`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`VOXX INTERNATIONAL CORPORATION
`
`Petitioner,
`
`V.
`
`JOHNSON SAFETY, INC.,
`Patent Owner.
`
`Patent No. 8,585,140
`Filing Date: May 29, 2009
`Issue Date: November 19, 2013
`Title: HEADREST-MOUNTED MONITOR
`
`
`
`Inter Partes Review No. IPR2OI7—00554
`
`DECLARATION OF JOHN T. WOODS
`
`Voxx International Corp. Exhibit 1006
`
`Voxx International Corp. Exhibit 1006
`
`
`
`Declaration of John T. Woods
`
`1, John T. Woods, make the following Declaration pursuant to 28 U.S.C. § 1746:
`
`1.
`
`2.
`
`I am an attorney at the law firm of Indiano & McConnell LLC.
`
`I provide this Declaration in connection with the above-identified Inter Partes
`
`review proceeding that has been requested at the United States Patent &
`
`Trademark Office (“USPTO”) by the above-identified petitioner under 35 U.S.C.
`
`§§ 311-319 and 37 C.F.R. § 42. Unless otherwise stated, the facts stated in this
`
`Declaration are based on my personal knowledge.
`
`Petitioner Exhibit 1004 is a true and correct copy of a “Directed Video Owner’s
`
`Guide / Installation Guide — Headrest Video Monitor Model HVM500”
`
`(hereinafter the “HVM500 Guide”) that came with an HVM500 Headrest Video
`
`Monitor that was purchased online.
`
`As indicated on the last page of the HVM500 Guide and reproduced below, the
`
`HVM500 Guide that came with the actual unit purchased includes a copyright
`
`notice of December 1, 2001.
`
`P,
`ELECTRONICS, INC.
`
`' Directed Electronics, Inc.
`Vista, CA 92083
`www.directed.com
`
`2001 Directed Etectmnics, inc. - All rights reserved
`N8I101 Rev. 1.0 12-01
`
`5.
`
`According to archives from the Internet WayBackMachine, the HVM500 Guide
`
`was available for download on Directed Electronics’ website at
`
`www.directed.com at least as early as April 14, 2002. See Exhibit A.
`
`Voxx International Corp. Exhibit 1006
`
`Voxx International Corp. Exhibit 1006
`
`
`
`6. Attached as Exhibit 1007 to the Petition is a true and correct copy of Japan Patent
`
`Application JP 1-94049 that was filed on March 30, 1987 by Matsushita Electrical
`
`Industrial Co. listing as inventors Shiro Tada, Hisao Ikeda, and Yoshinobu Ueno
`
`and entitled “Television Fixture for Vehicles” (hereinafter “Tada”). Attached as
`
`Exhibit 1008 to the Petition is a true and correct certified copy of a translation of
`
`Japan Patent Application JP 1-94049 that was obtained by Petitioner. The Tada
`
`application was laid open (i.e. — published) on April 12, 1989.
`
`7. Attached as Exhibit 1009 to the petition is a true and correct copy of Korean
`
`Patent Registration No. 20-0256470 that was filed on September 3, 2001 by
`
`Daedong Auto Sound Ltd. listing as an inventor Jung Ho Son and entitled
`
`“Headrest with a Built-in Monitor” (hereinafter “Son”). A certified translated
`
`copy of Son is attached to the petition as Exhibit 1010. Son was registered as a
`
`patent in Korea on November 23, 2001 and has a notice date of December 20,
`
`2001.
`
`8.
`
`I declare that all statements made herein of my knowledge are true, and that all
`
`statements made on information and belief are believed to be true, and that these
`
`statements were made with knowledge that willful false statements and the like so
`
`made are punishable by fine or imprisonment, or both, under Section 1001 of
`
`Title 18 of the United States Code.
`
`Dated: flgcegéaf
`
`By:
`
`John T. Woods
`
`Atty. Reg. No. 71,723
`
`Voxx International Corp. Exhibit 1006
`
`Voxx International Corp. Exhibit 1006
`
`
`
`Page 1 of 1
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`Exhibit A
`file://192.163.7.72/Pub11c/clients/v0)&(<1ZJ)0)(.tiiE1i&l3ElB1’tim?La116<}O(m,2dfsX2b2i.b It 1 6
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`Voxx International Corp. Exhibit 1006
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