`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`CISCO SYSTEMS INC.,
`Petitioner
`_______________
`DECLARATION OF JOSE MARIA DE CASTRO, JR.
`UNDER 37 C.F.R. § 1.68 IN SUPPORT OF PETITION
`FOR INTER PARTES REVIEW
`
`
`
`
`
`Ex. 1021
`CISCO SYSTEMS, INC. / Page 1 of 4
`
`
`
`My name is Jose Maria de Castro, Jr.
`I am over twenty-one years of age and not under any legal disability. I have
`personal knowledge of the following facts and, if called as a witness, could and
`would testify competently thereto.
`I am making this Declaration at the request of Cisco Systems, Inc. Although
`I am being compensated for my time to prepare this Declaration, my compensation
`is not dependent on the outcome of this, or any other proceeding, or the specifics of
`this Declaration and/or my testimony.
`Counsel for Cisco has asked that I prepare this Declaration to recount the
`details about my work on a telecommunications standard that published under the
`name: “XEP-0327: Rayo.” I refer to this standard as the “Rayo Standard”
`throughout this Declaration.
`Counsel for Cisco has provided me a document that bears a label identifying
`it as Exhibit 1009. I recognize this document (Exhibit 1009) as version 0.2 of the
`Rayo Standard. This document (Exhibit 1009) states that it was last updated on
`June 10, 2013. The June 10, 2013, date is consistent with my recollection of when
`version 0.2 of the Rayo Standard was published and became readily available.
`Since January 2009, I served as the Chief Technology Officer of Tropo
`LLC. During that time, I led the company’s technical strategy and participated
`actively in steering industry standards with various standards bodies. One
`standards body that I was particularly involved with, starting in 2010, is the XMPP
`Standards Foundation, which I refer to as XSF throughout this Declaration.
`During my work with XSF, I became very familiar with its rules and
`procedures. I continue to be involved with XSF today and I believe that its rules
`and procedures have not changed since I became involved with XSF in 2010.
`Back in 2013, as well as today, it was XSF’s standard practice to encourage
`proposals from industry professionals to enhance and improve the contents of
`
`Ex. 1021
`CISCO SYSTEMS, INC. / Page 2 of 4
`
`
`
`XSF’s telecommunications standards. These proposals were submitted, reviewed,
`and published as XMPP Extension Protocols (XEP) documents as part of XSF’s
`regular business operations. It is my understanding that one of the reasons XSF
`encouraged these proposals was to expand the scope of XEP documents and to
`encourage their adoption by the telecommunication’s industry. XSF’s website,
`XMPP.org, was, and still is, a well-known website to telecom industry
`professionals and developers of telecom applications. Developers regularly visit
`XMPP.org and access XEP documents to understand how to use XMPP protocols
`in their services.
`Back in 2013, as well as today, XSF’s XEP documents were publicly
`available, free of charge, to any interested person at the XSF’s website: XMPP.org.
`A full listing of XEP documents could be found on the website XMPP Extensions,
`Specifications, or similar headings.
`My work on what became the Rayo Standard began in January 2011 when I
`drafted the standard’s initial written concept. This concept included a problem
`statement, proposed solution approach, and various technical diagrams.
`As my work on the Rayo Standard matured, I presented about its benefits
`and uses at the CloudComm Summit in September 2011. In February 2012, AT&T
`became the first company to deploy the Rayo Standard in its network.
`In August 2012, I began drafting the document that would eventually
`become the Rayo Standard in the format required by XSF. This document would
`eventually be assigned the title “XEP-0327: Rayo.”
`On April 5, 2013, the first version (0.0.1) of the Rayo Standard was
`published on XSF’s website.
`On May 6, 2013, the next version (0.1) of the Rayo Standard was published
`on XSF’s website.
`
`Ex. 1021
`CISCO SYSTEMS, INC. / Page 3 of 4
`
`
`
`On June 10, 2013, the next version (0.2) of the Rayo Standard—which is the
`version of the standard contained in the document labeled Exhibit 1009—was
`published on XSF’s website.
`Additional versions (0.3, 0.4, and 0.5) were published on January 30, 2014,
`March 13, 2014, and September 23, 2014, respectively.
`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 that
`these statements were made with knowledge that willful false statements and the
`like so made are punishable by fine or imprisonment, or both, under section 1001
`of Title 18 of the United States Code.
`
`Dated:______________
`
`_________________________
`Jose Maria de Castro, Jr.
`
`Ex. 1021
`CISCO SYSTEMS, INC. / Page 4 of 4
`
`
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