Messaging and broadcasting content were a core part of the offering of the site and I managed the implementation and hosting aspect of setting up and running the various SMTP, MTA, WAP, and SMS servers to enable communication with our user base.
My opinions and analysis set forth in this Declaration are based on my education, training, and experience as summarized above and detailed in my C.V., as well as my review of the ’132 and ’322 patents, the May 2007 PCT application to which they claim priority (EX1008), and the references identified by Petitioner in these IPR proceedings.
For example, Abrams describes interactions between the user devices and server apparatus 110 that include email messaging and upload/download of photographs and other media data, tasks a POSITA would have considered to be relatively bandwidth-intensive in the 2006 timeframe of the ’132 and ’322 patents.
For example, Figure 2 of Khedouri shows the dedicated digital media playback device, which a POSITA would have recognized as being distinct from both personal computers and cellular phones that were generally available at the time: Cases IPR2022-00179, IPR2022-00180 Attorney Docket Nos: 50048-0015IP1, 50048-0016IP1
British Telecom, Apple, IBM, Triplay (against Facebook), Ford, Code Corp(ITC), and RPost, Sony as an expert related to e-commerce, telecommunication systems, video streaming and multimedia recording, database backed websites, photography, real-time communication, ,two-way and instant messaging.