`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`VALVE CORPORATION,
`
`Petitioner,
`
`V.
`
`IRONBURG INVENTIONS LTD.,
`
`Patent Owner.
`
`Case IPR2017-00136
`
`Patent 8,641,525
`
`Case IPR2017-00137
`
`Patent 9,089,770
`
`DECLARATION OF NICOLETA COSEREANU IN SUPPORT OF
`
`IRONBURG INVENTIONS LTD.’S PATENT OWNER RESPONSE
`
`IRONBURG EX2012, Page 1
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`IRONBURG EX2012, Page 1
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`
`
`I, Nicoleta Cosereanu, declare the following:
`
`1.
`
`I make this declaration based on my own personal knowledge.
`
`2.
`
`I am an employee of Scuf Gaming International LLC, my title is Finance
`
`Director, and 1 have been at Scuf Gaming International LLC since 2012.
`
`3. Scuf Gaming International LLC is a licensee of the Ironburg Inventions, Ltd.
`
`patent portfolio, which includes U.S. Patent Nos. 8,641,525 and 9,089,770.
`
`Scuf Gaming International LLC began marketing and offering for sale
`
`controller products with elongated back controls (“Scuf controller products”)
`
`in July 2011.
`
`. The first Scuf controller product offered in 201 1 was the Scuf Controller for
`
`use with Xbox 360 and PC.
`
`. The Scuf controller product line has expanded to include the SCUF Hybrid
`
`and SCUF Infinity contollers, for use with Xbox 360 and PC, Xbox One,
`
`Playstation 3, and Playstation 4. All of these controllers have elongated
`
`back controls.
`
`7.
`
`8.
`
`9.
`
`Current Scuf controller products may be found at www.scufgaming.com.
`
`Scuf Gaming International LLC is a global leader and innovator in esports.
`
`Over 90% of the top professional gamers in the world use Scuf controller
`
`products.
`
`IRONBURG EX2012, Page 2
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`IRONBURG EX2012, Page 2
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`
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`l0.Scuf controller products allow a user to: (1) utilize more of their hands in
`
`games; (2) shorten their response time when performing actions; (3) access
`
`more activation points on paddles; and (4) avoid playing “CLAW” and
`
`reduce hand strain.
`
`1 l.The elongated back controls on the back of Scuf controller products can be
`
`accessed across the length to suit all hand positions comfortably and
`
`ergonomically.
`
`l2.Scuf Gaming International LLC is the official controller partner of major
`
`gaming leagues, including CWL, MLG, ESL, UMG, Gfinity, and EGL.
`
`l3.Attached as Exhibit 2010 is a true and correct copy ofthe “Scufology” page
`
`from Scuf Gaming lntemational LLC’s website at
`
`https://scufgaming.com/s/scufology/.
`
`14.As is shown in Exhibit 2010, the Scuf controller products are handheld video
`
`game controllers having a front, back, top, and bottom that have elongated
`
`back controls located on the back of the controller, where the elongated back
`
`controls extend substantially the full distance between the top edge and
`
`bottom edge ofthe controller, as in the claims of U.S. Patent No. 8,641,525,
`
`and at least half of a distance between the top and bottom of the controller,
`
`as in the claims of U.S. Patent No. 9,089,770.
`
`DJ
`
`IRONBURG EX2012, Page 3
`
`IRONBURG EX2012, Page 3
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`
`
`15.Attached as Exhibit 201] is a true and correct copy ofa press release by
`
`Scuf Gaming International LLC announcing its licensing agreement with
`
`Microsoft Corporation on October 15, 2015.
`
`16.Prior to the license agreement with Microsofi, the Microsoft Xbox
`
`controllers had no back controls on the back of the controller.
`
`Date: February 6, 2017
`
`Respectful]
`
`s bmitted,
`
`By:
`
`3l8233l7-‘Ill
`
`_/ 3%
`
`5'
`Nicoleta Cosereanu
`
`o
`
`IRONBURG EX2012, Page 4
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`IRONBURG EX2012, Page 4
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`
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