`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________
`
`JUNIPER NETWORKS INC.,
`RUCKUS WIRELESS, INC.,
`BROCADE COMMUNICATION SYSTEMS, INC.,
`and NETGEAR, INC.,
`
`Petitioners,
`
`v.
`
`CHRIMAR SYSTEMS, INC.,
`
`
`
`Patent Owner.
`
`
`
`
`Case Nos. IPR2016-01391, 2106-01389, 2016-01399, and 2016-013971
`
`U.S. Patent Nos. 8,942,107 B2, 8,155,012 B2, 8,902,760 B2, and 9,019,838 B2
`
`
`
`
`[CORRECTED] DECLARATION OF CLYDE CAMP
`
`
`
`
`1 Ruckus Wireless, Inc., Brocade Communication Systems, Inc. and Netgear, Inc.
`
`filed a petition in (now terminated) IPR2017-00718, IPR2017-0790, IPR2017-0719,
`
`and IPR-2017-720 who have been joined to the instant proceeding.
`
`Page 1 of 4
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`
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`CHRIMAR 2048
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`
`
`
`Case Nos. IPR2016-01391, 2106-01389, 2016-01399, and 2016-01397
`
`
`
`I, Clyde Camp, declare:
`
`
`
`1.
`
`I was retained by Brooks Kushman to affirm the following based on
`
`historical records maintained by the IEEE-SA 802 LAN/MAN committee’s
`
`document server. I make this declaration on personal knowledge and am competent
`
`to testify.
`
`2.
`
`I was a member of the IEEE Standards Association Standards Board
`
`from 1991-2002 with the exception of 1999-2000, when I was under contract to the
`
`Association. The Standards Board is the governing body of all IEEE standards and
`
`the entity that ultimately initiates the work process to write standards (including the
`
`revision to the 802.3 standard known as 802.3af) and that approves the final standard
`
`itself. I was also chair of the IEEE Standards Association Patent Committee during
`
`2001 and part of 2002 while 802.3af was being developed.
`
`3. While I was not a member of 802.3af, I was personally aware that this
`
`work was being done and I am familiar with the record-keeping system and policies
`
`used by IEEE 802 LAN/MAN Standards Committee including 802.3af.
`
`4.
`
`The 802.3af Committee maintained a record of its proceedings by
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`posting documents pertaining to its work, including meeting minutes and
`
`presentations, on its public document server at http://www.ieee802.org/3/af/public/
`
`(“the Website”). Documents on the Website were made by both contributors and
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`visitors in the 802.af Committee and the documents were kept in the course of its
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`Page 2 of 4
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`CHRIMAR 2048
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`
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`Case Nos. IPR2016-01391, 2106-01389, 2016-01399, and 2016-01397
`
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`regularly conducted business activities. The documents on the Website were posted
`
`
`
`and available to the public on or near the date stated in the documents. The Website
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`is still accessible from the IEEE 802 LAN/MAN Standards Committee’s main
`
`website, http://www.ieee802.org/.
`
`5.
`
`One of the documents maintained on the Website is a copy of slides
`
`titled DTE Power via MDI: System Requirements, presented on November 5, 1999
`
`by Arlan Anderson of Nortel Networks. A copy of that document is attached as
`
`Exhibit
`
`2040.
`
`
`
`The web
`
`address
`
`for
`
`that
`
`document
`
`is
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`http://www.ieee802.org/3/power_study/public/nov99/anderson_1_1199.pdf.
`
`6.
`
`Another of the documents maintained on the Website is a copy of the
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`IEEE Power via MDI Task Force Meeting Minutes from March 7-8, 2000. A copy
`
`of that document is attached as Exhibit 2041. The web address for that document is
`
`http://www.ieee802.org/3/af/public/mar00/minutes_0300.pdf.
`
`7.
`
`Another of the documents maintained on the Website is a copy of the
`
`IEEE Power via MDI Task Force Meeting Minutes from May 24-25, 2000. A copy
`
`of that document is attached as Exhibit 2042. The web address for that document is
`
`http://www.ieee802.org/3/af/public/may00/minutes_0500.pdf.
`
`8.
`
`Another of the documents maintained on the Website is a copy of slides
`
`titled DTE Power over MDI: Building Consensus, presented on May 24, 2000 by
`
`Ralph Andersson of TDK Semiconductor, Daniel Dove of Hewlett Packard, and
`
`Page 3 of 4
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`CHRIMAR 2048
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`
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`Case Nos. IPR2016-01391, 2106-01389, 2016-01399, and 2016-01397
`
`
`Robert Muir of Level One Communications. A copy of that document is attached
`
`
`
`as Exhibit
`
`2043.
`
`
`
` The web
`
`address
`
`for
`
`that
`
`document
`
`is
`
`http://www.ieee802.org/3/af/public/may00/andersson_1_0500.pdf.
`
`9.
`
`Another of the documents maintained on the Website is a copy of slides
`
`titled Powering and Discovery Alternatives, presented on May 24, 2000 by Arlan
`
`Anderson of Nortel Networks. A copy of that document is attached as Exhibit 2044.
`
`The
`
`web
`
`address
`
`for
`
`that
`
`document
`
`is
`
`http://www.ieee802.org/3/af/public/may00/anderson_1_0500.pdf.
`
`10. Another of the documents maintained on the Website is a copy of the
`
`IEEE Power via MDI Task Force Meeting Minutes from July 11-12, 2000. A copy
`
`of that document is attached as Exhibit 2045. The web address for that document is
`
`http://www.ieee802.org/3/af/public/jul00/minutes_0700.pdf.
`
`11. Another of the documents maintained on the Website is a copy of slides
`
`titled “Technical Feasibility of Sending Common Mode Power on the Signal Pairs,”
`
`presented on July 11, 2000 by Roger Karam and Karl Nakamura of Cisco Systems.
`
`A copy of that document is attached as Exhibit 2046. The web address for that
`
`document is http://www.ieee802.org/3/af/public/jul00/karam_1_0700.pdf.
`
`I declare under penalty of perjury that the foregoing is true and accurate to the
`
`best of my ability.
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`Executed on: April 18, 2017
`
`
`
`
`
`/Clyde Camp /
`
`
`
`
`
`
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`Page 4 of 4
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`
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`CHRIMAR 2048
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`
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