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`DROPBOX EX. 1037
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`DROPBOX EX. 1037
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`DROPBOX, INC.,
`Petitioner,
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`v.
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`SYNCHRONOSS TECHNOLOGIES, INC.,
`Patent Owner
`__________________
`
`INTER PARTES REVIEW OF U.S. PATENT NO. 6,671,757
`__________________
`
`DECLARATION OF REMZI ARPACI-DUSSEAU, PH.D.
`CONCERNING EXHIBIT 1003
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`Dropbox Ex. 1037
`Page 1
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`Patent 6,671,757
`I, Remzi H. Arpaci-Dusseau, hereby declare and state the following:
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`1.
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`I am a Professor in the Computer Sciences Department at the
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`University of Wisconsin. I received my B.S. in Computer Engineering, summa
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`cum laude, from the University of Michigan. Subsequently, I obtained my M.S.
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`and Ph.D. from the University of California, Berkeley, in Computer Science.
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`2.
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`I have previously been a visiting professor at Stanford University, the
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`Ecole Polytechnique Federale (EPFL) in Lausanne (Switzerland), and the
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`University of Michigan. I have taught undergraduate and graduate courses in a
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`variety of topics, including Operating Systems, Distributed Systems, Storage
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`Systems, and Integrating Networks and Storage. In 2014-2015, I was a visiting
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`scientist at Google, Inc. While at Google, I worked on a team that developed the
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`distributed storage system that underlies many of Google’s applications and data.
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`3. During my teaching career, I have been recognized on five occasions
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`as the Student Chapter of the Association for Computing Machinery’s Professor
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`of the Year, and I also won the University of Wisconsin-Madison Chancellor’s
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`Distinguished Teaching Award. I have also been awarded multiple faculty
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`fellowships.
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`4.
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`Since 2008, I have served on the steering committee for the FAST
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`Conference. Since 2014, I have served as an associate editor for ACM TOCS. I
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`have served on many program committees, including SOSP (the Symposium on
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`Dropbox Ex. 1037
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`Patent 6,671,757
`Operating Systems Principles), OSDI (the conference on Operating Systems
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`Design and Implementation), and NSDI (the conference on Network Systems
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`Design and Implementations) to review publications submitted by researchers,
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`playing a role in deciding which papers will be published. I have chaired
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`academic conference on four separate occasions, including SOCC (Symposium on
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`Cloud Computing) in 2014, OSDI in 2010, FAST in 2007, and the USENIX
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`Annual Technical Conference in 2004.
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`5. My academic research has focused on file and storage systems,
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`including distributed varieties of these systems. As a result of my academic
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`research, we have won 10 best paper awards, which recognize excellence in
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`research on a particular topic. Several of these awards were given at the File and
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`Storage Technology (FAST) Conference, at which papers on filesystems and
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`storage systems, included distributed versions of such systems. Several of the
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`papers I have co-authored are related to the Coda filesystem and similar
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`distributed filesystems. I have over 100 refereed publications covering a range of
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`topics, such as filesystems, distributed computing and storage, and data
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`synchronization. I have been invited to deliver a lecture related to my research on
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`nearly 70 occasions.
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`6.
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`Since the spring semester of 2000, I have taught the CS 736 Graduate
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`Operating Systems Class. The class covers a selection of topics related to
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`Dropbox Ex. 1037
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`Patent 6,671,757
`operating system fundamentals, including function and design. Readings are
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`assigned to the students for each topic covered. The class was open to both
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`graduate and undergraduate students.
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`7. Links to each reading for the spring 2000 CS 736 are available from
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`my personal webpage maintained at the University of Wisconsin at the following
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`URL: http://pages.cs.wisc.edu/~remzi/Classes/736/Spring2000/Papers/. This
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`page is simply a directory listing of a directory containing all the electronic
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`versions of the papers that were assigned to the students to read. A true and
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`correct copy of a PDF printout of this webpage, made on April 25, 2017, is
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`attached as Exhibit 1037. The webpage shows the name of the file (hyperlinked
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`to the file itself), a “Last Modified” date, and the file size. This webpage has been
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`continually available on the Internet since even before I taught the class in early
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`2000.
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`8. One of the topics covered in CS 736, to which an entire class period
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`was devoted, is the well-known Coda distributed file system. Coda was
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`developed at Carnegie Mellon University under the supervision of Professor
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`Mahadev Satyanarayanan. The Coda file system attracted interest broadly among
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`professors of computer science because it offered the ability to access files stored
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`remotely at a time when network connectivity was far less robust than it presently
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`is (owing to the inception of widespread usage of laptop computers that often
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`Dropbox Ex. 1037
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`accessed a network over a dial-up network connection). Coda’s storage of files on
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`a portable computer, which were also stored on a server, provided a novel solution
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`to the problem of slow or spotty network connections.
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`9.
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`In preparation for the class discussion of Coda, I assigned as reading a
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`paper discussing how the Coda file system synchronized files between clients
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`(e.g., a portable laptop computer) and servers to allow access to files even if
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`network connectivity was poor. That paper is entitled “Disconnected Operation in
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`the Coda File System,” and was written by James J. Kistler and Mahadev
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`Satyanarayanan. I consider this paper to be a seminal paper in the field of
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`distributed systems and I know that many computer science professors have
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`included the paper as an assigned reading in their courses.
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`10. Two versions of the paper can be found on the class-readings
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`webpage I mentioned earlier, http://pages.cs.wisc.edu/~remzi/Classes/736/
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`Spring2000/Papers/, and can be seen in Exhibit 1038. One is entitled “coda-
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`sosp.pdf.” When I was collecting material in order to teach the CS 736 class, I
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`found this copy of the “Disconnected Operation in the Coda File System” through
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`a web search engine. As can be seen from the webpage, the Last Modified date
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`for this file is “27-Dec-1999,” or December 27, 1999. This is the date that I saved
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`a copy of this file onto the file system at the University of Wisconsin.
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`Dropbox Ex. 1037
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`I have compared the copy of the PDF version of the Coda paper on
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`11.
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`my class-readings webpage and the one submitted by Dropbox as Exhibit 1006.
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`They appear to me to be substantively identical to one another.
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`12. PDF documents include additional metadata that can be viewed using
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`Adobe Acrobat or Apple’s PDF Viewer. For instance, when I open the “coda-
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`sosp.pdf” file found on my website using Adobe Acrobat 11, I can then select the
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`“Properties” option under the “File” menu. On the “Description” tab, there is an
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`“Additional Metadata…” button. When I click on this button, in the left-hand
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`pane I see “Description” and “Advanced.” When I click on “Advanced,” I see
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`three options, one of which is “XMP Core Properties (xmp,
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`http://ns.adobe.com/xap/1.0/).” When I click on the plus sign to expand that
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`option, I see two entries: “xmp:CreateDate: 1998-09-10T18:43:34” and
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`“xmp:CreatorTool: M Satya and Scribe 7(1700).” I understand the “CreateDate”
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`field to mean that the file was created on 1998-09-10 and that the “CreatorTool”
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`filed to indicate the file was created by a user who was identified on the system
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`used to create the file as “M Satya.” The identification of the user who created the
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`file is consistent with my understanding that an author, in this case Dr. Mahadev
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`Satyanarayanan, identified within the PDF as “M Satya,” created the file.
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`13.
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`It is my opinion from this information that the PDF version of the
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`Coda paper was created on September 10, 1998. Based on my ability to locate the
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`Dropbox Ex. 1037
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`paper through a web search, it is also my opinion that the version of the Coda
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`paper submitted as Exhibit 1006 was publicly accessible to an interested person of
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`ordinary skill exercising reasonable diligence.
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`14.
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`I understand that this declaration will be filed as evidence in a
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`contested case before the Patent Trial and Appeal Board of the United States
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`Patent and Trademark Office. I also understand that I may be subject to cross-
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`examination concerning this declaration, and I will appear for cross-examination,
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`if required of me, during the time allotted for cross-examination.
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`15.
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`I hereby declare that all of the statements made herein of my own
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`knowledge are true and that all statements made on information and belief are
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`believed to be true; and further that these statements were made with knowledge
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`that willful false statements and the like so made are punishable by fine or
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`imprisonment, or both, under Section 1001 of Title 18 of the United States Code.
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`Date: April 26th, 2017
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`_____________________
`Dr. Remzi Arpaci-Dusseau
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`Dropbox Ex. 1037
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