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IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Derry Shribman et al.
`In re Patent of:
`10,484,510
`U.S. Patent No.:
`November 19, 2019
`Issue Date:
`Appl. Serial No.: 16/278,107
`Filing Date:
`February 17, 2019
`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
`
`DECLARATION OF WENSHENG MA
`
`Code200 Exhibit 1024
`Page 1 of 6
`
`

`

`1.
`
`My name is Wensheng Ma. I am over the age of 18, have personal
`
`knowledge of the facts set forth herein, and am competent to testify to the same. I
`
`am a counsel of record for the petitioner Major Data UAB in this petition.
`
`2.
`
`Exhibit 1001 is a true and correct copy of Shribman et al., U.S. Patent
`
`No. 10,484,510.
`
`3.
`
`Exhibit 1002 is a true and correct copy of the file history for United
`
`States Patent No. 10,484,510.
`
`4.
`
`Exhibit 1003 is a true and correct copy of the Challenged Claims of
`
`United States Patent No. 10,484,510. This document was originally submitted as
`
`Exhibit 1003 by the petitioner NetNut Ltd. in the co-pending Inter Partes Review
`
`Proceeding, NetNut Ltd. v. Bright Data Ltd., Case No. IPR2021-01493.
`
`5.
`
`Exhibit 1004 is a true and correct copy of Luminati’s Opposition to
`
`Defendant’s Motion to Dismiss filed in Luminati Networks Ltd. v. Teo LT, UAB, et
`
`al., Case No. 2:19-cv-395-JRG (E.D. Tex.), on April 7, 2020 (Document 28).
`
`6.
`
`Exhibit 1005 is a true and correct copy of Declaration of Keith J.
`
`Teruya with curriculum vitae.
`
`7.
`
`Exhibit 1006 is a true and correct copy of publication “Crowds:
`
`Anonymity for Web Transactions, ACM Transactions on Information and Systems
`
`Security” authored by Reiter et al., as downloaded from
`
`https://dl.acm.org/doi/abs/10.1145/290163.290168 (last accessed April 20, 2022).
`
`Code200 Exhibit 1024
`Page 2 of 6
`
`

`

`8.
`
`Exhibit 1007 is a true and correct copy of Declaration by Scott
`
`Delman (“Delman’s Decl.”), executed on June 24, 2020, with respect to the
`
`publication “Crowds: Anonymity for Web Transactions”. Delman’s Decl. was
`
`originally submitted as Exhibit 1007 by NetNut Ltd. in the co-pending Inter Partes
`
`Review Proceeding, NetNut Ltd. v. Bright Data Ltd., Case No. IPR2021-01493.
`
`9.
`
`Exhibit 1008 is a true and correct copy of publication “MorphMix - A
`
`Peer-to-Peer-based System for Anonymous Internet Access” authored by
`
`Rennhard, as downloaded from https://www.research-
`
`collection.ethz.ch/handle/20.500.11850/148022 (last accessed April 20, 2022).
`
`10.
`
`Exhibit 1009 is a true and correct copy of Declaration by Marc
`
`Rennhard (“Rennhard’s Decl.”), executed on June 9, 2020, with respect to the
`
`publication “MorphMix - A Peer-to-Peer-based System for Anonymous Internet
`
`Access”. Rennhard’s Decl. was originally submitted as Exhibit 1009 by the
`
`petitioner NetNut Ltd. in the co-pending Inter Partes Review Proceeding, NetNut
`
`Ltd. v. Bright Data Ltd., Case No. IPR2021-01493.
`
`11.
`
`Exhibit 1010 is a true and correct copy of Declaration by Bernhard
`
`Plattner (“Plattner’s Decl.”), executed on June 9, 2020, with respect to the
`
`publication “MorphMix - A Peer-to-Peer-based System for Anonymous Internet
`
`Access”. Plattner’s Decl. was originally submitted as Exhibit 1010 by the
`
`Code200 Exhibit 1024
`Page 3 of 6
`
`

`

`petitioner NetNut Ltd. in the co-pending Inter Partes Review Proceeding, NetNut
`
`Ltd. v. Bright Data Ltd., Case No. IPR2021-01493.
`
`12.
`
`Exhibit 1011 is a true and correct copy of Declaration by Andreas
`
`Berz (“Berz’s Decl.”), executed on June 11, 2020, with respect to the publication
`
`“MorphMix - A Peer-to-Peer-based System for Anonymous Internet Access”.
`
`Berz’s Decl. was originally submitted as Exhibit 1011 by the petitioner NetNut
`
`Ltd. in the co-pending Inter Partes Review Proceeding, NetNut Ltd. v. Bright Data
`
`Ltd., Case No. IPR2021-01493.
`
`13.
`
`Exhibit 1012 is a true and correct copy of Border et al., U.S. Patent
`
`No. 6,795,848 B1.
`
`14.
`
`Exhibit 1013 is a true and correct copy of RFC 2616, Hypertext
`
`Transfer Protocol – HTTP/1.1 (June 1999) downloaded from
`
`https://www.ietf.org/rfc/rfc2616.txt on April 16, 2022.
`
`15.
`
`Exhibit 1014 is a true and correct copy of RFC 1180, A TCP/IP
`
`Tutorial (January 1991) downloaded from https://www.ietf.org/rfc/rfc1180.txt on
`
`April 16, 2022.
`
`16.
`
`Exhibit 1015 is a true and correct copy of RFC 791, Internet Protocol,
`
`DARPA Internet Program, Protocol Specification (September 1981) downloaded
`
`from https://www.ietf.org/rfc/rfc791.txt on April 16, 2022.
`
`Code200 Exhibit 1024
`Page 4 of 6
`
`

`

`17.
`
`Exhibit 1016 is a true and correct copy of RFC 1122, Requirements
`
`for Internet Hosts – Communication Layers (October 1989) downloaded from
`
`https://www.ietf.org/rfc/rfc1122.txt on April 16, 2022.
`
`18.
`
`Exhibit 1017 is a true and correct copy of the Claim Construction
`
`Opinion and Order issued in Luminati Networks Ltd. v. Teo LT, UAB, et al., Case
`
`No. 2:19-cv-395-JRG (E.D. Tex.), on December 7, 2020 (Document 191).
`
`19.
`
`Exhibit 1018 is a true and correct copy of Glossary of Terms for
`
`Device Independence, W3C Working Draft 18 January 2005, downloaded from
`
`https://www.w3.org/TR/di-gloss/ on April 16, 2022.
`
`20.
`
`Exhibit 1019 is a true and correct copy of Gai et al., U.S. Patent
`
`Publication No. 2009/0037977 A1.
`
`21.
`
`Exhibit 1020 is a true and correct copy of the Supplemental Claim
`
`Construction Order issued in Luminati Networks Ltd. v. Teo LT, UAB, et al., Case
`
`No. 2:19-cv-395-JRG (E.D. Tex.), on August 6, 2021 (Document 453).
`
`22.
`
`Exhibit 1021 is a true and correct copy of the transcript from the
`
`Pretrial Conference held August 31/September 1, 2021, in Luminati Networks Ltd.
`
`v. Teo LT, UAB, et al., Case No. 2:19-cv-395-JRG (E.D. Tex.). This document was
`
`originally submitted as Exhibit 1021 by the petitioner NetNut Ltd. in the co-
`
`pending Inter Partes Review Proceeding, NetNut Ltd. v. Bright Data Ltd., Case No.
`
`IPR2021-01493.
`
`Code200 Exhibit 1024
`Page 5 of 6
`
`

`

`23.
`
`Exhibit 1022 is a true and correct copy of a comparison of claim 1
`
`from United States Patent No. 10,257,319 and claim 1 from United States Patent
`
`No. 10,484,510. This document was originally submitted as Exhibit 1022 by the
`
`petitioner NetNut Ltd. in the co-pending Inter Partes Review Proceeding, NetNut
`
`Ltd. v. Bright Data Ltd., Case No. IPR2021-01493.
`
`24.
`
`Exhibit 1023 is a true and correct copy of RFC 2068, Hypertext
`
`Transfer Protocol -- HTTP/1.1 (January 1997) downloaded from
`
`https://www.ietf.org/rfc/rfc2068.txt on April 21, 2022.
`
`25.
`
`I declare under the penalty of perjury that the forgoing is correct.
`
`Signed,
`
`Date: April 21, 2022
`
`_________________________________
`Wensheng Ma
`
`Code200 Exhibit 1024
`Page 6 of 6
`
`

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