Declaration of Jacob Robert Munford
`
`1
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`APPLE 1031
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`

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`1. My name is Jacob Robert Munford. I am over the age of 18, have personal
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`knowledge of the facts set forth herein, and am competent to testify to the
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`same.
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`2. I earned a Master of Library and Information Science (MLIS) from the
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`University of Wisconsin-Milwaukee in 2009. I have over ten years of
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`experience in the library/information science field. Beginning in 2004, I
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`have served in various positions in the public library sector including
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`Assistant Librarian, Youth Services Librarian and Library Director. I have
`
`attached my Curriculum Vitae as Appendix A.
`
`3. During my career in the library profession, I have been responsible for
`
`materials acquisition for multiple libraries. In that position, I have cataloged,
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`purchased and processed incoming library works. That includes purchasing
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`materials directly from vendors, recording publishing data from the material
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`in question, creating detailed material records for library catalogs and
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`physically preparing that material for circulation. In addition to my
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`experience in acquisitions, I was also responsible for analyzing large
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`collections of library materials, tailoring library records for optimal catalog
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`2
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`

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`search performance and creating lending agreements between libraries
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`during my time as a Library Director.
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`
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`4. I am fully familiar with the catalog record creation process in the library
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`sector. In preparing a material for public availability, a library catalog record
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`describing that material would be created. These records are typically
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`written in Machine Readable Catalog (herein referred to as “MARC”) code
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`and contain information such as a physical description of the material,
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`metadata from the material’s publisher, and date of library acquisition. In
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`particular, the 008 field of the MARC record is reserved for denoting the
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`date of creation of the library record itself. As this typically occurs during
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`the process of preparing materials for public access, it is my experience that
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`an item’s MARC record indicates the date of an item’s public availability.
`
`
`5. This declaration is being drafted as of November 2020. Public and university
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`libraries in my area have been closed for months due to the COVID-19
`
`pandemic. My state, Pennsylvania, has a travel advisory, which has affected
`
`my ability to travel. In my experience, library catalog records are accurate
`
`descriptions of a library’s collection and my lack of physical access to
`
`libraries at this time creates no doubt in my determinations of authenticity or
`
`availability of the exhibits noted below.
`
`3
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`

`

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`6. I have reviewed Exhibit 1004, an article entitled “Improving Selection
`
`Performance on Pen-Based Systems: A Study of Pen-Based Interaction for
`
`Selection Tasks” by Xiangshi Ren and Shinji Moriya as published in ACM
`
`Transactions on Computer Human Interaction, Vol. 3 No. 3 (2000).
`
`
`7. Attached hereto as Appendix REN01 is a true and correct copy of the
`
`MARC record describing ACM Transactions on Computer Human
`
`Interaction as held by the Carnegie-Mellon University’s library. I secured
`
`this record myself from the library’s online catalog. This MARC record
`
`accurately describes this journal’s title, publisher and ISSN. The 008 field of
`
`this MARC record indicates the journal ACM Transactions on Computer
`
`Human Interaction was first cataloged by Carnegie-Mellon University’s
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`library as of May 17, 1994. The location items field on page 1 of this record
`
`indicates the library’s collection spans from Vol. – Vol. 12, included the
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`Vol. 3 No. 3 edition containing “Improving Selection Performance on Pen-
`
`Based Systems: A Study of Pen-Based Interaction for Selection Tasks”.
`
`
`8. In comparing Exhibit 1004 to this MARC record, it is my determination that
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`Exhibit 1004 is a true and correct copy of “Improving Selection Performance
`
`on Pen-Based Systems: A Study of Pen-Based Interaction for Selection
`
`4
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`Tasks” from ACM Transactions on Computer Human Interaction, Vol. 3
`
`No. 3. Considering that Carnegie-Mellon University’s record indicates the
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`library began collecting this journal on May 17, 1994 and appended
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`subsequent volumes to this record since 2005, it is my determination that
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`ACM Transactions on Computer Human Interaction and therefore
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`“Improving Selection Performance on Pen-Based Systems: A Study of Pen-
`
`Based Interaction for Selection Tasks” was made available and accessible to
`
`the public by shortly after initial release in September 2000.
`
`
`9. I have reviewed Exhibit 1012, an article entitled “A New Era for High
`
`Precision Touchscreen” by Andrew Sears, Catherine Plaisant and Ben
`
`Shneiderman as published in Advances in Human-Computer Interaction Vol.
`
`3.
`
`
`10. Attached hereto as Appendix SEARS01 is a true and correct copy of the
`
`MARC record describing Advances in Human-Computer Interaction Vol. 3
`
`as held by the Linda Hall Library. I secured this record myself from the
`
`library’s online catalog. This MARC record accurately describes this book’s
`
`title, publisher and ISBN. The 008 field of this MARC record indicates
`
`Advances in Human-Computer Interaction Vol. 3 was first cataloged by the
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`Linda Hall Library as of February 1, 1995.
`
`5
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`

`

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`11. In comparing Exhibit 1012 to this MARC record, it is my determination that
`
`Exhibit 1012 is a true and correct copy of “A New Era for High Precision
`
`Touchscreen” from Advances in Human-Computer Interaction Vol. 3.
`
`Considering that Linda Hall Library’s record indicates the library began
`
`collecting this journal on February 1, 1995, it is my determination that
`
`Advances in Human-Computer Interaction Vol. 3 and therefore “A New Era
`
`for High Precision Touchscreen” was made available and accessible to the
`
`public as of February 1, 1995.
`
`
`12. I have reviewed Exhibit 1014, an article entitled “The Design and Analysis
`
`of Graphical Passwords” by Ian Jermyn, Alain Mayer, Fabian Monrose,
`
`Michael K. Reiter and Aviel D. Rubin as published in Proceedings of the 8th
`
`USENIX Security Symposium.
`
`
`13. Attached hereto as Appendix JERMYN01 is a true and correct copy of the
`
`MARC record describing Proceedings of the 8th USENIX Security
`
`Symposium as held by the Carnegie-Mellon University’s library. I secured
`
`this record myself from the library’s online catalog. This MARC record
`
`accurately describes this book’s title, publisher and ISBN. The 008 field of
`
`this MARC record indicates Proceedings of the 8th USENIX Security
`
`6
`
`

`

`Symposium was first cataloged by the Carnegie-Mellon University’s library
`
`as of October 6, 1999.
`
`
`14. In comparing Exhibit 1014 to this MARC record, it is my determination that
`
`Exhibit 1014 is a true and correct copy of “The Design and Analysis of
`
`Graphical Passwords” from Proceedings of the 8th USENIX Security
`
`Symposium. Considering that Carnegie-Mellon University’s library record
`
`indicates the library began collecting this journal on October 6, 1999, it is
`
`my determination that Proceedings of the 8th USENIX Security Symposium
`
`and therefore “The Design and Analysis of Graphical Passwords” was made
`
`available and accessible to the public by as of October 6, 1999.
`
`
`15. I have been retained on behalf of the Petitioner to provide assistance in the
`
`above-illustrated matter in establishing the authenticity and public
`
`availability of the documents discussed in this declaration. I am being
`
`compensated for my services in this matter at the rate of $100.00 per hour
`
`plus reasonable expenses. My statements are objective, and my
`
`compensation does not depend on the outcome of this matter.
`
`
`
`16. I declare under penalty of perjury that the foregoing is true and correct. I
`
`hereby declare that all statements made herein of my own knowledge are
`
`7
`
`

`

`true and that all statements made on information and belief are believed to
`
`be true; and further that these statements were made 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.
`
`
`
`Dated: November 5, 2020
`
`
`
`Jacob Robert Munford
`
`
`
`
`
`
`
`8
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`

`

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`APPENDIX A
`
`APPENDIX A
`
`9
`
`

`

`Appendix A - Curriculum Vitae
`
`Education
`
`University of Wisconsin-Milwaukee - MS, Library & Information Science, 2009
`Milwaukee, WI
`● Coursework included cataloging, metadata, data analysis, library systems,
`management strategies and collection development.
`● Specialized in library advocacy and management.
`
`
`Grand Valley State University - BA, English Language & Literature, 2008
`Allendale, MI
`● Coursework included linguistics, documentation and literary analysis.
`● Minor in political science with a focus in local-level economics and
`government.
`
`
`Professional Experience
`
`Researcher / Expert Witness, October 2017 – present
`Freelance
`Pittsburgh, Pennsylvania
`● Material authentication and public accessibility determination. Declarations
`of authenticity and/or public accessibility provided upon research
`completion. Depositions provided on request.
`● Research provided on topics of public library operations, material
`publication history, digital database services and legacy web resources.
`● Past clients include Apple, Fish & Richardson, Erise IP, Baker Botts and
`other firms working in patent law.
`
`
`
`Library Director, February 2013 - March 2015
`Dowagiac District Library
`Dowagiac, Michigan
`● Executive administrator of the Dowagiac District Library. Located in
`Southwest Michigan, this library has a service area of 13,000, an annual
`
`10
`
`

`

`operating budget of over $400,000 and total assets of approximately
`$1,300,000.
`● Developed careful budgeting guidelines to produce a 15% surplus during the
`2013-2014 & 2014-2015 fiscal years.
`● Using this budget surplus, oversaw significant library investments including
`the purchase of property for a future building site, demolition of existing
`buildings and building renovation projects on the current facility.
`● Led the organization and digitization of the library's archival records.
`● Served as the public representative for the library, developing business
`relationships with local school, museum and tribal government entities.
`● Developed an objective-based analysis system for measuring library services
`- including a full collection analysis of the library's 50,000+ circulating
`items and their records.
`
`
`
`November 2010 - January 2013
`Librarian & Branch Manager, Anchorage Public Library
`Anchorage, Alaska
`● Headed the 2013 Anchorage Reads community reading campaign including
`event planning, staging public performances and creating marketing
`materials for mass distribution.
`● Co-led the social media department of the library's marketing team, drafting
`social media guidelines, creating original content and instituting long-term
`planning via content calendars.
`● Developed business relationships with The Boys & Girls Club, Anchorage
`School District and the US Army to establish summer reading programs for
`children.
`
`
`June 2004 - September 2005, September 2006 - October 2013
`Library Assistant, Hart Area Public Library
`Hart, MI
`● Responsible for verifying imported MARC records and original MARC
`cataloging for the local-level collection as well as the Michigan Electronic
`Library.
`● Handled OCLC Worldcat interlibrary loan requests & fulfillment via
`ongoing communication with lending libraries.
`
`11
`
`

`

`
`Professional Involvement
`
`Alaska Library Association - Anchorage Chapter
`● Treasurer, 2012
`
`
`Library Of Michigan
`● Level VII Certification, 2008
`● Level II Certification, 2013
`
`
`Michigan Library Association Annual Conference 2014
`● New Directors Conference Panel Member
`
`
`Southwest Michigan Library Cooperative
`● Represented the Dowagiac District Library, 2013-2015
`
`
`
`Professional Development
`
`Library Of Michigan Beginning Workshop, May 2008
`Petoskey, MI
`● Received training in cataloging, local history, collection management,
`children’s literacy and reference service.
`
`
`Public Library Association Intensive Library Management Training, October 2011
`Nashville, TN
`● Attended a five-day workshop focused on strategic planning, staff
`management, statistical analysis, collections and cataloging theory.
`
`
`Alaska Library Association Annual Conference 2012 - Fairbanks, February 2012
`Fairbanks, AK
`● Attended seminars on EBSCO advanced search methods, budgeting,
`cataloging, database usage and marketing.
`
`12
`
`

`

`APPENDIX JERMYN01
`
`APPENDIX JERMYNOI
`
`13
`
`13
`
`

`

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`
`14
`
`14
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`

`

`APPENDIX REN01
`
`APPENDIX REN01
`
`15
`
`15
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`

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`##$aSHELVED BY TITLE $VVOL.
`3 1996 INC $wALPHANUM $c1 $iA035917 $d9/6/2000 $e8/7/1998 $lBY-REQUEST $mOFFSITE $n2 $q6 $rY $sY $tJOURNAL $u1/24/1997
`##$aSHELVED BY TITLE $VVOL. 4 1997 $wALPHANUM $c1 $iA035918 $d2/14/2002 $e3/17/1999 $lBYeREQUEST $mOFFSITE $n2 $q4 $rY $SY $tJOURNAL $u1/22/1998
`##$aSHELVED BY TITLE $VVOL.
`5 1998 $wALPHANUM $c1 $iA035919 $d2/14/2002 $lBY—REQUEST $mOFFSITE $q9 $rY $SY $tJOURNAL $u5/13/1999
`##$aSHELVED BY TITLE $VVOL. 6 1999 $wALPHANUM $c1 $iA035920 $d7/16/2004 $e7/15/2004 $1BY—REQUEST $m0FFSITE $n1 $q3 $rY $sY $tJOURNAL $u4/20/2000
`##$aSHELVED BY TITLE $VVOL. 7 2000 $wALPHANUM $c1 $1A035921 $d2/14/2002 $lBY—REQUEST $mOFFSITE $q2 $rY $SY $tJOURNAL $u3/27/2001
`##$aSHELVED BY TITLE $VVOL. 8 2001 $wALPHANUM $C1 $iA035922 $lBY- REQUEST $mOFFSITE $rY $SY $tJOURNAL $u3/29/2002
`##$aSHELVED BY TITLE $VVOL. 9 2002 $wALPHANUM $c1 $1A035923 $lBY REQUEST $mOFFSITE $rY $SY $tJOURNAL $u12/13/2002
`##$aURL $wALPHANUM $c1 $i442294- 20001 $d7/29/1999 $1WEB $mE— RESOURCE $rY $sY $tE— JOUR $u7/29/1999 FORM: SERIAL
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`18
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`18
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`

`

`APPENDIX SEARS01
`
`APPENDIX SEARSOI
`
`19
`
`19
`
`

`

`leader
`
`00764cam a2200265Ka 4500
`
`001
`005
`
`008
`020
`
`035
`035
`
`035
`035
`040
`049
`
`050
`100
`245
`260
`
`300
`
`599
`650
`650
`650
`700
`948
`994
`
`000 0 eng d
`
`993411863405961
`20020117222500.0
`
`950201m19851994nju
`##$20-89391-244-1
`
`##$a(0CoLC)31915798
`##$9466479
`
`##$a(MoKL)341186-lhalldb
`##$a(lhalldb)341186-lhalldb
`##$aNIA $CNIA $dLHL
`##$aLHLA
`
`##$aQA76.9.BS8 $bH37 0.5.
`1#$aHartson, Rex. H
`10$aAdvances in human-computer interaction / $cRex Hartson, editor.
`##$aNorwood, N.J.
`: $bAblex, $cc1985-
`
`##$av.
`
`: $bill.
`
`; $c24 cm.
`
`31$aDonated by Nortel Networks, April 1999.
`#0$aInteractive computer systems
`#0$aHuman—machine systems $vCongresses
`#0$aSystem design
`1#$aHartson, H. Rex
`##$aLTI 09/01/2008
`##$aE0 $bLHL
`
`20
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`20
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`