`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`H&S MANUFACTURING COMPANY, INC.
`
`Petitioner,
`
`v.
`
`OXBO INTERNATIONAL CORPORATION
`
`Patent Owner.
`
`____________
`
`Case IPR2016-00950
`Patent 8,166,739
`____________
`
`
`__________________________________________________________________
`
`DECLARATION OF BENJAMIN LEGATT
`__________________________________________________________________
`
`
`
`
`I, Benjamin Legatt, declare as follows:
`
`1. I am Vice President of Consulting Services of Shepherd Data Services. I
`
`have worked at Shepherd Data Services since 2010.
`
`2. Shepherd Data Services is an e-discovery vendor located in Minneapolis,
`
`Minnesota.
`
`3. Merchant & Gould is a client of Shepherd Data Services. Merchant & Gould
`
`contracts with Shepherd Data Services for e-discovery services including use
`
`of Relativity database software. Relativity is a commonly-used software
`
`platform that permits companies and law firms to manage large volumes of
`
`electronic data for review, analysis and production in litigation.
`
`4. I am a certified Relativity Instructor, and I have worked extensively with
`
`Relativity software for approximately six years. I regularly train and advise
`
`clients, including Merchant & Gould paralegals and attorneys, on how to
`
`best use Relativity and how to run advanced searches on keywords and
`
`metadata.
`
`5. I have worked directly with the paralegal and attorney team at Merchant &
`
`Gould on the Relativity database in the matter of Oxbo Int’l. Corp. v. H&S
`
`Manufacturing Co., Inc., Case No. 15-292-jdp (W.D. Wis.). I am familiar
`
`with that database, including how it was set up and the metadata fields
`
`contained therein.
`
`
`
`2
`
`
`
`6. One of the metadata fields is “Date Created.” The “Date Created” metadata
`
`field means the date on which the document was created.
`
`7. I have reviewed H&S 152469-H&S 152495 (Exhibit 2014). This set of
`
`documents was produced by H&S in the District Court case. The metadata
`
`corresponding to the documents in this set show a “Date Created” of
`
`November 14, 2008.
`
`8. I have reviewed H&S152672-H&S152727 (Exhibit 2012). The metadata
`
`corresponding to the documents in this set show a “Date Created” of March
`
`10, 2009.
`
`9. I have reviewed H&S 153873-H&S 153943 (Exhibit 2013). The metadata
`
`corresponding to the documents in this set show a “Date Created” of
`
`October 12, 2010.
`
`
`
`I declare under penalty of perjury of the laws of the United States of
`
`America that the foregoing is true to the best of my knowledge.
`
`
`
`February 28, 2017
`
`
`
`
`
`
`
`
`____________________
`Benjamin Legatt
`
`
`
`3
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
