UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________
`
`VALVE CORPORATION
`
`Petitioner,
`
`v.
`
`IRONBURG INVENTIONS LTD.,
`
`Patent Owner.
`
`_______________________
`
`Case IPR2017-00136
`
`Patent 8,641,525
`
`_______________________
`
`DECLARATION OF EHAB M. SAMUEL
`
`IN SUPPORT OF THE PATENT OWNER PRELIMINARY RESPONSE
`
`
`
`
`
`IRONBURG EX2013
`
`
`
`_______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________
`
`VALVE CORPORATION
`
`Petitioner,
`
`v.
`
`IRONBURG INVENTIONS LTD.,
`
`Patent Owner.
`
`_______________________
`
`Case IPR2017-00136
`
`Patent 8,641,525
`
`_______________________
`
`DECLARATION OF EHAB M. SAMUEL
`
`IN SUPPORT OF THE PATENT OWNER PRELIMINARY RESPONSE
`
`
`
`
`
`IRONBURG EX2013
`
`
`
`I, Ehab M. Samuel, make the following Declaration pursuant to 28 U.S.C.
`
`IPR2017-00136
`Patent No. 8,641,525
`
`
`
`
`1746:
`
`1.
`
`I am an attorney with the law firm of Manatt, Phelps & Phillips, LLP,
`
`and counsel for Patent Owner Ironburg Inventions Ltd.
`
`2.
`
`I provide this Declaration in connection with the Patent Owner
`
`Preliminary Response in the above-identified Inter Partes Review proceeding
`
`requested at the United States Patent and Trademark Office by Valve Corporation.
`
`Unless otherwise stated, the facts stated in this Declaration are based on my
`
`personal knowledge.
`
`3.
`
`Exhibit 2004 hereto is a true and correct copy of excerpts from
`
`Merriam-Webster’s Collegiate Dictionary (10th ed. 1998). An exhibit label and
`
`page number have been added to the bottom of each page of this exhibit, but no
`
`other alterations have been made.
`
`4.
`
`Exhibit 2005 hereto is a true and correct copy of excerpts from
`
`Webster’s New American Dictionary (1995). An exhibit label has been added to
`
`the bottom of each page of this exhibit, but no other alterations have been made.
`
`5.
`
`Exhibit 2006 hereto is a true and correct copy of the prosecution
`
`history for U.S. Patent No. 8,641,525 entitled “CONTROLLER FOR VIDEO
`
`GAME CONSOLE.” An exhibit label and page number have been added to the
`
`bottom of each page of this exhibit, but no other alterations have been made.
`
`
`
`- 2 -
`
`IRONBURG EX2013
`
`
`
`
`
`6.
`
`Exhibit 2007 hereto is a true and correct copy of U.S. Patent No.
`
`IPR2017-00136
`Patent No. 8,641,525
`
`7,859,514 entitled “MULTI-FUNCTIONAL USER INTERFACE FOR
`
`ELECTRONIC DEVICES.” An exhibit label has been added to the bottom of
`
`each page of this exhibit, but no other alterations have been made.
`
`7.
`
`Exhibit 2008 hereto is a true and correct copy of a printout of the
`
`LinkedIn webpage for Simon Burgess. An exhibit label and page number have
`
`been added to the bottom of each page of this exhibit, but no other alterations have
`
`been made.
`
`8.
`
`Exhibit 2009 hereto is a true and correct copy of a printout of the
`
`LinkedIn webpage for Duncan Ironmonger. An exhibit label and page number
`
`have been added to the bottom of each page of this exhibit, but no other alterations
`
`have been made.
`
`9.
`
`Exhibit 2014 hereto is a true and correct copy of the prosecution
`
`history for U.S. Patent No. 9,089,770 entitled “CONTROLLER FOR VIDEO
`
`GAME CONSOLE.” An exhibit label and page number have been added to the
`
`bottom of each page of this exhibit, but no other alterations have been made.
`
`10. Exhibit 2015 hereto is a true and correct copy of Petitioner’s first
`
`Corrected Petition for Inter Partes Review of U.S. Patent No. 8,641,525 in
`
`IPR2016-00948. An exhibit label and page number have been added to the bottom
`
`of each page of this exhibit, but no other alterations have been made.
`
`
`
`- 3 -
`
`IRONBURG EX2013
`
`
`
`
`
`11. Exhibit 2016 hereto is a true and correct copy of the Patent Trial &
`
`IPR2017-00136
`Patent No. 8,641,525
`
`Appeals Board’s Institution Decision in the Inter Partes Review of U.S. Patent No.
`
`8,641,525, IPR2016-00948, Paper 10 (September 27, 2016). An exhibit label and
`
`page number have been added to the bottom of each page of this exhibit, but no
`
`other alterations have been made.
`
`12. Exhibit 2017 hereto is a true and correct copy of an excerpt from the
`
`KR C2 Seminar Workbook of Basic Robot Programming, Release 4.1, by Kuka
`
`Roboter GmbH. An exhibit label and page number have been added to the bottom
`
`of each page of this exhibit, but no other alterations have been made. Additional
`
`information on Kuka Roboter’s KR C2 controller is available at www.kuka.com.
`
`13. Exhibit 2018 hereto is a true and correct copy of a printout of a
`
`webpage from www.GebrauchtRoboter.com regarding the Kuka KRC2 Controller,
`
`located at
`
`http://www.gebrauchtroboter.com/zubeh_angeb/W044_KCP2ed/zubeh_angebot.ht
`
`ml. An exhibit label and page number have been added to the bottom of each page
`
`of this exhibit, but no other alterations have been made.
`
`14. Exhibit 2019 hereto is a true and correct copy of a printout of a
`
`webpage from www.eurobots.net regarding the Kuka KRC2 Controller, located at
`
`http://www.eurobots.net/kuka-robots-kr360-on-linear-track-kl1500-p243-en.html.
`
`
`
`- 4 -
`
`IRONBURG EX2013
`
`
`
`
`An exhibit label and page number have been added to the bottom of each page of
`
`IPR2017-00136
`Patent No. 8,641,525
`
`this exhibit, but no other alterations have been made.
`
`15. Exhibit 2020 hereto is a true and correct copy of a printout of a
`
`webpage from www.ebay.com regarding the Kuka KRC2 Controller, located at
`
`http://www.ebay.com/itm/Kuka-KR200-Robot-w-KRC2-Controller-Pendant-
`
`Complete-ABB-Fanuc-Motoman-Nachi-/172362843522?hash=item2821a04582.
`
`An exhibit label and page number have been added to the bottom of each page of
`
`this exhibit, but no other alterations have been made.
`
`16. Exhibit 2021 hereto is a true and correct copy of a Motion for Leave
`
`to Amend Complaint filed on June 20, 2016 by Patent Owner in the underlying
`
`district court case before the U.S. District Court for the Northern District of
`
`Georgia (Case Docket No. 1:15-cv-04219-TWT) . An exhibit label and page
`
`number have been added to the bottom of each page of this exhibit, but no other
`
`alterations have been made.
`
`17.
`
`I have reviewed the above-referenced Case Docket No. 1:15-cv-
`
`04219-TWT. The Second Amended Complaint was then filed on August 15, 2016
`
`to add allegations of infringement of U.S. Patent No. 9,352,229.
`
`18.
`
`I understand that willful false statements and the like are punishable
`
`by fine or imprisonment, or both. I make this declaration of my own personal
`
`
`
`- 5 -
`
`IRONBURG EX2013
`
`
`
`
`knowledge, and all statements are true. If called to testify as to the matters stated
`
`IPR2017-00136
`Patent No. 8,641,525
`
`herein, I could and would testify competently.
`
` declare under penalty of perjury that the foregoing is true and correct.
`
` I
`
`Executed this 6th day of February, 2017, at Los Angeles, California.
`
`
`
`
`
`
`
`
`
`/ Ehab M. Samuel /
` Ehab M. Samuel
`
`
`
`
`
`- 6 -
`
`IRONBURG EX2013
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
