`
`Exhibit 18
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`
`
`Case 6:20-cv-00272-ADA Document 65-20 Filed 03/14/22 Page 2 of 5
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PA TENT TRIAL AND APPEAL BOARD
`
`APPLE INC.
`
`Petitioner,
`
`V.
`
`VOiP-PAL.COM, INC.,
`
`Patent Owner
`
`Case No. IPR2016-01201
`U.S. Patent 8,542,815
`
`DECLARATION IN SUPPORT PATENT OWNER
`RESPONSE TO INTER PARTES PETITION
`
`Voip-Pal Ex. 2016
`IPR2016-01201
`
`VOP _RBR0001897
`
`
`
`Case 6:20-cv-00272-ADA Document 65-20 Filed 03/14/22 Page 3 of 5
`
`IPR2016-01201
`Apple Inc. V. Voip-Pal
`
`I, William Henry Mangione-Smith, declare as follows:
`
`I.
`
`INTRODUCTION
`
`1.
`
`During the preparation of this Declaration, I have reviewed the
`
`following, as well as the other documents discussed in this Declaration:
`
`a. U.S. Patent No. 8,542,815 ("the '815 Patent") and its file history;
`
`b. U.S. Patent No. 9,179,005 ("the '005 Patent") and its file history;
`
`c. Apple, Inc.'s Petition For Inter Partes Review Of U.S. Patent No.
`
`8,542,815, including attached Declaration Of Henry H. Houh,
`
`PhD·
`'
`
`d. Apple, Inc.'s Petition For Inter Partes Review Of U.S. Patent No.
`
`9,179,005, including attached Declaration Of Henry H. Houh,
`
`PhD·
`'
`
`e. Declaration of Ryan Purita (Ex. 2011);
`
`f. Declaration of Johan Emil Viktor Bjorsell (Ex. 2012);
`
`g. Declaration of Clay Pen-eault (Ex. 2013);
`
`h. Declaration of David Terry (Ex. 2018);
`
`1. Deposition Transcript of Henry H. Houh, Ph.D. Volumes I and I
`
`(Ex. 2043, 2044)
`
`J. Subversion repository svn.tar file;
`
`k. U.S. Patent No. 7,486,684 to Chu ("the Chu '684 Patent");
`
`-1-
`
`VOP _RBR0001898
`
`
`
`Case 6:20-cv-00272-ADA Document 65-20 Filed 03/14/22 Page 4 of 5
`
`IPR2016-01201
`Apple Inc. V. Voip-Pal
`
`IV. LEVEL OF ORDINARY SKILL IN THE ART
`
`14. Based on my review of the '815 Patent and the '005 Patent and my
`
`background and experience in the field of computer science, it is my opinion that
`
`one of ordinary skill in the art as of the priority date would be someone with an
`
`undergraduate degree
`
`in either Computer Science, Computer Engineering,
`
`Electrical Engineering, or a closely related discipline. Furthermore, I believe that
`
`such a person would also have 2 years of experience in system-level software
`
`development.
`
`In my opinion a greater degree of professional experience could
`
`serve to replace some degree of formal education. I also believe that some greater
`
`degree of formal education could serve to replace some degree of professional
`
`work experience.
`
`15. Based on my education and experience, I am familiar with the level of
`
`knowledge that one of ordinary skill would have possessed during the relevant
`
`period of time. By the priority date of the '815 Patent and the '005 Patent, I was a
`
`person who had more than ordinary skill in the art.
`
`V. OVERVIEW OF THE '815 AND '005 PATENTS
`
`16. The '815 and '005 Patents disclose a method and apparatus for
`
`routing communications, such as voice calls or video calls, between an internet
`
`network (i.e. a network based on the Internet Protocol, or IP) and a public switched
`
`telephone network (PSTN), and between two endpoints on an IP network. The
`
`-8-
`
`VOP _RBR0001905
`
`
`
`Case 6:20-cv-00272-ADA Document 65-20 Filed 03/14/22 Page 5 of 5
`
`IPR2016-01201
`Apple Inc. V. Voip-Pal
`
`89.
`
`I declare under penalty of perjury under the laws of the United States
`
`of America that the foregoing is true and correct.
`
`Dated:
`
`2/10/17
`
`By:
`
`-81-
`
`VOP _RBR0001978
`
`
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