UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`THE DATA COMPANY TECHNOLOGIES INC.,
`Petitioner,
`
`v.
`
`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
`
`Code200, UAB v. Bright Data Ltd.
`Code 200's Exhibit 1077
`Page 1 of 7
`
`
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`THE DATA COMPANY TECHNOLOGIES INC.,
`Petitioner,
`
`v.
`
`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
`
`Code200, UAB v. Bright Data Ltd.
`Code 200's Exhibit 1077
`Page 1 of 7
`
`
`
`I, Adam R. Wichman, declare as follows:
`
`1.
`
`I am an attorney with Wolf, Greenfield & Sacks, P.C. (“WGS”),
`
`admitted to practice before all courts in the Commonwealth of Massachusetts and
`
`registered to practice before the U.S. Patent and Trademark Office. I am more than
`
`21 years old.
`
`2.
`
`I make these statements in support of The Data Company Technologies
`
`Inc. petition for inter partes review of U.S. Patent No. 10,257,319. I have personal
`
`knowledge of the matters set forth herein, and if called upon I would testify as
`
`follows.
`
`3.
`
`The following exhibits, filed with this declaration and the above-
`
`mentioned petition, are true and accurate copies of the following documents:
`
`a. Exhibit 1026: Pages from W. Richard Stevens, TCP/IP Illustrated,
`
`Volume 1: The Protocols. Canada: Addison-Wesley, 1994, chs. 1 & 18,
`
`bibliography (“Stevens”), made from a physical volume of Stevens at
`
`WGS.
`
`b. Exhibit 1033: Pages from L.L. Peterson, B.S. Davie, Computer
`
`Networks: A Systems Approach, 4th ed. San Francisco, CA: Elsevier,
`
`2007, chs. 1-2 (“Peterson”), made from a physical volume of Peterson
`
`at WGS.
`
`1
`
`Code200, UAB v. Bright Data Ltd.
`Code 200's Exhibit 1077
`Page 2 of 7
`
`
`
`4.
`
`Upon information and belief the following exhibits, filed with this
`
`declaration and the above-mentioned petition, are true and accurate copies of the
`
`following documents as retrieved from the indicated websites:
`
`a. Exhibit 1044: A. Rowstron and P. Druschel, “Pastry: Scalable,
`
`Decentralized Object Location, and Routing for Large-Scale Peer-to-
`
`Peer Systems.” IFIP/ACM International Conference on Distributed
`
`Systems Platforms and Open Distributed Processing: Middleware
`
`2001, pp. 329-350 (2001), available at
`
`https://link.springer.com/chapter/10.1007/3-540-45518-3_18.
`
`b. Exhibit 1045: S. Ratnasamy, M. Handley, R. Karp and S. Shenker,
`
`"Topologically-aware overlay construction and server selection."
`
`Proceedings Twenty-First Annual Joint Conference of the IEEE
`
`Computer and Communications Societies, vol. 3, pp. 1190-1199
`
`(2002), available at https://ieeexplore.ieee.org/document/1019369.
`
`c. Exhibit 1046: V. N. Padmanabhan and L. Subramanian, “An
`
`Investigation of Geographic Mapping Techniques for Internet Hosts.”
`
`ACM SIGCOMM Computer Communication Review, vol. 3, No. 4,
`
`pp. 173–185 (2001), available at
`
`https://doi.org/10.1145/964723.383073.
`
`2
`
`Code200, UAB v. Bright Data Ltd.
`Code 200's Exhibit 1077
`Page 3 of 7
`
`
`
`d. Exhibit 1047: M.J. Freedman, K. Lakshminarayanan, and D.
`
`Mazières, “OASIS: Anycast for Any Service.” Proceedings of the 3rd
`
`Conference on Networked Systems Design & Implementation, vol. 3,
`
`pp. 129-142 (2006), available at
`
`https://www.usenix.org/legacy/events/nsdi06/tech/full_papers/freedm
`
`an/freedman.pdf.
`
`e. Exhibit 1048: S. Agarwal and J.R. Lorch, “Matchmaking for Online
`
`Games and Other Latency-Sensitive P2P Systems.” ACM SIGCOMM
`
`Computer Communication Review, vol. 39, No. 4, pp. 315-326 (2009),
`
`available at https://dl.acm.org/doi/10.1145/1594977.1592605
`
`(published August 16, 2009).
`
`f. Exhibit 1050: H. Casanova, “Benefits and Drawbacks of Redundant
`
`Batch Requests.” Journal of Grid Computing, vol. 5, pp. 235–250
`
`(2007), available at https://doi.org/10.1007/s10723-007-9068-6.
`
`g. Exhibit 1055: S. J. Murdoch, “New Tor distribution for testing: Tor
`
`Browser Bundle,” January 30, 2008 post to tor-talk mailing list,
`
`available at https://lists.torproject.org/pipermail/tor-talk/2008-
`
`January/007837.html.
`
`5.
`
`Exhibit 1011 filed with this declaration and the above-mentioned
`
`petition is a declaration from Sandy Ginoza that includes nine exhibits. The
`
`3
`
`Code200, UAB v. Bright Data Ltd.
`Code 200's Exhibit 1077
`Page 4 of 7
`
`
`
`following exhibits filed herewith are true and accurate copies of the Ginoza
`
`Declaration exhibits. These were each saved from Exhibit 1011 and are presented
`
`separately as indicated for convenience and ease of reference.
`
`a. Ex. 1012, Ginoza Decl. Exh. 1, RFC 793: Transmission Control
`
`Protocol - DARPA Internet Program Protocol Specification,
`
`Information Sciences Institute (September 1981) (“RFC 793”).
`
`b. Ex. 1013, Ginoza Decl. Exh. 2, RFC 1001: Protocol Standard for a
`
`NetBIOS Service on a TCP/UDP Transport: Concepts and Methods,
`
`NetBIOS Working Group (March 1987) (“RFC 1001”).
`
`c. Ex. 1014, Ginoza Decl. Exh. 3, RFC 1122: Requirements for Internet
`
`Hosts -- Communication Layers, Internet Engineering Task Force
`
`(October 1989) (“RFC 1122”).
`
`d. Ex. 1015, Ginoza Decl. Exh. 4, RFC 1630: Universal Resource
`
`Identifiers in WWW - A Unifying Syntax for the Expression of Names
`
`and Addresses of Objects on the Network as used in the World-Wide
`
`Web, Network Working Group (June 1994) (“RFC 1630”).
`
`e. Ex. 1016, Ginoza Decl. Exh. 5, RFC 1738: Uniform Resource Locators
`
`(URL), Network Working Group (December 1994) (“RFC 1738”).
`
`4
`
`Code200, UAB v. Bright Data Ltd.
`Code 200's Exhibit 1077
`Page 5 of 7
`
`
`
`f. Ex. 1017, Ginoza Decl. Exh. 6, RFC 2187: Application of Internet
`
`Cache Protocol (ICP), version 2, National Laboratory for Applied
`
`Network Research/UCSD (September 1997) (“RFC 2187”).
`
`g. Ex. 1018, Ginoza Decl. Exh. 7, RFC 2616: Hypertext Transfer Protocol
`
`-- HTTP/1.1, The Internet Society (June 1999) (“RFC 2616”).
`
`h. Ex. 1019, Ginoza Decl. Exh. 8, RFC 2960: Stream Control
`
`Transmission Protocol, The Internet Society (October 2000) (“RFC
`
`2960”).
`
`i. Ex. 1020, Ginoza Decl. Exh. 9, RFC 6520: Transport Layer Security
`
`(TLS) and Datagram Transport Layer Security (DTLS) Heartbeat
`
`Extension, Internet Engineering Task Force (February 2012) (“RFC
`
`6520”).
`
`6.
`
`Exhibit 1021 filed with this declaration and the above-mentioned
`
`petition is a declaration from Gordon MacPherson that attaches IEEE 802.11-2007
`
`as Exhibit A. Exhibit 1022 filed herewith is a true and accurate copy of the
`
`MacPherson Declaration Exhibit A. This was saved from Exhibit 1021 and is
`
`separately presented for convenience and ease of reference.
`
`7.
`
`I declare that all statements made herein of my own knowledge are true
`
`and that all statements made on information and belief are believed to be true; and
`
`further that these statements were made with the knowledge that willful false
`
`5
`
`Code200, UAB v. Bright Data Ltd.
`Code 200's Exhibit 1077
`Page 6 of 7
`
`
`
`statements and the like are punishable by fine or imprisonment, or both, under
`
`Section 1001 of Title 18 of the United States Code.
`
`Executed this 1st day of November, 2021.
`
`/ Adam R. Wichman /
`
`
`
`Adam R. Wichman, Esq.
`
`
`
`
`
`6
`
`Code200, UAB v. Bright Data Ltd.
`Code 200's Exhibit 1077
`Page 7 of 7
`
`
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