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`the bottom of this document and highlighting has been added to this document but
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`no other alterations have been made.
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`4.
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`Exhibit 1028 hereto is a true and correct copy of Rosetta-Wireless
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`Corporation’s Local Patent Rule 2.2 Initial Infringement Contentions in Rosetta-
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`Wireless Corp. v. Samsung Elecs. Co. Ltd. et al., No. 1:15-cv-10605 (E.D. Tex.),
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`dated January 20, 2016, which I received via e-mail on January 20, 2016 from
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`Page 00002
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`Travis Anderson-Hamilton, Business Development Analyst at Kobre & Kim LLP,
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`which is counsel for Rosetta-Wireless Corporation in the aforementioned case. An
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`exhibit label on the first page and page numbers on all pages have been added to
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`the bottom of this document but no other alterations have been made.
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`5.
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`Attached to Exhibit 1029 hereto as Exhibit D is a true and correct
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`copy of a letter from David Valentine-Elam of OCLC, which I received via e-mail
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`on February 3, 2016 from Jois Henry, staff member in OCLC’s legal department.
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`Page numbers on all pages have been added to the bottom of this document but no
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`other alterations have been made.
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`6.
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`Attached to Exhibit 1029 hereto as Exhibit E is a true and correct
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`copy of the OCLC FirstSearch record for “Windows CE Developer’s Handbook”
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`by Terence Goggin, which was retrieved at my direction from OCLC FirstSearch
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`on February 2, 2016. Page numbers on all pages have been added to the bottom of
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`this document but no other alterations have been made.
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`7.
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`Attached to Exhibit 1029 hereto as Exhibit F is a true and correct copy
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`of excerpts of the publication “Windows CE Developer’s Handbook” by Terence
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`A. Goggin, which was published by Sybex Inc. in 1999 and obtained from the
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`George Mason University Library at my direction and which was copied at my
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`direction on or about February 7, 2016. Page numbers on all pages have been
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`added to the bottom of this document but no other alterations have been made.
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`-3-
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`Page 00003
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`8.
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`Attached to Exhibit 1029 hereto as Exhibit H are excerpts of a true
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`and correct copy of the publication “Essential Windows CE Application
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`Programming” by Robert Burdick, which was published by John Wiley & Sons,
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`Inc. in 1999 and obtained from the Library of Congress at my direction and which
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`was copied at my direction on or about February 8, 2016. Page numbers on all
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`pages have been added to the bottom of this document but no other alterations have
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`been made.
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`9.
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`Attached to Exhibit 1029 hereto as Exhibit J is a true and correct copy
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`of the OCLC FirstSearch record for “Essential Windows CE Application
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`Programming” by Robert Burdick, which was retrieved at my direction from
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`OCLC FirstSearch on February 2, 2016. Page numbers on all pages have been
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`added to the bottom of this document but no other alterations have been made.
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`10. Attached to Exhibit 1029 hereto as Exhibit L are excerpts of a true
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`and correct copy of the publication “Essential Windows CE Application
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`Programming” by Robert Burdick, which was published by John Wiley & Sons,
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`Inc. in 1999 and obtained from the North Carolina State University Library at my
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`direction and which was copied at my direction on February 8, 2016. Page
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`numbers on all pages have been added to the bottom of this document but no other
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`alterations have been made.
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`-4-
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`Page 00004
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`11. Attached to Exhibit 1029 hereto as Exhibit O is a true and correct
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`copy of the OCLC FirstSearch record for “Programming Microsoft Windows CE”
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`by Douglas M. Boling, which was retrieved at my direction from OCLC
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`FirstSearch on February 2, 2016. Page numbers on all pages have been added to
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`the bottom of this document but no other alterations have been made.
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`12. Exhibit 1030 hereto is a true and correct copy of the publication
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`“Windows CE Developer’s Handbook” by Terence A. Goggin, which was
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`published by Sybex Inc. in 1999 and obtained from the Library of Congress at my
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`direction and which was copied at my direction on or about February 8, 2016. An
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`exhibit label on the first page and page numbers on all pages have been added to
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`the bottom of this document but no other alterations have been made.
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`13. Exhibit 1031 hereto is a true and correct copy of the publication
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`“Essential Windows CE Application Programming” by Robert Burdick, which was
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`published by John Wiley & Sons, Inc. in 1999 and obtained from the George
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`Mason University Library at my direction and which was copied at my direction on
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`or about February 7, 2016. An exhibit label on the first page and page numbers on
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`all pages have been added to the bottom of this document but no other alterations
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`have been made.
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`14. Exhibit 1032 hereto is a true and correct copy of the publication
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`“Programming Microsoft Windows CE” by Douglas Boling, which was published
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`-5-
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`Page 00005
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`
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`by Microsoft Press in 1998 and obtained from the North Carolina State University
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`Library at my direction and which was copied at my direction on or about February
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`7, 2016. An exhibit label on the first page and page numbers on all pages have
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`been added to the bottom of this document but no other alterations have been
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`made.
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`15.
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`I have been warned that willful false statements and the like are
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`punishable by fine or imprisonment, or both. I make this declaration of my own
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`personal knowledge, and all statements are true. If called to testify as to the truth
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`of the matters stated herein, I could and would testify competently.
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`16.
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`I declare under penalty of perjury that the foregoing IS true and
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`correct.
`Executed on this /2+11
`day ofFebruary, 2016 at Washington, D.C.
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`~ ·
`
`har Lee
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`Page 00006