DECLARATION
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`I, Alexa Morris, based on my personal knowledge and information, hereby declare as
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`follows:
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`l.
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`I am Managing Director of the IETF Administration LLC and have held that
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`position since the LLC was formed in August 2018. Prior to that, starting on January 1, 2008, I
`was the Executive Director ofthe Internet Engineering Task Force, which was an activity of the
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`Internet Society, Since the business of IETF did not change in any materially relevant manner
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`with the formation of the LLC, I will collectively refer to both the activity and the LLC as IETF,
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`2,
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`One of my responsibilities with IETF has been to act as the custodian of Internet-
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`Drafts and records relating to Internet-Drafts. I am familiar with the record keeping practices
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`relating to Internet-Drafts, including the creation and maintenance of such records,
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`3,
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`I hereby declare thatall statements made herein are of my own knowledge and
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`information contained in the business records of IETF andare true, and that all statements made
`on information and belief are believed to be true; and further that these statements were made
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`with the knowledge that willful false statements may be punishable by fine or imprisonment, or
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`both, under Section 1001 of Title 18 of the United States Code.
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`4,
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`Since 1998, it has been the regular practice of the IETF to publish Internet-Drafts
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`and make them available to the public on its website at www.ietf.org (the IETF website), The
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`IETF maintains copies ofInternet-Drafts in the ordinary course of its regularly conducted
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`|
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`activities.
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`4827-8945-0120.1
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`0001
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`Ex. 1018
`Apple v. MPH Techs. Oy
`IPR2019-00820
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`Ex. 1018
`Apple v. MPH Techs. Oy
`IPR2019-00820
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`0001
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`

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`5,
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`Any Internet-Draft published on the IETF website was reasonably accessible to
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`the public and was disseminated or otherwise available to the extent that persons interested and
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`ordinarily skilled in the subject matter or art exercising reasonable diligence could have located
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`it. In particular, the Internet-Drafts were indexed and searchable on the IETF website.
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`6.
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`Internet-Drafts are posted to an IETF online directory, When an Internet-Draft is
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`published, an announcementofits publication that describes the Internet-Draft is disseminated.
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`Typically, that dated announcement is made within 24 hours of the publication of the Internet-
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`Draft, The announcementis kept in the IETF email archive and the date is affixed automatically,
`7,
`The records of posting the Internet-Drafts in the IETF online repository are kept
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`in the course of the IETF’s regularly conducted activity and ordinary course of business. The
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`records are made pursuantto established procedures and are relied upon by the JETF in the
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`performanceofits functions,
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`8.
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`It is the regular practice of the IETF to make and keep the records in the online
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`repository.
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`9,
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`Exhibit 1 is a true and correct copy of an announcementof the publication of
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`draft-dupont-movesptun-00, titled “Mobility-aware IPsec ESP tunnels.” I have determined that
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`an announcement of the publication of this Internet-Draft was made on February 26, 2001,
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`Therefore, based on the normalpractice of the IETF, that Internet-Draft was reasonably available
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`to the public within 24 hours of that announcement. Atthat time, the Internet-Draft would have
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`been disseminated or otherwise available to the extent that persons interested and ordinarily
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`skilled in the subject matter or art, exercising reasonable diligence, could have located it.
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`DECLARATION OF ALEXA MORRIS
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`0002
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`0002
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`

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`Pursuant to Section 1746 of Title 28 of United States Code, I declare under penalty of
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`perjury under the laws of the United States of America that the foregoing is true and correct and
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`that the foregoing is based upon personal knowledge and information andis believed to betrue,
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` Date: Por 7 7 (¢- op— By:
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`Aléxa Morris
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`DECLARATION OF ALEXA MORRIS
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`0003
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`0003
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`

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`EXHIBIT 1
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`0004
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`0004
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`

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`Archive
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`https://mailarchive ietf.org/arch/msg/ielf-announce-old/EV SHH...
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`I-D ACTION: draft-dupont-movesptun-00,txt
`Internet-Drafts@letf.org
`| Mon, 26 February 200118:26UTG | Show header
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`New Internet-Draftis available Fromthe on-line Internet-Draftsdirectories,|
`
`Title
`Author(s)
`Filename
`Pages
`Date
`
`: Mobility-aware IPsec ESP tunnels
`: F. Dupont
`: draft-dupont-movesptun-8@,txt
`4
`+ 23-Feb-$1
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`'A common usage of IPsec is bidirectional ESP tunnels (secure
`Nirtual Private Networks}:
`the original packet is encapsulated in
`ia new IP header and protected (ESP can provide confidentiality,
`authentication,
`integrity and anti-replay) by IPsec ESP (in tunnel
`ode).
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`A URL for this Internet-Draft is:
`
`
`Internet-Drafts are also available by anonymous FTP. Login with the username
`"anonymous" and a password of your e-mail address. After logging in,
`ype "cd internet-drafts" and then
`“get draft-dupont-movesptun-0@,. txt",
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`t
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`|
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`Uist of Internet-Drafts directories can be found in
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`
`
`Internet-Drafts can also be obtained by e-mail.
`
`
`
`iii
`
`Send a message to:
`agilservalett org,
`in the body type:
`"FILE /internet-drafts/draft-dupont-movesptun-0@, txt",
`
`° Themailserveratdetfgrgcanreturnthedocument
`
`To use this
`MIHE-encoded form by using the "mpack" utility,
`feature,
`insert the command “ENCODING mime" before the FILE"
`command,
`To decode the response(s}, you will need "munpack” or
`a MIME-compliant mail reader, Different MIME-compliant mail readers
`exhibit different behavior, especially when dealing with
`"multipart" MIME messages (i.e, documents which have been split
`up into multiple messages), so check your local documentation on
`how to manipulate these messages.
`
`in
`
`|
`ia
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`‘Balow is the data which will enable a MIME compliant mail reader
`implementation to automatically retrieve the ASCIZ version of the
`
`
`gnternet-Dratt.
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`ttoy//ftp Jettorg/internet-dratts/dratt-dupont-mavesptun-O0.ix "><fipitpJetiorginternet-dcrafts
`{draft-cdupont-movesptun-O0.txt>
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`I-D ACTION: draft-dupont-movesptun-@a. txt
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`Internet-Drafts
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`Hide Navigation Bat
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`0005
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`2/14/19, 11:52 AM
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`0005
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