`
`_______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________
`
`VALVE CORPORATION
`
`Petitioner,
`
`v.
`
`IRONBURG INVENTIONS LTD.,
`
`Patent Owner.
`
`_______________________
`
`Case IPR2016-00949
`
`Patent 9,089,770
`
`_______________________
`
`DECLARATION OF EHAB M. SAMUEL
`
`IN SUPPORT OF THE PATENT OWNER RESPONSE
`
`IRONBURG EX2012
`
`
`
`I, Ehab M. Samuel, make the following Declaration pursuant to 28 U.S.C.
`
`IPR2016-00948
`Patent No. 8,641,525
`
`
`
`
`1746:
`
`1.
`
`I am an attorney with the law firm of Manatt, Phelps & Phillips, LLP,
`
`and counsel for Patent Owner Ironburg Inventions Ltd.
`
`2.
`
`I provide this Declaration in connection with the Patent Owner
`
`Response in the above-identified Inter Partes Review proceeding requested at the
`
`United States Patent and Trademark Office by Valve Corporation. Unless
`
`otherwise stated, the facts stated in this Declaration are based on my personal
`
`knowledge.
`
`3.
`
`Exhibit 2001 hereto is a true and correct copy of the prosecution
`
`history for U.S. Patent No. 8,541,525 entitled “CONTROLLER FOR VIDEO
`
`GAME CONSOLE.” An exhibit label and page number have been added to the
`
`bottom of each page of this exhibit, but no other alterations have been made.
`
`4.
`
`Exhibit 2003 hereto is a true and correct copy of Dr. Glen Stevick’s
`
`Curriculum Vitae. An exhibit label and page number have been added to the
`
`bottom of each page of this exhibit, but no other alterations have been made.
`
`5.
`
`Exhibit 2004 hereto is a true and correct copy of excerpts from
`
`Merriam-Webster’s Collegiate Dictionary (10th ed. 1998). An exhibit label and
`
`page number have been added to the bottom of each page of this exhibit, but no
`
`other alterations have been made.
`
`
`
`- 2 -
`
`IRONBURG EX2012
`
`
`
`
`
`6.
`
`Exhibit 2005 hereto is a true and correct copy of excerpts from
`
`IPR2016-00948
`Patent No. 8,641,525
`
`Webster’s New American Dictionary (1995). An exhibit label and page number
`
`have been added to the bottom of each page of this exhibit, but no other alterations
`
`have been made.
`
`7.
`
`Exhibit 2007 hereto is a true and correct copy of U.S. Patent No.
`
`7,859,514 entitled “MULTI-FUNCTIONAL USER INTERFACE FOR
`
`ELECTRONIC DEVICES.” An exhibit label and page number have been added to
`
`the bottom of each page of this exhibit, but no other alterations have been made.
`
`8.
`
`Exhibit 2008 hereto is a true and correct copy of a printout of the
`
`LinkedIn webpage for Simon Burgess. An exhibit label and page number have
`
`been added to the bottom of each page of this exhibit, but no other alterations have
`
`been made.
`
`9.
`
`Exhibit 2009 hereto is a true and correct copy of a printout of the
`
`LinkedIn webpage for Duncan Ironmonger. An exhibit label and page number
`
`have been added to the bottom of each page of this exhibit, but no other alterations
`
`have been made.
`
`10.
`
`I understand 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 matters stated
`
`herein, I could and would testify competently.
`
`
`
`- 3 -
`
`IRONBURG EX2012
`
`
`
`
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`IPR2016-00948
`Patent No. 8,641,525
`
`Executed this 17th day of January, 2017, at Los Angeles, California.
`
`
`
`
`
`
`
`
`
`/ Ehab M. Samuel /
` Ehab M. Samuel
`
`
`
`
`
`- 4 -
`
`IRONBURG EX2012
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