`
`___________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________
`
`COMCAST CABLE COMMUNICATIONS, LLC,
`Petitioner,
`
`v.
`
`PROMPTU SYSTEMS CORPORATION,
`Patent Owner.
`
`___________
`
`Case IPR2018-00344
`Patent 7,047,196
`___________
`
`DECLARATION OF JEFFREY LAU IN SUPPORT OF PETITIONER’S
`
`REPLY TO PATENT OWNER’S RESPONSE
`
`Comcast - Exhibit 1028, cover
`
`
`
`I, Jeffrey Lau, make the following declaration in support of reply briefs filed by
`
`petitioner Comcast Cable Communications, LLC (“Comcast”) in two inter partes
`
`review proceedings involving U.S. Patent No. 7,047,196:
`
`1.
`
`I am an attorney with the law firm of Farella Braun + Martel LLP,
`
`counsel for Comcast. Unless otherwise stated, the facts stated in this declaration
`
`are based on my personal knowledge.
`
`2.
`
`The document submitted with the reply briefs and identified as
`
`Exhibit 1024 in both proceedings is a true and correct copy of excerpts from the
`
`transcript of the deposition of Paul M. Cook, which was taken over a period of
`
`three days including October 30, October 31, and November 1, 2018.
`
`3.
`
`The document submitted with the reply briefs and identified as
`
`Exhibit 1025 is a true and correct copy of the transcript of the deposition of David
`
`Chaiken, which was taken on November 30, 2018. We prepared and attached an
`
`index at the end of Exhibit 1025 showing the correspondence between the exhibit
`
`numbers used in the Chaiken deposition with exhibit numbers in these
`
`proceedings.
`
`4.
`
`The document submitted with the reply briefs and identified as
`
`Exhibit 1026 is a true and correct copy of the transcript of the deposition of John
`
`Tinsman, which was taken on November 29, 2018. We prepared and attached an
`
`index at the end of Exhibit 1026 showing the correspondence between the exhibit
`
`1
`
`Comcast - Exhibit 1028, page 1
`
`
`
`numbers used in the Tinsman deposition with exhibit numbers in these
`
`proceedings.
`
`5.
`
`The document submitted with the reply briefs and identified as
`
`Exhibit 1027 is a true and correct copy of paper entitled The Inducement Standard
`
`of Patentability, 120 Yale L.J. 1590 (2011) that appears to have been authored by
`
`Michael Abramowicz and John F. Duffy.
`
`I declare 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.
`
`Jeffrey Lau
`
`2
`
`Comcast - Exhibit 1028, page 2
`
`
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