Declaration of Jacob Robert Munford
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`1
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`APPLE 1031
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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
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`attached my Curriculum Vitae as Appendix A.
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`3. During my career in the library profession, I have been responsible for
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`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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`search performance and creating lending agreements between libraries
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`during my time as a Library Director.
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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.
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`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
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`pandemic. My state, Pennsylvania, has a travel advisory, which has affected
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`my ability to travel. In my experience, library catalog records are accurate
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`descriptions of a library’s collection and my lack of physical access to
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`libraries at this time creates no doubt in my determinations of authenticity or
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`availability of the exhibits noted below.
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`6. I have reviewed Exhibit 1006, an article entitled “Improving Selection
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`Performance on Pen-Based Systems: A Study of Pen-Based Interaction for
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`Selection Tasks” by Xiangshi Ren and Shinji Moriya as published in ACM
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`Transactions on Computer Human Interaction, Vol. 3 No. 3 (2000).
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`7. Attached hereto as Appendix REN01 is a true and correct copy of the
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`MARC record describing ACM Transactions on Computer Human
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`Interaction as held by the Carnegie-Mellon University’s library. I secured
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`this record myself from the library’s online catalog. This MARC record
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`accurately describes this journal’s title, publisher and ISSN. The 008 field of
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`this MARC record indicates the journal ACM Transactions on Computer
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`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
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`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-
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`Based Systems: A Study of Pen-Based Interaction for Selection Tasks”.
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`8. In comparing Exhibit 1006 to this MARC record, it is my determination that
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`Exhibit 1006 is a true and correct copy of “Improving Selection Performance
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`on Pen-Based Systems: A Study of Pen-Based Interaction for Selection
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`Tasks” from ACM Transactions on Computer Human Interaction, Vol. 3
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`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-
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`Based Interaction for Selection Tasks” was made available and accessible to
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`the public by shortly after initial release in September 2000.
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`9. I have been retained on behalf of the Petitioner to provide assistance in the
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`above-illustrated matter in establishing the authenticity and public
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`availability of the documents discussed in this declaration. I am being
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`compensated for my services in this matter at the rate of $100.00 per hour
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`plus reasonable expenses. My statements are objective, and my
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`compensation does not depend on the outcome of this matter.
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`10. I declare under penalty of perjury that the foregoing is true and correct. I
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`hereby declare that all statements made herein of my own knowledge are
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`true and that all statements made on information and belief are believed to
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`be true; and further that these statements were made the knowledge that
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`willful false statements and the like so made are punishable by fine or
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`imprisonment, or both, under Section 1001 of Title 18 of the United States
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`Code.
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`
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`Dated: 11/5/2020
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`
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`Jacob Robert Munford
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`6
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`APPENDIX A
`APPENDIX A
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`Appendix A - Curriculum Vitae
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`Education
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`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.
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`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.
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`Professional Experience
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`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.
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`
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`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
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`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.
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`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.
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`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.
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`9
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`Professional Involvement
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`Alaska Library Association - Anchorage Chapter
`● Treasurer, 2012
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`Library Of Michigan
`● Level VII Certification, 2008
`● Level II Certification, 2013
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`Michigan Library Association Annual Conference 2014
`● New Directors Conference Panel Member
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`Southwest Michigan Library Cooperative
`● Represented the Dowagiac District Library, 2013-2015
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`
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`Professional Development
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`Library Of Michigan Beginning Workshop, May 2008
`Petoskey, MI
`● Received training in cataloging, local history, collection management,
`children’s literacy and reference service.
`
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`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.
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`Alaska Library Association Annual Conference 2012 - Fairbanks, February 2012
`Fairbanks, AK
`● Attended seminars on EBSCO advanced search methods, budgeting,
`cataloging, database usage and marketing.
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`APPENDIX REN01
`APPENDIX RENO1
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`ACMtransactions on computer-human interaction : a publication of the Association for
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`Human-computerinteraction -- Periodicals >
`ACM's transactions on computer-human interaction
`Association for Computing Machinery transactions on computer-human interaction
`Transactions on computer-human interaction
`Available in other form: ACM transactions on human-computerinteraction (Online)
`ACM series on computing methodologies >
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`Vol. 1, no. 1 (Mar, 1994)-
`c1994-
`v. rill. ; 26cm.
`Four times a year
`Carnegie Mellon hasaccesstothis title online through the ACM Digital Library.
`v.1-12, 1994-2005 bound, in offsite storage, available by request
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