`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`MICROSOFT CORPORATION
`Petitioner
`
`
`v.
`
`
`
`PROXYCONN, INC.
`Patent Owner
`
`____________
`
`U.S. Patent No. 6,757,717 B1
`Issued: June 29, 2004
`Application No. 09/398,007
`Filed: September 16, 1999
`Title: SYSTEM AND METHOD FOR DATA ACCESS
`
`____________
`
`DECLARATION OF MARLA BEIER IN SUPPORT
`OF PETITION FOR INTER PARTES REVIEW OF CLAIM NOS.
`15, 16, 17, 19, 20, 21, 25, 26, AND 27 OF U.S. PATENT NO. 6,757,717
`
`
`Page 1
`
`
`
`
`
`I, Marla Beier, declare as follows:
`
`1.
`
`I am over 18 years of age and a paralegal employed by Klarquist
`
`Sparkman, LLP. I make this declaration based on my own knowledge, personal
`
`experience, and belief. If called upon, I can competently testify to the facts stated in
`
`this declaration.
`
`2.
`
`This declaration is submitted in support of Petitioner’s Request for Inter
`
`Partes Review of claims 15-17, 19-21, and 25-27 of U.S. Patent No. 6,757,717
`
`(“Petition”).
`
`3.
`
`On Friday, November 4, 2016 I used the Internet to visit the portion of
`
`W3C’s website located at http://www.w3.org/Submission/1997/10/Comment.html,
`
`which is a page labeled “W3C Staff Note on HTTP Distribution and Replication
`
`Protocol Submission” and contains a note dated August 27, 1997, regarding
`
`Novadigm’s assertion of patent rights and suit filed against Marimba in March of
`
`1997. I converted that page to a PDF file that accurately reflects the contents of the
`
`Web site and the image of the page on my computer on which the PDF was created.
`
`A true and correct copy of that PDF is filed concurrently with this declaration as
`
`Exhibit 1014 to the Petition.
`
`4.
`
`On Friday, November 4, 2016 I utilized the Internet to visit the portion
`
`of W3C’s website located at http://www.w3.org/Submission/1997/10/, which is a
`
`page labeled “HTTP Distribution and Replication Protocol Submission Request to
`
`Declaration of Marla Beier
`
`
`
`Page 2
`
`
`
`
`
`the World Wide Web Consortium consisting of a joint submission request by W3C
`
`Members Marimba, Inc., Netscape Communications Corp., Novell, Inc., Sun
`
`Microsystems, Inc. and @Home Network, Inc.,” dated August 20, 1997. I converted
`
`that page to a PDF file that accurately reflects the contents of the Web site and the
`
`image of the page on my computer on which the PDF was created. A true and correct
`
`copy of that PDF is filed concurrently with this declaration as Exhibit 1015 to the
`
`Petition.
`
`5.
`
`On Wednesday, August 17, 2016 I utilized the Internet to visit
`
`https://web.archive.org/web/19980213220701/http:/www13.w3.org/Submission/,
`
`which is an archived page of W3C’s website as it appeared on February 13, 1998,
`
`when it was preserved by the Internet archive. The page is titled “Acknowledged
`
`Submissions to W3C.” I converted that page to a PDF file that accurately reflects
`
`the contents of the Web site and the image of the page on my computer on which the
`
`PDF was created. A true and correct copy of that PDF is filed concurrently with this
`
`declaration as Exhibit 1016 to the Petition.
`
`6.
`
`Filed concurrently with this declaration as Exhibit 1017 to the Petition,
`
`is a true and correct copy of excerpts from InfoWorld Magazine, Vol. 19, Issue 35,
`
`dated September 1, 1997 containing an article titled, Marimba, friends support data
`
`replication protocol - Proposed standard sent to W3C, authored by Lynda
`
`Radosevich.
`
`Declaration of Marla Beier
`
`
`
`Page 3
`
`
`
`
`
`7.
`
`Filed concurrently with this declaration as Exhibit 1018 to the Petition,
`
`is a true and correct copy of excerpts from NetworkWorld Magazine, Vol. 14,
`
`Number 35, dated September 1, 1997 containing an article titled, Vendors push for
`
`‘Net replication standard, authored by Chris Nerney.
`
`8.
`
`On Wednesday, August 17, 2016 I utilized the Internet to visit
`
`https://web.archive.org/web/19980213183443/http:/www13.w3.org/Architecture/9
`
`709_Workshop/, which is an archived page of W3C’s website as it appeared on
`
`February 13, 1998, when it was preserved by the Internet archive. The page is titled
`
`“W3C Workshop on Push Technology.” I converted that page to a PDF file that
`
`accurately reflects the contents of the Web site and the image of the page on my
`
`computer on which the PDF was created. A true and correct copy of that PDF is filed
`
`concurrently with this declaration as Exhibit 1019 to the Petition.
`
`I declare under the penalty of perjury under the laws of the United States that
`
`the foregoing is true and correct.
`
`Executed on the 14th day of November, 2016, in Portland, Oregon.
`
`
`
`_____________________________
`Marla Beier
`
`Declaration of Marla Beier
`
`
`
`Page 4
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