`IPR2022-00031; IPR2022-00033
`
` Declaration of Angelo J. Christopher
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE, INC.
`Petitioner
`
`v.
`
`MEMORYWEB, LLC
`Patent Owner
`
`Patent No. 10,621,228
`Patent No. 10,423,658
`
`Inter Partes Review No. IPR2022-00031
`Inter Partes Review No. IPR2022-00033
`
`DECLARATION OF ANGELO J. CHRISTOPHER
`
`MemoryWeb Ex. 2018
`Apple v. MemoryWeb – IPR2022-00031
`
`
`
`Patent Nos. 10,621,228 and 10,423,658
`IPR2022-00031; IPR2022-00033
`
`
`I, Angelo J. Christopher, hereby declare as follows:
`
`
`
` Declaration of Angelo J. Christopher
`
`1.
`
`I am an attorney at Nixon Peabody LLP, attorneys for MemoryWeb,
`
`LLC (“Patent Owner”) in the above-captioned inter partes reviews and in co-
`
`pending district court litigation titled MemoryWeb, LLC v. Apple, Inc., 3:21-cv-
`
`09839-VC, pending in the United States District Court for the Northern District of
`
`California and MemoryWeb, LLC v. Samsung Electronics Co., Ltd. and Samsung
`
`Electronics America, Inc., Case No. 6:21-cv-00411-ADA, pending the United States
`
`District Court for the Western District of Texas.
`
`2.
`
`Submitted with Patent Owner’s Preliminary Response as Ex. 2006 is an
`
`eBay Order Confirmation for “Apple Aperture 3 Upgrade for Mac Brand New
`
`Photography” dated February 8, 2022. I purchased this Aperture 3 product from
`
`eBay.com on behalf of Patent Owner.
`
`3.
`
`Submitted with Patent Owner’s Preliminary Response as Ex. 2007 is a
`
`true and correct copy of the Apple Inc. Aperture Software License Agreement from
`
`the Aperture 3 installation DVD purchased from eBay.
`
`4.
`
`Submitted with Patent Owner’s Preliminary Response as Ex. 2009 is a
`
`true and correct copy of the webpage available from the following URL:
`
`https://web.archive.org/web/201072615004/http://documentation.apple.com/en/ape
`
`rture/usermanual/.
`
`
`
`1
`
`MemoryWeb Ex. 2018
`Apple v. MemoryWeb – IPR2022-00031
`
`
`
`Patent Nos. 10,621,228 and 10,423,658
`IPR2022-00031; IPR2022-00033
`
`
`
`
` Declaration of Angelo J. Christopher
`
`5.
`
`Submitted with Patent Owner’s Preliminary Response as Ex. 2010 is a
`
`true and correct copy of the webpage available from the following URL:
`
`https://web.archive.org/web/20100217035925/http://documentation.apple.com/en/a
`
`perture/usermanual/.
`
`6.
`
`Submitted with Patent Owner’s Preliminary Response as Ex. 2013 is a
`
`true and correct copy of the webpage available from the following URL:
`
`https://web.archive.org/web/201000312214951/http://www.apple.com/.
`
`7.
`
`Submitted with Patent Owner’s Preliminary Response as Ex. 2014 is a
`
`true and correct copy of the webpage available from the following URL:
`
`https://techcrunch.com/2010/03/19/review-aperture-3/.
`
`8.
`
`Submitted with Patent Owner’s Preliminary Response as Ex. 2015 is a
`
`true and correct copy of the webpage available from the following URL:
`
`https://6thfloor.blogs.nytimes.com/2011/04/18/who-made-googles-map-pin/.
`
`9.
`
`Submitted with Patent Owner’s Preliminary Response as Ex. 2016 is a
`
`true and correct copy of the webpage available from the following URL:
`
`https://developers.google.com/maps/documentation/javascript/custom-
`
`markers#try-sample.
`
`10. Submitted with Patent Owner’s Preliminary Response as Ex. 2017 is a
`
`true and correct copy of the webpage available from the following URL:
`
`
`
`2
`
`MemoryWeb Ex. 2018
`Apple v. MemoryWeb – IPR2022-00031
`
`
`
`Patent Nos. 10,621,228 and 10,423,658
`IPR2022-00031; IPR2022-00033
`
`https://web.archive.org/web/20120527122157/http://kml4earth.appspot.com/:80/ic
`
` Declaration of Angelo J. Christopher
`
`
`
`ons.html.
`
`I declare under penalty of perjury under the laws of the United States that the
`
`foregoing is true and correct to the best of my knowledge.
`
`By: /s/ Angelo J. Christopher
`
`
`
`
`Angelo J. Christopher
`
`
`
`
`
`Dated: February 23, 2022
`
`
`
`
`
`
`
`
`
`3
`
`MemoryWeb Ex. 2018
`Apple v. MemoryWeb – IPR2022-00031
`
`