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`_______________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_______________________
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`VALVE CORPORATION
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`Petitioner,
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`v.
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`IRONBURG INVENTIONS LTD.,
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`Patent Owner.
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`_______________________
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`Case IPR2017-00136
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`Patent 8,641,525
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`_______________________
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`DECLARATION OF EHAB M. SAMUEL
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`IN SUPPORT OF THE PATENT OWNER PRELIMINARY RESPONSE
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`
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`IRONBURG EX2013
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`
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`I, Ehab M. Samuel, make the following Declaration pursuant to 28 U.S.C.
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`IPR2017-00136
`Patent No. 8,641,525
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`
`
`
`1746:
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`1.
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`I am an attorney with the law firm of Manatt, Phelps & Phillips, LLP,
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`and counsel for Patent Owner Ironburg Inventions Ltd.
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`2.
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`I provide this Declaration in connection with the Patent Owner
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`Preliminary Response in the above-identified Inter Partes Review proceeding
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`requested at the United States Patent and Trademark Office by Valve Corporation.
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`Unless otherwise stated, the facts stated in this Declaration are based on my
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`personal knowledge.
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`3.
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`Exhibit 2004 hereto is a true and correct copy of excerpts from
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`Merriam-Webster’s Collegiate Dictionary (10th ed. 1998). An exhibit label and
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`page number have been added to the bottom of each page of this exhibit, but no
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`other alterations have been made.
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`4.
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`Exhibit 2005 hereto is a true and correct copy of excerpts from
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`Webster’s New American Dictionary (1995). An exhibit label has been added to
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`the bottom of each page of this exhibit, but no other alterations have been made.
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`5.
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`Exhibit 2006 hereto is a true and correct copy of the prosecution
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`history for U.S. Patent No. 8,641,525 entitled “CONTROLLER FOR VIDEO
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`GAME CONSOLE.” An exhibit label and page number have been added to the
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`bottom of each page of this exhibit, but no other alterations have been made.
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`- 2 -
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`IRONBURG EX2013
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`6.
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`Exhibit 2007 hereto is a true and correct copy of U.S. Patent No.
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`IPR2017-00136
`Patent No. 8,641,525
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`7,859,514 entitled “MULTI-FUNCTIONAL USER INTERFACE FOR
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`ELECTRONIC DEVICES.” An exhibit label has been added to the bottom of
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`each page of this exhibit, but no other alterations have been made.
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`7.
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`Exhibit 2008 hereto is a true and correct copy of a printout of the
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`LinkedIn webpage for Simon Burgess. An exhibit label and page number have
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`been added to the bottom of each page of this exhibit, but no other alterations have
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`been made.
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`8.
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`Exhibit 2009 hereto is a true and correct copy of a printout of the
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`LinkedIn webpage for Duncan Ironmonger. An exhibit label and page number
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`have been added to the bottom of each page of this exhibit, but no other alterations
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`have been made.
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`9.
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`Exhibit 2014 hereto is a true and correct copy of the prosecution
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`history for U.S. Patent No. 9,089,770 entitled “CONTROLLER FOR VIDEO
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`GAME CONSOLE.” An exhibit label and page number have been added to the
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`bottom of each page of this exhibit, but no other alterations have been made.
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`10. Exhibit 2015 hereto is a true and correct copy of Petitioner’s first
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`Corrected Petition for Inter Partes Review of U.S. Patent No. 8,641,525 in
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`IPR2016-00948. An exhibit label and page number have been added to the bottom
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`of each page of this exhibit, but no other alterations have been made.
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`- 3 -
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`IRONBURG EX2013
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`
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`11. Exhibit 2016 hereto is a true and correct copy of the Patent Trial &
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`IPR2017-00136
`Patent No. 8,641,525
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`Appeals Board’s Institution Decision in the Inter Partes Review of U.S. Patent No.
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`8,641,525, IPR2016-00948, Paper 10 (September 27, 2016). An exhibit label and
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`page number have been added to the bottom of each page of this exhibit, but no
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`other alterations have been made.
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`12. Exhibit 2017 hereto is a true and correct copy of an excerpt from the
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`KR C2 Seminar Workbook of Basic Robot Programming, Release 4.1, by Kuka
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`Roboter GmbH. An exhibit label and page number have been added to the bottom
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`of each page of this exhibit, but no other alterations have been made. Additional
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`information on Kuka Roboter’s KR C2 controller is available at www.kuka.com.
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`13. Exhibit 2018 hereto is a true and correct copy of a printout of a
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`webpage from www.GebrauchtRoboter.com regarding the Kuka KRC2 Controller,
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`located at
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`http://www.gebrauchtroboter.com/zubeh_angeb/W044_KCP2ed/zubeh_angebot.ht
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`ml. An exhibit label and page number have been added to the bottom of each page
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`of this exhibit, but no other alterations have been made.
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`14. Exhibit 2019 hereto is a true and correct copy of a printout of a
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`webpage from www.eurobots.net regarding the Kuka KRC2 Controller, located at
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`http://www.eurobots.net/kuka-robots-kr360-on-linear-track-kl1500-p243-en.html.
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`- 4 -
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`IRONBURG EX2013
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`
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`An exhibit label and page number have been added to the bottom of each page of
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`IPR2017-00136
`Patent No. 8,641,525
`
`this exhibit, but no other alterations have been made.
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`15. Exhibit 2020 hereto is a true and correct copy of a printout of a
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`webpage from www.ebay.com regarding the Kuka KRC2 Controller, located at
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`http://www.ebay.com/itm/Kuka-KR200-Robot-w-KRC2-Controller-Pendant-
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`Complete-ABB-Fanuc-Motoman-Nachi-/172362843522?hash=item2821a04582.
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`An exhibit label and page number have been added to the bottom of each page of
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`this exhibit, but no other alterations have been made.
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`16. Exhibit 2021 hereto is a true and correct copy of a Motion for Leave
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`to Amend Complaint filed on June 20, 2016 by Patent Owner in the underlying
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`district court case before the U.S. District Court for the Northern District of
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`Georgia (Case Docket No. 1:15-cv-04219-TWT) . An exhibit label and page
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`number have been added to the bottom of each page of this exhibit, but no other
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`alterations have been made.
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`17.
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`I have reviewed the above-referenced Case Docket No. 1:15-cv-
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`04219-TWT. The Second Amended Complaint was then filed on August 15, 2016
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`to add allegations of infringement of U.S. Patent No. 9,352,229.
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`18.
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`I understand that willful false statements and the like are punishable
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`by fine or imprisonment, or both. I make this declaration of my own personal
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`- 5 -
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`IRONBURG EX2013
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`
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`knowledge, and all statements are true. If called to testify as to the matters stated
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`IPR2017-00136
`Patent No. 8,641,525
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`herein, I could and would testify competently.
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` declare under penalty of perjury that the foregoing is true and correct.
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` I
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`Executed this 6th day of February, 2017, at Los Angeles, California.
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`/ Ehab M. Samuel /
` Ehab M. Samuel
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`- 6 -
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`IRONBURG EX2013
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`