UNITED STATES PATENT AND TRADEMARK OFFICE
`
`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 WILLIAM JOHNSON PROVIDING
`SUPPLEMENTAL EVIDENCE
`
`
`
`
`40472756.2
`
`
`
`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 WILLIAM JOHNSON PROVIDING
`SUPPLEMENTAL EVIDENCE
`
`
`
`
`40472756.2
`
`
`
`I, William Johnson, hereby declare as follows:
`I am the Managing Member, Director, and founder of BillJCo, LLC
`
`1.
`
`(the “Company” or “BillJCo”), a Texas limited liability company with its principal
`
`place of business located at 1704 Katherine Court, Flower Mound, TX 75022.
`
`2.
`
`I founded BillJCo in January of 2008 specifically to pursue beacon
`
`technologies, including the patents at issue in this litigation. I am the inventor of
`
`U.S. 8,639,267, which is the subject this inter partes review. 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 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.) and Exhibits Ex. G, H, I, M, N, O, P, Q, R, and S to the same. I
`
`have personal knowledge of the authenticity of Exhibit 2015 in my capacity as the
`
`Managing Member of BillJCo in that I authorized and oversaw counsel’s filing of
`
`the Amended Complaint in the Northern District of California.
`
`4.
`
`Exhibit G to the Amended Complaint (Exhibit 2015) is a true and copy
`
`of an email dated October 1, 2009, that I sent to Richard “Chip” Lutton, who at the
`
`time was Petition Apple, Inc.’s chief patent counsel.
`
`40472756.2
`
`
`
`5.
`
`Exhibit H to the Amended Complaint (Exhibit 2015) is a true and
`
`correct copy of an email April 20, 2010, that I sent to Tom Mavrakakis, who at the
`
`time was Director of Patent Strategy for Petitioner Apple, Inc.
`
`6.
`
`Exhibit I to the Amended Complaint (Exhibit 2015) is an email dated
`
`June 14, 2010, that I sent to Steve Dowling, Petitioner Apple, Inc.’s, Vice President
`
`of Communications.
`
`7.
`
`Exhibit M to the Amended Complaint (Exhibit 2015) is a true and
`
`correct copy of a string of emails dated December 14, 2011 to April 9, 2012, sent
`
`between myself Edward Scott, who at the time was Petition Apple, Inc.’s in-house
`
`attorney responsible for Patent Strategy and Licensing.
`
`8.
`
`Exhibit N to the Amended Complaint (Exhibit 2015) is a true and
`
`correct copy of a string of emails sent between myself Mr. Scott, dated December
`
`14, 2011 to April 10, 2012.
`
`9.
`
`Exhibit O to the Amended Complaint (Exhibit 2015) is a true and
`
`correct copy of a document title “LBXsum.doc” that I provided to Mr. Scott, and
`
`that was an attachment to Exhibits I and N.
`
`10. Exhibit P to the Amended Complaint (Exhibit 2015) is a true and
`
`correct copy of a string of emails between Mr. Scott and myself, dated December
`
`14, 2011 to June 13, 2012.
`
`40472756.2
`
`2
`
`
`
`11. Exhibit Q to the Amended Complaint (Exhibit 2015) is a true and
`
`correct copy of two emails sent by me to Mr. Scott on December 12, 2012.
`
`12. Exhibit R to the Amended Complaint (Exhibit 2015) is a true and
`
`correct copy of an email that I sent to Kirk Gottlieb, an attorney at the law firm of
`
`Fish & Richardson, a firm that represented Petitioner Apple, Inc., on November 11,
`
`2014.
`
`13. Exhibit S to the Amended Complaint (Exhibit 2015) is a true and
`
`correct copy of a PowerPoint presentation titled “LBXcode.pptx” that I created and
`
`that was attached to the email Exhibit R that I sent to Mr. Gottlieb.
`
`14. Exhibit 2016 is a true and correct copy of a confidential agreement with
`
`a third party that I signed on August 10, 2017, in my capacity as Director of Patent
`
`Owner BillJCo, LLC.
`
`15. Exhibit 2017 is a true and correct copy of a confidential agreement with
`
`a third party that I signed effective August 3, 2022, both individually and in my
`
`capacity as Managing Member of Patent Owner BillJCo, LLC.
`
`16. Exhibit 2018 is a true and correct copy of a confidential agreement with
`
`a third party that I signed effective March 8, 2022, in my capacity as Managing
`
`Member of Patent Owner BillJCo, LLC.
`
`I declare upon penalty of perjury that the forgoing is true and correct to the
`
`best of my understanding and belief.
`
`40472756.2
`
`3
`
`
`
`
`Dated: September 8, 2022
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/William Johnson
`William Johnson
`
`40472756.2
`
`4
`
`
`
`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 WILLIAM JOHNSON 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
`
`
`Date: September 8, 2022
`
`
`
`
`
`
`
`
`larissa.bifano@dlapiper.com
`
`Joseph.Wolfe@us.dlapiper.com
`
`Zack.Conrad@dlapiper.com
`
`/Brian R. Michalek/
`(Reg. No. 65,816)
`Attorney for Patent Owner
`
`40472756.2
`
`5
`
`
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