IPR2020-00031
`Patent 10,043,188 B2
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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`GUARDIAN ALLIANCE TECHNOLOGIES, INC.
`Petitioner,
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`v.
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`TYLER MILLER
`Patent Owner.
`____________
`
`
`Case IPR2020-00031
`Patent 10,043,188 B2
`_____________________________
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`DECLARATION OF DAVID HOWELL
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`Declaration of David Howell
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`INTRODUCTION
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`facts, analysis and opinions are true:
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`I, David Howell, declare under the penalty of perjury that the following
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`A. Engagement
`1. I have been engaged as an expert by Tyler Miller/Miller Mendel, Inc. in
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`connection with the captioned proceeding to provide my analyses and
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`opinions on certain technical aspects of this dispute, including my opinion
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`on validity of the claims of U.S. Patent No. 10,043,188 B2 (hereinafter
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`“the ’188 Patent”) that have been challenged by Guardian Alliance
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`Technologies, Inc. (GAT).
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`2. The statements made herein are based on my own knowledge and opinion.
`B. Background and Qualifications
`3. I am an expert in the fields of software engineering, mobile application
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`I can and will testify to these matters if called as a live witness at trial.
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`design and development, software architecture and systems, and user
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`interface design and implementation. In formulating my opinions, I have
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`relied upon my training, knowledge, and experience in this art. A true and
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`correct copy of my curriculum vitae, identified as Exhibit 2068 in this
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`proceeding, provides a description of my professional experience,
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`including my academic and employment history, publications, patents,
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`and patent applications.
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`C. Compensation and Prior Testimony
`4. I am being compensated at a rate of $250 per hour for my study in this
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`matter. I am also being reimbursed for reasonable and customary expenses
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`associated with my work and testimony in this investigation. My
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`compensation is not contingent on the outcome of this matter or the
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`5. In the last four years, I have appeared as an expert witness in the matter
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`specifics of my testimony.
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`of Perfect Company v. Adaptics, Ltd., No. 3:14-cv-05976-RBL, W.D.
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`infringement.
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`Washington on the issues of claim construction, patent validity, and
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`D. Information Considered
`6. My opinions are based on my years of education, research, and
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`experience, as well as my investigation and study of relevant materials. In
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`forming my opinions, I have considered the materials I identify in this
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`7. I may rely upon these materials and/or additional materials to respond to
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`report.
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`arguments raised by the Court. I may also consider additional documents
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`and
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`information
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`in
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`forming any necessary opinions—including
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`8. My analysis of the materials produced in this investigation is ongoing and
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`documents that may not yet have been provided to me.
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`I will continue to review any new material as it is provided. This report
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`represents only those opinions I have formed to date. I reserve the right to
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`revise, supplement, and/or amend my opinions stated herein based on new
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`information and on my continuing analysis of the materials already
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`provided.
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`E. Legal Standards
`9. In expressing my opinions and considering the subject matter of the
`10. I understand that claims are construed in this inter partes review
`11. I understand that the obviousness standard is defined in the patent statute
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`claims of the ’188 Patent, I am relying upon certain basic legal principles
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`that have been explained to me, which are summarized here.
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`proceeding as they would be in litigation.
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`(pre-AIA 35 U.S.C. § 103(a)) as follows:
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`A patent for a claimed invention may not be obtained,
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`notwithstanding that the claimed invention is not identically
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`disclosed as set forth in section 102, if the differences between
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`the claimed invention and the prior art are such that the claimed
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`invention as a whole would have been obvious before the
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`effective filing date of the claimed invention to a person having
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`ordinary skill in the art to which the claimed invention pertains.
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`Patentability shall not be negated by the manner in which the
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`invention was made.
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`12. I understand that the following standards govern the determination of
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`whether a claim in a patent is obvious. I have applied these standards in
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`my evaluation of whether claims of the ’188 Patent would have been
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`13. I understand that to find a claim in a patent obvious, one must make
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`considered obvious prior to the effective filing date of the claims.
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`certain findings regarding the claimed invention and the prior art.
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`Specifically, I understand that the obviousness question requires
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`consideration of four factors (although not necessarily in the following
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`order):
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`• The scope and content of the prior art;
`• The differences between the prior art and the claims at issue;
`• The knowledge of a person of ordinary skill in the pertinent art; and
`• Whatever objective factors indicating obviousness or non-obviousness
`14. In addition, I understand that the obviousness inquiry should not be done
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`may be present in any particular case.
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`in hindsight, but must be done using the perspective of a person of
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`ordinary skill in the relevant art as of the effective filing date of the patent
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`15. I understand the objective factors indicating obviousness or non-
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`claim.
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`obviousness may include: commercial success of products covered by the
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`patent claims; a long-felt need for the invention; failed attempts by others
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`to make the invention; copying of the invention by others in the field;
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`unexpected results achieved by the invention; praise of the invention by
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`those in the field; the taking of licenses under the patent by others;
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`expressions of surprise by experts and those skilled in the art at the making
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`of the invention; and the patentee having proceeded contrary to the
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`accepted wisdom of the prior art. I also understand that any of this
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`evidence must be specifically connected to the invention rather than being
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`associated with the prior art or with marketing or other efforts to promote
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`16. I understand the combination of familiar elements according to known
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`an invention.
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`methods is likely to be obvious when it does no more than yield
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`predictable results. I also understand that an example of a solution in one
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`field of endeavor may make that solution obvious in another related field.
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`I also understand that market demands or design considerations may
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`prompt variations of a prior art system or process, either in the same field
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`or a different one, and that these variations will ordinarily be considered
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`17. I also understand that if a person of ordinary skill can implement a
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`obvious variations of what has been described in the prior art.
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`predictable variation, that variation would have been considered obvious.
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`I understand that for similar reasons, if a technique has been used to
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`improve one device, and a person of ordinary skill in the art would
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`recognize that it would improve similar devices in the same way, using
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`that technique to improve the other device would have been obvious
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`unless its actual application yields unexpected results or would have been
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`18. I understand that the obviousness analysis need not seek out precise
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`beyond the ordinary skill to implement.
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`teachings directed to the specific subject matter of the challenged claim,
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`but instead can take account of the “ordinary innovation” and
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`experimentation that does no more than yield predictable results, which
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`are inferences and creative steps that a person of ordinary skill in the art
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`19. I understand that sometimes it will be necessary to look to interrelated
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`would employ.
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`teachings of multiple patents; the effects of demands known to the design
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`community or present in the marketplace; and the background knowledge
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`possessed by a person having ordinary skill in the art. I understand that
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`all these issues may be considered to determine whether there was an
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`apparent reason to combine the known elements in the fashion claimed by
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`20. I understand that the obviousness analysis cannot be confined by a
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`the patent at issue.
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`formalistic conception of
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`the words “teaching, suggestion, and
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`motivation.” I understand that in 2007, the Supreme Court issued its
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`decision in KSR Int’l Co. v. Teleflex, Inc. where the Court rejected the
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`previous requirement of a “teaching, suggestion, or motivation to
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`combine” known elements of prior art for purposes of an obviousness
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`21. I understand that an invention that might be considered an obvious
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`analysis as a precondition for finding obviousness.
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`variation or modification of the prior art may be considered non-obvious
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`if one or more prior art references discourages or leads away from the line
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`22. I understand that a person of ordinary skill is also a person of ordinary
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`of inquiry disclosed in the reference(s).
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`creativity. I further understand that KSR expressly states that the prior art
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`may be beyond the capabilities of the person having ordinary skill.
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` ANALYSIS
`A. OVERVIEW OF THE ’188 PATENT AND THE FIELD OF ART
`23. I understand that the Patent Owner has summarized the ’188 Patent in his
`24. The ’188 Patent involves a computer-based
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`Preliminary Response. Additionally, I would add the following.
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`invention requiring
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`substantial background in the computer arts:
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`IPR2020-00031
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`A web based software system generally designed for processing
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`pre-employment background investigations is described. The
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`software system allows an organization the ability to create and
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`customize electronic documents to be sent to their applicants to
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`complete via the web based software system, and returned in the
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`same fashion. ’188 Patent, Abstract.
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`incorporating the World Wide Web protocols and underlying network
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`protocols.
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`25. A web-based software system implies a client-server architecture
`B. LEVEL OF ORDINARY SKILL IN THE ART
`26. I understand that the validity of patent claims is measured with respect to
`27. As stated above, the ’188 Patent is ground in the computer arts. The
`28. Referring to my CV, I have extensive experience in such web-based
`29. The patent also discusses sending hyperlinks to potential applicants via
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`the expertise of the “Person Having Ordinary Skill in the Art.”
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`(“PHOSITA”).
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`technology may be applied to specific application areas.
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`client-server architectures.
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`electronic mail, essentially incorporating communication by non-WWW
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`protocols into the application. Additionally, the patent discusses storing
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`a variety of data types (e.g., text, video, scanned documents) in permanent
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`storage, essentially involving heterogeneous database technology.
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`30. During the course of my career, I have reviewed thousands of resumes
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`and interviewed hundreds of candidates for positions requiring expertise
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`in computer hardware, computer software, or both. As a general rule, in
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`my experience, a minimum education qualification for a software
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`engineer is a Bachelor of Science degree in Computer Science or a related
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`discipline having substantial focus on computer systems and software.
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`While there are rare exceptions (e.g., highly gifted individuals), it is
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`highly unlikely that I would consider such a person for an entry-level
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`position in basic software development, especially for a project involving
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`highly confidential personally-identifying information.
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`31. In sharp contrast, GAT asserts that the PHOSITA would be a person
`32. GAT asserts that the PHOSITA would “have had at least a high school
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`having substantially no education or experience in computer science or
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`related disciplines.
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`degree, or equivalent thereof, and at least one to three years of experience
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`in the relevant field, which includes background investigation methods,
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`systems, and technologies.” Petition at ¶ E. “Methods, systems, and
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`technologies” is vague, and GAT does not explain what comprises its so-
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`called field, let alone what constitutes “experience” in that field. For
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`example, hundreds of millions of people have experience using
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`computers. Computers are ubiquitous in first-world countries and
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`incorporated into televisions, cell phones, toys, cars, and even door bells.
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`The number of people with experience using these computer-based
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`technologies vastly exceeds the number of those capable of constructing
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`such systems, which typically requires significant education and
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`professional experience.
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`instructive” regarding the ordinary level of skill in the art.
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`33. Finally, GAT asserts that the background of its two declarants “are
`34. Statistically speaking, two data points provide very little information
`35. Nevertheless, the backgrounds of GAT’s declarants shed little light on
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`about the characteristics of a data set with millions of individuals.
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`GAT’s proposition that the person of ordinary skill in the art might be
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`little more than a high school graduate, with some vague “experience”
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`36. As a first order test of this proposition, GAT’s declarant, Mr. Ward, states
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`involving criminal justice.
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`that he received a Bachelor of Science degree in Criminal Justice
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`Administration and Political Science from Brigham Young University,
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`but he does not provide a date. Ex. 1009, ¶ 2. He further states that he
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`obtained a “Masters of Public Administration,” also from BYU, on an
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`37. According to BYU archives, there was a Law Enforcement and Justice
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`unspecified date. Id.
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`Administration (LEJA) program from 1974–1978 (Ex. 2004), which
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`appears consistent with Mr. Ward obtaining employment as a police
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`officer in 1979. However, there is no detailed curriculum in the 1974–
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`1975 BYU Undergraduate Course Catalog requiring persons in the LEJA
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`program to have any substantial coursework in computer science. (Ex.
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`2005 at 15-18).
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`38. Mr. Ward further suggests that he spent approximately 30 years in law
`39. Mr. Ward does not suggest that he has any background or expertise in
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`enforcement with the Dallas Police Department. Id. at ¶ 3.
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`software development. Further, he does not assert that he engaged in
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`writing any software related to the so-called Background Assistant
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`software. In sum, Mr. Ward’s declaration does not establish that he would
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`be a person of ordinary skill capable of creating a “web based software
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`40. GAT’s second declarant, Mr. Klosson, states that he received a Bachelor
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`system” in any application area.
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`of Science in Business Administration from National University in an
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`unspecified year. Ex. 1014, ¶ 2. According to U.S. News and Worls
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`Reports, which provides annual college rankings, National University has
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`41. According to National University’s web site, NU’s BBA (Bachelor of
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`no established ranking as an academic institution.
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`Business Administration) degree has no prerequisites or curriculum
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`related
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`to Computer Science, Management Information Science,
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`Information Technology, or any related subject areas. See Ex. 2006 at 1-
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`2. This business degree appears to be substantially irrelevant to this instant
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`42. Mr. Klosson further states that he is a “self-taught developer” (Ex. 1014,
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`question.
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`¶ 3) but he provides substantially no detail regarding his background, his
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`technical expertise, or his specific contributions to any software
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`development projects. He makes a conclusory statement that he has
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`worked in the area of law enforcement background investigation, but
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`provides no explanation of his position. Was he a police officer or a
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`programmer? In short, he provides no verifiable facts, only conclusions.
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`43. In summary, Mr. Klosson’s declaration sheds no light on the
`C. EXHIBIT 1002 APPEARS TO HAVE BEEN CREATED NO
`44. It is my understanding that GAT asserts that the video identified as Ex.
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`qualifications of the person having ordinary skill in the art.
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`EARLIER THAN DECEMBER 2012
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`1002 is prior art to the ’188 Patent. This assertion is not credible for
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`several reasons, for example, the video itself appears to be created using
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`materials claiming copyright date in 2012 as illustrated in the figures
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`45. Indeed, if one assumes that the video was capturing operational software
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`below.
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`in real-time, the operational dates that appear in the software indicate that
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`at least some portions of the video were made on December 17, 2012,
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`approximately eight months after the parent application for the ’188
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`46. Approximately five seconds (00:05) into the video, there is a screen
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`Patent was filed.
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`containing the legend “Applications in Progress.” The screen lists three
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`names with “Creation Dates” for the names as October 31, 2012,
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`November 2, 2012, and November 3, 2012 respectively. Although there
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`appears to be space for a time of day, the times are all zero. This may
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`indicate that time was not actually captured/stored by the underlying
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`software (if any existed).
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`47. As the video proceeds, the user selects the “Investigator Dashboard” tab
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`at approximately 00:50, then zooms into the third icon associated with the
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`first name. As the video zooms out, there appears to be a “jump cut”1
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`transition to a screen titled “Generate Correspondence.”
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`48. At approximately 1:54, the number 10 is typed into the entry filed titled
`49. In another jump cut, a window titled “View Correspondence” appears. A
`50. Most notably, each of the entries on the page bears the “Creation Date” of
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`“Mile Radius,” and the “Generate” button appears to be activated.
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`legend in green states that “Your documents have been successfully
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`generated.”
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`December 17, 2012 at the window is viewed from 2:04 to 2:21.
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`1 In video production, a jump cut is an abrupt transition from one scene to another.
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`51. As the video proceeds, the user selects an item associated with a specific
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`police department (“Addison Police Dept.”), and there is a “jump cut” to
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`a window displaying a sample letter. The letter is dated December 17,
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`2012, however, it has a blank logo for “Hometown Police” at the top.
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`52. At time 6:14, the video displays a page title Fax. This page also bears the
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`There is no information about the Addison Police Dept in the letter.
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`date December 17, 2012.
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`53. Around time 7:14, the user appears to click on the “check mark” icon for
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`the first entry at which point December 17, 2012 appears in the “Date
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`Received” column for the Addison Police Dept entry.
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`54. Around time 7:53, the user appears to click on the “check mark” icon one
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`more time for the first entry at which point December 17, 2012 appears in
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`the “Date Completed” column for the Addison Police Dept entry.
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`55. Around time 7:53, a “fade transition” appears to occur in which several
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`entries have been updated to show “12/17/12” in the Date Received
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`column. This transition confirms that this is not a video showing the real-
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`time operation of a software product. Rather, it appears to be a production
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`56. Based on the material displayed in Ex. 1002, it is highly unlikely that this
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`made from source material created on December 17, 2012.
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`video was created prior to December 17, 2012. Rather, I conclude that the
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`source material was likely created no earlier than December 17, 2012, and
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`the video itself was created later.
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`to have been a “printed publication” prior to the filing of the parent
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`application for the ’188 Patent in April 2012.
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`57. As a result, it would have been chronologically impossible for Ex. 1002
`58. In my opinion, Ex. 1002 is not prior art to the ’188 Patent.
`D. EXHIBIT 1004 DOES NOT APPEAR TO BE AN AUTHENTIC
`59. Based on my investigation and analysis, Ex. 1004 does not appear to be
`60. GAT asserts that “The Internet Archive supports Mr. Ward’s testimony
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`DOCUMENT
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`an authentic document.
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`that the printed publication was available on Background Solutions’
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`homepage no later than November 23, 2009.” I will explain why The
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`Internet Archive does not in fact support that testimony.
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`61. The Internet Archive does not necessarily display accurate web pages
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`captured on a specific date. The Internet Archive makes this clear in the
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`“Standard Affidavit” that it will provide in legal proceedings. Ex. 2007, ¶
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`62. This affidavit notes that each link on a web page may be archived on a
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`5.
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`different date. This is particularly important for embedded objects, which
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`includes images, frames, scripts, etc., because these can be rendered to
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`produce a composite object that did not exist previously:
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`The date assigned by the Internet Archive applies to the HTML
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`file but not to image files linked therein. Thus images that appear
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`on the printed page may not have been archived on the same date
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`as the HTML file. Likewise, if a website is designed with
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`"frames," the date assigned by the Internet Archive applies to the
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`frameset as a whole, and not to the individual pages within each
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`frame. (Bold added).
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`63. I can illustrate that with a simple hypothetical example. Assume that a
`64. The Internet Archive stores an aggregation of pages captured by various
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`web page contains text and two image objects, the latter being referenced
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`by a separate URLs (Uniform Resource Locators, or web addresses).
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`means including “web crawler.” In my example, a series of web crawls,
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`the HTML for the page might be captured on January 1st, however the
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`capture parameter might exclude all image files. In a subsequent crawl,
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`the capture might include image files 1MB or less, and exclude larger
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`files. In a third crawl, the capture might include image files as large as
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`65. However, if the page owner changes the image files between crawls,
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`10MB.
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`different components of the page may have been captured on different
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`dates. That is, the content held by the archive can be a composite
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`collection of content that did not exist together on the original capture
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`date. For this reason, it is critical to review the capture date of each link
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`66. Exhibits 1004 and 1023 are both allegedly captured from the Internet
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`that is alleged to be part of the prior art.
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`Archive. However, there are distinct differences in how they were
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`converted to PDF for submission to the Board. Indeed, different tools
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`were used to create the files according to the PDF metadata.
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`67. For example, Exhibit 1023 has been printed in such a manner that at least
`68. Thus,
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`some link information is preserved. For example, if one hovers a cursor
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`over the blue links, the target URL will be displayed.
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`the
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`“captures”
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`link
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`points
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`to
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`https://web.archive.org/web/*/http://www.backgroundsolutions.com/ind
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`ex.html.
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`The
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`“more”
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`link
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`points
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`to:
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`https://web.archive.org/web/20091123000618/http:/www.backgroundsol
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`IPR2020-00031
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`utions.com:80/demo.html. Clicking on these links will retrieve a page
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`69. In contrast, Exhibit 1004 appears to have been captured as a series of
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`from the Internet Archive.
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`screenshots that have been assembled into a document that has removed
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`the underlying links. That is, the underlying HTML has not been
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`70. I retrieved the HTML for the URL that appears to identify the document:
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`preserved and submitted to the Patent Owner and the Board.
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`http://web.archive.org/web/20110201221611/http://www.esdevllc.com/p
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`obits/help/index.html by typing this directly into a Safari browser
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`window. The page title was “POBITS User's Manual and Technical
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`Reference.” On this page there were two primary frames: a table of
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`contents, and a content frame that initially opened to “Introduction: Peace
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`Officer Background Investigation Tracking System.”
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`Declaration of David Howell
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`IPR2020-00031
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`71. The HTML Source for the URL above is attached as Ex. 2008. As
`72. With Safari’s developer tools enabled, I right-clicked on the navigation
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`indicated this brief file defines a FRAME SET. The left frame is the
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`“navigation” frame, while the right is the “content” frame.
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`
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`area on the page, and selected the popup menu item “Show Frame
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`Source.” This displayed the source code for the navigation frame. I have
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`attached that source code as Exhibit 2009. This HTML builds an HTML
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`table object, specifically the entries seen in the Navigation frame.
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`According to the Archive, this content was archived on August 8, 2019.
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`Declaration of David Howell
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`73. Then, with Safari’s developer tools enabled, I right-clicked on the Content
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`IPR2020-00031
`Patent 10,043,188
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`Frame on the page (the right frame), and selected the popup menu item
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`“Show Frame Source.” This displayed the source code for the content
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`74. Examining the HTML code in Exhibit 2010 revealed that the archived
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`frame. I have attached that source code as Exhibit 2010.
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`source code for the Introduction frame was archived by the Internet
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`Archive on August 8, 2019. Like other files, a comment inserted by the
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`Archive in the captured source code was explicit about this.
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`
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`75. In fact, stepping through the table of contents on that page and examining
`76. I have examined the recorded capture dates for each of the links below
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`each content frame revealed that all of the content frames were captured
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`on August 8, 2019, years after the effective filing date of the ’188 Patent.
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`and correlated them to the corresponding page in Ex. 1004. Page 6 has an
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`asterisk because Ex. 1004 does not actually display the “Information
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`Security” content. Rather, the content in the submitted document is the
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`same as page 5 “Information Integrity and Data Ownership.” As
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`illustrated in the table, all of the child pages, which are illustrated in the
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`Declaration of David Howell
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`IPR2020-00031
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`right side of the page in Exhibit 1004 appear to have been captured by the
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`Internet Archive on August 8, 2019.
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`Internet Archive capture link
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/introduction.htm.
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/concept_of_operation.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/benefits.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/electronic_vs_paper.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/information_integrity.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/information_security.htm*
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/system_architecture.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/about_this_manua.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/learning_to_use_pobits.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/useful_concepts.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/user_roles.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/manager.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/investigator.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/viewer.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/other_roles.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/web_application_basics.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/your_dashboard.htm
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`Declaration of David Howell
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`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/the_main_menu.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/managing_candidates2.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/personal_information.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/deleting_a_candidate.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/personal_history_statement.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/working_with_lists.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/executive_summary.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/relatives_and_references.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/parents.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/spouses_former_spouses_domesti.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/siblings.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/children.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/personal_references.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/secondary_references2.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/education.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/high_schools.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/colleges.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/trade_schools.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
`m/pobits/help/post_academies.htm
`http://web.archive.org/web/20190808074437if_/http://www.esdevllc.co
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`Declaration of David Howell
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`Page 24
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