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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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`1.
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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
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`was the Executive Director of the 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.
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`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 that all statements made herein are of my own knowledge and
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`information contained in the business records of IETF and are true, and that all statements made
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`on information and belief are believed to be true; and further thai 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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`activities.
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`4327'5945'0‘10-l
`
`0001
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`EX. 1018
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`Apple v. MPH Techs. Oy
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`IPR2019-00820
`
`Ex. 1018
`Apple v. MPH Techs. Oy
`IPR2019-00820
`
`0001
`
`
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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 announcement of its 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 announcement is kept in the IETF email archive and the date is affixed automatically.
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`7.
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`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 pursuant to established procedures and are relied upon by the IETF in the
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`performance of its 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 announcement of the publication of
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`draft—dupont-movesptun-00, titled “Mobility-aware IPsee 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 normal practice of the IETF, that Internet-Draft was reasonably available
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`to the public Within 24 hours of that announcement. At that 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
`
`0002
`
`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 and is believed to be true.
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` Al xa Morris
`
`DECLARATION OF ALEXA MORRIS
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`0003
`
`0003
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`
`
`EXHIBIT 1
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`0004
`
`0004
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`
`
`Archive
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`httpsszmaiiarchiye.ictf.org/arch/msgr‘iolf—announce-oldeVSHH9...
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`|~D ACTION:draftudupont—movesptun—00.txt
`mmnmbnmfls@bfiom | MomZBFemuwyZOMlBQSUTC )
`
`
`
`flmwhemmr
`
`
`New Internet—Draft is available from the online lnternet— Drafts directoriesr
`
`Title
`Author(s)
`Filename
`Pages
`Date
`
`: Mobility—aware IPsec ESP tunnels
`: F. oupont
`: draft—ddpont—movesptun—Be.txt
`: 4
`: 23—Feb—31
`
`f common usage of IPsec is bidirectional ESP tunnels (secure
`Virtual Private Networks):
`the original packet is encapsulated in
`a new IP header and protected (ESP can provide confidentiality,
`authentication,
`integrity and anti—replay) by IPsec ESP (in tunnel
`ode).
`
`5 URL for this Internet—Draft 15:
`
`iinternet—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—dupent—movesptun—Be.txt”y
`
`list of Internet—Drafts directories can be round in
`www.1etr or shadowrhtml
`
`
`
`Internet~0rafts can also be obtained by e~mail.
`
`Send a message to:
`
`l :
`
`mailserygietf.orq.
`gn the body type:
`"FILE /internet—drafts/draft—dupontsmoyesptun—BG.lxt".
`1
`
`: elow is the data which will enable a MIME compliant mail reader
`implementation to automatically retrieve the ASCII version of the
`
`
`internet—Draft.
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`[drafiMdupontohovesgtuneOGtha
`
`le AC[IO§gggaft-gngont—mgyesgganefiitgg
`
`Internet—Drafts
`
`Hide Navigallon Ear
`
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`
`0005
`
`2/14/19, 11:52 AM
`
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`
`To use this
`MIME—encoded form by using the "mpack" utility.
`feature.
`insert the command “ENCODING mime" before the “FILE'I
`command.
`To decode the responsels), you will need ”munpack” or
`a MIME—compliant mail reader. Different MIMEmcompliant mail readers
`exhibit different behavior, especially when dealing with
`”multipart" MIME messages li.e. documents which have been split
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`how to manipulate these messages.
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