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`• Chichester
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`• Toronto
`
`• Singapore
`
`TCL Exhibit 1008
`Page 2
`
`
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`New York
`
`John Wiley & Sons, Inc.
`• Chichester
`• Brisbane
`• Toronto
`
`• Singapore
`
`TCL Exhibit 1008
`Page 4
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`TCL Industries Holdings Co., Ltd.,
`Petitioner
`v.
`Koninklijke Philips N.V.,
`Patent Owner
`
`PTAB Case Nos. IPR2021-00495, IPR2021-00496, and IPR2021-00497
`Patent Nos. 9,590,977 B2 and 10,298,564 B2
`_________________________________________
`
`DECLARATION OF JACOB ROBERT MUNFORD
`
`TCL Exhibit 1008
`Page 24
`
`
`
`1. My name is Jacob Robert Munford. I am over the age of 18, have
`
`personal knowledge of the facts set forth herein, and am competent to testify to the
`
`same.
`
`2.
`
`I earned a Master of Library and Information Science (MLIS) from the
`
`University of Wisconsin-Milwaukee in 2009. I have over ten years of experience in
`
`the library/information science field. Beginning in 2004, I have served in various
`
`positions in the public library sector including Assistant Librarian, Youth Services
`
`Librarian and Library Director. I have attached my Curriculum Vitae as Appendix
`
`CV.
`
`3.
`
`During my career in the library profession, I have been responsible for
`
`materials acquisition for multiple libraries. In that position, I have cataloged,
`
`purchased and processed incoming library works. That includes purchasing
`
`materials directly from vendors, recording publishing data from the material in
`
`question, creating detailed material records for library catalogs and physically
`
`preparing that material for circulation. In addition to my experience in acquisitions,
`
`I was also responsible for analyzing large collections of library materials, tailoring
`
`library records for optimal catalog search performance and creating lending
`
`agreements between libraries during my time as a Library Director.
`
`4.
`
`I am fully familiar with the catalog record creation process in the library
`
`sector. In preparing a material for public availability, a library catalog record
`
`TCL Exhibit 1008
`Page 25
`
`
`
`describing that material would be created. These records are typically written in
`
`Machine Readable Catalog (herein referred to as “MARC”) code and contain
`
`information such as a physical description of the material, metadata from the
`
`material’s publisher, and date of library acquisition. In particular, the 008 field of
`
`the MARC record is reserved for denoting the date of creation of the library record
`
`itself. As this typically occurs during the process of preparing materials for public
`
`access, it is my experience that an item’s MARC record indicates the date of an
`
`item’s public availability.
`
`5.
`
`Typically, in creating a MARC record, a librarian would gather various
`
`bits of metadata such as book title, publisher and subject headings among others and
`
`assign each value to a relevant numerical field. For example, a book’s physical
`
`description is tracked in field 300 while title/attribution is tracked in field 245. The
`
`008 field of the MARC record is reserved for denoting the creation of the library
`
`record itself. As this is the only date reflecting the inclusion of said materials within
`
`the library’s collection, it is my experience that an item’s 008 field accurately
`
`indicates the date of an item’s public availability.
`
`6.
`
`This declaration is being drafted as of February 2021. Public and
`
`university 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
`
`- 1 -
`
`TCL Exhibit 1008
`Page 26
`
`
`
`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.
`
`7.
`
`I have reviewed Exhibit 1008, scans of Applied Cryptography:
`
`Protocols, Algorithms and Source Code in C by Bruce Schneier, 2nd Edition,
`
`provided to me by counsel.
`
`8.
`
`Attached hereto as Appendix CMU01 is a true and correct copy of the
`
`MARC record for Applied Cryptography: Protocols, Algorithms and Source Code
`
`in C as held by the Carnegie-Mellon University library. I secured this record myself
`
`from the library’s public catalog. The MARC record contained within Appendix
`
`CMU01 accurately describes the title, author, publisher, and ISBN number of
`
`Applied Cryptography: Protocols, Algorithms and Source Code in C.
`
`9.
`
`Attached hereto as Appendix UPITT01 is a true and correct copy of the
`
`MARC record for Applied Cryptography: Protocols, Algorithms and Source Code
`
`in C as held by the University of Pittsburgh library. I secured this record myself from
`
`the library’s public catalog. The MARC record contained within AppendixUPITT01
`
`accurately describes the title, author, publisher, and ISBN number of Applied
`
`Cryptography: Protocols, Algorithms and Source Code in C. The 505 field in this
`
`record, designated to describe the formatted contents of the material, accurately
`
`- 2 -
`
`TCL Exhibit 1008
`Page 27
`
`
`
`describes the table of contents of Applied Cryptography: Protocols, Algorithms and
`
`Source Code in C found on page V of Exhibit 1008.
`
`10.
`
`In comparing the information listed in Appendices CMU01 and
`
`UPITT01 to Exhibit 1008, it is my determination that Exhibit 1008 is a true and
`
`correct copy of Applied Cryptography: Protocols, Algorithms and Source Code in
`
`C.
`
`11.
`
`The 008 field of the MARC record noted on page 1 of Appendix
`
`CMU01 indicates that Applied Cryptography: Protocols, Algorithms and Source
`
`Code in C was first cataloged by Carnegie-Mellon University library as of March
`
`27, 1995. The 008 field of the MARC record noted on page 1 of Appendix UPITT01
`
`also indicates that Applied Cryptography: Protocols, Algorithms and Source Code
`
`in C was first cataloged by University of Pittsburgh library as of March 27, 1995.
`
`Based on this information, it is my determination that Applied Cryptography:
`
`Protocols, Algorithms and Source Code in C was made available to the public
`
`shortly after March 1995.
`
`12.
`
`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
`
`- 3 -
`
`TCL Exhibit 1008
`Page 28
`
`
`
`statements are objective, and my compensation does not depend on the outcome of
`
`this matter.
`
`13.
`
`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 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: 2/9/2021
`
`_____________________________________
`
`Jacob Robert Munford
`
`- 4 -
`
`TCL Exhibit 1008
`Page 29
`
`
`
`APPENDIX CV
`
`APPENDIX CV
`
`TCL Exhibit 1008
`Page 30
`
`
`
`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
`
`TCL Exhibit 1008
`Page 31
`
`
`
`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.
`
`TCL Exhibit 1008
`Page 32
`
`
`
`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.
`
`TCL Exhibit 1008
`Page 33
`
`
`
`APPENDIX CMU01
`
`APPENDIX CMUOl
`
`TCL Exhibit 1008
`Page 34
`
`
`
`screenshot-cmu.primo.exlibrisgroup.com-2021.02.03-09_25_58
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`
`: acid-Free paper)
`
`TCL Exhibit 1008
`
`Page 35
`
`TCL Exhibit 1008
`Page 35
`
`
`
`APPENDIX UPITT01
`
`APPENDIX UPITTOl
`
`TCL Exhibit 1008
`Page 36
`
`
`
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`
`TCL Exhibit 1008
`
`Page 37
`
`TCL Exhibit 1008
`Page 37
`
`
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