Case 6:20-cv-00272-ADA Document 65-2 Filed 03/14/22 Page 1 of 5
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`
`
`CASE NO. 6:20-cv-00267-ADA
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`JURY TRIAL DEMANDED
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`
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`§§§§§§§§§§
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`CASE NO. 6:20-cv-00269-ADA
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`JURY TRIAL DEMANDED
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`CASE NO. 6:20-cv-00272-ADA
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`JURY TRIAL DEMANDED
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` §§§§§§§§§
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` §§§§§§§§§
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`VOIP-PAL.COM, INC.,
`
`Plaintiff,
`
`v.
`
`META PLATFORMS, INC. and
`WHATSAPP LLC,
`
`Defendants.
`
`
`VOIP-PAL.COM, INC.,
`
`Plaintiff,
`
`v.
`
`GOOGLE LLC,
`
`Defendant.
`
`
`VOIP-PAL.COM, INC.,
`
`Plaintiff,
`
`v.
`
`AMAZON.COM, INC., et al.,
`
`Defendants.
`
`DECLARATION OF ROBERT W. UNIKEL IN SUPPORT OF
`DEFENDANTS’ OPENING CLAIM CONSTRUCTION BRIEF
`
`
`
`
`
`
`
`
`
`
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`CASE NO. 6:20-cv-00267-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`§§§§§§§§§§
`
`
`
`
`
`CASE NO. 6:20-cv-00269-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`CASE NO. 6:20-cv-00272-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`
`
` §§§§§§§§§
`
`
`
` §§§§§§§§§
`
`VOIP-PAL.COM, INC.,
`
`Plaintiff,
`
`v.
`
`META PLATFORMS, INC. and
`WHATSAPP LLC,
`
`Defendants.
`
`
`VOIP-PAL.COM, INC.,
`
`Plaintiff,
`
`v.
`
`GOOGLE LLC,
`
`Defendant.
`
`
`VOIP-PAL.COM, INC.,
`
`Plaintiff,
`
`v.
`
`AMAZON.COM, INC., et al.,
`
`Defendants.
`
`DECLARATION OF ROBERT W. UNIKEL IN SUPPORT OF
`DEFENDANTS’ OPENING CLAIM CONSTRUCTION BRIEF
`
`
`
`
`
`
`
`
`
`
`
`Case 6:20-cv-00272-ADA Document 65-2 Filed 03/14/22 Page 2 of 5
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`
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`I, Robert W. Unikel, declare as follows:
`
`1.
`
`I am an attorney with the law firm Paul Hastings LLP and counsel for Defendant
`
`Google LLC (“Google”). I have personal knowledge of the facts contained in the declaration
`
`and, if called upon to do so, I could and would testify competently to the matters set forth herein.
`
`2.
`
`Attached hereto as Exhibit 1 is a true and correct copy of U.S. Patent No.
`
`10,218,606 (issued Feb. 26, 2019).
`
`3.
`
`Attached hereto as Exhibit 2 is a true and correct copy of excerpts from Alexander
`
`Clemm, Network Management Fundamentals (2007), bearing the Bates range DEFS-VOIP-
`
`2020-CC-00000108 - DEFS-VOIP-2020-CC-00000112.
`
`4.
`
`Attached hereto as Exhibit 3 is a true and correct copy of Siemens Networks
`
`GmbH, “Network Element Auto-configuration in a Managed Network,” IEEE (2007), bearing
`
`the Bates range DEFS-VOIP-2020-CC-00000057 - DEFS-VOIP-2020-CC-00000075.
`
`5.
`
`Attached hereto as Exhibit 4 is a true and correct copy of Hong-Taek Ju et al.,
`
`“An efficient and lightweight embedded Web server for Web-based network element
`
`management,” 10 Int. J. Network Mgmt 261 (2000), bearing the Bates range DEFS-VOIP-2020-
`
`CC-00000093 - DEFS-VOIP-2020-CC-00000107.
`
`6.
`
`Attached hereto as Exhibit 5 is a true and correct copy of Network Working
`
`Group RFC 2216, “Network Element Service Specification Template” (Sept. 1997), bearing the
`
`Bates range DEFS-VOIP-2020-CC-00000113 - DEFS-VOIP-2020-CC-00000134.
`
`7.
`
`Attached hereto as Exhibit 6 is a true and correct copy of excerpts from the
`
`Telecommunications Act of 1996, bearing the Bates range DEFS-VOIP-2020-CC-00000135 -
`
`DEFS-VOIP-2020-CC-00000140.
`
`2
`
`
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`Case 6:20-cv-00272-ADA Document 65-2 Filed 03/14/22 Page 3 of 5
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`
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`8.
`
`Attached hereto as Exhibit 7 is a true and correct copy of excerpts from Andy
`
`Valdar, Understanding Telecommunications Networks,
`
`bearing
`
`the Bates
`
`range
`
`VOP_RBR0002426 - VOP_RBR0002428.
`
`9.
`
`Attached hereto as Exhibit 8 is a true and correct copy of excerpts from Harri
`
`Holma and Antti Toskala, WCDMA for UMTS: Radio Access for Third Generation Mobile
`
`Communications (3rd ed. 2004), bearing the Bates range DEFS-VOIP-2020-CC-00000141 -
`
`DEFS-VOIP-2020-CC-00000148.
`
`10.
`
`Attached hereto as Exhibit 9 is a true and correct copy of Tong Luo et al., “A
`
`Reliable CORBA-Based Network Management System,” IEEE (1999), bearing the Bates range
`
`DEFS-VOIP-2020-CC-00000079 - DEFS-VOIP-2020-CC-00000092.
`
`11.
`
`Attached hereto as Exhibit 10 is a true and correct copy of U.S. Patent
`
`Application No. 15/942,282, Information Disclosure Statement (filed Oct. 17, 2018), bearing the
`
`Bates range VOP_RBR0000160 - VOP_RBR0000221.
`
`12.
`
`Attached hereto as Exhibit 11 is a true and correct copy of WIPO International
`
`Patent Application Publication No. WO 2004/008786 A1 (published Jan. 22, 2004), bearing the
`
`Bates range VOP_RBR0000490 - VOP_RBR0000576.
`
`13.
`
`Attached hereto as Exhibit 12 is a true and correct copy of excerpts from the Joint
`
`Disputed Claim Construction Chart (Dkt. No. 93-2) in Case No. 5:20-cv-02995-LHK (N.D. Cal.
`
`July 27, 2021), bearing the Bates range DEFS-VOIP-2020-CC-00000001 - DEFS-VOIP-2020-
`
`CC-00000042.
`
`14.
`
`Attached hereto as Exhibit 13 is a true and correct copy of excerpts from Federal
`
`Standard 1037C, “Telecommunications: Glossary of Telecommunication Terms” (1996),
`
`3
`
`
`
`Case 6:20-cv-00272-ADA Document 65-2 Filed 03/14/22 Page 4 of 5
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`
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`prepared by the National Communications System Technology and Standards Division and
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`bearing the Bates range DEFS-VOIP-2020-CC-00000043 - DEFS-VOIP-2020-CC-00000050.
`
`15.
`
`Attached hereto as Exhibit 14 is a true and correct copy of excerpts from
`
`Microsoft Computer Dictionary (5th ed. 2002), bearing the Bates range DEFS-VOIP-2020-CC-
`
`00000051 - DEFS-VOIP-2020-CC-00000056.
`
`16.
`
`Attached hereto as Exhibit 15 is a true and correct copy of excerpts from Althos
`
`Publishing, Wireless Encyclopedia (2007), bearing the Bates range DEFS-VOIP-2020-CC-
`
`00000076 - DEFS-VOIP-2020-CC-00000078.
`
`17.
`
`Attached hereto as Exhibit 16 is a true and correct copy of U.S. Patent
`
`Application Publication No. US 2014/0024367 A1 (published Jan. 23, 2014).
`
`18.
`
`Attached hereto as Exhibit 17 is a true and correct copy of WIPO International
`
`Patent Application Publication No. WO 01/089145 A2 (published Nov. 11, 2001).
`
`19.
`
`Attached hereto as Exhibit 18 is a true and correct copy of excerpts from the
`
`Declaration of Dr. William Henry Mangione-Smith that was filed as Exhibit 2016 in IPR2016-
`
`01201, bearing the Bates range VOP_RBR0001897 - VOP_RBR0001978.
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed this
`
`11th day of March, 2022 in Chicago, Illinois.
`
`
`
`
`/s/ Robert W. Unikel
`Robert W. Unikel
`
`
`
`4
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`Case 6:20-cv-00272-ADA Document 65-2 Filed 03/14/22 Page 5 of 5
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that, on March 11, 2022, a true and correct copy of the
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`foregoing document was served to all counsel of record who are deemed to have consented to
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`electronic service via email due to the Court’s ECF system being inoperable that day. The
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`undersigned further certifies that, on March 14, 2022, a true and correct copy of the foregoing
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`document was also served via the Court’s ECF system on all counsel of record who are deemed to
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`have consented to electronic service.
`
`/s/ Daniel T. Shvodian
`____________________________________
`Daniel T. Shvodian
`
`
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