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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Canon Inc., Canon U.S.A., Inc., and Axis Communications AB,
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`Petitioners,
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`V.
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`Avigilon Fortress Corporation,
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`Patent Owner.
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`Case No. IPR2019-00311
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`U.S. Patent No. 7,932,923
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`DECLARATION OF JENNIFER A. BABBITT
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`AVIGILON EX. 2011
`IPR2019-00311
`Page 1 of 5
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`I, JENNIFER A. BABBITT, declare under penalty of perjury as follows:
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`1.
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`I am an Electronic Services Librarian of the law firm Kirkland & Ellis,
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`LLP.
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`2.
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`I obtained a Masters in Library and Information Science from San Jose
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`State University in 2013. In connection with that degree, I took multiple courses
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`relating to library operations and catalog management.
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`3.
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`From 2012 to 2014, I worked as an Archive Consultant at the Golden
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`Gate National Recreation Area. I assisted in archival of Golden Gate National
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`Recreation Area documents and maintenance of active division records. I also
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`created finding aids for discrete collections, as well as preserving and arranging
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`active records for multiple divisions within the Golden Gate National Recreation
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`Area, including the superintendent's office.
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`4.
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`From 2014 to present, I have been working as a Research Assistant at
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`Kirkland & Ellis LLP. My primary responsibilities include the following: (1)
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`maintain library catalog, including coordination of cataloging new material and
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`routing of serial publications, (2) work with outside vendors to maintain/update
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`standing orders and facilitate new orders, (3) coordinate interlibrary loans, ( 4)
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`catalog and maintain technical book collection, and (5) research and document
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`retrieval.
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`AVIGILON EX. 2011
`IPR2019-00311
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`5.
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`I make this Declaration in support of the petition for inter partes review
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`of U.S. Patent No. 7,932,923 before the United States Patent and Trademark Office.
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`I make this Declaration of my own personal knowledge.
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`6.
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`Exhibit 2005 is a true and correct copy of Thomas Olson & Frank Brill,
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`Moving Object Detection & Event Recognition Algorithms for Smart Cameras, 1
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`PROC. 1997 IMAGE UNDERSTANDING WORKSHOP 159-175 (1997), that I obtained
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`from U.S. Patent No. 7,868,912 Reexamination Request No. 90/012,878 located at
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`https://portal.uspto.gov/pair/PublicPair on April 9, 2019.
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`7.
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`Exhibit 2006 is a true and correct copy of Jonathan D. Courtney,
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`Automatic Video
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`Indexing Via Object Motion Analysis, 30(4) PATTERN
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`RECOGNITION 607-625 (1997), that I obtained from https://www.sciencedirect.com
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`on April 9, 2019.
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`8.
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`Exhibit 2008 is a true and correct copy of Young Francis Day, et al,
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`Spatio-Temporal Modeling of Video Data for On-Line Object-Oriented Query
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`Processing, Proceedings of the International Conference on Multimedia Computing
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`and Systems 98-105 (1995), that I obtained from U.S. Patent No. 7,932,923
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`Reexamination
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`Request
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`No.
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`90/012,876
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`located
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`at
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`https://portal.uspto.gov/pair/PublicPair on April 9, 2019.
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`3
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`AVIGILON EX. 2011
`IPR2019-00311
`Page 3 of 5
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`9.
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`Exhibit 2009 is a true and correct copy of the U.S. Patent No. 7,932,923
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`Second Supplemental Amendment, dated Feb. 4, 2011 that I obtained from
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`https://portal.uspto.gov/pair/PublicPair on April 5, 2019.
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`10. Exhibit 2012 is a true and correct copy of the Search Works Catalog
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`entry for the Image Understanding Workshop Proceedings series at the Stanford
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`University
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`Library
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`website
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`that
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`I
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`obtained
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`from
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`https://searchworks.stanford.edu/view/1267489 on March 5, 2019.
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`11. Exhibit 2013 is a copy of the scanned cover and front matter from
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`PATTERN RECOGNITION, Vol. 30, No. 4, dated April 1997 obtained on March 5, 2019.
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`4
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`AVIGILON EX. 2011
`IPR2019-00311
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`12.
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`I declare under penalty of perjury under the laws of the United States
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`of America that all statements made herein of my own knowledge are true and that
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`all statements made on information and belief are believed to be true; and further
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`that these statements were made with the knowledge that willful false statements and
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`the like so made are punishable by fine or imprisonment, or both, under Section 1001
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`of the Title 18 of the United States Code.
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`Executed on April 9, 2019, in San Francisco, California.
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`5
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