throbber
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`United States Patent No.: 5,915,210
`Inventors: Dennis Wayne Cameron, et al.
`Formerly Application No.: 08/899,476
`Issue Date: Jun. 22, 1999
`Filing Date: Jul. 24, 1997
`Former Group Art Unit: 2649
`Former Examiner: Thanh Cong Le
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`Attorney Docket No.:
`109109-0017-651
`Customer No. 28120
`
`Petitioners: Aruba Networks,
`Inc.; Hewlett Packard
`Enterprise Co.; HP Inc.; ARRIS
`Group, Inc.; Juniper Networks,
`Inc.; Brocade Communications
`Systems, Inc.; Ruckus Wireless,
`Inc.
`
`For: METHOD AND SYSTEM FOR PROVIDING MULTICARRIER
`SIMULCAST TRANSMISSION
`
`MAIL STOP PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`Post Office Box 1450
`Alexandria, Virginia 22313-1450
`
`DECLARATION OF SHARON LEE IN SUPPORT
`OF PETITION FOR INTER PARTES REVIEW OF
`UNITED STATES PATENT NO. 5,915,210
`
`I, Sharon Lee, make the following Declaration pursuant to 28 U.S.C. § 1746:
`
`1.
`
`2.
`
`I am an associate at the law firm of Ropes & Gray LLP.
`
`I provide this Declaration in connection with the above-identified
`
`Inter Partes Review proceeding that is being requested at the United States Patent
`
`and Trademark Office (“USPTO”) by Aruba Networks, Inc., Hewlett Packard
`
`Enterprise Company, HP Inc., ARRIS Group, Inc., Juniper Networks, Inc.,
`
`Aruba Networks et al. Exhibit 1016 Page 00001
`
`

`
`Brocade Communications Systems, Inc., and Ruckus Wireless, Inc. (collectively
`
`“Petitioners”). Unless otherwise stated, the facts stated in this Declaration are
`
`based on my personal knowledge.
`
`3.
`
`Exhibit 1004 is a true and correct copy of the Declaration of Gerard P.
`
`Grenier, Senior Director of Publishing Technologies at the IEEE, dated December
`
`12, 2016, with Exhibit A thereto, including an article titled “The coded orthogonal
`
`frequency division multiplexing (COFDM) technique, and its application to digital
`
`radio broadcasting towards mobile receivers” by J.C. Rault, D. Castelain, and B.
`
`Le Floch, which I obtained from the IEEE on December 12, 2016. This document
`
`has been marked with an exhibit label and page numbers on each page at the
`
`bottom right corner. However, no alterations, other than these noted markings,
`
`have been made to this document.
`
`4.
`
`Exhibit 1012 is a true and correct copy of the Declaration of Gerard P.
`
`Grenier, Senior Director of Publishing Technologies at the IEEE, dated January 9,
`
`2017, with Exhibit A thereto, including an article titled, “256 QAM Modem for
`
`Multicarrier 400 Mbit/s Digital Radio” by Yasuhisa Nakamura and Yoichi Saito,
`
`which I obtained from the IEEE on January 9, 2017. This document has been
`
`marked with an exhibit label and page numbers on each page at the bottom right
`
`corner. However, no alterations, other than these noted markings, have been made
`
`to this document.
`
`Page 00002
`
`

`
`
`
`
`
`5.
`
`Exhibit 1013 is a true and correct copy of a certificate from the United
`
`States Library of Congress, dated December 23, 2016, with excerpts from IEEE
`
`Journal on Selected Areas in Communications (April 1987, Volume SAC-5,
`
`Number 3) thereto, including an article titled “256 QAM Modem for Multicarrier
`
`400 Mbit/s Digital Radio” by Yasuhisa Nakamura and Yoichi Saito, which was
`
`retrieved from the United States Library of Congress and scanned at my request.
`
`The document includes a copyright page, which bears a stamp that states
`
`“LIBRARY OF CONGRESS COPYRIGHT OFFICE MAY 14 1987 COPY 1.”
`
`This document has been marked with an exhibit label and page numbers on each
`
`page at the bottom right corner. However, no alterations, other than these noted
`
`markings, have been made to this document. The article contained in Exhibit 1012
`
`(pages 6-12) and the article contained in Exhibit 1013 (pages 4-10) were compared
`
`at my direction and they were determined to contain the same substance, including
`
`the same text and figures.
`
`6.
`
`Exhibit 1014 is a true and correct copy of a certificate from the United
`
`States Library of Congress, dated December 23, 2016, with excerpts from IEEE
`
`Global Telecommunications Conference & Exhibition (Dallas, Texas, November
`
`27-30, 1989, Vol. 1 of 3) thereto, including an article titled “The coded orthogonal
`
`frequency division multiplexing (COFDM) technique, and its application to digital
`
`radio broadcasting towards mobile receivers” by J.C. Rault, D. Castelain, and B.
`
`Page 00003
`
`

`
`Le Floch, which was retrieved from the United States Library of Congress and
`
`scanned at my request. The document includes a page bearing a stamp that states
`
`“LIBRARY OF CONGRESS CIP OCT 25 1990 COPY.” This document has been
`
`marked with an exhibit label and page numbers on each page at the bottom right
`
`corner. However, no alterations, other than these noted markings, have been made
`
`to this document. The article contained in Exhibit 1004 (pages 7-11) and the
`
`article contained in Exhibit 1014 (pages 23-27) were compared at my direction and
`
`they were determined to contain the same substance, including the same text and
`
`figures.
`
`7.
`
`I hereby declare that all
`
`statements made herein of my own
`
`knowledge are true and that all statements made on information and belief are
`
`believed to be true; and further that
`
`these statements were made with the
`
`knowledge that willful false statements and the like so made are punishable by fine
`
`or imprisonment, or both, under 18 U.S.C. 1001. If called to testify as to the truth
`
`of the matters stated herein, I could and would testify competently.
`
`8.
`
`I declare under penalty of perjury that the foregoing is true and
`
`correct.
`
`Executed this 10th day of January, 2017, in Washington, D.C.
`
`
`
`Page 00004
`
`Page 00004

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket