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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
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`THE DATA COMPANY TECHNOLOGIES INC.,
`Petitioner,
`
`v.
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`BRIGHT DATA LTD.,
`Patent Owner.
`_____________
`
`Case No. TBD
`Patent No. 10,257,319
`
`_____________
`
`
`DECLARATION OF ADAM R. WICHMAN IN SUPPORT OF
`THE DATA COMPANY TECHNOLOGIES INC. PETITION FOR
`INTER PARTES REVIEW OF U.S. PATENT NO. 10,257,319
`
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`
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`Data Co Exhibit 1077
`Data Co v. Bright Data
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`
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`I, Adam R. Wichman, declare as follows:
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`1.
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`I am an attorney with Wolf, Greenfield & Sacks, P.C. (“WGS”),
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`admitted to practice before all courts in the Commonwealth of Massachusetts and
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`registered to practice before the U.S. Patent and Trademark Office. I am more than
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`21 years old.
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`2.
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`I make these statements in support of The Data Company Technologies
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`Inc. petition for inter partes review of U.S. Patent No. 10,257,319. I have personal
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`knowledge of the matters set forth herein, and if called upon I would testify as
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`follows.
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`3.
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`The following exhibits, filed with this declaration and the above-
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`mentioned petition, are true and accurate copies of the following documents:
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`a. Exhibit 1026: Pages from W. Richard Stevens, TCP/IP Illustrated,
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`Volume 1: The Protocols. Canada: Addison-Wesley, 1994, chs. 1 & 18,
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`bibliography (“Stevens”), made from a physical volume of Stevens at
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`WGS.
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`b. Exhibit 1033: Pages from L.L. Peterson, B.S. Davie, Computer
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`Networks: A Systems Approach, 4th ed. San Francisco, CA: Elsevier,
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`2007, chs. 1-2 (“Peterson”), made from a physical volume of Peterson
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`at WGS.
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`1
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`4.
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`Upon information and belief the following exhibits, filed with this
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`declaration and the above-mentioned petition, are true and accurate copies of the
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`following documents as retrieved from the indicated websites:
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`a. Exhibit 1044: A. Rowstron and P. Druschel, “Pastry: Scalable,
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`Decentralized Object Location, and Routing for Large-Scale Peer-to-
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`Peer Systems.” IFIP/ACM International Conference on Distributed
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`Systems Platforms and Open Distributed Processing: Middleware
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`2001, pp. 329-350 (2001), available at
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`https://link.springer.com/chapter/10.1007/3-540-45518-3_18.
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`b. Exhibit 1045: S. Ratnasamy, M. Handley, R. Karp and S. Shenker,
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`"Topologically-aware overlay construction and server selection."
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`Proceedings Twenty-First Annual Joint Conference of the IEEE
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`Computer and Communications Societies, vol. 3, pp. 1190-1199
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`(2002), available at https://ieeexplore.ieee.org/document/1019369.
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`c. Exhibit 1046: V. N. Padmanabhan and L. Subramanian, “An
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`Investigation of Geographic Mapping Techniques for Internet Hosts.”
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`ACM SIGCOMM Computer Communication Review, vol. 3, No. 4,
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`pp. 173–185 (2001), available at
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`https://doi.org/10.1145/964723.383073.
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`2
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`
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`d. Exhibit 1047: M.J. Freedman, K. Lakshminarayanan, and D.
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`Mazières, “OASIS: Anycast for Any Service.” Proceedings of the 3rd
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`Conference on Networked Systems Design & Implementation, vol. 3,
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`pp. 129-142 (2006), available at
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`https://www.usenix.org/legacy/events/nsdi06/tech/full_papers/freedm
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`an/freedman.pdf.
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`e. Exhibit 1048: S. Agarwal and J.R. Lorch, “Matchmaking for Online
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`Games and Other Latency-Sensitive P2P Systems.” ACM SIGCOMM
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`Computer Communication Review, vol. 39, No. 4, pp. 315-326 (2009),
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`available at https://dl.acm.org/doi/10.1145/1594977.1592605
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`(published August 16, 2009).
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`f. Exhibit 1050: H. Casanova, “Benefits and Drawbacks of Redundant
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`Batch Requests.” Journal of Grid Computing, vol. 5, pp. 235–250
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`(2007), available at https://doi.org/10.1007/s10723-007-9068-6.
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`g. Exhibit 1055: S. J. Murdoch, “New Tor distribution for testing: Tor
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`Browser Bundle,” January 30, 2008 post to tor-talk mailing list,
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`available at https://lists.torproject.org/pipermail/tor-talk/2008-
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`January/007837.html.
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`5.
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`Exhibit 1011 filed with this declaration and the above-mentioned
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`petition is a declaration from Sandy Ginoza that includes nine exhibits. The
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`3
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`following exhibits filed herewith are true and accurate copies of the Ginoza
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`Declaration exhibits. These were each saved from Exhibit 1011 and are presented
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`separately as indicated for convenience and ease of reference.
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`a. Ex. 1012, Ginoza Decl. Exh. 1, RFC 793: Transmission Control
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`Protocol - DARPA Internet Program Protocol Specification,
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`Information Sciences Institute (September 1981) (“RFC 793”).
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`b. Ex. 1013, Ginoza Decl. Exh. 2, RFC 1001: Protocol Standard for a
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`NetBIOS Service on a TCP/UDP Transport: Concepts and Methods,
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`NetBIOS Working Group (March 1987) (“RFC 1001”).
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`c. Ex. 1014, Ginoza Decl. Exh. 3, RFC 1122: Requirements for Internet
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`Hosts -- Communication Layers, Internet Engineering Task Force
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`(October 1989) (“RFC 1122”).
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`d. Ex. 1015, Ginoza Decl. Exh. 4, RFC 1630: Universal Resource
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`Identifiers in WWW - A Unifying Syntax for the Expression of Names
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`and Addresses of Objects on the Network as used in the World-Wide
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`Web, Network Working Group (June 1994) (“RFC 1630”).
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`e. Ex. 1016, Ginoza Decl. Exh. 5, RFC 1738: Uniform Resource Locators
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`(URL), Network Working Group (December 1994) (“RFC 1738”).
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`4
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`f. Ex. 1017, Ginoza Decl. Exh. 6, RFC 2187: Application of Internet
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`Cache Protocol (ICP), version 2, National Laboratory for Applied
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`Network Research/UCSD (September 1997) (“RFC 2187”).
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`g. Ex. 1018, Ginoza Decl. Exh. 7, RFC 2616: Hypertext Transfer Protocol
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`-- HTTP/1.1, The Internet Society (June 1999) (“RFC 2616”).
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`h. Ex. 1019, Ginoza Decl. Exh. 8, RFC 2960: Stream Control
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`Transmission Protocol, The Internet Society (October 2000) (“RFC
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`2960”).
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`i. Ex. 1020, Ginoza Decl. Exh. 9, RFC 6520: Transport Layer Security
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`(TLS) and Datagram Transport Layer Security (DTLS) Heartbeat
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`Extension, Internet Engineering Task Force (February 2012) (“RFC
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`6520”).
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`6.
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`Exhibit 1021 filed with this declaration and the above-mentioned
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`petition is a declaration from Gordon MacPherson that attaches IEEE 802.11-2007
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`as Exhibit A. Exhibit 1022 filed herewith is a true and accurate copy of the
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`MacPherson Declaration Exhibit A. This was saved from Exhibit 1021 and is
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`separately presented for convenience and ease of reference.
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`7.
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`I declare that all statements made herein of my own knowledge are true
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`and that all statements made on information and belief are believed to be true; and
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`further that these statements were made with the knowledge that willful false
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`5
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`statements and the like are punishable by fine or imprisonment, or both, under
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`Section 1001 of Title 18 of the United States Code.
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`Executed this 1st day of November, 2021.
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`/ Adam R. Wichman /
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`
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`Adam R. Wichman, Esq.
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`6
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