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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`UNIFIED PATENTS INC.
`Petitioner,
`
`v.
`
`BRADIUM TECHNOLOGIES LLC,
`Patent Owner
`
`
`
`IPR2018-00952
`Patent 9,253,239
`
`
`
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`
`
`
`DECLARATION OF CHRIS COULSON IN SUPPORT OF
`PATENT OWNER’S PRELIMINARY RESPONSE
`UNDER 37 C.F.R. § 42.107
`
`
`
`Bradium Exhibit 2026
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 1 of 6
`
`
`
`
`
`
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`IPR2018-00952
`
`I, Chris J. Coulson, make the following declaration pursuant to 28 U.S.C. §1746:
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`1.
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`2.
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`I am an attorney at the law firm of Bunsow De Mory LLP.
`
`I provide this declaration in connection with Patent Owner’s
`
`Preliminary Response under 37 C.F.R. § 42.107 to the request for Inter Partes
`
`Review No. IPR2018-00952.
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`3.
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`Unless otherwise stated, the facts stated in this Declaration are based
`
`on my personal knowledge.
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`4.
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`Exhibit 2005 hereto is a true and correct copy of a web page entitled
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`“Team,” downloaded from the Unified Patents website via the URL on the bottom
`
`of each page of Exhibit 2005: https://www.unifiedpatents.com/team/#. An exhibit
`
`label and page numbers have been added to the bottom of the document, but no
`
`other alterations have been made.
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`5.
`
`Exhibit 2006 hereto is a true and correct copy of a web page entitled
`
`“Join,” downloaded from the Unified Patents website via the URL on the bottom
`
`of each page of Exhibit 2006: https://www.unifiedpatents.com/join/. An exhibit
`
`label and page numbers have been added to the bottom of the document, but no
`
`other alterations have been made.
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`6.
`
`Exhibit 2007 hereto is a true and correct copy of a web page entitled
`
`“Join,” dated May 17, 2018, downloaded from the web.archive.org website via the
`
`
`
`1
`
`Bradium Exhibit 2026
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 2 of 6
`
`
`
`
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`URL on the bottom of each page of Exhibit 2007:
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`IPR2018-00952
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`https://web.archive.org/web/20180517015601/https://www.unifiedpatents.com/join
`
`/. An exhibit label and page numbers have been added to the bottom of the
`
`document, but no other alterations have been made.
`
`7.
`
`Exhibit 2010 hereto is a true and correct copy of Belcher, Marta, et
`
`al., “Hacking the Patent System: A guide to Alternative Patent Licensing for
`
`Innovators,” Juelsgaard Intellectual Property & Innovation Clinic Stanford Law
`
`School, dated May 2014, downloaded from the Unified Patents website via:
`
`https://www.unifiedpatents.com/join-1/. An exhibit label and page numbers have
`
`been added to the bottom of the document, but no other alterations have been
`
`made.
`
`8.
`
`Exhibit 2011 hereto is a true and correct copy of a web page entitled
`
`“Protected Zones,” downloaded from web.archive.org website via the URL on the
`
`bottom of each page of Exhibit 2011:
`
`https://web.archive.org/web/20161027135832/http://www.unifiedpatents.com:80/z
`
`ones/. An exhibit label and page numbers have been added to the bottom of the
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`document, but no other alterations have been made.
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`9.
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`Exhibit 2017 hereto is a true and correct copy of a web page entitled
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`“Bradium Technologies and Microsoft Settle Patent Lawsuit,” dated October 17,
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`2017, downloaded from the Bradium Technologies website via the URL on the
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`
`
`2
`
`Bradium Exhibit 2026
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 3 of 6
`
`
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`
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`bottom of each page of Exhibit 2017:
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`IPR2018-00952
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`http://www.bradiumtechnologies.com/bradium/bradium-technologies-and-
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`microsoft-settle-patent-lawsuit. An exhibit label and page numbers have been
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`added to the bottom of the document, but no other alterations have been made.
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`10. Exhibit 2024 hereto is a true and correct copy of Excerpts of Unified
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`Patents Home Page dated January 4, 2014, downloaded from the Unified Patents
`
`website via the URL on the top of each page of Exhibit 2024:
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`https://web.archive.org/web/20140101033720/http://unifiedpatents.com/. An
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`exhibit label and page numbers have been added to the bottom of the document,
`
`but no other alterations have been made.
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`11. Exhibit 2028 hereto is a true and correct copy of a web page entitled
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`“Orthogonality,” downloaded from the Wikipedia website via the URL on the
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`bottom of each page of Exhibit 2028: https://en.wikipedia.org/wiki/Orthogonality.
`
`An exhibit label and page numbers have been added to the bottom of the
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`document, but no other alterations have been made.
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`12. Exhibit 2029 hereto is a true and correct copy of a web page entitled
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`“IPRs: Balancing Effectiveness vs. Cost,” printed from the RPX Corp. website via
`
`the URL listed on the bottom of each page of Exhibit 2029:
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`https://www.rpxcorp.com/2016/06/17/iprs-balancing-effectiveness-vs-cost/. An
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`exhibit label and page numbers have been added to the bottom of the document,
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`
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`3
`
`Bradium Exhibit 2026
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 4 of 6
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`
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`
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`but no other alterations have been made.
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`IPR2018-00952
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`13. Exhibit 2030 hereto is a true and correct copy of a web article entitled
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`“How much does IPR cost?,” printed from the Patent Trademark Blog: IPR Q&A
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`website via the URL on the bottom of each page of Exhibit 2030:
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`http://www.patenttrademarkblog.com/how-much-does-ipr-cost/. An exhibit label
`
`and page numbers have been added to the bottom of the document, but no other
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`alterations have been made.
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`14. Exhibit 2033 hereto is a true and correct copy of a web page entitled
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`“NPE Zones: Deter bad NPE conduct,” printed from Unified Patents’ website via
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`the URL listed on the bottom of each page of Exhibit 2033:
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`https://www.unifiedpatents.com/npe/. An exhibit label and page numbers have
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`been added to the bottom of the document, but no other alterations have been
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`made.
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`15. Exhibit 2038 hereto is a true and correct copy of a web page entitled
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`“Unified’s Real Party-in-Interest PTAB Panel Decisions (/news/real-party-in-
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`interest-panel-decisions),” printed from Unified Patents’ website via the URL
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`listed on the bottom of each page of page 5 Exhibit 2038:
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`https://www.unifiedpatents.com/news/real-party-in-interest-panel-decisions. An
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`exhibit label and page numbers have been added to the bottom of the document,
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`but no other alterations have been made.
`
`
`
`4
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`Bradium Exhibit 2026
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 5 of 6
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`
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`IPR2018-00952
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`16.
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`I hereby declare that all the statements made in this Declaration are of
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`my own knowledge and true; that all statements made on information and belief
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`are believed to be true; and further that these statements were made with the
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`knowledge that willful false statements and the like so made are punishable by fine
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`or imprisonment, or both, under Section 1001 of the Title 18 of the United States
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`Code. I declare under penalty of perjury that the foregoing is true and correct.
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`
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`Executed this 24th day of September, 2018, at Scarsdale, New York.
`
`
`
`
`
` /s/ Chris J. Coulson
`Chris J. Coulson
`
`
`
`
`5
`
`Bradium Exhibit 2026
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 6 of 6
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