`
`—————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`—————
`
`DISH NETWORK L.L.C.,
`Petitioner,
`v.
`BROADBAND iTV, INC.,
`Patent Owner.
`
`—————
`
`U.S. Patent No. 9,998,791
`Original Issue Date: June 12, 2018
`
`Title: VIDEO-ON-DEMAND CONTENT DELIVERY METHOD FOR
`PROVIDING VIDEO-ON-DEMAND SERVICES TO TV SERVICE
`SUBSCRIBERS
`
`Case No. IPR2020-01281
`
`—————
`
`DECLARATION OF CHRISTIE POLAND
`
`DISH Ex. 1110, p. 1
` DISH v. BBiTV
` IPR2020-01281
`
`
`
`I, Christie Poland, declare as follows:
`
`1.
`
`I am over 21 years of age and otherwise competent to make this
`
`declaration. I am not being compensated for my time in preparing this declaration.
`
`The opinions here are my own, and I have no personal stake in the outcomes of the
`
`petitions for inter partes review (IPR) filed against U.S. Patent Nos. 9,648,388;
`
`9,998,791; 10,028,026; and 10,506,269, or any related litigation or administrative
`
`proceeding.
`
`2.
`
`I am currently employed at Cable Television Laboratories, Inc.
`
`(“CableLabs”) as a Manager of the Specifications & Technical Editing group. I
`
`have held this position, or similarly titled positions, since March 1, 2002. I have
`
`been with CableLabs since November 17, 1997. As part of my current position at
`
`CableLabs, I am responsible for managing technical changes, formatting, and
`
`publication of CableLabs technical specifications and other documents under strict
`
`document management control.
`
`3.
`
`As of the 2002-2003 timeframe, I was employed by CableLabs as a
`
`Manager. My responsibilities included managing technical changes to, formatting
`
`of, and publication of all CableLabs technical specifications. In that position, I had
`
`personal knowledge and familiarity with the specification management and
`
`publication process for the Metadata (“MD”) series of specifications.
`
`1
`
`DISH Ex. 1110, p. 2
` DISH v. BBiTV
` IPR2020-01281
`
`
`
`4.
`
`As of the 2002-2003 timeframe, it was the Standards group’s standard
`
`practice to make specifications available as Adobe PDF files on CableLabs’
`
`website, cablelabs.com. This website had private and public sections. In the
`
`public section, any member of the interested public could search for, browse by
`
`topic, view, and download published technical documents, including those related
`
`to the Metadata series of specifications. “Issued” specifications, which had
`
`undergone rigorous cable industry and vendor review and were suitable for use by
`
`vendors to design in conformance with, and suitable for field testing, were made
`
`available to the public on this website.
`
`5.
`
`According to Standards group’s standard practice in the 2002-2003
`
`timeframe, the Metadata specifications were posted to cablelabs.com as of the date
`
`that appeared on the “Document Status Sheet” page of each specification.
`
`Metadata specifications were also assigned a unique Document Control Number
`
`that identified the document, its revision, and its release date.
`
`6.
`
`On the same date that Metadata specifications were publicly posted on
`
`the website, the Standards group would have also emailed an announcement of the
`
`specification’s availability on cablelabs.com to a listserv
`
`(OpenCable_Announce@cablelabs.com), which in the 2002-2003 timeframe,
`
`included over a thousand email addresses of individuals at the cable operators and
`
`cable equipment vendors.
`
`2
`
`DISH Ex. 1110, p. 3
` DISH v. BBiTV
` IPR2020-01281
`
`
`
`7.
`
`Exhibit 1109 is a true and correct copy of the Metadata CableLabs®
`
`Video-On-Demand Content Specification with CableLabs Document Control
`
`Number “MD-SP-VOD-CONTENT1.1-01-020927.” The Document Control
`
`Number indicates that this document is the First Issued Release (“I01”) of version
`
`1.1 (“v1.1”) of the Video-On-Demand Content (“VOD-CONTENT”) Specification
`
`dated September 27, 2002 (“020927”). Further, as indicated by the “Date” and
`
`“Distribution Restrictions” fields on the inner cover (page ii) (“Document Status
`
`Sheet”), this document was made available to the public on September 27, 2002.
`
`An electronic copy of this document would have been on cablelabs.com available
`
`for access or download on September 27, 2002, and members of the
`
`OpenCable_Announce@cablelabs.com listserv would have received an email
`
`announcing the public availability of the document on the same day.
`
`8.
`
`I declare that all statements made herein of my own knowledge are
`
`true, and that all statements made on information and belief are believed to be true,
`
`and that these statements are made with the knowledge that willful false statements
`
`and the like so made are punishable by fine or imprisonment, or both, under
`
`Section 1001 of Title 18 of the United States Code.
`
`Executed in Boulder, CO, on the 28th day of April 2020.
`
`Christie Poland
`
`3
`
`DISH Ex. 1110, p. 4
` DISH v. BBiTV
` IPR2020-01281
`
`
`
`4
`
`DISH Ex. 1110, p. 5
`DISH Ex. 1110, p. 5
`DISH v. BBiTV
` DISH v. BBiTV
`|PR2020-01281
` IPR2020-01281
`
`
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