UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CISCO SYSTEMS, INC., DISH NETWORK, LLC,
`COMCAST CABLE COMMUNICATIONS, LLC,
`COX COMIVIUNICATIONS, INC.,
`TIME WARNER CABLE ENTERPRISES LLC,
`VERIZON SERVICES CORR, and ARRIS GROUP, INC.,
`Petitioner,1
`
`-VS.-
`
`TQ DELTA, LLC
`Patent Owner
`
`IPR2016-01020
`
`US. Patent No. 9,014,243
`IPR2016—01021
`
`US. Patent No. 8,718,158
`
`DECLARATION OF DAVID BADER
`
`UNDER 37 C.F.R. § 1.68
`
`1 DISH Network, LLC, who filed a Petition in IPR2017—00255, and Comcast
`Cable Communications, LLC, Cox Communications, Inc., Time Warner Cable
`Enterprises L.L.C., Verizon Services Corp., and ARRIS Group, Inc., who filed a
`Petition in IPR2017—00417, have been joined in this proceeding.
`
`CSCO—103 1
`
`Cisco V. TQ Delta
`Page 1 of 10
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CISCO SYSTEMS, INC., DISH NETWORK, LLC,
`COMCAST CABLE COMMUNICATIONS, LLC,
`COX COMIVIUNICATIONS, INC.,
`TIME WARNER CABLE ENTERPRISES LLC,
`VERIZON SERVICES CORR, and ARRIS GROUP, INC.,
`Petitioner,1
`
`-VS.-
`
`TQ DELTA, LLC
`Patent Owner
`
`IPR2016-01020
`
`US. Patent No. 9,014,243
`IPR2016—01021
`
`US. Patent No. 8,718,158
`
`DECLARATION OF DAVID BADER
`
`UNDER 37 C.F.R. § 1.68
`
`1 DISH Network, LLC, who filed a Petition in IPR2017—00255, and Comcast
`Cable Communications, LLC, Cox Communications, Inc., Time Warner Cable
`Enterprises L.L.C., Verizon Services Corp., and ARRIS Group, Inc., who filed a
`Petition in IPR2017—00417, have been joined in this proceeding.
`
`CSCO—103 1
`
`Cisco V. TQ Delta
`Page 1 of 10
`
`
`
`Declaration of David Bader under 37 C.F.R. § 1.68M
`
`1, David Bader, hereby declare as follows:
`
`1. I am a librarian at Haynes and Boone, LLP. I have worked in this
`
`capacity since March 1, 2000.
`
`2. CSCO-1023 is a true and accurate copy of a paper thatI purchased
`
`from the IEEE Xplore Digital Library, authored by Dennis J.G. Mestdagh and
`
`Paul M.P. Spruyt, titled “A Method to Reduce the Probability of Clipping in
`
`DMT-Based Transceivers.” The publication information provided by IEEE
`
`Xplore Digital Library and the date stamp in the publication itself indicates that
`
`CSCO-1023 was published in the periodical IEEE TRANSACTIONS ON
`
`COMMUNICATIONS, vol. 44, issue 10, in October 1996. I understand that IEEE
`
`Xplore Digital Library is a commercial database carrying documents available
`
`to the public. IEEE Xplore Digital Library is accessible to the public at the
`
`website https://Xplore.ieee.org/. Our library regularly relies upon the IEEE
`
`Xplore Digital Library database for access to such public documents. I
`
`understand that CSCO—1023 will be submitted in the inter partes review
`
`proceedings noted above.
`
`3. CSCO-1024 is a true and accurate copy of a paper that I purchased
`
`from the IEEE Xplore Digital Library, authored by Stefan H. Muller and
`
`Johannes B. Huber, titled “A Comparison of Peak Power Reduction Schemes
`
`CSCO—1031
`
`Cisco v. TQ Delta
`Page 2 of 10
`
`
`
`Declaration of David Bader under 37 C.F.R. § 1.68W
`
`for OFDM.” The publication information provided by IEEE Xplore Digital
`
`Library indicates that CSCO-1024 was presented at IEEE Global
`
`Telecommunications Conference held November 3—8, 1997, and published in
`
`the conference record of that conference (ISBN 0-7803-4198—8). I understand
`
`that IEEE Xplore Digital Library is a commercial database carrying documents
`
`available to the public. IEEE Xplore Digital Library is accessible to the public
`
`at the website https://Xplore.ieee.org/. Our library regularly relies upon the
`
`IEEE Xplore Digital Library database for access to such public documents. I
`
`understand that CSCO-1024 will be submitted in the inter partes review
`
`proceedings noted above.
`
`4. CSCO-1030 is a true and accurate copy of a paper that I purchased
`
`from the IEEE Xplore Digital Library, authored by Mohamed Zekri, Patrick
`
`Boets, and Leo Van Biesen, titled “DMT Signals with Low Peak-to—Average
`
`Power Ratio.” The publication information provided by IEEE Xplore Digital
`
`Library indicates that CSCO-103O was presented at IEEE International
`
`Symposium on Computers and Communications held July 6—8, 1999, and
`
`published in the proceedings of that conference (ISBN 0—7695-0250-4). I
`
`understand that IEEE Xplore Digital Library is a commercial database carrying
`
`documents available to the public. IEEE Xplore Digital Library is accessible to
`
`the public at the website https://xplore.ieee.org/. Our library regularly relies
`
`CSCO-1031
`
`Cisco V. TQ Delta
`Page 3 of 10
`
`
`
`Declaration of David Bader under 37 C.F.R. § 1.68
`
`upon the IEEE Xplore Digital Library database for access to such public
`
`documents. I understand that CSCO-1030 will be submitted in the inter partes
`
`review proceedings noted above.
`
`5. CSCO-1032 is a true and accurate copy of a paper that I purchased
`
`from the IEEE Xplore Digital Library, authored by Kamran Sistanizadeh, Peter
`
`S. Chow, and John M. Cioffi, titled “Multi-Tone Transmission for Asymmetric
`
`Digital Subscriber Lines (ADSL).” The publication information provided by
`
`IEEE Xplore Digital Library indicates that CSCO-1032 was presented at IEEE
`
`International Conference on Communications held May 23—26, 1993, and
`
`published in the record of that conference (ISBN 0-7803—0950—2). I understand
`
`that IEEE Xplore Digital Library is a commercial database carrying documents
`
`available to the public. IEEE Xplore Digital Library is accessible to the public
`
`at the website https://xplore.ieee.org/. Our library regularly relies upon the
`
`IEEE Xplore Digital Library database for access to such public documents. I
`
`understand that CSCO—1032 will be submitted in the inter partes review
`
`proceedings noted above.
`
`6. CSCO—1033 is a true and accurate copy of a paper that I purchased
`
`from the IEEE Xplore Digital Library, authored by Peter S. Chow, and John M.
`
`Cioffi, and John A.C. Bingham, titled “A Practical Discrete Multitone
`
`Transceiver Loading Algorithm for Data Transmission over Spectrally Shaped
`
`CSCO-1031
`
`Cisco V. TQ Delta
`Page 4 of 10
`
`
`
`Declaration of David Bader under 37 CPR. § 1.68
`
`Channels.” The publication information provided by IEEE Xplore Digital
`
`Library indicates that CSCO-1033 was published in IEEE TRANSACTIONS ON
`
`COMMUNICATIONS, vol. 43, issue 234 (February/March/April 1995). I
`
`understand that IEEE Xplore Digital Library is a commercial database carrying
`
`documents available to the public. IEEE Xplore Digital Library is accessible to
`
`the public at the website https://xplore.ieee.org/. Our library regularly relies
`
`upon the IEEE Xplore Digital Library database for access to such public
`
`documents. I understand that CSCO—lO33 will be submitted in the inter partes
`
`review proceedings noted above.
`
`7. Attached as Appendix A is the true and accurate copy of the
`
`copyright registration record that I obtained from the Library of Congress that
`
`evidences that the book authored by Thomas Starr, John M. Cioffi, and Peter J.
`
`Silverman titled UNDERSTANDING DIGITAL SUBSCRIBER LINE TECHNOLOGY,
`
`with ISBN: 0-13—780545—4 was published at least as of December 29, 1998. I
`
`obtained Appendix A by first accessing the http://www.copyright.gov/ website,
`
`selecting the hyperlink “Search Copyright Records,” and performing a search
`
`by title for the above noted title, next clicking on the hyperlink for “Format for
`
`Print/Save,” then copying the record displayed on the resulting webpage.
`
`8. Attached as Appendix B is the true and accurate copy of the
`
`copyright registration record that I obtained from the Library of Congress that
`
`CSCO-1031
`
`Cisco v. TQ Delta
`Page 5 of 10
`
`
`
`Declaration of David Bader under 37 C.F.R. § 1.68
`
`W e
`
`vidences that the book authored by George Abe titled RESIDENTIAL
`
`BROADBAND, 2d ed., with ISBN: 1—57870—177—5 was published at least as of
`
`December 23, 1999. I obtained Appendix B by first accessing the
`
`http://www.copyright.gov/ website, selecting the hyperlink “Search Copyright
`
`Records,” and performing a search by title for the above noted title, next
`
`clicking on the hyperlink for “Format for Print/Save,” then copying the record
`
`displayed on the resulting webpage.
`
`9. I hereby declare under penalty of perjury under the laws of the United
`
`States of America that the foregoing is true and correct, and that all statements
`
`made of my own knowledge are true and that all statements made on
`
`information and belief are believed to be true. I understand that willful false
`
`statements are punishable by fine or imprisonment or both. See 18 U.S.C. §
`
`1001 .
`
`Date: June 7, 2017
`
`Respectfully submitted,
`
`David Bader
`
`CSCO- 1 03 1
`
`Cisco v. TQ Delta
`Page 6 of 10
`
`
`
`APPENDIX A
`
`CSCO-103 1
`
`Cisco V. TQ Delta
`Page 7 of 10
`
`
`
`Type of Work:
`
`Computer File
`
`Registration Number / Date:
`TX0004880052 / 1999-04-26
`
`Title:
`
`Understanding digital subscriber line technology / Thomas
`Starr, John M. Cioffi, Peter Silverman.
`
`Imprint:
`
`Upper Saddle River, NJ : Prentice Hall PTR,
`
`c1999.
`
`Description:
`
`CD—ROM + 474 p.
`
`Copyright Claimant:
`
`Prentice-Hall,
`
`Inc. Preexisting material: figures by ATIS.
`
`Date of Creation:
`
`1997
`
`Date of Publication:
`1998—12—29
`
`Copyright Note:
`
`NM:
`
`text & ill. and compilation on CD—ROM.
`
`Names:
`
`Starr, Thomas
`Cioffi, John M.
`Silverman, Peter
`Prentice—Hall,
`Inc.
`ATIS
`
`CSCO—1031
`
`Cisco V. TQ Delta
`Page 8 of 10
`
`
`
`APPENDIX B '
`
`CSCO-1031
`
`Cisco V. TQ Delta
`Page 9 of 10
`
`
`
`Type of Work:
`
`Text
`
`Registration Number / Date:
`TX0005127106 / 2000-01-13
`
`Title:
`
`Residential broadband / George Abe.
`
`Edition:
`
`2nd ed.
`
`Imprint:
`
`Indianapolis : Cisco Press,
`
`c2000.
`
`Description:
`
`387 p.
`
`Copyright Claimant:
`
`Cisco Press
`
`Date of Creation:
`
`1999
`
`Date of Publication:
`1999-12—23
`
`Names:
`
`Abe, George
`Cisco Press
`
`‘ (3500—1031
`
`Cisco V. TQ Delta
`Page 10 of 10
`
`
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