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