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`______________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`______________________
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`RUBICON COMMUNICATIONS, LP
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`Petitioner,
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`v.
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`LEGO A/S
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`Patent Owner.
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`________________________
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`Case IPR2016-01187
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`Patent 8,894,066
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`
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`DECLARATION OF CHRIS D. THOMPSON
`REGARDING PETITIONER’S EXHIBITS
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`Rubicon Communications, LP – Exh. 1029
`Rubicon Communications, LP v. Lego A/S
`IPR2016-01187
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`
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`Declaration of Chris D. Thompson
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`I, Chris D. Thompson, declare as follows:
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`1.
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`I am over the age of 18, and am competent to make this declaration. I
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`have personal knowledge of the facts set forth herein, which are true and
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`correct. I drafted the petition that was filed on June 10, 2016 in the above-
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`captioned proceeding.
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`2.
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`Exhibit B1 of the original Petition consists of true and correct
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`photocopies of pages from the book, Building Robots with Lego ®
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`MindstormsTM: The ULTIMATE Tool for Mindstorms Maniacs!, by Mario
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`Ferrari, Giulio Ferrari, and Ralph Hempel (the “Book”). The photocopies of
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`the pages of the Book in Exhibit B1 were made under my direction. The
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`copy of the Book from which the photocopies were made was obtained from
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`the Austin Public Library (“APL”). The APL identifies the Book by Call
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`Number 629.892 FE. The copyright page indicates that the Book was
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`published by Syngress Publishing, Inc., and bears the copyright notice
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`“Copyright © 2002”.
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`3.
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`Exhibit 1025 is a true and correct copy of pages at the following URL,
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`https://web.archive.org/web/20040908132652/http://www.amazon.co
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`m/exec/obidos/tg/detail/-/1928994679?v=glance
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`which was obtained from the Internet Archive, along with an affidavit of
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`Christopher Butler, Office Manager with the Internet Archive, regarding the
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`content and date of the pages from the Internet Archive. The pages show a
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`listing of the Book as available for purchase on Amazon.com, along with
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`book reviews from the 2002-2004 time frame.
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`4.
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`Exhibit 1026 is a true and correct copy of an email message from
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`Katrin Abel, Reference Librarian with the APL. The foregoing email
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`message includes a database entry indicating that a record for the Book was
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`created by the APL on November 20, 2003.
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`5.
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`Exhibit 1027 is true and correct copy of a paper entitled Using Legos
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`to Interest High School Students and Improve K12 STEM Education, by
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`Lawrence E. Whitman and Tonya L. Witherspoon, for the 33rd ASEE/IEEE
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`Frontiers in Education Conference, which was held from November 5-8,
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`2003, in Boulder, Colorado. The paper includes a citation to the Book. The
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`paper was found at the following URL:
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`http://citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.120.1
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`643&rep=rep1&type=pdf
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`6.
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`Exhibit B2, filed with the original petition, is a true and correct copy
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`of pages found at the following URLs:
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`https://web.archive.org/web/20041204044616/http://www.philohome.
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`com/mindstorms.htm
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`https://web.archive.org/web/20041206160318/http://www.philohome.
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`com/steercar/steeringcar.htm
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`https://web.archive.org/web/20041208200048/http://philohome.com/s
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`imon/bricksimon.htm
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`https://web.archive.org/web/20041204051150/http://www.philohome.
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`com/sensors.htm
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`https://web.archive.org/web/20041204162945/http://www.philohome.
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`com/sensors/rotsensor.htm
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`The pages at these URLs are referred to in the original petition as “Philo’s
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`Home Page.”
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`7.
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`Exhibit B3, filed with the original petition, is a true and correct copy
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`of pages found at the following link:
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`https://web.archive.org/web/20041204111548/http://www.plazaearth.
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`com/usr/gasperi/lego.htm
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`The page at this URL is referred to in the original petition as “Gasperi.”
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`8.
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`Exhibit 1028 is a true and correct copy of pages obtained from the
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`Internet Archive for the URLs listed under Paragraphs 6 and 7, along with
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`- 4 -
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`an affidavit of Christopher Butler, Office Manager with the Internet Archive,
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`regarding the content and date of the pages from the Internet Archive.
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`I hereby declare that all statements made herein of my own knowledge are true and
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`correct, and that any statements made on information and belief are believed to be
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`true; and further that these statements are made with the knowledge that willful
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`false statements and the like so made are punishable by fine or imprisonment, or
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`both, under Section 1001 of Title 18 of the United States Code and that such
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`willful false statements may jeopardize the validity of the application or any
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`/Chris D. Thompson/
`Chris D. Thompson
`Reg. No. 43,188
`cthompson@intprop.com
`MEYERTONS, HOOD,
`KIVLIN, KOWERT &
`GOETZEL
`1120 S. Capital of Texas Hwy.
`Building 2, Suite 300
`Austin, Texas 78746
`(512) 853-8877
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`patents issued thereon.
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`Date: January 6, 2017
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