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`______________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`______________________________
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`CANON INC., CANON U.S.A., INC., and
`AXIS COMMUNICATIONS AB,
`Petitioners,
`
`v.
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`AVIGILON FORTRESS CORPORATION,
`Patent Owner.
`
`______________________________
`
`CASE: IPR2019-00314
`U.S. Patent No. 7,932,923
`
`______________________________
`
`Declaration of Guang-Yu Zhu
`
`______________________________
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`
`
`
`
`
`
`IPR2019-00314
`U.S. Patent No. 7,932,923
`
`I, Guang-Yu Zhu, declare as follows:
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`1.
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`I am an attorney at the law firm of Finnegan, Henderson, Farabow,
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`Garrett & Dunner, LLP, counsel for Petitioner Axis Communications AB in this
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`matter. I am licensed to practice in the District of Columbia. I have personal
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`knowledge of the matters set forth herein.
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`2.
`
`Exhibit 1042 is a true and accurate copy of “Understanding MARC
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`Bibliographic: Parts 1 to 6,” available at https://www.loc.gov/marc/umb/
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`um01to06.html (last accessed August 1, 2019) obtained from the Internet.
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`3.
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`Exhibit 1043 is a true and accurate copy of “Understanding MARC
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`Bibliographic: Parts 7 to 10,” available at https://www.loc.gov/marc/umb/
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`um07to10.html (last accessed August 1, 2019) obtained from the Internet.
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`4.
`
`Exhibit 1044 is a true and accurate copy of Nevenka Dimitrova et al.,
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`“Motion Recovery for Video Content Classification,” ACM Transactions on
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`Information Systems, Vol. 13, No. 4, 408-439 (1995), obtained from the
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`Massachusetts Institute of Technology (“MIT”) Libraries.
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`5.
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`Exhibit 1045 is a true and accurate copy of Bruce E. Flinchbaugh et
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`al., “Autonomous Video Surveillance,” SPIE Proceedings, 25th AIPR Workshop:
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`Emerging Applications of Computer Vision, Vol. 2962, pp. 144-151 (1997),
`
`obtained from the Library of Congress.
`
`1
`
`
`
`IPR2019-00314
`U.S. Patent No. 7,932,923
`
`6.
`
`Exhibit 1046 is a true and accurate copy of Frank Brill et al., “Event
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`Recognition and Reliability Improvements for the Autonomous Video Surveillance
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`System” Proceedings of the Image Understanding Workshop, Nov. 20-23, 1998,
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`Vol. 1, pp. 267-283, obtained from the University of Virginia Library, with the title
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`and cover pages scanned in color.
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`7.
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`Exhibit 1047 is a true and accurate copy of the Declaration of Katie
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`Zimmerman filed in KAZ USA, Inc. v. Exergen Corp., Case IPR2016-01437,
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`Exhibit 1027.
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`8.
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`Exhibit 1048 is a true and accurate copy of the Declaration of Marilyn
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`McSweeney filed in Yahoo! Inc. v. CreateAds LLC, Case IPR2014-00200, Exhibit
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`1007.
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`9.
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`I declare under penalty of perjury that the foregoing is true and
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`correct. I further declare that all statements made herein of my own knowledge are
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`true, that all statements made on information and belief are believed to be true, and
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`that these statements were made with the knowledge that willful false statements
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`and the like so made are punishable by fine or imprisonment, or both, under
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`section 1001 of Title 18 of the United States Code.
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`
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`Dated: August 5, 2019
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`/Guang-Yu Zhu/
`By:
`Guang-Yu Zhu
`
`
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`2
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