UNITED STATES PATENT AND TRADEMARK OFFICE
`
`___________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________
`
`CLOUDFLARE, INC. AND SONICWALL INC.
`Petitioners
`
`v.
`
`SABLE NETWORKS, INC.
`Patent Owner
`
`___________
`
`Case IPR2021-01005
`Patent No. 7,012,919
`___________
`
`DECLARATION OF DANIEL C. CALLAWAY IN SUPPORT OF
`
`PETITION FOR INTER PARTES REVIEW
`
`
`
`Cloudflare – Exhibit 1032, page 1
`
`
`
`___________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________
`
`CLOUDFLARE, INC. AND SONICWALL INC.
`Petitioners
`
`v.
`
`SABLE NETWORKS, INC.
`Patent Owner
`
`___________
`
`Case IPR2021-01005
`Patent No. 7,012,919
`___________
`
`DECLARATION OF DANIEL C. CALLAWAY IN SUPPORT OF
`
`PETITION FOR INTER PARTES REVIEW
`
`
`
`Cloudflare – Exhibit 1032, page 1
`
`
`
`I, Daniel C. Callaway, make the following declaration in support of the
`
`petition by Cloudflare, Inc. and SonicWall Inc. for inter partes review of U.S.
`
`Patent No. 7,012,919:
`
`1.
`
`I am an attorney with the law firm of Farella Braun + Martel LLP,
`
`counsel for Cloudflare, Inc. Unless otherwise stated, the facts stated in this
`
`declaration are based on my personal knowledge.
`
`2.
`
`The document submitted with the petition and identified as
`
`Exhibit 1007 is a true and correct copy of Andrikopoulos, I., Pavlou, G.,
`
`“Supporting Differentiated Services in MPLS Networks,” IWQoS ’99: 1999
`
`Seventh International Workshop on Quality of Service, including Declaration
`
`of Rachel J. Watters, Librarian and Director of Wisconsin TechSearch.
`
`3.
`
`The document submitted with the petition and identified as
`
`Exhibit 1013 is a true and correct copy of Rosen, E. et al., “A Proposed
`
`Architecture for MPLS” (July 1997), which was retrieved using the following
`
`URL: https://datatracker.ietf.org/doc/html/draft-ietf-mpls-arch-00.
`
`4.
`
`The document submitted with the petition and identified as
`
`Exhibit 1014 is a true and correct copy Rosen E. et al., “Multiprotocol Label
`
`Switching Architecture” RFC 3031 (January 2001), which was retrieved using the
`
`following URL: https://datatracker.ietf.org/doc/html/rfc3031.
`
`5.
`
`The document submitted with the petition and identified as
`
`
`
`Cloudflare – Exhibit 1032, page 2
`
`
`
`Exhibit 1015 is a true and correct copy of Li, T., Rekhter, Y., “A Provider
`
`Architecture for Differentiated Services and Traffic Engineering (PASTE),” RFC
`
`2430 (October 1998), which was retrieved using the following URL:
`
`https://datatracker.ietf.org/doc/html/rfc2430.
`
`6.
`
`The document submitted with the petition and identified as
`
`Exhibit 1016 is a true and correct copy of Andrikopoulos, I., Pavlou, G., et al.
`
`“Experiments and Enhancements for IP and ATM Integration: The IthACI
`
`Project,” IEEE Communications Magazine, Vol. 39, No. 5 (May 2001), including
`
`Declaration from Rachel J. Watters, Librarian and Director of Wisconsin
`
`TechSearch.
`
`7.
`
`The document submitted with the petition and identified as
`
`Exhibit 1017 is a true and correct copy of Le Faucheur, F., et al., “MPLS Support
`
`of Differentiated Services,” (February 2000), which was retrieved using the
`
`following URL: https://datatracker.ietf.org/doc/html/draft-ietf-mpls-diff-ext-03.
`
`8.
`
`The document submitted with the petition and identified as
`
`Exhibit 1018 is a true and correct copy of Girish, M., et al., “A Framework for
`
`Service Differentiated in MPLS Networks,” (March 2000), which was retrieved
`
`using the following URL: https://datatracker.ietf.org/doc/html/draft-vaananen-
`
`mpls-svc-diff-framework-00.
`
`9.
`
`The document submitted with the petition and identified as
`
`
`
`Cloudflare – Exhibit 1032, page 3
`
`
`
`Exhibit 1019 is a true and correct copy of Horlait, E., et. al, “Differentiated
`
`Services and Integrated Services Use of MPLS,” IEEE (2000).
`
`10.
`
`The document submitted with the petition and identified as Exhibit 1020
`
`is a true and correct copy of Nichols, K., et al., “Definition of the Differentiated
`
`Services Field (DS Field) in the IPv4 and IPv6 Headers” (December 1998), retrieved
`
`using the following URL: https://datatracker.ietf.org/doc/html/rfc2474.
`
`11.
`
`The document submitted with the petition and identified as
`
`Exhibit 1021 is a true and correct copy of the Supplemental Order Regarding Court
`
`Operations Under the Exigent Circumstances Created by the COVID-19 Pandemic,
`
`issued by the United States District Court for the Western District of Texas, dated
`
`May 8, 2020.
`
`12.
`
`The document submitted with the petition and identified as
`
`Exhibit 1022 is a true and correct copy of the Supplemental Order Regarding Court
`
`Operations Under the Exigent Circumstances Created by the COVID-19 Pandemic,
`
`issued by the United States District Court for the Western District of Texas, dated
`
`June 18, 2020.
`
`13.
`
`The document submitted with the petition and identified as
`
`Exhibit 1023 is a true and correct copy of the Supplemental Order Regarding Court
`
`Operations Under the Exigent Circumstances Created by the COVID-19 Pandemic,
`
`United States District Court for the Western District of Texas, dated July 2, 2020.
`
`
`
`Cloudflare – Exhibit 1032, page 4
`
`
`
`14.
`
`The document submitted with the petition and identified as
`
`Exhibit 1024 is a true and correct copy of the Seventh Supplemental Order
`
`Regarding Court Operations Under the Exigent Circumstances Created by the
`
`COVID-19 Pandemic, United States District Court for the Western District of
`
`Texas, dated August 6, 2020.
`
`15.
`
`The document submitted with the petition and identified as
`
`Exhibit 1025 is a true and correct copy of the Eighth Supplemental Order
`
`Regarding Court Operations Under the Exigent Circumstances Created by the
`
`COVID-19 Pandemic, United States District Court for the Western District of
`
`Texas, dated September 21, 2020.
`
`16.
`
`The document submitted with the petition and identified as
`
`Exhibit 1026 is a true and correct copy of the Ninth Supplemental Order Regarding
`
`Court Operations Under the Exigent Circumstances Created by the COVID-19
`
`Pandemic, United States District Court for the Western District of Texas, dated
`
`October 14, 2020.
`
`17.
`
`The document submitted with the petition and identified as
`
`Exhibit 1027 is a true and correct copy of the Tenth Supplemental Order Regarding
`
`Court Operations Under the Exigent Circumstances Created by the COVID-19
`
`Pandemic, United States District Court for the Western District of Texas, dated
`
`November 18, 2020.
`
`
`
`Cloudflare – Exhibit 1032, page 5
`
`
`
`18.
`
`The document submitted with the petition and identified as
`
`Exhibit 1028 is a true and correct copy of the Eleventh Supplemental Order
`
`Regarding Court Operations Under the Exigent Circumstances Created by the
`
`COVID-19 Pandemic, United States District Court for the Western District of
`
`Texas, dated December 10, 2020.
`
`19.
`
`The document submitted with the petition and identified as
`
`Exhibit 1029 is a true and correct copy of the Twelfth Supplemental Order
`
`Regarding Court Operations Under the Exigent Circumstances Created by the
`
`COVID-19 Pandemic, United States District Court for the Western District of
`
`Texas, dated January 7, 2021.
`
`20.
`
`The document submitted with the petition and identified as
`
`Exhibit 1030 is a true and correct copy of the Thirteenth Supplemental Order
`
`Regarding Court Operations Under the Exigent Circumstances Created by the
`
`COVID-19 Pandemic, United States District Court for the Western District of
`
`Texas, dated February 2, 2021.
`
`21.
`
`The document submitted with the petition and identified as
`
`Exhibit 1031 is a true and correct copy of the Fourteenth Supplemental Order
`
`Regarding Court Operations Under the Exigent Circumstances Created by the
`
`COVID-19 Pandemic, United States District Court for the Western District of
`
`Texas, dated March 17, 2021.
`
`
`
`Cloudflare – Exhibit 1032, page 6
`
`
`
`I declare under penalty of perjury under the laws of the United States that
`
`the foregoing is true and correct and that this declaration was executed on May 28,
`
`2021, in San Francisco, California.
`
`/s/ Daniel C. Callaway
`Daniel C. Callaway
`Registration No. 74,267
`
`
`
`Cloudflare – Exhibit 1032, page 7
`
`
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