UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________
`
`TWITTER, INC.
`Petitioner
`
`v.
`
`VIDSTREAM LLC,
`Patent Owner.
`
`_________________
`
`Case IPR2017-01131
`Patent 8,464,304
`
`_________________
`
`SUPPLEMENTAL DECLARATION OF HENRY HOUH
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`Page 1
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`_________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________
`
`TWITTER, INC.
`Petitioner
`
`v.
`
`VIDSTREAM LLC,
`Patent Owner.
`
`_________________
`
`Case IPR2017-01131
`Patent 8,464,304
`
`_________________
`
`SUPPLEMENTAL DECLARATION OF HENRY HOUH
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`Page 1
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`I, Henry Houh, do hereby declare as follows:
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`1.
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`I previously submitted a declaration on behalf of Petitioner Twitter,
`
`Inc. in connection with these proceedings. (Exhibit 1003.) Since submitting Ex.
`
`1003, I have reviewed Patent Owner’s Response (“Response”), and accompanying
`
`exhibits, including the Declaration of James Olivier (“Olivier Declaration”, Ex.
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`2002). I have also reviewed Ex. Nos. 2003-2007, submitted with Dr. Olivier’s
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`declaration. I have also reviewed Dr. Olivier’s deposition transcript, which I
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`understand is being filed and referenced in these proceedings as Ex. 1051. I
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`provide this supplemental declaration to address some technical inaccuracies and
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`mischaracterizations set forth in the Response and Dr. Olivier’s testimony in both
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`IPR2017-1131 and IPR2017-1133.
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`2.
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`In connection with preparing this supplemental declaration, and in
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`addition to the materials identified in Ex. 1003 and above in ¶ 1, I have reviewed
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`the following materials bearing Exhibit Nos. that I understand are being filed and
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`referenced in the proceedings to which this supplemental declaration accompanies.
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` Ex. 1033 is a true and correct copy of a webpage from
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`www.fonearena.com describing characteristics of the Nokia E50 mobile
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`phone. As shown in the footer, this webpage was archived by the
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`Wayback Machine at web.archive.org on October 21, 2006.
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` Ex. 1036 is a true and correct copy of a webpage from phys.org titled
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`“Samsung Starts Selling World’s First 10 Megapixel Camera Phone”
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`dated October 10, 2006.
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` Ex. 1037 is a true and correct copy of a webpage from
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`www.letsgodigital.org titled “Samsung SCH-V770 7 Megapixel digital
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`camera phone” dated March 10, 2008.
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` Ex. 1043 is a true and correct copy of a web page from
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`www.symbian.com identifying SDKs. As shown in the footer, this
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`webpage was archived by the Wayback Machine at web.archive.org on
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`February 9, 2006.
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` Ex. 1044 is a true and correct copy of a web page from
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`www.symbian.com identifying Symbian phones. As shown in the footer,
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`this webpage was archived by the Wayback Machine at web.archive.org
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`on December 20, 2006.
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` Ex. 1045 is a true and correct copy of a web page from www.wired.com
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`titled “By Open Sourcing Symbian, Nokia Kicks Off The Mobile Age”
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`dated June 24, 2008. Wired is a reputable source for information on
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`technology and electronic devices, and which is commonly referred to
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`and relied upon by persons of ordinary skill in the art.
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` Ex. 1047 is a webpage from www.symbian.com titled “Class CCamera”.
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`As shown in the footer, this webpage was archived by the Wayback
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`Machine at web.archive.org on February 8, 2008.
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` Ex. 1048 is a webpage from www.symbian.com titled “Class CCamera”.
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`As shown in the footer, this webpage was archived by the Wayback
`
`Machine at web.archive.org on September 17, 2006.
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` Ex. 1049 is an article from www.samsung.com titled “SAMSUNG
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`Launches the World’s First 10 Megapixel Camera Phone” and dated
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`October 10, 2006. This webpage was published by Samsung, a well-
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`known mobile phone manufacturer and is recognized in the art as a
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`reputable source of publicly information regarding the products that it
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`manufactures and sells. It is a source that is commonly referred to and
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`relied upon by persons of ordinary skill in the art as an easily-accessible
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`reference for characteristics of Samsung products, including mobile
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`phones.
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` Ex. 1050 is a true and correct copy of a webpage from
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`www.photographyblog.com titled “Samsung SCH-B600 10 Megapixel
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`Camera Phone” and dated October 10, 2006. As shown in the footer, this
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`webpage was archived by the Wayback Machine at web.archive.org on
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`April 5, 2009.
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`3.
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`Dr. Olivier defined a person having ordinary skill in the art
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`(“POSITA”) as having “a Bachelor of Science in Electrical Engineering, Computer
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`Engineering, or Computer Science and about two years of experience in the area of
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`networked video, or equivalent experience and education.” (Ex. 2002, ¶ 39). Dr.
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`Olivier then goes on to define timeframe for the relevant knowledge of a POSITA
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`as January 2011. (Id., ¶¶ 40, 41). Below, I respond to certain aspects of Dr.
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`Olivier’s POSITA.
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`4.
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`Although Dr. Olivier and I agree about the general education level a
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`POSITA would have, we disagree on the specific areas of knowledge of a
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`POSITA. As I explained in my initial declaration, a POSITA would have
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`“approximately two years of experience in network architecture and multimedia
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`systems, including creating and distributing multimedia.” (Ex. 1003, ¶ 44). Dr.
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`Olivier states that a POSITA “would have had a Bachelor of Science in Electrical
`
`Engineering, Computer Engineering, or Computer Science and about two years of
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`experience in the area of networked video, or equivalent experience and
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`education.” (Ex 2002, ¶39). While these appear to be similar, I disagree with Dr.
`
`Olivier’s opinions regarding the knowledge of a POSITA at the relevant
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`timeframe.
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`5.
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`For example, in the early 2000s, mobile devices, including phones and
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`other video recording devices, such as camcorders, had become commonplace. A
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`POSITA would have had knowledge of such devices, including the software tools
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`that were associated with the devices. In the relevant timeframe, a POSITA would
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`have known that such devices operated through operating system technology. Such
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`devices were designed such that application developers could create applications to
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`take advantage of modern day technical capabilities. Tools that developers had
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`access to included operating system application programming interfaces (“APIs”)
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`and software development kits (“SDKs”). A POSITA would have had knowledge
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`of these tools for a wide variety of devices and operating systems.
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`6.
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`This is consistent with the teachings of the ’506 and ’304 patents
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`(“challenged patents”), which are directed, inter alia, to systems and methods for
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`capturing videos on a client computing device, which includes mobile phones with
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`a mobile application (see ’506 patent Fig. 1 item 122, Fig. 18, 10:17-19, 12:24-30,
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`12:43-50, 13:1-10, 14:50-53, 14:59-63, 23:65-24:20, 25:3-10; ’304 patent Fig. 1
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`item 122, Fig. 18, 10:11-14, 12:19-25, 12:38-45, 12:63-13:5, 14:43-46, 14:53-56,
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`23:58-24:12, 24:62-25:2), and uploading the video to a server where it is
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`transcoded for distribution and transferred to a distribution server. Furthermore the
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`challenged patent discloses that “[r]egardless of device or operating system, users
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`from virtually any commercially viable system are able to recode and upload video
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`that can be transcoded into broadcast quality video files and/or into video files
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`appropriate for Internet distribution.” (’506 patent at 18:30-34; see also ’304 patent
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`at 18:22-26). The patent further discloses that “native capabilities of the user
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`computing device 120 can be accessed to receive captured video and audio data
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`through an API on the computing device 120.” (’506 patent at 12:30-32; ’304
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`patent at 12:25-27).
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`7.
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`Throughout the 2000’s I was personally familiar with various phone
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`manufactures including Nokia, Samsung, and Apple. I also was familiar with the
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`various major operating systems for smart phones throughout the mid-to-late
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`2000’s, including Android, Windows Mobile, iPhone OS/iOS, and Symbian.
`
`Symbian had a dominant share of the smartphone operating system market in the
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`early to mid-2000’s and maintained a large share through 2010 and 2011.1 In the
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`context of the patents and claims at issue here, a POSITA would have been
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`familiar with the pertinent technology and application development tools from the
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`pre-January 2011 timeframe, including mobile operating systems, APIs, and SDKs.
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`Dr. Olivier agrees that a POSITA would have knowledge of tools which include
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`APIs including “a package that sits on top of the operating system.” Ex 1051,
`
`
`1 See, for example, https://www.statista.com/statistics/219966/global-
`smartphone-market-shareforecast-of-symbian-and-microsoft/ and
`https://www.digitaltrends.com/mobile/symbian-captures-88-market-share/ and
`http://www.metrics2.com/blog/2007/03/26/nokia_leads_smarphone_market_with_
`56_share_symbian.html; see also Exhibit 1045.
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`34:9-10, see also Ex. 2002, ¶37 and Ex. 1051, 32:7-34:18, 37:17-38:18. Dr.
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`Olivier further acknowledges that the Mobile Media API referenced in Lahti (Ex.
`
`1006, p. 6) was a “Java-based API that’s provided in some products in this era.”
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`Ex. 1051, 68:21-23 see also 68:5-69:4. A POSITA wound understand that tthe
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`Mobile Media API would indeed be a package that sits on top of the operating
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`system.
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`8.
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`I disagree with Dr. Olivier’s opinion that a POSITA would lack
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`detailed knowledge of the Symbian operating system. (Ex. 1051, 115:9-18). Dr.
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`Olivier admits that Nokia devices he relied on use the Symbian operating system.
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`(Ex. 1051, 119:16-121:25). It is nonsensical to suggest that a POSITA would not
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`know about Symbian or be unable to find detailed information about Symbian
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`APIs and SDKs.
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`9.
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`Second, although I agree that the relevant timeframe is January 2011,
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`Dr. Oliver appears to have ignored the years following the publication of the Lahti
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`paper. His declaration discusses certain Nokia devices from the 2004-2006, but
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`says nothing about pertinent technical advancements between 2006 and 2011, or
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`how a person of ordinary skill in the art in 2011 would understand Lahti. This is
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`significant because capabilities of camera phones evolved during this period. For
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`example, the Apple iPhone 4 became available on June 24, 20102, and was capable
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`of recording HD 720p (1280x720) video at up to 30 frames per second3. The
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`Nokia N8, based on the Symbian operating system, began shipping by October 1,
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`20104, and was also capable of recording HD 720p video5. The data generation
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`rate of video at full HD 720p resolution and frame rate is roughly 100 times the
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`data generation rate of video at 176x144 resolution and 15 frames per second,
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`representing orders-of-magnitude improvements to video capture data recording in
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`the time from 2006 to 2011.
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`10. These facts further support how I, and any other POSITA, would have
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`understand Lahti at the time of the alleged invention in 2011. However, as
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`discussed below, even when understood solely on the basis of technology as it
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`existed in 2006, Dr. Olivier’s opinion is wrong and takes a much too narrow view
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`of Lahti’s teachings.
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`11. Dr. Olivier appears to have allowed the supposed capabilities of three
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`Nokia mobile phones from the 2004-2006 timeframe to have influenced his
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`2 See https://www.apple.com/newsroom/2010/06/07Apple-Presents-iPhone-
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`4/
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`3 See https://support.apple.com/kb/sp587?locale=en_US
`4 See https://www.webwire.com/ViewPressRel.asp?aId=124210 and
`https://techcrunch.com/2010/09/29/nokia-n8-starts-shipping-worldwide/
`5 See https://www.zdnet.com/article/the-nokia-n8-uncompromising-
`specifications-and-functions-in-the-smartphone-world/
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`opinions. However, a POSITA in 2006, 2007, 2008, 2009, 2010, or 2011 would
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`not have reached the same conclusion as Dr. Olivier.
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`12.
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`In fact, the exhibits allegedly describing the three Nokia devices on
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`which Dr. Olivier rely, do not stand for the proposition that he says. For example,
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`it is clear that the Nokia 6630 was capable of recording video using at least two
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`different resolutions. Regarding the E50, I have reviewed additional documentation
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`(Ex. 1033) describing the E50 beyond what Dr. Olivier reviewed that indicates that
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`the E50 could also record video using at least two different resolutions, which
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`undermines Dr. Olivier’s suggestion at ¶ 69 that it was only capable of recording at
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`one resolution. This is significant because Dr. Olivier uses the capabilities of just
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`three phones to conclude that Lahti does not teach that the MobiCon application
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`sets the frame rate or frame size since all cameras recorded at a default setting that
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`matches the resolution specifically listed in the Lahti reference. Dr. Olivier states
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`that cameras defaulted to specific resolutions for recording, but bases his reasoning
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`on a few references which simply list the available frame sizes and frame rates of a
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`few phones, and does not rely to any documents that inform a POSITA how to
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`capture video in any mobile phone operating system, or otherwise how a POSITA
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`would understand the teachings of Lahti. See (Ex. 2002, ¶¶ 73-76).
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`13.
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`In addition, Dr. Olivier completely ignored the functionality mobile
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`phone vendors provided via Software Developer Kits and Application
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`Programming Interfaces made available through the operating system for the
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`mobile device.
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`14. For example, many mobile phones, including Nokia mobile phones,
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`and the Nokia 6630 mentioned in Lahti in particular, operated on the Symbian
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`Operating System. The Symbian Operating System provided application
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`developers with significant functionality. As it pertains to this case and Dr.
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`Olivier’s opinions, I discuss some here. Operating system APIs typically allow an
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`application developer to access the capabilities, features and functions of the
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`underlying hardware. The Symbian OS APIs are no different. I have reviewed the
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`APIs for accessing the video recording functions in versions 7.0, 8.1 and 9.1 of the
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`Symbian OS, as well as descriptions of the video recording API for version 9.1
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`from publicly available books (such as Multimedia on Symbian OS Inside The
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`Convergence Device, dated 2008) that would have been available to a POSITA
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`prior to 2011. All of these versions of the Symbian OS had been released by 2006.6
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`In order for a developer to create an application which records video, the developer
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`uses the EnumerateVideoFrameRates() and EnumerateVideoFrameSizes() API
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`functions to read the capabilities of the underlying camera. Prior to starting to
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`6 See Ex. 1043.
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`record video, the developer must use the PrepareVideoCaptureL() API function7 to
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`specify both a frame size and a frame rate at which to record. There are no default
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`values for the frame rate or the frame size. After the video camera is prepared in
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`such a fashion, the video capture can be started using the StartVideoCapture() API
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`function.8
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`15.
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`In addition, whether in 2006 or 2011, Dr. Olivier ignored dozens if
`
`not hundreds of different mobile phone models. A quick internet search of one of
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`the most popular mobile phone manufacturers, Samsung, indicates that by 2006 it
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`was selling at least two mobile phones that could record video at 15-30 frames per
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`second. (See, e.g., Ex. 1036, Ex. 1037, Ex. 1049, Ex. 1050) (describing the
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`Samsung SCH-V770 and the Samsung SCH-B600 as each recording video at 15-
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`30 frames per second). This is significant because Lahti, in the section titled
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`“Implementation objectives,” teaches utilizing SDKs provided by the camera
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`phone vendor to implement video recording. (Ex. 1006, p. 10). “Video recording,
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`the first function, is relatively straightforward to implement with vendor provided
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`
`7 See, Ex. 1047; Ex. 1048;
`http://web.archive.org/web/20060517210803/http://www.symbian.com:80/develop
`er/techlib/v9.1docs/doc_source/guide/Multimedia-subsystem-
`guide/N100DE/HowToUse.guide.html#OnboardCameraGuide%2eHowToUse;
`8
`http://web.archive.org/web/20050411000225/http://www.symbian.com:80/develop
`er/techlib/v70sdocs/doc_source/reference/cpp/OnboardCameraRef/CCameraClass.
`html
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`SDKs.” (emphasis in original). A POSITA would understand Lahti to be teaching
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`that the system be implemented on a multitude of vendor phones, which even in
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`the 2006 timeframe comprised phones with a variety of frame resolutions and bit
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`rates.
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`16. Dr. Olivier reasons that a POSITA would want to minimize the
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`variables in the code of the MobiCon application that depended on the model of
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`the camera phone on which the MobiCon application was installed. (See Ex. 2002,
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`¶72). Dr. Olivier continues that “[a]ttempting to govern or not govern the video-
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`capture parameters on an ad-hoc basis depending on the model of camera phone
`
`would have required additional complexity and entire code modules not only to
`
`govern the video capture parameters, but also additional code modules to govern
`
`whether or not the video-capture-parameter code modules would be activated
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`depending on the model of camera phone” Id. and that “attempting to control those
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`video capture parameters with the MobiCon application – even if possible – would
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`have unnecessarily complicated the code needed to implement the MobiCon
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`application.” (Id., ¶76). Dr. Olivier’s incorrect contrived musings are contrary to
`
`the understandings of a POSITA. For example, Dr. Olivier’s statements are
`
`contrary to what the Symbian operating system allowed at the time specifying
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`frame rates, frame sizes, etc., which would have been easily implemented by a
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`POSITA independently of any specific camera model without any of the complex
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`code modules Dr. Olivier claims is necessary. The APIs provided by Symbian, for
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`example, obviate the need for applications to have complex code modules that are
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`dependent on specific phone models. The Symbian OS APIs discussed above for
`
`preparing and starting video capture do not require the application developer to
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`have any knowledge of a specific phone model in order to perform video capture.
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`Indeed, one of the main points of an operating system and the APIs that the OS
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`provides is to abstract away the lower level hardware details so that application
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`developers do not have to have any knowledge of how a specific task is performed
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`on a wide range of disparate hardware platforms.
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`17.
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`In addition, Dr. Olivier mischaracterizes the teachings of the
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`expressed disclosure of Lahti. His conclusion that Lahti does not teach that
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`MobiCon controls video capture is an unreasonable conclusion. In describing
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`MobiCon, Lahti explicitly states that MobiCon’s “UIManager is a controller
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`component,” and further that it “coordinates the video capture using the mobile
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`phone’s camera …” (Ex. 1006, p. 5). Lahti goes on to explain that when capturing
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`new video, “MobiCon’s main screen is displayed” and a “new video clip is
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`captured in Capture Screen using Mobile Media API and it is recorded according
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`to 3GPP specification using AMR coding for audio and H.263 at 176x144 pixels
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`size at 15 frames per second for video.” (Id., p. 6). This is all handled by
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`MobiCon’s UIManager which is a “controller component.” Thus, Lahti teaches a
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`POSITA that MobiCon is using server-provided constraints to control the video
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`capture process.
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`18. Lahti emphasizes that enabling MobiCon to control the video
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`recording capabilities of a mobile phone, and to foster the goals of the application
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`to minimize network traffic, conserve battery power and minimize use of the CPU
`
`and memory presents difficulties because of the varying characteristics of mobile
`
`phones features and operating systems:
`
`Moreover, application developers must pay attention to
`
`the way resources are used: network traffic should be
`
`minimized, battery power should be conserved when
`
`possible, and CPU and memory ought to be utilized with
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`frugality. These restrictions come on top of the classic
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`mobile phone application development nightmares (device
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`incompatibilities,
`
`network
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`application
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`debugging,
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`immature SDKs, and different operating system versions
`
`with undocumented bugs) making the development of an
`
`application like MobiCon challenging.
`
`(Ex. 1006 at 3) (emphasis added).
`
`19. The Response notes this passage and construes it to mean that
`
`MobiCon’s developers simply chose not to engage in these challenges at all
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`insofar as the application relates to the capture of videos. Dr. Olivier states that “A
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`POSITA at that time would have wanted to minimize the variables in the code of
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`the MobiCon application that depended on the model of camera phone on which
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`the MobiCon application was installed.” (Ex. 2002, ¶72). Dr. Oliver states that
`
`“[a]ttempting to govern or not govern the video-capture parameters on an ad-hoc
`
`basis depending on the model of camera phone would have required additional
`
`complexity and entire code modules not only to govern the video capture
`
`parameters, but also additional code modules to govern whether or not the video-
`
`capture-parameter code modules would be activated depending on the model of
`
`camera phone. Thus, that a POSITA would have understood that some camera
`
`phones did not permit adjustment of video capture parameters also strongly
`
`counsels against Dr. Houh’s interpretation of Lahti’s discussion of the parameters
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`at which video was captured.” Id. That interpretation is nonsensical.
`
`20. Phone operating systems provide APIs which allow application
`
`developers to write applications in which the specific model of phone and specific
`
`underlying hardware do not matter. I explained above about the APIs in the
`
`Symbian OS which allow an application developer to query the frame size and
`
`frame rate capabilities of the underlying hardware. This process allows the
`
`application to simply read the video recording capabilities while hiding any
`
`specific phone model from the application itself, and relieves the application of the
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`complexity of managing video capture on a per-phone model basis. The ’304 and
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`’506 patents themselves also discuss using the computing device’s APIs in order to
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`receive captured video using the device’s native recording capabilities: “The native
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`recording capabilities of the user computing device 120 can be accessed to receive
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`captured video and audio data through an API on the computing device 120.”
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`(’506 patent at 12:30-32, see also 12:63-67; ’304 patent at 12:25-27, 12:58-63).
`
`The challenged patent discloses that the computing device 120 “can include any
`
`type of computing device such as desktop computer, a laptop computer, a handheld
`
`computer, a tablet, a personal digital assistant (PDA), a cellular telephone, a
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`network appliance, a camera, a smart phone, an enhanced general packet radio
`
`service (EGPRS) mobile phone, or a combination of any two or more of these data
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`processing devices or other data processing devices.” (’506 patent at 12:3-10; ’304
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`patent at 11:65-12:5). Other than mentioning video capture through the use of
`
`APIs, the patent specification is silent on any complexity with respect to how to
`
`manage such a capture not just on mobile phones (and all the different models
`
`thereof) but also on computers, tablets, other platforms and combinations thereof.
`
`Video Length [IPR2017-01133, Only ’506 patent]
`
`21.
`
`I disagree with Dr. Olivier’s opinion that Lahti teaches away from
`
`limiting video length. (Ex. 2002, ¶¶79-95.). Dr. Olivier reasons that “[b]ecause
`
`Lahti addresses ‘home video clips’ that one would not want to artificially limit in
`
`time, and because Lahti has already addressed the technical issues that Dr. Houh
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`contends warrant such an artificial limit, my opinion is that Lahti teaches away
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`from limiting the duration of captured videos.” (Ex. 2002, ¶94).
`
`22.
`
`In support of his opinion, Dr. Olivier gives an example that “[i]n the
`
`home video context contemplated by Lahti, it would make little sense to capture
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`video in predetermined lengths. For example, one would not want to hit the
`
`predetermined video length constraint just prior to their child blowing out the
`
`candles on a cake.” (Ex. 2002, ¶82).
`
`23. First, Candela and MobiCon are not limited to the home video domain
`
`upon which Dr. Olivier relies: “The Candela system was originally developed for
`
`the personal home video domain but, due to its modular and tiered architecture, it
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`can be used as a basis for different video management applications by using some
`
`of the generic components and adding domain-specific ones.” (Ex. 1006, p. 4).
`
`24.
`
`In addition, with respect to Dr. Olivier’s statements with respect to the
`
`Candela server architecture of Lahti (Ex. 2002, ¶¶84-86, 90), limited storage is a
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`problem with any real-world system as all of them have limitations on storage
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`space; simply providing a server to which a user uploads videos does not solve all
`
`storage problems nor does it teach away from providing limits to video length. It
`
`was well known that video storage and management services that were available in
`
`the 2006-2010 time frame had limits on the lengths of videos. Video storage and
`
`management service operators may want to impose limits on video file sizes for
`
`SUPPLEMENTAL DECLARATION OF HENRY HOUH
`
`Page 18
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`
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`many reasons, including to limit the overall storage used per user, or to offer
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`various tiered levels of service in which those who pay more are allowed to upload
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`longer videos. Video sharing sites such as YouTube have such limits as well as
`
`partner and premium offerings in which limits on video length are relaxed.9 By
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`2009 Flickr, a well-known photo and video upload site, allowed users to upload
`
`videos limited to 90 seconds in length, with free users subject to a limit of two
`
`videos per month, and paid users with no such restriction.10 Any such real-world
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`limits necessitate possibly aborting a video recording at a time that a user does not
`
`desire, and it was already well known at the time to limit the duration of video
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`uploads.
`
`25. Furthermore, Dr. Olivier also reasons that “my opinion is that Lahti
`
`teaches away from limiting the duration of captured videos.” (Ex. 2002, ¶94). Dr.
`
`Olivier also states that “Lahti…never describes a limit on the length on videos
`
`recorded using the described MobiCon software, nor does it provide any rationale
`
`for limiting video length.” (Ex. 2002, ¶81). The lack of any such statements in
`
`Lahti is not “teaching away.” Lahti does not teach away from launching rockets to
`
`
`9 See, for example, https://youtube.googleblog.com/2010/07/upload-limit-
`increases-to-15-minutes.html
`10 See, for example,
`https://web.archive.org/web/20090304100419/https://www.flickr.com/help/limits/
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`SUPPLEMENTAL DECLARATION OF HENRY HOUH
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`Page 19
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`
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`the moon, or not launching rockets to the moon, simply because it does not
`
`mention anything about rockets.
`
`I, Henry Houh, do hereby declare and state, 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 Section 1001 of Title 18 of the United States
`
`Code.
`
`Dated:
`
`'8 / g} / K
`
`k ll Jh~~
`
`Signature
`
`SUPPLEMENTAL DECLARATION OF HENRY HOUH
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`
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`RED
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`Page 20
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