`Google, et al. v. Parus Holdings, Inc.
`IPR2020-00846
`Page 1 of 4
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`Case No. IPR2020-00846 & -00847
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`US. Patent Nos. 7,076,431 & 9,451,084
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`1. Paul Mulka, hereby declare the following:
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`1.
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`My name is Paul Mulka. 1 am a citizen of the United States
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`over 21 years of age. I make this Declaration based on facts and matters within my
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`own knowledge and on information provided to me by others, and if called as a
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`witness, I could and would competently testify to the matters set forth herein.
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`2.] am a professional software engineer with over 20 years of work
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`experience in the sofiware industry.
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`I graduated from college with a Bachelor of
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`Science in Computer Science and Mathematics in the December 1998. After
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`graduating college, [joined Webley Systems as a software engineer. Starting in
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`July 1999, 1 was part of the team that developed the Webley Assistant. Through
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`the remainder of 1999 and into 2000,
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`I worked on debugging and developing
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`software related to the Webley Assistant.
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`3. While working at Webley,
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`I became personally acquainted with
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`Alexander Kurganov and Valery Zhukoff.
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`4. Based on information provided to me from the management at Parus, Inc.
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`(formerly Webley Systems) and a review of the source code management system,
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`it is my understanding that Alex and Valery were employed by Webley Systems in
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`1999 and 2000. From at least November 1999 through January 2000, Alex and
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`Valery were employed full time in developing the Webley Assistant’s website
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`access functionality, including weather, stock price, and other functionality.
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`l
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`Parus Exhibit 2060, Page 2 of 4
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`Parus Exhibit 2060, Page 2 of 4
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`Case No. IPR2020-00846 & -00847
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`US. Patent Nos. 7,076,431 & 9,451,084
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`5. From the time I started working at Webley Systems, the company used a
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`source code management tool called CVS. CVS tracks when source code is
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`checked into the system after creation or after edits have been made by users. The
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`time of the check-in and the identity of the person who checked the source code in
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`to the system is tracked by the system. Typically, a source code file is created by a
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`software engineer and later checked into the CVS system.
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`6. Based on my review of the CVS records between December 1, 1999 and
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`January 10, 2000 (attached as Exhibit A), Alex checked in 11 source code files
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`related to speech recognition and functionality additions to the Webley Assistant
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`and Valery checked in 47 source code files between December 1, 1999 and
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`January 7, 2000 related to web server and agent code. Most, if not all, of the
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`source code files checked in to the CVS system by Alex and Valery related to the
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`website access component of the Webley Assistant.
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`That
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`supports my
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`understanding that Alex and Valery were working full time on the website access
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`aspects of the Webley Assistant.
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`I»)
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`Parus Exhibit 2060, Page 3 of 4 7%
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`Parus Exhibit 2060, Page 3 of 4
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`Case No. 1PR2020-00846 & -00847
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`US. Patent Nos. 7,076,431 & 9,451,084
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`I declare that all statements made herein of my knowledge are true, and that
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`all statements made on information and belief are believed to be true, and that
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`these statements were made with the knowledge that willful false statements and
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`the like so made are punishable by fine or imprisonment, or both, under Section
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`1001 ofTitle 18 ofthe United States Code.
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`Date:
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`" / 0 Q: L) Q /
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`By:
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`Paul Mulka
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`Lu
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`Parus Exhibit 2060, Page 4 of 4
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`Parus Exhibit 2060, Page 4 of 4
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