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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`‘CISCO SYSTEMS, INC.,
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`Petitioner
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`¥.
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`FATPIPE NETWORKS PRIVATE LIMITED
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`Patent Owner
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`Case IPR2017-01845
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`Patent 6,775,235
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`DECLARATION OF ROBERT HILTON
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`Cisco Systems, Inc.
`IPR2017-01845
`Exhibit 1022
`Page 1 of 3
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`
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`Declaration of Robert C. Hilton
`IPR2017-01845 (Patent 6,775,235)
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`I, Robert C. Hilton, hereby declare as follows:
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`| am a Partner at McGuireWoods LLP.
`My nameis Robert Hilton.
`1.
`make this declaration from my personal knowledge.
`|
`
`I
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`2.
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`I am lead counsel for Viptela, LLC, formerly known as Viptela,Inc.,
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`in IPR2017-00684 and IPR201 7-01 125. I managed a team at McGuireWoodsthat
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`was involvedin all aspects of the preparation ofthe petitions for interpartes
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`review, including the search for relevantprior art.
`
`3,
`Aspart of the analysis and preparation for IPR2017-00684 and
`IPR2017-01125, McGuireWoods engaged a professional search firm, CardinalIP,
`to search for prior art relevant to U.S. Patent No, 6,775,235, Attached as Exhibit
`
`1023 is a copy of the Patent Search Report provided by Cardinal IP on November
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`23, 2016. Ex. 1023. The Patent Search Report includes the search results provided
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`by Cardinal IP (Ex. 1023, pp. 2-25) and the search history performed by Cardinal
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`IP (Ex. 1023, pp. 26-33). The Cardinal IP Patent Search Report does notlist U.S.
`Patent No. 6,243,754 to Guerin (“Guerin”), which I understand is Exhibit 1006 in
`
`IPR2017-01845,
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`4,
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`I was not aware of Guerin prior to its appearance in Cisco’s public
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`- filing of IPR2017-01845, and I would have known if any member of my team was
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`aware of Guerin.
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`Cisco Systems, Inc.
`IPR2017-01845
`Exhibit 1022
`Page 2 of 3
`
`
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`Declaration of Robert C. Hilton
`IPR2017-01845 (Patent 6,775,235)
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`II. Conclusion
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`5:
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`I declare that all statements made herein of my own knowledgeare
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`true and that all statements made on information andbelief are believed to betrue;
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`and furtherthat these statements were made with the knowledge that willful false
`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code.
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`Executed on this 22nd day ofNovember, 2017.
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`RCiptlt
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`Robert C. Hilton
`Dallas, Texas
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`Cisco Systems, Inc.
`IPR2017-01845
`Exhibit 1022
`Page 3 of 3
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`