`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Canon Inc., Canon U.S.A., Inc., and Axis Communications AB,
`
`Petitioners,
`
`Vv.
`
`Avigilon Fortress Corporation,
`
`Patent Owner.
`
`Case No. IPR2019-00314
`
`U.S. Patent No. 7,932,923
`
`DECLARATION OF JENNIFERA. BABBITT
`IN SUPPORT OF PATENT OWNER’S RESPONSE
`
`AVIGILONEX. 2023
`
`IPR2019-003 14
`Page | of 4
`
`AVIGILON EX. 2023
`IPR2019-00314
`Page 1 of 4
`
`
`
`I, JENNIFER A. BABBITT,declare under penalty of perjury as follows:
`
`1.
`
`I am an Electronic Services Librarian of the law firm Kirkland & Ellis,
`
`LLP.
`
`2.
`
`I obtained a Masters in Library and Information Science from San Jose
`
`State University in 2013. In connection with that degree, I took multiple courses
`
`relating to library operations and catalog management.
`
`3.
`
`From 2012 to 2014, I worked as an Archive Consultant at the Golden
`
`Gate National Recreation Area.
`
`I assisted in archival of Golden Gate National
`
`Recreation Area documents and maintenance of active division records.
`
`I also
`
`created finding aids for discrete collections, as well as preserving and arranging
`
`active records for multiple divisions within the Golden Gate National Recreation
`
`Area, including the superintendent’s office.
`
`4,
`
`From 2014 to present, I have been working as a Research Assistant at
`
`Kirkland & Ellis LLP. My primary responsibilities include the following:
`
`(1)
`
`maintain library catalog, including coordination of cataloging new material and
`
`routing of serial publications, (2) work with outside vendors to maintain/update
`
`standing orders and facilitate new orders, (3) coordinate interlibrary loans, (4)
`
`catalog and maintain technical book collection, and (5) research and document
`
`retrieval.
`
`AVIGILON EX. 2023
`
`IPR2019-003 14
`Page 2 of 4
`
`AVIGILON EX. 2023
`IPR2019-00314
`Page 2 of 4
`
`
`
`5.
`
`I makethis Declaration in supportof the petition for inter partes review
`
`of U.S. Patent No. 7,932,923 before the United States Patent and Trademark Office.
`
`I make this Declaration of my own personal knowledge.
`
`6.
`
`Exhibit 2021 is a true and correct copy of David G. Lowe, Distinctive
`
`Image Feature From Scale-Invariant Keypoints, 60(2) INTERNATIONAL JOURNAL
`
`OF
`
`COMPUTER
`
`VISION
`
`91-110
`
`(2004),
`
`that
`
`I
`
`obtained
`
`from
`
`https://link.springer.com/article/10.1023/B%3AVISI.0000029664.99615.94
`
`on
`
`October 9, 2019.
`
`7.
`
`Exhibit 2022is a true and correct copy of Herbert Bay,et al., Speeded-
`
`Up Robust Features
`
`(SURF),
`
`110
`
`COMPUTER VISION AND IMAGE
`
`UNDERSTANDING
`
`346-359
`
`(2008),
`
`that
`
`I
`
`obtained
`
`from
`
`https://Awww.sciencedirect.com/science/article/pii/S1077314207001555 on October
`
`9, 2019.
`
`8.
`
`I declare under penalty of perjury under the laws of the United States
`
`of America that all statements made herein of my own knowledgeare true and that
`
`all statements made on information and belief are believed to be true; and further
`
`that these statements were made with the knowledgethat willful false statements and
`
`3
`
`AVIGILON EX. 2023
`
`IPR2019-003 14
`Page 3 of 4
`
`AVIGILON EX. 2023
`IPR2019-00314
`Page 3 of 4
`
`
`
`the like so madeare punishable by fine or imprisonment, or both, under Section 1001
`
`of the Title 18 of the United States Code.
`
`Executed on October 9, 2019, in San Francisco, California.
`
`
`
`‘nite tA. Bab
`
`
`
`Je
`
`4
`
`AVIGILON EX.2023
`IPR2019-003 14
`Page 4 of 4
`
`AVIGILON EX. 2023
`IPR2019-00314
`Page 4 of 4
`
`
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