`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`APPLE INC.,
`Petitioner
`
`v.
`
`BILLJCO LLC,
`Patent Owner
`
`
`CASE: IPR2022-00131
`U.S. PATENT NO. 8,639,267
`
`DECLARATION OF JULIE DILLNER PROVIDING SUPPLEMENTAL
`EVIDENCE
`
`
`
`
`40489808.1.docx
`
`
`
`I, Julie Dillner, hereby declare as follows:
`I am a paralegal in the law firm of Saul Ewing Arnstein & Lehr LLP,
`
`1.
`
`counsel of record for Patent Owner BillJCo, LLC (“BillJCo”).
`
`2.
`
`I have personal knowledge of the facts set forth in this Declaration. I
`
`make this Declaration to provide supplemental evidence, pursuant to 37 C.F.R. §
`
`42.64(b)(2), in response to Petitioner’s Objection to Evidence dated August 24,
`
`2022. See Paper 17.
`
`3.
`
`Exhibit 2014 is a true and correct copy of the technical dictionary
`
`definitions for the term “privileged instruction,” “privilege,” and “preferences.” The
`
`definitions were downloaded on August 17, 2022 from the following online sources:
`
`https://encyclopedia2.thefreedictionary.com/privileged+instruction;
`
`https://en.wikipedia.org/wiki/Privilege_(computing);
`
`https://www.techopedia.com/definition/16044/privilege-security;
`
`https://dictionary.cambridge.org/us/dictionary/english/preference;
`
`https://www.google.com/search?q=preference+definition;
`
`https://www.yourdictionary.com/preferences;
`
`and
`
`https://www.computerhope.com/jargon/p/preference.htm.
`
`4.
`
`Exhibit 2015 is a true and correct copy of the Amended Complaint [Dkt
`
`No. 68] (SEALED) filed in BillJCo, LLC v. Apple, Inc., Case No.: 5:22-CV-03201-
`
`VKD (N.D. Cal.) (“the Amended Complaint”), and select exhibits, including
`
`40489808.1.docx
`
`
`
`Exhibit LL. Exhibit LL to the Amended Complaint is a true and correct copy of
`
`Exhibit H (ECF No. 1-13) to the original Complaint for Patent Infringement (ECF
`
`No. 1) filed in the litigation BillJCo, LLC v. Apple, Inc., Case No.: 6:21-cv-00528
`
`(E.D. Tex.), which was transferred to the Northern District of California. Exhibit LL
`
`to the Amended Complaint is a claim chart comparing claims of U.S. 8,639,267 to
`
`Apple iOS Products.
`
`5.
`
`Exhibit 2020 is a true and correct copy of a document title “Getting
`
`Started With iBeacon,” Version 1.0 and dated June 2, 2014. Exhibit 2020 was
`
`downloaded 1.0 (June 2, 2014), from https://developer.apple.com/ibeacon/Getting‐
`
`Started‐with‐iBeacon.pdf on October 26, 2020.
`
`I declare upon penalty of perjury that the forgoing is true and correct to the
`
`best of my understanding and belief.
`
`
`Dated: September 8, 2022
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` /s/ Julie Dillner
`Julie Dillner
`
`
`
`40489808.1.docx
`
`2
`
`
`
`Certification of Service Under 37 C.F.R. § 42.6(e)(4)
`
`
`
`The undersigned hereby certifies that on September 8, 2022, I caused a true
`
`and correct copy of the DECLARATION OF JULIE DILLNER PROVIDING
`
`SUPPLEMENTAL EVIDENCE to be served on the following counsel for Petitioner
`
`by electronic mail to the following email addresses:
`
`Larissa S. Bifano
`
`Joseph Wolfe
`
`Zachary Conrad
`
`
`
`larissa.bifano@dlapiper.com
`
`Joseph.Wolfe@us.dlapiper.com
`
`Zack.Conrad@dlapiper.com
`
`
`Date: September 8, 2022
`
`
`
`
`
`
`
`/Brian R. Michalek/
`(Reg. No. 65,816)
`Attorney for Patent Owner
`
`40489808.1.docx
`
`3
`
`
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