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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
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`APPLE INC.,
`
`Petitioner,
`
`v.
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`FIRSTFACE CO., LTD.,
`
`Patent Owner.
`
`____________
`
`Case IPR2019-01011
`
`U.S. Patent No. 9,633,373
`
`____________
`DECLARATION OF VICTOR CHEUNG IN SUPPORT OF THE
`PETITION FOR INTER PARTES REVIEW OF UNITED
`STATES PATENT NO. 9,633,373
`
`I, Victor Cheung, make the following Declaration pursuant to 28 U.S.C.
`
`§ 1746:
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`1.
`
`2.
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`I am an associate at the law firm of Ropes & Gray LLP.
`
`I provide this Declaration in connection with the above-identified
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`Inter Partes Review proceeding that is being requested at the United States Patent
`
`Apple Ex. 1036
`Apple Inc. v. Firstface Co., Ltd.
`IPR2019-01011
`Page 00001
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`
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`and Trademark Office (“USPTO”) by Apple Inc. Unless otherwise stated, the facts
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`stated in this Declaration are based on my personal knowledge.
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`3.
`
`Exhibit 1007 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
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`has been marked with an exhibit label and page numbers on each page at the
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`bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`4.
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`Exhibit 1014 hereto is a true and correct copy of German Patent
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`Application Publication No. DE 197 10 546 A1 to Herfet (with a certified English
`
`translation). This document has been marked with an exhibit label and page
`
`numbers on each page at the bottom right corner. However, no alterations, other
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`than these noted markings, have been made to this document.
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`5.
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`Exhibit 1021 hereto is a true and correct copy of Peter H. Lewis, THE
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`EXECUTIVE COMPUTER; Compaq Finally Makes a Laptop, The New York
`
`Times (October 23, 1988) (https://www.nytimes.com/1988/10/23/business/the-
`
`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
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`right corner. However, no alterations, other than these noted markings, have been
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`made to this document.
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`-2
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`IPR2019-01011 Page 00002
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`6.
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`Exhibit 1022 hereto is a true and correct copy of J. Flinn & M.
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`Satyanarayanan, Energy-aware adaptation for mobile applications, 33 SIGOPS
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`Oper. Syst. Rev. 48-63 (December 12, 1999)
`
`(DOI=http://dx.doi.org/10.1145/319344.319155). This document has been marked
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`with an exhibit label and page numbers on each page at the bottom right corner.
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`However, no alterations, other than these noted markings, have been made to this
`
`document.
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`7.
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`Exhibit 1023 hereto is a true and correct copy of A. Roy, S. M.
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`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
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`corner. However, no alterations, other than these noted markings, have been made
`
`to this document.
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`8.
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`Exhibit 1024 hereto is a true and correct copy of Your Palm Treo 680
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`Smart Device User Guide (2006)
`
`(https://www.att.com/support_static_files/manuals/Palm_Treo_680.pdf). This
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`document has been marked with an exhibit label and page numbers on each page at
`
`-3
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`IPR2019-01011 Page 00003
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`9.
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`Exhibit 1025 hereto is a true and correct copy of D. Muthukumaran,
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`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 1026 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
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`corner. However, no alterations, other than these noted markings, have been made
`
`to this document.
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`11. Exhibit 1033 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
`
`-4
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`IPR2019-01011 Page 00004
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`
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`2000 International Conference on Software Engineering: ICSE 2000 the New
`
`Millennium, Pages 809-810 (2000) (DOI=https://doi.org/10.1145/337180.337827).
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`This document has been marked with an exhibit label and page numbers on each
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`page at the bottom right corner. However, no alterations, other than these noted
`
`markings, have been made to this document.
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`12.
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`I hereby declare that all statements made herein of my own
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`knowledge are true; and further that these statements were made with the
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`knowledge that willful false statements and the like so made are punishable by fine
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`or imprisonment, or both, under 18 U.S.C. § 1001. If called to testify as to the
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`truth of the matters stated herein, I could and would testify competently.
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`13.
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`I declare under penalty of perjury that the foregoing is true and
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`correct.
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`Executed this 24th day of April, 2019, in Washington, D.C.
`
`/Victor Cheung/
`Victor Cheung
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`-5
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`IPR2019-01011 Page 00005
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`