DECLARATION
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`I, Crystal Daugherty, declare that the following statements are true and correct to the
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`best of my knowledge, information and belief:
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`I.
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`I am a Author School Relations Customer Service employed by ProQuest LLC
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`("ProQuest") in Ann Arbor. Michigan. I have worked for ProQuest since 1990 (26
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`years). ProQuest is an information company that collects, organizes publishes and
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`distributes for sale content from a wide range of sources, including dissertations and
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`master’s theses. A "Record" (as defined in paragraph 3) of each dissertation and each
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`master’s thesis submitted to ProQuest is published in ProQuest’s print publication
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`Dissertations Abstracts International or Master’s Abstracts International, respectively,
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`as well as our ProQuest® Digital Dissertations and Theses Database ("Abstract
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`Database").1 I am fully familiar with ProQuest’s sales and publication practices as well
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`as the Abstract Database.
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`.
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`,
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`ProQuest receives dissertations and master’s theses from participating degree granting
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`institutions. Shortly after these works are received, ProQuest makes them available for
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`sale to the public, unless specifically restricted from sales by the dissertation author or
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`the degree granting institution.
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`I am fully familiar with ProQuest’s business practices in relation to its dissertations and
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`master’s theses publishing program. ProQuest maintains a Record for each dissertation
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`or master’s thesis. At the time of publication of the Dissertation in question (the full
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`citation is provided in paragraph 6 below), ProQuest published in the Abstract Database
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`I This Database has been maintained exclusively by ProQuest under various corporate
`names, including Bell & Howell Information and Learning Company, ProQuest
`Information and Learning Company, UMI Company and University Microfilms, Inc.
`and has been licensed to subscribers under various product names including
`"’Dissertation Abstracts Online" and "ProQuest~, Digital Dissertations." ProQuest LLC
`(and its predecessor entities) is and at all times has been a U.S. Company based in Ann
`Arbor, MI.
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`LG Electronics, Inc. et al.
`EXHIBIT 1023
`IPR Petition for
`U.S. Patent No. 7,149,511
`Page 1 of 3
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`a Record of each dissertation and each master’s thesis that ProQuest offers for sale with
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`records added on a monthly basis. The Abstract Database is widely available
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`throughout the United States. Currently approximately 1,500 institutions subscribe to
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`the database. Each Record consists of an abstract, index record and citation. Once a
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`Record is published on the Abstract Database, the Record is available to the students,
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`faculty, staff and/or patrons of any institutions that subscribe to the Abstract Database.
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`At the time of the Dissertation’s publication, the publication of the print publication
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`Dissertations Abstracts International (DAI) occurred on a monthly basis, a
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`dissertation may be available for sale before its Record is published in the print edition.
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`Once ProQuest has received a work and made it available for sale, the work may be
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`ordered in print, microform and for dissertations published after 1997 in PDF form,
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`even if the Record has not yet been included in a print edition of DAI.
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`Originally, Records were published only in the print publications Dissertations
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`Abstracts International and Master’s Abstracts International. In 1985, the Records in
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`these print publications were combined to create the Abstract Database which was
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`made available online through third party vendors, including Dialog. In 1987, ProQuest
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`began to offer the Abstract Database on CD ROM, and in 1997, ProQuest made
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`available the contents of the Abstract Database in its ProQuest Digital Dissertations and
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`Theses service ("PQDT"). which is accessible via the world wide web to authenticated
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`subscribers. The PQDT service includes the Dissertation Abstracts International
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`Records and the Master’s Theses International Records and is supplemented by the
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`addition of certain select dissertations and master’s theses in PDF format. Whether a
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`dissertation is represented in full PDF format varies based on a number of factors,
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`including the format in which the dissertation or theses was originally submitted for
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`publication (digital, paper or microfiche) or whether the dissertation or theses was part
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`of a retrospective digitization effort.
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`I have reviewed ProQuest’s records regarding the dissertation cited as:
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`Dissertation No. :
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`9708664
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`Title:
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`Degree Date:
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`University:
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`A new filesystemformobilecomputing
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`1997
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`University ofNotre Dame
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`DAI Volume:
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`DAI 57-10
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`These records show that the Dissertation was received by ProQuest on December 2,
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`1996 and first made available for sale on February 5, 1997. The full text of the
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`dissertation was released in PDF format in PQDT on February I0, 2006, and made
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`available for sale in microfilm, print and/or PDF formats. A Record of the Dissertation
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`was published in the print edition of Dissertation Abstracts International (DAI) volume
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`and publication date noted above. The print edition of DAI was distributed to
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`subscribing Academic Research Libraries, including those located in the United States.
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`The Record was made available online via third party vendors, including Dialog, as part
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`of the Abstract Database which was made available via such vendors in the ordinary
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`course of business on or about the same time as the print publication.
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`The attached print copy of the Dissertation is a true and complete copy of the
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`.
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`Dissertation as originally published and kept by ProQuest in the ordinary course of its
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`business.
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`I declare that the foregoing is true and correct to the best of my information, knowledge
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`and belief after reasonable investigation.
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`Cr) I Dau
`Author School
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`REV.27jan2015/,.ID.
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`pmer Service
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`Page 3 of 3