`
`Derry Shribman et al.
`In re Patent of:
`10,257,319
`U.S. Patent No.:
`April 9, 2019
`Issue Date:
`Appl. Serial No.: 15/957,945
`Filing Date:
`April 20, 2018
`Title:
`SYSTEM PROVIDING FASTER AND MORE EFFICIENT
`DATA COMMUNICATION
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`DECLARATION OF WENSHENG MA
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`Major Data Exhibit 1022
`Page 1 of 6
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`1. My name is Wensheng Ma. I am over the age of 18, have personal
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`knowledge of the facts set forth herein, and am competent to testify to the same. I
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`am a counsel of record for the petitioner Major Data UAB in this petition.
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`2.
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`Exhibit 1001 is a true and correct copy of Shribman et al., U.S. Patent
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`No. 10,257,319.
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`3.
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`Exhibit 1002 is a true and correct copy of the file history for United
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`States Patent No. 10,257,319.
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`4.
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`Exhibit 1003 is a true and correct copy of the Challenged Claims of
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`United States Patent No. 10,257,319. This document was originally submitted as
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`Exhibit 1003 by the petitioner NetNut Ltd. in the co-pending Inter Partes Review
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`Proceeding, NetNut Ltd. v. Bright Data Ltd., Case No. IPR2021-01492.
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`5.
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`Exhibit 1004 is a true and correct copy of Luminati’s Opposition to
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`Defendant’s Motion to Dismiss filed in Luminati Networks Ltd. v. Teo LT, UAB, et
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`al., Case No. 2:19-cv-395-JRG (E.D. Tex.), on April 7, 2020 (Document 28).
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`6.
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`Exhibit 1005 is a true and correct copy of Declaration of Keith J.
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`Teruya with curriculum vitae.
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`7.
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`Exhibit 1006 is a true and correct copy of publication “Crowds:
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`Anonymity for Web Transactions, ACM Transactions on Information and Systems
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`Security” authored by Reiter et al., as downloaded from
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`https://dl.acm.org/doi/abs/10.1145/290163.290168 (last accessed April 20, 2022).
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`Major Data Exhibit 1022
`Page 2 of 6
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`8.
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`Exhibit 1007 is a true and correct copy of Declaration by Scott
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`Delman (“Delman’s Decl.”), executed on June 24, 2020, with respect to the
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`publication “Crowds: Anonymity for Web Transactions”. Delman’s Decl. was
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`originally submitted as Exhibit 1007 by NetNut Ltd. in the co-pending Inter Partes
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`Review Proceeding, NetNut Ltd. v. Bright Data Ltd., Case No. IPR2021-01492.
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`9.
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`Exhibit 1008 is a true and correct copy of publication “MorphMix - A
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`Peer-to-Peer-based System for Anonymous Internet Access” authored by
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`Rennhard, as downloaded from https://www.research-
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`collection.ethz.ch/handle/20.500.11850/148022 (last accessed April 20, 2022).
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`10. Exhibit 1009 is a true and correct copy of Declaration by Marc
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`Rennhard (“Rennhard’s Decl.”), executed on June 9, 2020, with respect to the
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`publication “MorphMix - A Peer-to-Peer-based System for Anonymous Internet
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`Access”. Rennhard’s Decl. was originally submitted as Exhibit 1009 by the
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`petitioner NetNut Ltd. in the co-pending Inter Partes Review Proceeding, NetNut
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`Ltd. v. Bright Data Ltd., Case No. IPR2021-01492.
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`11. Exhibit 1010 is a true and correct copy of Declaration by Bernhard
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`Plattner (“Plattner’s Decl.”), executed on June 9, 2020, with respect to the
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`publication “MorphMix - A Peer-to-Peer-based System for Anonymous Internet
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`Access”. Plattner’s Decl. was originally submitted as Exhibit 1010 by the
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`Major Data Exhibit 1022
`Page 3 of 6
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`petitioner NetNut Ltd. in the co-pending Inter Partes Review Proceeding, NetNut
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`Ltd. v. Bright Data Ltd., Case No. IPR2021-01492.
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`12. Exhibit 1011 is a true and correct copy of Declaration by Andreas
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`Berz (“Berz’s Decl.”), executed on June 11, 2020, with respect to the publication
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`“MorphMix - A Peer-to-Peer-based System for Anonymous Internet Access”.
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`Berz’s Decl. was originally submitted as Exhibit 1011 by the petitioner NetNut
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`Ltd. in the co-pending Inter Partes Review Proceeding, NetNut Ltd. v. Bright Data
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`Ltd., Case No. IPR2021-01492.
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`13. Exhibit 1012 is a true and correct copy of Border et al., U.S. Patent
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`No. 6,795,848 B1.
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`14. Exhibit 1013 is a true and correct copy of RFC 2616, Hypertext
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`Transfer Protocol – HTTP/1.1 (June 1999) downloaded from
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`https://www.ietf.org/rfc/rfc2616.txt on April 16, 2022.
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`15. Exhibit 1014 is a true and correct copy of RFC 1180, A TCP/IP
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`Tutorial (January 1991) downloaded from https://www.ietf.org/rfc/rfc1180.txt on
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`April 16, 2022.
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`16. Exhibit 1015 is a true and correct copy of RFC 791, Internet Protocol,
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`DARPA Internet Program, Protocol Specification (September 1981) downloaded
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`from https://www.ietf.org/rfc/rfc791.txt on April 16, 2022.
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`Major Data Exhibit 1022
`Page 4 of 6
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`17. Exhibit 1016 is a true and correct copy of RFC 1122, Requirements
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`for Internet Hosts – Communication Layers (October 1989) downloaded from
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`https://www.ietf.org/rfc/rfc1122.txt on April 16, 2022.
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`18. Exhibit 1017 is a true and correct copy of the Claim Construction
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`Opinion and Order issued in Luminati Networks Ltd. v. Teo LT, UAB, et al., Case
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`No. 2:19-cv-395-JRG (E.D. Tex.), on December 7, 2020 (Document 191).
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`19. Exhibit 1018 is a true and correct copy of Glossary of Terms for
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`Device Independence, W3C Working Draft 18 January 2005, downloaded from
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`https://www.w3.org/TR/di-gloss/ on April 16, 2022.
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`20. Exhibit 1019 is a true and correct copy of Gai et al., U.S. Patent
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`Publication No. 2009/0037977 A1.
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`21. Exhibit 1020 is a true and correct copy of the Supplemental Claim
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`Construction Order issued in Luminati Networks Ltd. v. Teo LT, UAB, et al., Case
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`No. 2:19-cv-395-JRG (E.D. Tex.), on August 6, 2021 (Document 453).
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`22. Exhibit 1021 is a true and correct copy of the transcript from the
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`Pretrial Conference held August 31/September 1, 2021, in Luminati Networks Ltd.
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`v. Teo LT, UAB, et al., Case No. 2:19-cv-395-JRG (E.D. Tex.). This document was
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`originally submitted as Exhibit 1021 by the petitioner NetNut Ltd. in the co-
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`pending Inter Partes Review Proceeding, NetNut Ltd. v. Bright Data Ltd., Case
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`No. IPR2021-01492.
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`Major Data Exhibit 1022
`Page 5 of 6
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`23.
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`I declare under the penalty of perjury that the forgoing is correct.
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`Date: April 21, 2022
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`Signed,
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`_________________________________
`Wensheng Ma
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`Major Data Exhibit 1022
`Page 6 of 6
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