UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_____________________________
`
`BEFORE THE UNITED STATES PATENT TRIAL AND APPEAL BOARD
`
`_____________________________
`
`TURNSIGNL, INC. AND TURNSIGNL FOUNDATION,
`
`Petitioners,
`
`v.
`
`REDMON JEANG LLC,
`
`Patent Owner.
`
`_____________________________
`
`CASE No. IPR2024-00104
`U.S. Patent No. 11,494,862
`
`_____________________________
`
`DECLARATION OF SUSAN HANRAHAN
`
`TurnSignl - Exhibit 1044
`Page 1 of 8
`
`
`
`_____________________________
`
`BEFORE THE UNITED STATES PATENT TRIAL AND APPEAL BOARD
`
`_____________________________
`
`TURNSIGNL, INC. AND TURNSIGNL FOUNDATION,
`
`Petitioners,
`
`v.
`
`REDMON JEANG LLC,
`
`Patent Owner.
`
`_____________________________
`
`CASE No. IPR2024-00104
`U.S. Patent No. 11,494,862
`
`_____________________________
`
`DECLARATION OF SUSAN HANRAHAN
`
`TurnSignl - Exhibit 1044
`Page 1 of 8
`
`
`
`I, Susan Hanrahan declare as follows:
`
`1.
`
`I am a Knowledge Services Research Manager at Barnes & Thornburg
`
`LLP.
`
`2.
`
`I received a Masters of Library Science from Kent State University in
`
`1994. I have over 25 years of experience working as a Reference Librarian and in a
`
`managerial roles related to Library Services.
`
`3.
`
`I am familiar and have extensive knowledge in search tools, such as
`
`various internet-based search tools to locate and identify references.
`
`4.
`
`I submit this Declaration to authenticate the references described
`
`below.
`
`5.
`
`I make this Declaration based on my personal knowledge that the
`
`Exhibits listed below filed on October 27, 2023, in IPR2024-00104, are as described,
`
`and are true and correct copies.
`
`6.
`
`I verified on October 24, 2023, that Exhibit 1008 is a true and correct
`
`copy of the document available at https://blog.textedly.com/smartphone-history-
`
`when-were-smartphones-invented. I am familiar with the internet-based tools used
`
`to identify this reference, and I personally downloaded the document and compared
`
`it to Exhibit 1008.
`
`7.
`
`I verified on October 24, 2023, that Exhibit 1009 is a true and correct
`
`copy of the document available at https://www.zippia.com/advice/mobile-app-
`
`2
`
`TurnSignl - Exhibit 1044
`Page 2 of 8
`
`
`
`industry-statistics/. I am familiar with the internet-based tools used to identify this
`
`reference, and I personally downloaded the document and compared it to Exhibit
`
`1009.
`
`8.
`
`I verified on October 24, 2023, that Exhibit 1010 is a true and correct
`
`copy of the document available at https://location.services.mozilla.com/. I am
`
`familiar with the internet-based tools used to identify this reference, and I personally
`
`downloaded the document and compared it to Exhibit 1010.
`
`9.
`
`I verified on October 24, 2023, that Exhibit 1011 is a true and correct
`
`copy of the document available at https://www.britannica.com/technology/Skype. I
`
`am familiar with the internet-based tools used to identify this reference, and I
`
`personally downloaded the document and compared it to Exhibit 1011.
`
`10.
`
`I verified on October 24, 2023, that Exhibit 1012 is a true and correct
`
`copy of the document available at https://www.zdnet.com/article/apple-talk-is-
`
`facetime-video-chat-steve-jobss-latest-clever-call/. I am familiar with the internet-
`
`based tools used to identify this reference, and I personally downloaded the
`
`document and compared it to Exhibit 1012.
`
`11.
`
`I verified on October 24, 2023, that Exhibit 1013 is a true and correct
`
`copy of the document available at https://www.quora.com/Can-I-put-my-lawyer-on-
`
`facetime-on-my-phone-during-a-traffic-stop/log. I am familiar with the internet-
`
`based tools used to identify this reference, and I personally downloaded the
`
`
`
`3
`
`TurnSignl - Exhibit 1044
`Page 3 of 8
`
`
`
`document and compared it to Exhibit 1013.
`
`12.
`
`I verified on October 24, 2023, that Exhibit 1014 is a true and correct
`
`copy of the document available at https://vator.tv/news/2020-03-26-when-zoom-
`
`was-young-the-early-years. I am familiar with the internet-based tools used to
`
`identify this reference, and I personally downloaded the document and compared it
`
`to Exhibit 1014.
`
`13.
`
`I verified on October 24, 2023, that Exhibit 1020 is a true and correct
`
`copy of
`
`the document available at https://www.comstocksmag.com/web-
`
`only/updated-quicklegal. I am familiar with the internet-based tools used to identify
`
`this reference, and I personally downloaded the document and compared it to Exhibit
`
`1020.
`
`14.
`
`I verified on October 24, 2023, that Exhibit 1021 is a true and correct
`
`copy of the document available at https://www.huffpost.com/entry/teens-police-
`
`brutality-app_n_5687934. I am familiar with the internet-based tools used to identify
`
`this reference, and I personally downloaded the document and compared it to Exhibit
`
`1021.
`
`15.
`
`I verified on October 24, 2023, that Exhibit 1022 is a true and correct
`
`copy of the document available at https://www.aclunebraska.org/en/news/mobile-
`
`justice. I am familiar with the internet-based tools used to identify this reference, and
`
`I personally downloaded the document and compared it to Exhibit 1022.
`
`
`
`4
`
`TurnSignl - Exhibit 1044
`Page 4 of 8
`
`
`
`16.
`
`I verified on October 24, 2023, that Exhibit 1023 is a true and correct
`
`copy of the document available at https://www.psafe.com/en/blog/apps-designed-
`
`recording-police-encounters/. I am familiar with the internet-based tools used to
`
`identify this reference, and I personally downloaded the document and compared it
`
`to Exhibit 1023.
`
`17.
`
`I verified on October 24, 2023, that Exhibit 1024 is a true and correct
`
`copy of the document available at https://www.wired.com/2015/05/right-film-
`
`police-apps-can-help/. I am familiar with the internet-based tools used to identify
`
`this reference, and I personally downloaded the document and compared it to Exhibit
`
`1024.
`
`18.
`
`I verified on October 24, 2023, that Exhibit 1025 is a true and correct
`
`copy of the document available at https://m.apkpure.com/oh-crap-app/ohcrap.main.
`
`I am familiar with the internet-based tools used to identify this reference, and I
`
`personally downloaded the document and compared it to Exhibit 1025.
`
`19.
`
`I verified on October 24, 2023, that Exhibit 1026 is a true and correct
`
`copy of the document available at https://www.techrepublic.com/article/an-app-
`
`that-passively-records-your-life-so-you-always-have-a-witness/. I am familiar with
`
`the internet-based tools used to identify this reference, and I personally downloaded
`
`the document and compared it to Exhibit 1026.
`
`20.
`
`I verified on October 24, 2023, that Exhibit 1028 is a true and correct
`
`
`
`5
`
`TurnSignl - Exhibit 1044
`Page 5 of 8
`
`
`
`copy
`
`of
`
`the
`
`document
`
`available
`
`https://web.archive.org/web/20150924172730/https://www.onetouchlaw.com/.
`
`at
`
`I
`
`am familiar with the internet-based tools used to identify this reference, and I
`
`personally downloaded the document and compared it to Exhibit 1028.
`
`21.
`
`I verified on October 24, 2023, that Exhibit 1029 is a true and correct
`
`copy of the document available at https://www.ctvnews.ca/sci-tech/smartphone-
`
`app-offers-legal-advice-for-police-encounters-1.2446034. I am familiar with the
`
`internet-based tools used to identify this reference, and I personally downloaded the
`
`document and compared it to Exhibit 1029.
`
`22.
`
`I verified on October 24, 2023, that Exhibit 1030 is a true and correct
`
`copy of the document available at https://www.nbcnews.com/news/nbcblk/were-
`
`you-stopped-police-theres-app-n476636. I am familiar with the internet-based tools
`
`used to identify this reference, and I personally downloaded the document and
`
`compared it to Exhibit 1030.
`
`23.
`
`I verified on October 24, 2023, that Exhibit 1032 is a true and correct
`
`copy of the document available at https://www.lawnext.com/2016/03/new-app-
`
`become-uber-law.html. I am familiar with the internet-based tools used to identify
`
`this reference, and I personally downloaded the document and compared it to Exhibit
`
`1032.
`
`
`
`24.
`
`I verified on October 24, 2023, that Exhibit 1037 is a true and correct
`
`6
`
`TurnSignl - Exhibit 1044
`Page 6 of 8
`
`
`
`copy
`
`of
`
`the
`
`document
`
`available
`
`at
`
`https://commonlaw.uottawa.ca/sites/commonlaw.uottawa.ca/files/ksg_report_-
`
`_mcgill_et_al_oct_13_final_to_send_to_sshrc.pdf. I am familiar with the internet-
`
`based tools used to identify this reference, and I personally downloaded the
`
`document and compared it to Exhibit 1037.
`
`
`
`7
`
`TurnSignl - Exhibit 1044
`Page 7 of 8
`
`
`
`I declare under penalty of perjury under the laws of the United States of America
`that the foregoing is true and correct.
`
`
`Dated: October 24, 2023
`
`
`
`Susan Hanrahan
`
`
`
`8
`
`TurnSignl - Exhibit 1044
`Page 8 of 8
`
`
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