`FOR THE DISTRICT OF MASSACHUSETTS
`
`INTELLECTUAL VENTURES I, LLC, et al.
`
`Plaintiffs,
`
`v.
`
`EMC CORPORATION, et al.,
`
`Defendants.
`
`Civil Action No. I: 16-CV -1 0860-IT
`
`DECLARATION OF INTERNATIONAL BUSINESS MACHINES CORPORATION
`
`1.
`
`My name is Carol Edwards. 1 am over the age of eighteen and 1 am a Publications
`
`Business Area Expert at International Business Machines Corporation ("IBM") located at 6300
`
`Diagonal Highway, Boulder, Colorado. 1 make this declaration of my own personal knowledge
`
`and based upon my investigation of the matters herein as IBM's designated corporate witness.
`
`2.
`
`I understand copies of the documents listed in the table below were provided to
`
`IBM as Exhjbits A and B to a subpoena, dated December 7, 2016, that IBM received from EMC
`
`Corporation in connection with the above-captioned matter.
`
`Document
`Number
`SG24-6291 -00
`
`GA27-4274-00
`
`Document Title
`
`Using iSCSI Solutions' Planning and
`Implementation
`TotaiStorage JP Storage 200i Administrator's
`Guide
`
`Date of Public
`Availability
`February 25, 2002
`
`September 27, 200 1
`
`3.
`
`T he documents listed in the table above were drafted by someone with knowledge
`
`of the subject matter described in the documents on or about the dates indicated on the
`
`documents. Creating these types of documents is a regular business practice of IBM.
`
`LENOVO ET AL. EXHIBIT 1019
`Page 1 of 2
`
`
`
`4.
`
`These documents were publicly available from IBM as of the dates indicated
`
`above and have been kept and indexed by IBM using the above listed document numbers and
`
`titles in the course of its regularly conducted business since the indicated dates. Red books, such
`
`as document SG24-6291-00, have been indexed since at least February 2002 through search
`
`functionality provided on IBM's web site.
`
`5.
`
`Document number SG24-6291-00 was available to the public on February 25,
`
`2002, at http://www.redbooks.ibm.com/redbooks/pdfs/sg24629 l .pdf; where it remains accessible
`
`to the public today. This document has been made available and also provided to the public in
`
`hard copy form since on or about February 25, 2002.
`
`6.
`
`Likewise, document number GA27-4274-00 has been available and provided to
`
`the public since September 27,2001, through IBM's ftp site at
`
`ftp://fto.softwarc.ibm.com/storage/iscsi/tcchdocslfliOmst.pdf; where it remains accessible to the
`
`public today.
`
`7.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Executed this 15th day of December, 20 16.
`
`LENOVO ET AL. EXHIBIT 1019
`Page 2 of 2
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