UNITED STATES PATENT AND TRADEMARK OFFICE
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`__________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`___________________
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`MOBILEIRON, INC.,
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`Petitioner,
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`v.
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`BLACKBERRY CORPORATION and BLACKBERRY, LTD.,
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`Patent Owners.
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`____________________
`
`Case IPR2020-XXX
`Patent 7,372,961
`__________________________________________________________
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`Title: Method of Public Key Generation
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`DECLARATION OF DANIELE MICCIANCIO IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,372,961
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`MOBILEIRON, INC. - EXHIBIT 1024
`Page 001
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`I, Daniele Micciancio, declare:
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`I make this declaration of my own personal knowledge, and if called upon as a witness
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`could and would testify competently to the matters stated herein.
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`1.
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`I am currently a Professor of Computer Science and Engineering employed by the
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`University of California: San Diego (“UCSD”), and I specialize in cryptography. I am also an
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`International Association of Cryptography Research (“IACR”) fellow, and have served as the
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`IACR program chair of CRYPTO 2019 and CRYPTO 2020. As part of my profession, I author
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`papers on various topics relevant to cryptography.
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`2.
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`While I was a graduate student at the Massachusetts Institute of Technology, I co-
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`authored with Mihir Bellare and Shafi Goldwasser a paper titled “ ‘Pseudo-Random’ Number
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`Generation Within Cryptographic Algorithms: The DDS Case,” which was published by
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`Springer as a part of the Lecture Notes in Computer Science (“LNCS”) book series in
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`proceedings of the Annual International Cryptology Conference (“CRYPTO”) in 1997.1
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`3.
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`The paper discusses the ramifications arising from the fact that if numbers for
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`the Digital Signal Standard (“DSS”) algorithm are generated using a linear congruential
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`pseudorandom number generator (“LCG”), then the secret key can be quickly recovered
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`after seeing a few signatures.
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`4.
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`The publisher Springer is a well-known publication that releases one of the
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`primary series of volumes in the cryptography space. Any library that offered the Springer series
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`in 1997 would likely have indexed this volume too, and made it available shortly after
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`publication to any member of the public, particularly those interested in the topic of
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`cryptography. I have personal knowledge that several libraries indexed Springer in the period
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`1997-99, because I myself used Springer in my research during this period.
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`1 Citation to this paper can be found in the bibliography, available for download as “Back
`Matter” on Springer’s book publication page available at
`https://link.springer.com/content/pdf/bbm%3A978-3-662-12521-2%2F1.pdf.
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`5.
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`On August 19, 1997, I presented my paper at CRYPTO, which is held in Santa
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`Barbara, California.2 My presentation was public, and was not made subject to any
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`confidentiality restrictions.
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`6.
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`CRYPTO is the premier cryptography event and has been held annually since the
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`1980s. Its popularity and fame in the field of cryptography can be likened to the “Oscars of
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`cryptography.” I myself have chaired CRYPTO twice – in 2019 and 2020 – and am very
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`familiar with its procedures, including how rapidly papers presented at the conference are
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`disseminated to and made publicly available to researchers and practitioners in the field of
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`cryptography.
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`7.
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`In 1997, when I presented my paper, 514 people registered to attend the
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`conference and I believe at least 400 were in attendance during my presentation.3 I believe that
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`this constitutes a large fraction of the cryptography research community worldwide. Anyone
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`could register to attend CRYPTO and, to my knowledge, there were no specific confidentiality
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`requirements on the use of materials presented at the conference. At CRYPTO, printed materials
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`of all of the conference workshops, including my paper, were distributed to all attendees without
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`any restrictions on their further dissemination. They were also widely disseminated and made
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`publicly available immediately after the conference, throughout the next two years.
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`8.
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`It is common practice in academia to bolster work product on personal websites
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`and to make it widely available to others in the scientific and engineering field to which the
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`paper relates. I recall that I made my 1997 CRYPTO paper available in 1997 on my personal
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`MIT student page, but that webpage no longer exists. However, a version of my paper, dated
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`May 1997, is available online on my UCSD webpage4 and on an MIT publication listing.5 My
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`2 The full program is available online at https://www.iacr.org/conferences/c97/c97prog.html.
`3 The IACR keeps statistics of its attendees and makes them publicly available at
`https://secure.iacr.org/membership/statistics/conferences.php.
`4 http://cseweb.ucsd.edu/~daniele/papers/BGM.html.
`5 http://groups.csail.mit.edu/cis/cis-publications.html.
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`1997 CRYPTO paper has been locatable since shortly after its presentation in 1997 through
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`common Internet search engines.
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`9.
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`Additionally, I have personal knowledge that my paper disseminated world-wide
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`to others in the field of cryptography between my presentation at CRYPTO in 1997 and 1999.
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`For instance, the following citations to my paper were published by other researchers located in
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`Europe, Japan, China, and the United States who were interested in and involved with
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`cryptography during this period:
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`a. December 9, 1997 thesis, “Digital Signature Schemes,” written by Nick
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`Carruthers while a student at Middlebury College, p. 32 & n.5 (copy attached);6
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`b. May 1998 doctoral dissertation, “Design of an Efficient Public-Key
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`Cryptographic Library for RISC-Based Smart Cards,” written by Jean-François
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`Dhem while a student at the Université Catholique de Louvain (p. 154 & n.
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`[BGM97], p. 1999 (excerpts attached);7
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`c. Kosheba Takeshi, Unpredictability of Pseduorandom Number Generators on
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`Public Key Cryptosystems with Models of Computation and Algorithms (in
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`Japanese), RIMS Kokyuroku (1093), 162-167, 1999-04 (Kyoto University), at p.
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`167 n.1 (copy attached);8
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`d. June 1998 Master’s thesis, “Study on Elliptic Curve Public Key Cryptosystems
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`with Application of Pseudorandom Number Generator,” written by Yuen Ching
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`Wah while a student at The Chinese University of Hong Kong;9 and
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`e. Modern Cryptography, Probabilistic Proofs and Pseudorandomness, a book
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`written by notable cryptographer, Oded Goldreich, which was published in
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`1999.10
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`6 http://citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.100.1506&rep=rep1&type=pdf.
`7 http://users.belgacom.net/dhem/these/these_public.pdf.
`8 https://hdl.handle.net/2433/62954 & https://ci.nii.ac.jp/naid/110000163518/.
`9 https://core.ac.uk/download/pdf/48534838.pdf.
`10 https://link.springer.com/book/10.1007/978-3-662-12521-2.
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`10.
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`Thus, based on my personal knowledge and experience, my paper was published,
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`indexed and readily locatable to persons interested in the subject matter of applied mathematics
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`and cryptography prior to 1999 using at least common keyword searches on internet search
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`engines. It was also published and disseminated in the materials made public during the 1997
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`CRYPTO conference, and was later further made available to libraries and similar repositories
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`via the Springer publication.
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`I declare under the penalty of perjury that the foregoing is true and correct to the best of
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`my information, knowledge and belief after reasonable investigation, and this declaration was
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`executed on September 28, 2020 in San Diego, CA, USA.
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`____________________________________
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`Daniele Micciancio
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`MOBILEIRON, INC. - EXHIBIT 1024
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