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`--------------------------
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.,
`
`Petitioner
`
`v.
`
`UNILOC 2017 LLC,
`
`Patent Owners.
`
`--------------------------
`
`Case IPR2018-00282
`
`Patent 7,092,671
`
`--------------------------
`
`
`
`Declaration of Marc Breverman
`
`
`
`
`
`
`
`APPL-1018 / IPR2018-00282
`Apple v. Uniloc / Page 1 of 4
`
`
`
`I, Marc Breverman, declare:
`
`1. I am employed as Corporate Counsel, Patent Litigation at Apple Inc. (“Apple”).
`
`2. On May 31, 2017, Apple was served with a complaint by Uniloc USA, Inc. and Uniloc
`Luxembourg, S.A, which plead infringement of U.S. Patent No. 7,092,671 (the “’671
`Patent”). No. 2:17-cv-00457-JRG (E.D. Tex.), Dkt. 1. On December 6, 2017, Apple filed
`a petition for inter partes review, designated as IPR2018-00282 (the “Apple IPR”).
`
`3. From my review of the docket on the Patent Trial and Appeal Board End to End website,
`on December 11, 2017, Unified Patents, Inc. (“Unified Patents”) filed a petition for inter
`partes review, designated as IPR2018-00199. On December 12, 2017, Apple first
`became aware that Unified Patents knew of the ’671 Patent, and had filed a petition for
`inter partes review of the ’671 Patent, by way of the email attached hereto as Exhibit 1.
`
`4. I am the member of the Apple in-house legal team responsible for supervising the
`preparation and filing of the Apple IPR. Apple solely financed the Apple IPR. Apple
`solely controlled all aspects of the Apple IPR, including the selection of the prior art, the
`formulation of the grounds, and the development of the positions. Apple did not inform
`Unified Patents of Apple’s interest in the ’671 Patent, of the prior art to be used in the
`Apple IPR, or of the grounds to be used in the Apple IPR. Apple did not provide to
`Unified Patents any drafts materials that became the Apple IPR.
`
`5. Apple did not solicit any input from Unified Patents with respect to the Apple IPR.
`Apple did not receive any contributions, financial or otherwise, from Unified Patents with
`respect to the preparation or filing of the Apple IPR. Apple received no information from
`Unified Patents with respect to the Apple IPR. Apple received no instructions from
`Unified Patents that Apple should file the Apple IPR.
`
`6. I declare that all statements made herein of my own knowledge are true and 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.
`
`
`
`
`
`
`
`
`Dated:
` Marc Breverman
`
`
`
`
`
`
`
`
`
`
`
`APPL-1018 / IPR2018-00282
`Apple v. Uniloc / Page 2 of 4
`
`
`
`
`
`EXHIBIT 1
`EXHIBIT 1
`
`APPL-1018 / IPR2018-00282
`Apple v. Uniloc / Page 3 of 4
`
`APPL-1018 / IPR2018-00282
`Apple v. Uniloc / Page 3 of 4
`
`
`
`Subject: Another Uniloc patent challenged as likely invalid From: "Robert Jain" <rjain@unifiedpatents.com> Received(Date): Tue, 12 Dec 2017 15:01:25 -0800 To: <cwheeler@apple.com> On December 11, 2017, Unified filed a petition for inter partes review (IPR) against U.S. Patent 7,092,671 owned and asserted by Uniloc Luxembourg, S.A. and Uniloc USA (collectively "Uniloc"), a well-known NPE responsible for filing 95 new patent litigations since January 2017. The '671 patent, directed to a "system where a user*s handheld computer could automatically dial a telephone number stored in its memory by interacting with a telephone" has been asserted in district court against Apple and Samsung . To read the petition and view the entire case proceeding, see our PTAB Portal .Thank you,Unified Patents
`
`APPL-1018 / IPR2018-00282
`Apple v. Uniloc / Page 4 of 4
`
`
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