UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`APPLE INC.,
`
`SAMSUNG ELECTRONICS CO., LTD.,
`
`and
`
`SAMSUNG ELECTRONICS AMERICA, INC.,
`
`Petitioners,
`
`v.
`
`FIRSTFACE CO., LTD.,
`
`Patent Owner.
`
`____________
`
`Case IPR2019-00612
`
`U.S. Patent No. 8,831,557
`
`____________
`DECLARATION OF VICTOR CHEUNG IN SUPPORT OF THE
`PETITION FOR INTER PARTES REVIEW OF UNITED
`STATES PATENT NO. 8,831,557
`
`I, Victor Cheung, make the following Declaration pursuant to 28 U.S.C.
`
`§ 1746:
`
`Apple and Samsung Ex. 1136
`Apple Inc., Samsung Electronics Co., Ltd., and
`Samsung Electronics America, Inc. v. Firstface Co., Ltd.
`IPR2019-00612
`Page 00001
`
`
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`APPLE INC.,
`
`SAMSUNG ELECTRONICS CO., LTD.,
`
`and
`
`SAMSUNG ELECTRONICS AMERICA, INC.,
`
`Petitioners,
`
`v.
`
`FIRSTFACE CO., LTD.,
`
`Patent Owner.
`
`____________
`
`Case IPR2019-00612
`
`U.S. Patent No. 8,831,557
`
`____________
`DECLARATION OF VICTOR CHEUNG IN SUPPORT OF THE
`PETITION FOR INTER PARTES REVIEW OF UNITED
`STATES PATENT NO. 8,831,557
`
`I, Victor Cheung, make the following Declaration pursuant to 28 U.S.C.
`
`§ 1746:
`
`Apple and Samsung Ex. 1136
`Apple Inc., Samsung Electronics Co., Ltd., and
`Samsung Electronics America, Inc. v. Firstface Co., Ltd.
`IPR2019-00612
`Page 00001
`
`
`
`1.
`
`2.
`
`I am an associate at the law firm of Ropes & Gray LLP.
`
`I provide this Declaration in connection with the above-identified
`
`Inter Partes Review proceeding that is being requested at the United States Patent
`
`and Trademark Office (“USPTO”) by Apple Inc. Unless otherwise stated, the facts
`
`stated in this Declaration are based on my personal knowledge.
`
`3.
`
`Exhibit 1107 hereto is a true and correct copy of iPhone User Guide
`
`For iPhone OS 3.1 Software User Guide from support.apple.com. This document
`
`has been marked with an exhibit label and page numbers on each page at the
`
`bottom right corner. However, no alterations, other than these noted markings,
`
`have been made to this document.
`
`4.
`
`Exhibit 1108 hereto is a true and correct copy of Anand L. Shimpi,
`
`Apple’s iPhone: The Future is Here, AnandTech (July 2, 2007),
`
`http://www.anandtech.com:80/show/2265/4 (retrieved from
`
`https://web.archive.org/web/20110225040334/http://www.anandtech.com:80/show
`
`/2265/4). This document has been marked with an exhibit label and page numbers
`
`on each page at the bottom right corner. However, no alterations, other than these
`
`noted markings, have been made to this document.
`
`5.
`
`Exhibit 1121 hereto is a true and correct copy of Peter H. Lewis, THE
`
`EXECUTIVE COMPUTER; Compaq Finally Makes a Laptop, The New York
`
`Times (October 23, 1988) (https://www.nytimes.com/1988/10/23/business/the-
`
`-2-
`
`IPR2016-00612 Page 00002
`
`
`
`executive-computer-compaq-finally-makes-a-laptop.html). This document has
`
`been marked with an exhibit label and page numbers on each page at the bottom
`
`right corner. However, no alterations, other than these noted markings, have been
`
`made to this document.
`
`6. Exhibit 1122 hereto is a true and correct copy of J. Flinn & M.
`
`Satyanarayanan, Energy-aware adaptation for mobile applications, 33 SIGOPS
`
`Oper. Syst. Rev. 48-63 (December 12, 1999)
`
`(DOI=http://dx.doi.org/10.1145/319344.319155). This document has been marked
`
`with an exhibit label and page numbers on each page at the bottom right corner.
`
`However, no alterations, other than these noted markings, have been made to this
`
`document.
`
`7. Exhibit 1123 hereto is a true and correct copy of A. Roy, S. M.
`
`Rumble, R. Stutsman, P. Levis, D. Mazières, & N. Zeldovich, Energy Management
`
`in Mobile Devices with the Cinder Operating System, Proceedings of the sixth
`
`conference on Computer systems (EuroSys ’11), Pages 139-52 (April 10, 2011)
`
`(DOI=http://dx.doi.org/10.1145/1966445.1966459). This document has been
`
`marked with an exhibit label and page numbers on each page at the bottom right
`
`corner. However, no alterations, other than these noted markings, have been made
`
`to this document.
`
`
`
`-3-
`
`IPR2016-00612 Page 00003
`
`
`
`8. Exhibit 1124 hereto is a true and correct copy of Your Palm Treo 680
`
`Smart Device User Guide (2006)
`
`(https://www.att.com/support_static_files/manuals/Palm_Treo_680.pdf). This
`
`document has been marked with an exhibit label and page numbers on each page at
`
`the bottom right corner. However, no alterations, other than these noted markings,
`
`have been made to this document.
`
`9. Exhibit 1125 hereto is a true and correct copy of D. Muthukumaran,
`
`A. Sawani, J. Schiffman, B. M. Jung, & T. Jaeger, Measuring Integrity on Mobile
`
`Phone Systems, Proceedings of the 13th ACM symposium on Access control
`
`models and technologies (SACMAT ’08), Pages 155-64 (June 11, 2008)
`
`(DOI=http://dx.doi.org/10.1145/1377836.1377862). This document has been
`
`marked with an exhibit label and page numbers on each page at the bottom right
`
`corner. However, no alterations, other than these noted markings, have been made
`
`to this document.
`
`10. Exhibit 1126 hereto is a true and correct copy of M. Landman,
`
`Managing Smart Phone Security Risks, 2010 Information Security Curriculum
`
`Development Conference (InfoSecCD ’10), Pages 145-55 (October 1, 2010)
`
`(DOI=http://dx.doi.org/10.1145/1940941.1940971). This document has been
`
`marked with an exhibit label and page numbers on each page at the bottom right
`
`
`
`-4-
`
`IPR2016-00612 Page 00004
`
`
`
`corner. However, no alterations, other than these noted markings, have been made
`
`to this document.
`
`11. Exhibit 1129 hereto is a true and correct copy of iOS: A visual
`
`History, The Verge (September 16, 2013)
`
`(https://www.theverge.com/2011/12/13/2612736/ios-history-iphone-ipad). This
`
`document has been marked with an exhibit label and page numbers on each page at
`
`the bottom right corner. However, no alterations, other than these noted markings,
`
`have been made to this document.
`
`12. Exhibit 1130 hereto is a true and correct copy of iPhone Q&A:
`
`Differences Between the Original iPhone & iPhone 3G, EveryiPhone.com
`
`(November 18, 2011) (https://everymac.com/systems/apple/iphone/iphone-
`
`faq/differences-between-the-original-iphone-and-iphone-3g.html). This document
`
`has been marked with an exhibit label and page numbers on each page at the
`
`bottom right corner. However, no alterations, other than these noted markings,
`
`have been made to this document.
`
`13. Exhibit 1133 hereto is a true and correct copy of P. Tarr, W.
`
`Harrison, H. Ossher, A. Finkelstein, B. Nuseibeh, & D. Perry, Workshop on Multi-
`
`Dimensional Separation of Concerns in Software Engineering, Proceedings of the
`
`2000 International Conference on Software Engineering: ICSE 2000 the New
`
`Millennium, Pages 809-810 (2000) (DOI=https://doi.org/10.1145/337180.337827).
`
`
`
`-5-
`
`IPR2016-00612 Page 00005
`
`
`
`This document has been marked with an exhibit label and page numbers on each
`
`page at the bottom right corner. However, no alterations, other than these noted
`
`markings, have been made to this document.
`
`14.
`
`I hereby declare that all statements made herein of my own
`
`knowledge are 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 18 U.S.C. § 1001. If called to testify as to the
`
`truth of the matters stated herein, I could and would testify competently.
`
`15.
`
`I declare under penalty of perjury that the foregoing is true and
`
`correct.
`
`Executed this 23rd day of January, 2019, in Washington, D.C.
`
`
`
`
`
`/Victor Cheung/
`Victor Cheung
`
`-6-
`
`IPR2016-00612 Page 00006
`
`
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