`U.S. Patent 8,577,813
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ____________
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`UNIFIED PATENTS INC.
`Petitioner
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`v.
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`UNIVERSAL SECURE REGISTRY LLC
`Patent Owner
`____________
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`IPR2018-00067
`Patent 8,577,813
` ____________
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`DECLARATION OF MICHELLE CALLAGHAN
`IN SUPPORT OF PETITIONER’S MOTION TO CORRECT
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`IPR2018-00067
`Unified EX1020 Page 1
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`Callaghan Declaration, IPR2018-00067
`U.S. Patent 8,577,813
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`DECLARATION OF MICHELLE CALLAGHAN
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`I, Michelle Callaghan, declare that the following statements made of my own
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`knowledge are true, and that any statements below made on information and belief are
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`believed to be true:
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`1.
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`I am an associate attorney at Erise IP, P.A. I was admitted to the
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`Colorado Bar on October 31, 2016.
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`2.
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`Since approximately July 28, 2017, I have contributed to the preparation
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`of the Petition for Inter Partes Review of U.S. patent 8,577,813 (’813 Patent) on
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`behalf of Petitioner Unified Patents Inc. (“Petitioner”).
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`3.
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`Between July 2017 and September 2017, I reviewed various prior art
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`patents and printed publication references related to the subject matter of the ’813
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`Patent. As I reviewed this art, I mapped the teachings of prior art references against
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`the claims and limitations of the ’813 Patent using claim charts. Such references
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`included, among others, U.S. Patent 6,016,476 to Maes et al. (“Maes”), U.S. Patent
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`5,870,723 to Pare et al. (“Pare”), U.S. Pub. US 2004/0107170 Al to Labrou et al.
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`(“Labrou”), and WO 2001/024123 to Burger et al. (“Burger”). For the limitations of
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`Claim 1 (an independent claim) and Claim 5 (which depends from Claim 1), I mapped
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`applicable teachings in Maes, Pare, Labrou, among other references, into the claim
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`charts. For the limitations of Claim 6 (which depends from Claim 5), I mapped
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`IPR2018-00067
`Unified EX1020 Page 2
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`
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`Callaghan Declaration, IPR2018-00067
`U.S. Patent 8,577,813
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`applicable teachings in Burger into the claim charts. For the limitations of Claims 7-9
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`(which depend from Claim 6 either directly or indirectly), I mapped applicable
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`teachings in Maes, a reference relied upon for limitations of Claim 1, into the claim
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`charts. For the limitations of Claim 10 (which depends from Claim 7), I mapped
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`applicable teachings in Labrou, another reference already relied upon for limitations
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`of Claim 1, into the claim charts.
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`4.
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`In September 2017, I began copying and pasting the content of the art
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`mapped against the claims of the ’813 Patent and their related arguments from the
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`claim charts into a template petition. I was responsible for preparing a first draft
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`petition, including the proposed Grounds 1 and 2.
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`5.
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`On October 2, 2017, I sent a draft petition to my supervising attorney,
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`Jason Mudd. In this draft, I mistakenly transcribed the mapping and arguments for
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`Maes regarding claims 7-9 and for Labrou regarding claim 10 into Ground 1 instead
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`of Ground 2, where they were intended to be inserted based on their direct or indirect
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`dependency from claim 6, which was included in Ground 2.
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`6.
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`Between October 3, 2017, and October 16, 2017, through various
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`drafting iterations, I received various comments from Mr. Mudd and others to
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`incorporate into the final version of the Petition ultimately filed on October 16, 2017,
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`but none of these comments addressed my transcription error.
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`IPR2018-00067
`Unified EX1020 Page 3
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`Callaghan Declaration, IPR2018-00067
`U.S. Patent 8,577,813
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`On February 7, 2018, I reviewed the Preliminary Response filed by
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`7.
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`Patent Owner Universal Secure Registry LLC. Upon reviewing the Preliminary
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`Response, I first became aware of my clerical mistake with respect to the transcription
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`of Claims 7-10 under Ground 1 instead of Ground 2 and alerted Mr. Mudd of the
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`mistake.
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`I declare that all statements made herein of my own knowledge are true and
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`that all statements made on information and belief are believed to be true; and
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`further that these statements were made with the knowledge that willful false
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`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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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed on March 2, 2018
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`Respectfully submitted,
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`BY: /Michelle A. Callaghan/
`Michelle A. Callaghan
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`IPR2018-00067
`Unified EX1020 Page 4
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