`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––––––––––
`
`RIOT GAMES, INC.,
`Petitioner,
`
`v.
`
`PALTALK HOLDINGS, INC.,
`Patent Owner.
`
`––––––––––––––––––
`
`Case Nos. IPR2018-00129, -130, -131, -132
`U.S. Patent Nos. 5,822,523 and 6,226,686
`
`––––––––––––––––––
`
`SUPPLEMENTAL DECLARATION OF
`DAVID H. CROCKER
`
`Petitioner Riot Games – Ex. 1038, Page Cover
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`IPR2018-00129, -130, -131, -132
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`Suppl. Decl. of David H. Crocker
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`Table of Contents
`
`I.
`
`II.
`
`Introduction ...................................................................................................... 1
`
`Authentication of RFC, RFC Editor, and IETF Documents ........................... 2
`
`III.
`
`Publication of RFC Documents ....................................................................... 4
`
`Public Accessibility via Web, FTP, and Email ..................................... 4
`
`Electronic Dissemination via Email Distribution Lists ....................... 10
`
`Publication Dates of RFCs .................................................................. 12
`
`A.
`
`B.
`
`C.
`
`
`
`
`
`
`
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`Suppl. Decl. of David H. Crocker
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`
`
`EXHIBIT LIST
`
`No.
`1010
`1011
`
`1018
`
`1040
`1041
`
`1042
`
`1043
`
`1044
`
`Exhibit Description
`Transport Multiplexing Protocol (TMUX), RFC 1692 (Aug. 1994)
`Internet Protocol DARPA Internet Program Protocol Specification,
`RFC 791 (Sept. 1981)
`Protocol Standard for a NetBIOS Service on a TCP/UDP Transport:
`Concepts and Methods, RFC 1001 (Mar. 1987)
`The Internet Standards Process – Revision 2, RFC 1602 (Mar. 1994)
`1021
`Internet Official Protocol Standards, RFC 1720 (Nov. 1994)
`1022
`Internet Relay Chat Protocol, RFC 1459 (May 1993)
`1025
`1027 Dave Crocker CV
`1028
`The Internet Standards Process, RFC 1310 (Mar. 1992)
`1029
`The Internet Standards Process – Revision 3, RFC 2026 (Oct. 1996)
`1039
`FYI on Questions and Answers: Answers to Commonly asked “New
`Internet User” Questions, RFC 1206 (Feb. 1991)
`Index of /rfc, https://www.ietf.org/rfc/
`Internet Monthly Reports (Aug. 1994), available at https://www.rfc-
`editor.org/in-notes/museum/imr/imr9408.txt
`ftp.nisc.sri.com: netinfo/interest-groups, List of lists, June 14, 1993,
`available https://www.rfc-editor.org/in-notes/museum/internet-list-of-
`lists
`RFC Editor History of RFC 1692, available at
`https://datatracker.ietf.org/doc/rfc1692/history/
`RFC Editor History of RFC 1459, available at
`https://datatracker.ietf.org/doc/rfc1459/history/
`1045 Michael Santifaller, TCP/IP and NFS: Internetworking in a UNIX
`Environment (1991)
`Ed Tittel, PC Networking Handbook (1996)
`
`1046
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`Suppl. Decl. of David H. Crocker
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`No.
`1047
`
`1048
`
`Exhibit Description
`Internet Request For Comments (RFC), Ohio State University, available
`at http://www.cis.ohio-state.edu/hypertext/information/rfc.html
`(Archive.org capture: Dec. 1996)
`Rfc-index, Ohio Statement University, available at http://www.cis.ohio-
`state.edu:80/htbin/rfc/rfc-index.html (Archive.org capture: Dec. 1996)
`
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`Suppl. Decl. of David H. Crocker
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`I.
`
`Introduction
`
`1.
`
`I, David H. Crocker, make this declaration. I am over 21 and
`
`otherwise competent to make this declaration.
`
`2.
`
`All statements herein made of my own knowledge are true, and all
`
`statements herein made based on information and belief are believed to be true.
`
`Unless a specific time period is noted, all statements herein refer to the time period
`
`relevant to the above-captioned proceeding.
`
`3.
`
`I am a principal at Brandenburg InternetWorking (“Brandenburg”),
`
`which I founded in 1991, and I have participated in the development of technical
`
`specifications for the Internet and its predecessor, the Advanced Research Projects
`
`Agency Network (“ARPANET”), since 1972. I understand that my CV has been
`
`filed as Exhibit 1027.
`
`4.
`
`I have been retained by counsel for Petitioner as an expert witness in
`
`the above-captioned proceeding. My opinions in this declaration are informed by
`
`my substantial background and expertise in the RFC development and publication
`
`process, as well as the specific RFC documents I discuss below and the other
`
`evidence I cite in this declaration. Although I am being compensated for my time
`
`in preparing this declaration, the opinions herein are my own.
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`Suppl. Decl. of David H. Crocker
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`5.
`
`I previously submitted a declaration in this proceeding that I
`
`understand was filed as Exhibit 1026. I intend this declaration to supplement that
`
`previous declaration on the following points.
`
`II. Authentication of RFC, RFC Editor, and IETF Documents
`
`6.
`
`In the following paragraphs, I have compared the document filed as a
`
`given exhibit to the authoritative RFC provided by the RFC Editor and determined
`
`that the two documents are the same. In addition, in many cases I recognize the
`
`RFC that was filed as the exhibit, such as RFC 1692, which I co-authored, and
`
`RFC 1459, which I received in the 1993-1995 timeframe. Based on these
`
`comparisons and my knowledge and experience in the RFC process, the exhibits
`
`are therefore true and correct copies of the corresponding RFCs. In addition, I
`
`have compared each remaining exhibit to its authoritative source and determined
`
`that the two documents are the same.
`
`7.
`
`Exhibit 1010 is a true and correct copy of RFC 1692, obtained from
`
`the RFC Editor at the following address: https://www.rfc-editor.org/info/rfc1692.
`
`8.
`
`Exhibit 1011 is a true and correct copy of RFC 791, obtained from the
`
`RFC Editor at the following address: https://www.rfc-editor.org/info/rfc791.
`
`9.
`
`Exhibit 1018 is a true and correct copy of RFC 1001, obtained from
`
`the RFC Editor at the following address: https://www.rfc-editor.org/info/rfc1001.
`
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`Suppl. Decl. of David H. Crocker
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`10. Exhibit 1021 is a true and correct copy of RFC 1602, obtained from
`
`the RFC Editor at the following address: https://www.rfc-editor.org/info/rfc1602.
`
`11. Exhibit 1022 is a true and correct copy of RFC 1720, obtained from
`
`the RFC Editor at the following address: https://www.rfc-editor.org/info/rfc1720.
`
`12. Exhibit 1025 is a true and correct copy of RFC 1459, obtained from
`
`the RFC Editor at the following address: https://www.rfc-editor.org/info/rfc1459.
`
`13. Exhibit 1028 is a true and correct copy of RFC 1310, obtained from
`
`the RFC Editor at the following address: https://www.rfc-editor.org/info/rfc1310.
`
`14. Exhibit 1029 is a true and correct copy of RFC 2026, obtained from
`
`the RFC Editor at the following address: https://www.rfc-editor.org/info/rfc2026.
`
`15. Exhibit 1039 is a true and correct copy of RFC 1206, obtained from
`
`the RFC Editor at the following address: https://www.rfc-editor.org/info/rfc1026.
`
`16. Exhibit 1040 is a true and correct copy of the IETF’s index of RFCs,
`
`obtained from the IETF at the following address: https://www.ietf.org/rfc/.
`
`17. Exhibit 1041 is a true and correct copy of the August 1994 edition of
`
`Internet Monthly Reports, as hosted by the RFC-Editor’s Museum, obtained from
`
`the RFC Editor at the following address: https://www.rfc-editor.org/in-
`
`notes/museum/imr/imr9408.txt.
`
`18. Exhibit 1042 is a true and correct copy of the Internet “List of Lists,”
`
`dated June 14, 1993, as hosted by the RFC-Editor’s Museum, and obtained from
`
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`Suppl. Decl. of David H. Crocker
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`the RFC Editor at the following address: https://www.rfc-editor.org/in-
`
`notes/museum/internet-list-of-lists.
`
`19. Exhibit 1043 is a true and correct copy of the RFC Editor’s Document
`
`History page for RFC 1692, obtained from the RFC Editor at the following
`
`address: https://datatracker.ietf.org/doc/rfc1692/history/.
`
`20. Exhibit 1044 is a true and correct copy of the RFC Editor’s Document
`
`History page for RFC 1459, obtained from the RFC Editor at the following
`
`address: https://datatracker.ietf.org/doc/rfc1459/history/.
`
`III. Publication of RFC Documents
`
`21. My initial declaration explains that RFCs were published and widely
`
`disseminated as of the date on their face. I offer the following analysis and
`
`evidence to expand on certain points, which further confirms and corroborates my
`
`prior analysis in my initial declaration.
`
`A.
`
`Public Accessibility via Web, FTP, and Email
`
`22. RFC 1206 was produced by the User Services Working Group of the
`
`Internet Engineering Task Force (IETF) to document commonly asked questions
`
`and answers about the Internet. Ex. 1039, 1. RFC 1206 explains that RFCs are
`
`published and widely disseminated via email distribution lists:
`
`RFCs are accessible online in public access files, and a short
`message is sent to a notification distribution list indicating the
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`Suppl. Decl. of David H. Crocker
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`availability of the memo. Requests to be added to this distribution list
`should be sent to RFCREQUEST@NIC.DDN.MIL.
`
`Ex. 1039, 5.
`
`23. RFCs are assigned unique numbers that never change, which can be
`
`used to index, identify, and locate a specific RFC:
`
`Once a document is assigned an RFC number and published,
`that RFC is never revised or re-issued with the same number. There is
`never a question of having the most recent version of a particular
`RFC. However, a protocol (such as File Transfer Protocol (FTP)) may
`be improved and re-documented many times in several different
`RFCs. It is important to verify that you have the most recent RFC on a
`particular protocol. The "IAB Official Protocol Standards" [2] memo
`is the reference for determining the correct RFC to refer to for the
`current specification of each protocol.
`
`Ex. 1039, 6.
`
`24. RFC 1206 provides specific instructions to new Internet users for
`
`where and how to obtain RFCs over the Internet. For example, users can obtain
`
`them via FTP or email from the Department of Defense:
`
`RFCs can be obtained via FTP from NIC.DDN.MIL, with the
`pathname RFC:RFCnnnn.TXT or RFC:RFCnnnn.PS (where "nnnn"
`refers to the number of the RFC). Login using FTP, username
`"anonymous" and password "guest". The NIC also provides an
`automatic mail service for those sites which cannot use FTP. Address
`the request to SERVICE@NIC.DDN.MIL and in the subject field of
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`Suppl. Decl. of David H. Crocker
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`the message indicate the RFC number, as in "Subject: RFC nnnn" (or
`"Subject: RFC nnnn.PS" for PostScript RFCs).
`
`Ex. 1039, 6. DDN stands for “Defense Data Network,” which comprises the
`
`MILNET and several other Department of Defense (DoD) networks. Id., 22.
`
`25. As another example, users can obtain RFCs via FTP or email from the
`
`National Science Foundation (NSF):
`
`RFCs can also be obtained via FTP from NIS.NSF.NET. Using
`FTP, login with username "anonymous" and password "guest"; then
`connect to the RFC directory ("cd RFC"). The file name is of the form
`RFCnnnn.TXT-1 (where "nnnn" refers to the number of the RFC).
`The NIS also provides an automatic mail service for those sites which
`cannot use FTP. Address the request to NIS-INFO@NIS.NSF.NET
`and leave the subject field of the message blank. The first line of the
`text of the message must be "SEND RFCnnnn.TXT-1", where nnnn is
`replaced by the RFC number.
`
`Ex. 1039, 6.
`
`26. Users can also obtain a list of RFCs, including the number, title,
`
`authors, issue date, and length. Ex. 1039, 6-7. RFC 1206 provides a new Internet
`
`user specific guidance on how to obtain this index of RFCs, such as via the DoD
`
`website or in hardcopy:
`
`The NIC maintains a file that is an index of the RFCs. It lists
`each RFC, starting with the most recent, and for each RFC provides
`the number, title, author(s), issue date, and number of hardcopy pages.
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`Suppl. Decl. of David H. Crocker
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`In addition, it lists the online formats (PostScript or ASCII text) for
`each RFC and the number of bytes each such version is online on the
`NIC.DDN.MIL host. If an RFC is also an FYI, that fact is noted, with
`the corresponding FYI number. (There is a parallel FYI Index
`available). Finally, the Index notes whether or not an RFC is
`obsoleted or updated by another RFC, and gives the number of that
`RFC, or if an RFC itself obsoletes or updates another RFC, and gives
`that RFC number. The index is updated online each time an RFC is
`issued.
`
`This RFC Index is available online from the NIC.DDN.MIL
`host as RFC:RFC-INDEX.TXT. The FYI Index is online as FYI:FYI-
`INDEX.TXT. It is also available from the NIC in hardcopy for $10, as
`are individual RFCs. Call the NIC at 1-800-235-3155 for help in
`obtaining the file.
`
`Ex. 1039, 6-7.
`
`27. RFCs were frequently identified and described in print materials that
`
`would have been well-known or accessible to users interested in networking. For
`
`example, the book “TCP/IP and NFS: Internetworking in a UNIX Environment”
`
`(1991) explains that an interested user can obtain RFCs from the NIC (described
`
`above in RFC 1206):
`
`As you will find out in the following chapters, most protocols
`of the TCP /IP architecture are specified by a so-called RFC (Request
`For Comment). RFCs are publications for the Internet community;
`namely, those people and institutions who belong to the ARPA-
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`Internet (more about. the ARPA-Internet in Chapter 2). RFCs are
`published by the IAB (Internet Activities Board). They may be
`obtained either by electronic mail from the Network Information
`Centre (NIC) at the Stanford Research Institute (SRI) or in machine-
`readable form by file transfer from a computer in the NIC. The precise
`addresses for information about RFCs are given in an appendix.
`
`Ex. 1045, 2-3. The book then identifies detailed contact information for the RFC
`
`Editor and the NIC, including email, telephone, and mailing addresses. Id., 219.
`
`28. As another example, the book “PC Networking Handbook” (1996)
`
`identifies multiple Internet hosts that allow interested users to obtain RFCs:
`
`RFCs actually dictate how protocols behave and what functions
`they must perform. Failure to conform to these definitions, especially
`for required or recommended protocols, can cost a vendor the
`opportunity of doing business with the United States government and
`all the other bodies and agencies that adhere to its guidelines. Access
`to the RFCs may be obtained from the Internet host ds.internic.net via
`FTP or electronic mail, or via the Word Wide Web at
`http://www.cis.ohio-state.edu/hypertext/information/rfc.html.
`
`Ex. 1046, 176-177.
`
`29. The earliest Internet Archive capture of the Ohio State website, from
`
`December 1996 (Ex. 1046), includes an index that lists all RFCs in reverse
`
`numeric order (Ex. 1047). The index identifies the following RFCs, along with
`
`their titles, and provides URLs for accessing them: RFC 791 (Ex. 1048, 66); RFC
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`Suppl. Decl. of David H. Crocker
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`1001 (Id., 55); RFC 1206 (Id., 45); RFC 1310 (Id., 39); RFC 1459 (Id., 31); RFC
`
`1602 (Id., 24); RFC 1692 (Id., 19-20); RFC 1720 (Id., 18); RFC 2026 (Id., 3).
`
`Although the Internet Archive was not yet founded in 1995, this Ohio State listing
`
`and the ability to access all of the RFCs that had been published is representative
`
`of what would have been available in 1995 on a variety of Internet hosts.
`
`30.
`
`I note that this index includes RFCs published the same month as the
`
`Internet Archive capture: December 1996. Ex. 1048, 2. I believe this is
`
`representative of the speed at which repositories of RFCs were updated to include
`
`newly published RFCs.
`
`31. The “PC Networking Handbook” has further information that would
`
`allow an interested user to access any RFC via e-mail or FTP:
`
`Ex. 1046, 202. Based on my experience, using email for retrieval in the manner
`
`documented above was open to the public without restriction, as was retrieval via
`
`Anonymous FTP.
`
`
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`32. Based on my personal and professional experience, the analysis I
`
`provided in my initial declaration, and my review of the documents I cite in this
`
`declaration, I believe that all of the following RFCs would have been accessible to
`
`any user interested in networking and the Internet by 1995: RFC 791 (Ex. 1011);
`
`RFC 1001 (Ex. 1018); RFC 1206 (Ex. 1039); RFC 1310 (Ex. 1028); RFC 1459
`
`(Ex. 1025); RFC 1602 (Ex. 1021); RFC 1692 (Ex. 1010); and RFC 1720 (Ex.
`
`1022).
`
`B.
`
`Electronic Dissemination via Email Distribution Lists
`
`33. RFC 1206 also references several mailing lists, including a “list-of-
`
`lists” maintained by ftp.nisc.sri.com that lists most of the major mailing lists,
`
`describes their primary topics, and explains how to subscribe to them. Ex. 1039,
`
`16. The RFC Editor maintains a historical archive of the “list-of-lists,” including
`
`the June 14, 1993 copy. Ex. 1042. One list described in this document is the
`
`“RFC Announcements” list, which was used to distribute announcements of new
`
`Requests for Comments:
`
`This list is for distribution of announcements of new Requests
`for Comments. These are the publications of the Internet protocol
`development community, and include the specifications of protocol
`standards for the Internet, as well as policy statements and
`informational memos.
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`Requests to be added or deleted should be sent to: RFC-
`REQUEST@NIC.DDN.MIL
`
`Ex. 1042, 361-62. This distribution list is representative of the type of broad email
`
`dissemination a newly published RFC would receive.
`
`34. Another example is the Internet Monthly Reports (IMRs). E.g., Ex.
`
`1041. These reports communicate to the Internet Research Group the
`
`accomplishments, milestones reached, or problems discovered by the participating
`
`organizations. Ex. 1041, 1. Anyone could subscribe to the IMRs by sending an
`
`email to imr_request@isi.edu. Id. The IMR distributed in August 1994 identifies
`
`33 RFCs published during the month of August, 1994, including RFC 1692. Ex.
`
`1041, 7-8, 23. This announcement is representative of the type of broad email
`
`dissemination a newly published RFC would receive.
`
`35. For example, I myself downloaded a copy of RFC 1692 when it was
`
`announced. I made a habit of printing out RFCs where I was the author or co-
`
`author when they were announced.
`
`36. Based on my personal and professional experience, the analysis I
`
`provided in my initial declaration, and my review of the documents I cite in this
`
`declaration, I believe that all of the following RFCs would have been electronically
`
`announced and disseminated to any user interested in networking and the Internet
`
`on or around their date of publication via email distribution lists: RFC 791 (Ex.
`
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`1011); RFC 1001 (Ex. 1018); RFC 1206 (Ex. 1039); RFC 1310 (Ex. 1028); RFC
`
`1459 (Ex. 1025); RFC 1602 (Ex. 1021); RFC 1692 (Ex. 1010); and RFC 1720 (Ex.
`
`1022).
`
`C.
`
`Publication Dates of RFCs
`
`37. Based on my personal and professional experience, and particularly
`
`my involvement in the RFC process and as a frequent RFC author, the date on the
`
`top right corner of an RFC is the publication date of that RFC. It would have been
`
`added at or near the time of publication by the RFC Editor. The RFC Editor keeps
`
`these dates in the course of its regularly conducted activity of publishing RFCs:
`
`once the date is added it is not removed or modified. Adding this date was a
`
`regular practice of the RFC Editor as part of the publication process, as evidenced
`
`by that date being present on the face of every RFC.
`
`38. The statement in the top corner of an RFC is widely understood to be
`
`the publication date of the RFC. Given that all of the RFCs I have reviewed in this
`
`proceeding are true and correct copies of the authoritative RFCs, they would have
`
`been published on the date on their face.
`
`39. These dates are further corroborated by numerous sources. The RFC
`
`Editor maintains document histories for each RFC. E.g., Ex. 1043, 1044. For
`
`example, the RFC Editor’s history for RFC 1692 states that RFC 1692 was
`
`published in August 1994. Ex. 1043. As another example, the RFC Editor’s
`
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`history for RFC 1459 states that RFC 1459 was published in May 1993. Ex. 1044.
`
`These statements match the publication dates on the documents themselves. See
`
`Ex. 1010, 1011.
`
`40. These dates are further corroborated by the IETF’s index of RFCs,
`
`which includes, for example, (1) an August 1994 last-modified date for the RFC
`
`1692 text file, and (2) a May 1993 last-modified date for the RFC 1459 text file.
`
`Ex. 1040, 176, 196. These statements match the publication dates on the
`
`documents themselves. See Ex. 1010, 1011.
`
`41. Based on my personal and professional experience, the analysis I
`
`provided in my initial declaration, and my review of the documents I cite in this
`
`declaration, I believe that all of the following RFCs would have been published
`
`and made accessible and electronically disseminated to any user interested in
`
`networking and the Internet in the month and year that is listed in the top right
`
`corner of the document: RFC 791 (Ex. 1011); RFC 1001 (Ex. 1018); RFC 1206
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`(Ex. 1039); RFC 1310 (Ex. 1028); RFC 1459 (Ex. 1025); RFC 1602 (Ex. 1021);
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`RFC 1692 (Ex. 1010); and RFC 1720 (Ex. 1022).
`
`*
`
`*
`
`*
`
`
`
`
`
`Petitioner Riot Games – Ex. 1038, Page 13
`Riot Games, Inc. v. PalTalk Holdings, Inc., IPR2018-00129, -130, -131, -132
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`
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`IPR2018-00129, -130, -131, -132
`
`Suppl. Decl. of David H. Crocker
`
`42.
`
`I 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, under Section 1001 of Title 18 of the United States Code.
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`
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`Dated: June 11, 2018
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`
`
`
`
`
`
`
`
` By:
` Printed Name: David H. Crocker
`
`
`
`
`
`
`Petitioner Riot Games – Ex. 1038, Page 14
`Riot Games, Inc. v. PalTalk Holdings, Inc., IPR2018-00129, -130, -131, -132
`
`
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