IPR2021-01146
`U.S. Patent No. 9,928,044
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`SAP AMERICA, INC.,
`
`Petitioner,
`
`v.
`
`EXPRESS MOBILE, INC.,
`
`Patent Owner.
`
`____________
`
`Case IPR2021-01146
`
`U.S. Patent No. 9,928,044
`
`____________
`
`DECLARATION OF JONATHAN BRADFORD
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF UNITED STATES PATENT NO. 9,928,044
`
`SAP Exhibit 1033
`SAP v. Express Mobile, Inc.
`IPR2021-01146
`Page 00001
`
`
`U.S. Patent No. 9,928,044
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`SAP AMERICA, INC.,
`
`Petitioner,
`
`v.
`
`EXPRESS MOBILE, INC.,
`
`Patent Owner.
`
`____________
`
`Case IPR2021-01146
`
`U.S. Patent No. 9,928,044
`
`____________
`
`DECLARATION OF JONATHAN BRADFORD
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF UNITED STATES PATENT NO. 9,928,044
`
`SAP Exhibit 1033
`SAP v. Express Mobile, Inc.
`IPR2021-01146
`Page 00001
`
`
`
`IPR2021-01146
`U.S. Patent No. 9,928,044
`
`1.
`
`I, Jonathan Bradford, make the following Declaration pursuant to 28
`
`U.S.C. § 1746: I am a Senior IP Paralegal at the law firm of Ropes & Gray LLP.
`
`2.
`
`I provide this Declaration in connection with the above-identified
`
`Inter Partes Review proceeding that is before the United States Patent and
`
`Trademark Office (“USPTO”). Unless otherwise stated, the facts stated in this
`
`Declaration are based on my personal knowledge.
`
`3.
`
`Ex. 1015 is a true and correct copy of Shorter Oxford English
`
`Dictionary (6th Ed. 2007), which was retrieved from the Ropes & Gray library and
`
`scanned at my request. This document has been marked with an exhibit label and
`
`page numbers on each page at the bottom right corner. However, no alterations,
`
`other than these noted markings, have been made to this document.
`
`4.
`
`Ex. 1016 is a true and correct copy of Oxford Dictionary of
`
`Computing (6th Ed. 2008), which was retrieved from the Ropes & Gray library and
`
`scanned at my request. This document has been marked with an exhibit label and
`
`page numbers on each page at the bottom right corner. However, no alterations,
`
`other than these noted markings, have been made to this document.
`
`5.
`
`Ex. 1022 is a true and correct copy of Plaintiff Express Mobile, Inc.’s
`
`Disclosure of Asserted Claims and Infringement Contentions, Express Mobile, Inc.
`
`v. SAP SE, No. 3:20-cv-08492-RS (N.D. Cal. Mar. 18, 2021), which was served by
`
`counsel for Express Mobile, Inc. on counsel for SAP SE on March 18, 2021. This
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`1
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`IPR2021-01146 Page 00002
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`
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`IPR2021-01146
`U.S. Patent No. 9,928,044
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`document has been marked with an exhibit label and page numbers on each page at
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`the bottom right corner. However, no alterations, other than these noted markings,
`
`have been made to this document.
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`6.
`
`Ex. 1023 is a true and correct copy of Order Granting in Part and
`
`Denying in Part Stay Motions, Express Mobile, Inc. v. SAP SE, No. 3:20-cv-
`
`08492-RS, D.I. 34 (N.D. Cal. Apr. 5, 2021), which was downloaded from the
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`United States Court’s Public Access to Court Electronic Records (“PACER”)
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`system. This document has been marked with an exhibit label and page numbers
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`on each page at the bottom right corner. However, no alterations, other than these
`
`noted markings, have been made to this document.
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`7.
`
`Ex. 1024 is a true and correct copy of Joint Statement re:
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`Coordination of Claim Construction Proceedings, Express Mobile, Inc. v. SAP SE,
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`No. 3:20-cv-08492-RS, D.I. 35, 35-1 (N.D. Cal. Apr. 23, 2021), which was
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`downloaded from the PACER system. This document has been marked with an
`
`exhibit label and page numbers on each page at the bottom right corner. However,
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`no alterations, other than these noted markings, have been made to this document.
`
`8.
`
`Ex. 1025 is a true and correct copy of Order re: Claim Construction
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`Schedule, Express Mobile, Inc. v. SAP SE, No. 3:20-cv-08492-RS, D.I. 36 (N.D.
`
`Cal. Apr. 26, 2021), which was downloaded from the PACER system. This
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`document has been marked with an exhibit label and page numbers on each page at
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`2
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`IPR2021-01146 Page 00003
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`
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`IPR2021-01146
`U.S. Patent No. 9,928,044
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`the bottom right corner. However, no alterations, other than these noted markings,
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`have been made to this document.
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`9.
`
`Ex. 1026 is a true and correct copy of Claim Construction
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`Memorandum Opinion, Shopify Inc. v. Express Mobile, Inc., No. 1:19-cv-439-
`
`RGA, D.I. 137 (D. Del. Jun. 23, 2020), which was downloaded from the PACER
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`system. This document has been marked with an exhibit label and page numbers
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`on each page at the bottom right corner. However, no alterations, other than these
`
`noted markings, have been made to this document.
`
`10. Ex. 1027 is a true and correct copy of Claim Construction Order,
`
`Shopify Inc. v. Express Mobile, Inc., No. 1:19-cv-439-RGA, D.I. 142 (D. Del. Jun.
`
`30, 2020), which was downloaded from the PACER system. This document has
`
`been marked with an exhibit label and page numbers on each page at the bottom
`
`right corner. However, no alterations, other than these noted markings, have been
`
`made to this document.
`
`11. Ex. 1028 is a true and correct copy of Claim Construction
`
`Memorandum Opinion, Express Mobile, Inc. v. GoDaddy.Com, LLC, No. 1:19-cv-
`
`1937-RGA, D.I. 121 (D. Del. Jun. 1, 2021), which was downloaded from the
`
`PACER system. This document has been marked with an exhibit label and page
`
`numbers on each page at the bottom right corner. However, no alterations, other
`
`than these noted markings, have been made to this document.
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`3
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`IPR2021-01146 Page 00004
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`
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`IPR2021-01146
`U.S. Patent No. 9,928,044
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`12.
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`Ex. 1029 is a true and correct copy of Claim Construction
`
`Memorandum Order, Express Mobile, Inc. v. GoDaddy.Com, LLC, No. 1:19-cv-
`
`1937-RGA, D.I. 129 (D. Del. Jun. 8, 2021), which was downloaded from the
`
`PACER system. This document has been marked with an exhibit label and page
`
`numbers on each page at the bottom right corner. However, no alterations, other
`
`than these noted markings, have been made to this document.
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`13. Certain pages have been resized to 8.5 x 11 inches. No content was
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`removed by this resizing.
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`14.
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`I hereby declare that all statements made herein of my own
`
`knowledge are true and that all statements made on information and belief are
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`believed to be true; and further that these statements were made with the
`
`knowledge that willful false statements and the like so made are punishable by fine
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`or imprisonment, or both, under 18 U.S.C. § 1001. If called to testify as to the
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`truth of the matters stated herein, I could and would testify competently.
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`15.
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`I declare under penalty of perjury that the foregoing is true and
`
`correct.
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`Executed this 2nd day of July, 2021, in Boston, Massachusetts.
`
`
`
`
`/Jonathan Bradford/
`Jonathan Bradford
`ROPES & GRAY LLP
`
`4
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`IPR2021-01146 Page 00005
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