IPR2021-01459
`U.S. Patent 8,489,599
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`TWITTER, INC.,
`Petitioners
`
`V.
`
`PALO AL TO RESEARCH CENTER INC.,
`Patent Owners
`
`Case IPR2021-01459
`Patent 8,489,599
`
`DECLARATION OF SA YEM OSMAN
`
`Twitter Exhibit 1013
`Page 00001
`
`
`U.S. Patent 8,489,599
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`TWITTER, INC.,
`Petitioners
`
`V.
`
`PALO AL TO RESEARCH CENTER INC.,
`Patent Owners
`
`Case IPR2021-01459
`Patent 8,489,599
`
`DECLARATION OF SA YEM OSMAN
`
`Twitter Exhibit 1013
`Page 00001
`
`
`
`IPR2021-01459
`U.S. Patent 8,489,599
`
`I, Sayem Osman, make the following Declaration pursuant to 28 U.S.C. § 1746:
`
`1.
`
`I am a senior litigation paralegal at the law firm of Paul, Weiss, Rifkind,
`
`Wharton & Garrison LLP.
`
`2.
`
`I provide this Declaration in connection with the above-identified Patent
`
`Owner's Preliminary Response to the Inter Partes Review proceeding that is being
`
`requested at the U.S. Patent and Trademark Office by Petitioners under 35 U.S.C.
`
`§§ 311-319, 37 C.F.R. § 42. Unless otherwise stated, the facts stated in this
`
`Declaration are based on my personal knowledge.
`
`3.
`
`EX1001 hereto is a true and correct copy of the United States Patent No.
`
`8,489,599 B2, which I retrieved on August 27, 2021 from the Google Patents
`
`website (https ://patentimages.storage.googleapis.com/b7 /1 f/9d/6608eeea9e6e51/
`
`US8489599 .pdf). An exhibit label on the first page and page numbers on all pages
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`have been added to the bottom of this document but no other alterations have been
`
`made.
`
`4.
`
`EXl 002 hereto is a true and correct copy of the File History for U.S. Patent
`
`8,489,599, which I retrieved on August 27, 2021 from the U.S. Patent & Trademark
`
`Office's Public PAIR Website (https://portal.uspto.gov/pair/PublicPair). An exhibit
`
`label on the first page and page numbers on all pages have been added to the bottom
`
`of this document but no other alterations have been made.
`
`Page 00002
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`
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`IPR2021-01459
`U.S. Patent 8,489,599
`
`5.
`
`EX1004 hereto is an excerpt from a true correct copy from the Declaration of
`
`Gordon MacPherson ofIEEE (EX1014) containing "PALLAS: Personalised
`
`Language Leaming on Mobile Devices." An exhibit label on the first page has been
`
`added to the bottom of this document but no other alterations have been made.
`
`6.
`
`EXl 006 hereto is a true and correct copy of an article titled "CAST middteware:
`
`Security Middleware of Context-Awareness Simulation Toolkit for Ubiquitous
`
`Computer Research Environment" by Insu Kim, et al. from Volume 344 of Lecture
`
`Notes in Control and Information Sciences, entitled Intelligent Control and
`
`Automation, International Conference on Intelligent Computing, JC! 2006 Kunming
`
`China, August 16--19, 2006, which I retrieved from Springer.com on August 30,
`
`2021 (https://link.springer.com/chapter/10.1007/978-3-540-37256-1_61). An
`
`exhibit label on the first page and page numbers on all pages have been added to the
`
`bottom of this document but no other alterations have been made.
`
`7.
`
`EX1007 hereto is a true and correct copy of the United States Patent
`
`Application Publication No. 2003/0063072 Al, which I retrieved on August 27,
`
`2021 from the Google Patents website (https://patentimages.storage.googleapis.
`
`com/ee/90/02/5dc649c28829b0/US20030063072Al .pdf). An exhibit label on the
`
`first page and page numbers on all pages have been added to the bottom of this
`
`document but no other alterations have been made.
`
`Page 00003
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`
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`IPR2021-01459
`U.S. Patent 8,489,599
`
`8.
`
`EX1008 hereto is a true and correct copy of the United States Patent No.
`
`2009/0265764 Al, which I retrieved on August 27, 2021 from the Google Patents
`
`website (https://patentimages.storage.googleapis.com/ca/87/ee/b3ca758ecfef56/
`
`_ US20090265764Al .pdf). An exhibit label on the first page and page numbers on
`
`all pages have been added to the bottom of this document but no other alterations
`
`have been made.
`
`9.
`
`EX1009 hereto is a true and correct copy of the United States Patent
`
`Application Publication No. 2009/0254971 Al, which I retrieved on August 27,
`
`2021 from the Google Patents website (https://patentimages.storage.googleapis.
`
`com/4c/18/a7/25fbla077877f4/US20090254971Al.pdf). An exhibit label on the
`
`first page and page numbers on all pages have been added to the bottom of this
`
`document but no other alterations have been made.
`
`10. EX1010 hereto is a true and correct copy of the International Publication No.
`
`WO 2006/104345 Al, which I retrieved on August 27, 2021 from the Google
`
`Patents website (https://patentimages.storage.googleapis.com/83/ ab/3 3/
`
`eb0fce0cc13da0/W02006104345Al.pdf). An exhibit label on the first page and
`
`page numbers on all pages have been added to the bottom of this document but no
`
`other alterations have been made.
`
`11. EXI O 11 hereto is a true and correct copy of the United States Patent No.
`
`7,130,622 B2, which I retrieved on August 27, 2021 from the Google Patents
`
`Page 00004
`
`
`
`IPR2021-01459
`U.S. Patent 8,489,599
`
`website (https://patentimages.storage.googleapis.com/14/78/90/a85b66cc70c67I/
`
`US7130622.pdf). An exhibit label on the first page and page numbers on all pages
`
`have been added to the bottom of this document but no other alterations have been
`
`made.
`
`12. EXI012 hereto is a true and correct copy of the United States Patent
`
`Application Publication No. 2004/0111477 Al, which I retrieved on August 27,
`
`2021 from the Google Patents website (https://patentimages.storage.googleapis.
`
`com/22/5a/b6/4fa9f5c20f3557/US20040111477Al.pdf). An exhibit label on the
`
`first page and page numbers on all pages have been added to the bottom of this
`
`document but no other alterations have been made.
`
`13. EX1016 hereto is the IEEEE information for Yau, et al., "A Context-aware
`
`and Adaptive Leaming Schedule framework for supporting learners' daily
`
`routines." I retrieved this exhibit on August 30, 2021 available at
`
`https://ieeexplore.ieee.org/document/4196333 (including the main page, and by
`
`downloading the PDFs accessed by clicking on the linked "Cover," "Title page,"
`
`"Copyright notice," and "Table of contents"). An exhibit label on the first page
`
`and page numbers on all pages have been added to the bottom of this document but
`
`no other alterations have been made.
`
`14. EX1017 hereto is the IEEEE information for ICONS International
`
`Conference on Systems and Yau. I compiled this exhibit on August 30, 2021 from
`
`Page 00005
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`
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`IPR2021-01459
`U.S. Patent 8,489,599
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`https://ieeexplore.ieee.org/xpl/conhome/4196296/proceeding (including the main
`
`page, and by downloading the PDFs accessed by clicking on the linked "Cover,"
`
`"Title page," "Copyright notice," and "Table of contents"). An exhibit label on the
`
`first page and page numbers on all pages have been added to the bottom of this
`
`document but no other alterations have been made.
`
`15. EX1018 hereto is a true and correct copy of the Complaint for Palo Alto
`
`Research Center Inc. v. Snap Inc., Case No.2:20-cv-10755, Dkt. No. 1 (Nov. 25,
`
`2020). I retrieved this exhibit on August 20, 2021 available at
`
`https://ecf.cacd.uscourts.gov/docl/031134403947. An exhibit label on the first
`
`page and page numbers on all pages have been added to the bottom of this
`
`document but no other alterations have been made.
`
`16. EX1019 hereto is a true and correct copy of the Complaint for Palo Alto
`
`Research Center Inc. v. Twitter, Inc., Case No.2:20-cv-10754, Dkt. No. 1 (Nov. 25,
`
`2020). I retrieved this exhibit on July 28, 2021 available at
`
`https://ecf.cacd.uscourts.gov/docl/031134403424. An exhibit label on the first
`
`page and page numbers on all pages have been added to the bottom of this
`
`document but no other alterations have been made.
`
`17. EX] 020 hereto is a true and correct copy of the Complaint for Palo Alto
`
`Research Center Inc. v. Facebook, Inc., Case No.2:20-cv-10753, Dkt. No. 1 (Nov.
`
`25, 2020). I retrieved this exhibit on July 28, 2021 available at
`
`Page 00006
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`
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`IPR2021-01459
`U.S. Patent 8,489,599
`
`https://ecf.cacd.uscourts.gov/docl/031134402205. An exhibit label on the first
`
`page and page numbers on all pages have been added to the bottom of this
`
`document but no other alterations have been made.
`
`18. EX1021 hereto is a true and correct copy of the Order re: Stipulation and
`
`Joint Request to Stay Proceedings for Palo Alto Research Center Inc. v. Twitter,
`
`Inc., Case No.2:20-cv-10754, Dkt. No. 61 (July 15, 2021). I retrieved this exhibit
`
`on July 28, 2021 available athttps://ecf.cacd.uscourts.gov/docl/031135928675.
`
`An exhibit label on the first page and page numbers on all pages have been added
`
`to the bottom of this document but no other alterations have been made.
`
`19. EX1022 hereto is a true and correct copy of the Order re: Stipulation and
`
`Joint Request to Stay Proceedings for Palo Alto Research Center Inc. v. Facebook,
`
`Inc.; Twitter, Inc.; Snap Inc., Case Nos. 2:20-cv-10753, -10754, -10755, Dkt. No.
`
`57 (May 19, 2021). I retrieved this exhibit on July 28, 2021 available at
`
`https://ecf.cacd.uscourts.gov/docl/031135563677. An exhibit label on the first
`
`page and page numbers on all pages have been added to the bottom of this
`
`document but no other alterations have been made.
`
`20. EXl 023 hereto is the Springer information for Kim, et al., "CAST mictdleware:
`
`Security Middleware of Context-Awareness Simulation Toolkit for Ubiquitous
`
`Computer Research Environment." I retrieved this exhibit on August 30, 2021
`
`available at https://link.springer.com/bookseries/642. An exhibit label on the first
`
`Page 00007
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`
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`IPR2021-01459
`U.S. Patent 8,489,599
`
`page and page numbers on all pages have been added to the bottom of this
`
`document but no other alterations have been made.
`
`21 .
`
`I have been warned that willful false statements and the like are punishable
`
`by fine or imprisonment, or both. I make this declaration of my own personal
`
`knowledge, and all statements are true. If called to testify as to the truth of the
`
`matters stated herein, I could and would testify competently.
`
`22.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Executed on this 30th day of August, 2021 at Washington, D.C.
`
`SayemOsman
`
`Page 00008
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