`
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________________
`
`RUBICON COMMUNICATIONS, LP
`
`Petitioner,
`
`
`
`v.
`
`
`
`LEGO A/S
`
`Patent Owner.
`
`________________________
`
`Case IPR2016-01187
`
`Patent 8,894,066
`
`
`
`DECLARATION OF CHRIS D. THOMPSON
`REGARDING PETITIONER’S EXHIBITS
`
`
`
`
`
`
`
`Rubicon Communications, LP – Exh. 1029
`Rubicon Communications, LP v. Lego A/S
`IPR2016-01187
`
`
`
`
`
`Declaration of Chris D. Thompson
`
`I, Chris D. Thompson, declare as follows:
`
`1.
`
`I am over the age of 18, and am competent to make this declaration. I
`
`have personal knowledge of the facts set forth herein, which are true and
`
`correct. I drafted the petition that was filed on June 10, 2016 in the above-
`
`captioned proceeding.
`
`2.
`
`Exhibit B1 of the original Petition consists of true and correct
`
`photocopies of pages from the book, Building Robots with Lego ®
`
`MindstormsTM: The ULTIMATE Tool for Mindstorms Maniacs!, by Mario
`
`Ferrari, Giulio Ferrari, and Ralph Hempel (the “Book”). The photocopies of
`
`the pages of the Book in Exhibit B1 were made under my direction. The
`
`copy of the Book from which the photocopies were made was obtained from
`
`the Austin Public Library (“APL”). The APL identifies the Book by Call
`
`Number 629.892 FE. The copyright page indicates that the Book was
`
`published by Syngress Publishing, Inc., and bears the copyright notice
`
`“Copyright © 2002”.
`
`3.
`
`Exhibit 1025 is a true and correct copy of pages at the following URL,
`
`https://web.archive.org/web/20040908132652/http://www.amazon.co
`
`m/exec/obidos/tg/detail/-/1928994679?v=glance
`
`
`
`- 2 -
`
`
`
`
`
`which was obtained from the Internet Archive, along with an affidavit of
`
`Christopher Butler, Office Manager with the Internet Archive, regarding the
`
`content and date of the pages from the Internet Archive. The pages show a
`
`listing of the Book as available for purchase on Amazon.com, along with
`
`book reviews from the 2002-2004 time frame.
`
`4.
`
`Exhibit 1026 is a true and correct copy of an email message from
`
`Katrin Abel, Reference Librarian with the APL. The foregoing email
`
`message includes a database entry indicating that a record for the Book was
`
`created by the APL on November 20, 2003.
`
`5.
`
`Exhibit 1027 is true and correct copy of a paper entitled Using Legos
`
`to Interest High School Students and Improve K12 STEM Education, by
`
`Lawrence E. Whitman and Tonya L. Witherspoon, for the 33rd ASEE/IEEE
`
`Frontiers in Education Conference, which was held from November 5-8,
`
`2003, in Boulder, Colorado. The paper includes a citation to the Book. The
`
`paper was found at the following URL:
`
`http://citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.120.1
`
`643&rep=rep1&type=pdf
`
`6.
`
`Exhibit B2, filed with the original petition, is a true and correct copy
`
`of pages found at the following URLs:
`
`
`
`- 3 -
`
`
`
`
`
`https://web.archive.org/web/20041204044616/http://www.philohome.
`
`com/mindstorms.htm
`
`https://web.archive.org/web/20041206160318/http://www.philohome.
`
`com/steercar/steeringcar.htm
`
`https://web.archive.org/web/20041208200048/http://philohome.com/s
`
`imon/bricksimon.htm
`
`https://web.archive.org/web/20041204051150/http://www.philohome.
`
`com/sensors.htm
`
`https://web.archive.org/web/20041204162945/http://www.philohome.
`
`com/sensors/rotsensor.htm
`
`The pages at these URLs are referred to in the original petition as “Philo’s
`
`Home Page.”
`
`7.
`
`Exhibit B3, filed with the original petition, is a true and correct copy
`
`of pages found at the following link:
`
`https://web.archive.org/web/20041204111548/http://www.plazaearth.
`
`com/usr/gasperi/lego.htm
`
`The page at this URL is referred to in the original petition as “Gasperi.”
`
`8.
`
`Exhibit 1028 is a true and correct copy of pages obtained from the
`
`Internet Archive for the URLs listed under Paragraphs 6 and 7, along with
`
`
`
`- 4 -
`
`
`
`
`
`an affidavit of Christopher Butler, Office Manager with the Internet Archive,
`
`regarding the content and date of the pages from the Internet Archive.
`
`I hereby declare that all statements made herein of my own knowledge are true and
`
`correct, and that any statements made on information and belief are believed to be
`
`true; and further that these statements are made with the knowledge that willful
`
`false statements and the like so made are punishable by fine or imprisonment, or
`
`both, under Section 1001 of Title 18 of the United States Code and that such
`
`willful false statements may jeopardize the validity of the application or any
`
`/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
`
`patents issued thereon.
`
`
`
`Date: January 6, 2017
`
`
`
`
`
`
`
`
`
`
`
`- 5 -
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