Third Declaration of Ian Crayford in Support of Petition for Inter Partes Review of
`U.S. Patent No. 9,019,838
`UNITED STATES PATENT AND TRADEMARK OFFICE
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`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 No. IPR2016-01397
`U.S. Patent No. 9,019,838
`Third Declaration of Ian Crayford
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`Juniper Ex 1048-p. 1
`Juniper v ChriMar
`IPR2016-01397
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`U.S. Patent No. 9,019,838
`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 No. IPR2016-01397
`U.S. Patent No. 9,019,838
`Third Declaration of Ian Crayford
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`Juniper Ex 1048-p. 1
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`Third Declaration of Ian Crayford in Support of Petition for Inter Partes Review of
`U.S. Patent No. 9,019,838
`
`PETITIONERS’ EXHIBITS FILED IN IPR2016-01397
`
`
`Number
`1001
`
`1002
`
`1003
`1004
`1005
`1006
`
`10071
`1008
`1009
`1010
`
`Short Name
`‘838 Patent
`
`Crayford-1
`
`Hunter
`Bulan
`Bloch
`IEEE-1993
`
`IEEE-1995 (part 1)
`IEEE-1995 (part 2)
`Huizinga
`Blacharski
`
`Description
`U.S. Patent 9,019,838 to Austermann, III
`et al.
`Declaration of Ian Crayford in Support of
`Petition
`WO 96/23377 to Hunter
`U.S. Patent 5,089,927 to Bulan et al.
`U.S. Patent 4,173,714 to Bloch et al.
`IEEE International Standard ISO/IEC 8802-
`3: 1993
`IEEE Standard 802.3u-1995
`IEEE Standard 802.3u-1995
`U.S. Patent 4,046,972 to Huizinga et al.
`Dan Blacharski, “Maximum Bandwith: A
`Serious Guide to High-Speed Networking”,
`Que Corporation (1997)
`
`
`1 IEEE Standard 802.3u-1995 has been separated into Exhibits 1007 and
`
`1008 to comply with file size limitations for Exhibits. Exhibits 1007 and 1008 are
`
`continuously paginated, from 1-200, and 201-415, respectively.
`
`
`
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`Third Declaration of Ian Crayford in Support of Petition for Inter Partes Review of
`U.S. Patent No. 9,019,838
`Number
`Short Name
`1011
`Katz
`
`1012
`
`1013
`1014
`
`Related Matters
`
`Crayford C.V.
`IEEE Press Release
`
`1015
`
`Complaint
`
`‘058 patent
`N/A
`
`N/A
`
`N/A
`Madisetti
`Declaration
`
`Level One
`
`Pulse
`
`Valor
`
`1016
`1017
`
`1018
`
`1019
`1020
`
`1021
`
`1022
`
`1023
`
`
`
`
`Description
`Randy H. Katz, “High Performance Network
`and Channel-Based Storage”, Report
`UCB/CSD 91/650, September 1991
`List of Pending Cases Involving U.S. Patent
`9,019,838
`Resume of Ian Crayford
`IEEE Standards Association News &
`Events: Press Releases “IEEE 802.3
`Standard for Ethernet Marks 30 Years of
`Innovation and Global Market Growth”
`
`Chrimar Systems, Inc. et al. v. Juniper
`Networks, Inc., Case No. 6:15-cv-00630
`(N.D. Cal.), Dkt. No. 1.
`U.S. Patent 6,247,058 to Miller et al.
`Gordnia Declaration in support of pro hac
`vice motion
`Kagan Declaration in support of pro hac
`vice motion
`Reserved
`Deposition transcript for the June 21 and
`June 22, 2017 deposition of Dr. Vijay
`Madisetti
`Level One LXT914 Data Sheet, June 1997,
`Revision 2.2
`Pulse LAN Isolation Transformer Catalog,
`May 1998
`Valor Electronics Products Catalog, 1992
`(excerpts)
`
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`Third Declaration of Ian Crayford in Support of Petition for Inter Partes Review of
`U.S. Patent No. 9,019,838
`Number
`Short Name
`1024
`Halo
`
`Description
`Halo TD43-2006K Drawing, December 18,
`1996
`Fisher or ‘998 patent U.S. Patent 5,994,998 to Fisher et al.
`‘911 Patent
`U.S. Patent 6,140,911 to Fisher et al.
`De Nicolo or ‘468
`U.S. Patent 6,115,468 to De Nicolo
`patent
`‘356 patent
`Smith
`Chrimar
`Presentation to IEEE
`
`1025
`1026
`1027
`
`1028
`1029
`1030
`
`1031
`
`1032
`1033
`
`1034
`
`1035
`
`1036
`
`1037
`
`
`
`
`Madisetti Deposition
`Exhibit 2
`
`IEEE 802.9
`IEEE Dictionary
`
`Madisetti Deposition
`Exhibit 1
`Lucent
`
`Agenda
`
`Muir
`
`U.S. Patent 6,295,356 to De Nicolo
`U.S. Patent 5,321,372 to Smith
`“Power on the 802.3 connection July 11th &
`12th, 2000 Power, Detection and Discovery
`over the Existing Ethernet Wiring” by CMS
`Technologies
`Madisetti Deposition Exhibit 2, Belden
`“Conduit and Media Twist” white paper,
`August 25, 1997
`IEEE 802.9 Standard, 1994
`The IEEE Standard Dictionary of Electrical
`and Electronics Terms, Sixth Edition, 1996
`(excerpts)
`Madisetti Deposition Exhibit 1, June 22,
`2017
`Lucent Technologies, “TransTalk™ 9000
`Digital Wireless System MDW 9030P
`Wireless Pocketphone Installation and Use,”
`March 1997 (excerpts)
`Steve Carlson, “802.3 DTE Power via MDI
`Study Group” (November 1999)
`Robert Muir, “DTE power over MDI - DTE
`
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`Third Declaration of Ian Crayford in Support of Petition for Inter Partes Review of
`U.S. Patent No. 9,019,838
`Number
`Short Name
`
`1038
`
`Frazier
`
`1039
`
`Karam
`
`1040
`
`1041
`
`Nootbar
`
`Love
`
`1042
`
`Nakamura
`
`‘012 patent
`
`‘107 patent
`
`‘760 patent
`
`Crayford-2
`
`1043
`
`1044
`
`1045
`
`1046
`
`
`
`
`Description
`Discovery Process Proposal” (November
`1999)
`Howard Frazier, Karl Nakamura and Roger
`Karam, “Power over the MDI” (January
`2000)
`Roger Karam, “Common mode Rejection
`Through Center Tap of Magnetics” (March
`2000)
`Michael Nootbar, “Why Power Over Signal
`Pairs?” (March 2000)
`Robert Love and Dave Kooistra, “User
`Requirements for Cabling Support” (May
`2000)
`Karl Nakamura and Roger Karam, “Power
`over the MDI using the two Signal Pairs”
`(May 2000)
`U.S. Patent 8,155,012 to Austermann, III
`et al.
`U.S. Patent 8,942,107 to Austermann, III
`et al.
`U.S. Patent 8,902,760 to Austermann, III
`et al.
`Second Declaration of Ian Crayford (in
`Support of Reply)
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`Third Declaration of Ian Crayford in Support of Petition for Inter Partes Review of
`U.S. Patent No. 9,019,838
`I, Ian Crayford, declare as follows:
`
`1.
`
`I am an expert in the field of networking and communication systems.
`
`I have been retained by Petitioners Juniper Networks, Inc., Ruckus Wireless, Inc.,
`
`Brocade Communication Systems, Inc., and Netgear, Inc. (“Petitioners”) to
`
`provide my independent, expert opinions.
`
`2.
`
`I previously submitted a declaration (Exhibit 1002) in support of the
`
`Petition, and a second declaration (Exhibit 1046) in support of the Reply in each of
`
`IPRs Nos. IPR2016-01389, IPR2016-01391, IPR2016-01397, and IPR2016-01399.
`
`3.
`
`I am being compensated at my usual rate of $425 per hour for the time
`
`spent by me in connection with these proceedings. This compensation is not
`
`contingent upon my opinions or the outcome of the proceedings.
`
`4.
`
`I have personal knowledge of the facts stated in this Declaration and,
`
`if called upon to do so, could and would attest to these facts under oath. I provide
`
`this Declaration to affirm the following. There are eleven (11) Exhibits to this
`
`Declaration. See Exhibits A through K, attached.
`
`5.
`
`I have over 20 years of experience in broadband wired and wireless
`
`communications, including (1) Ethernet local area networks (LANs); (2) Ethernet
`
`devices including repeaters, bridges, switches, and router devices; and (3) the
`
`802.3 standards. Exhibit 1013. My resume (Exhibit 1013), incorporated herein by
`
`reference, provides additional details about my background and qualifications. Id.
`
`
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`Third Declaration of Ian Crayford in Support of Petition for Inter Partes Review of
`U.S. Patent No. 9,019,838
`
`
`From April 1997 to April 1998, I was employed at Bay Networks Inc.
`
`6.
`
`in Santa Clara, CA as the Director of the Switch Architecture and Strategy, Multi-
`
`LAN Switching Business Unit. Id. There, I was responsible for the definition and
`
`execution of next generation hybrid modular switch products for heterogeneous
`
`enterprise LANs (ATM, Ethernet, and Token Ring). In this role for my business
`
`unit, I was a primary engineering interface to customers, the sales force, other Bay
`
`Networks business units, and the Bay Architecture Labs (BAL). Id.
`
`7.
`
`From April 1998 to November 2002, I was employed at Broadcom
`
`Corp., in San Jose, CA as the Director of Switch Architecture and Business
`
`Development. Id. I was responsible for both Ethernet switch chip development,
`
`and the identification of new and emerging markets in broadband communications,
`
`with my focus being on LAN, wide area networks (WAN), and wireless LAN
`
`(WLAN) opportunities. Id. I led technical due-diligence teams on a number of
`
`prospective and completed acquisitions and investments. Id.
`
`8.
`
`From March 1988 to April 1997, I was employed by Advanced Micro
`
`Devices Inc. (AMD) in Sunnyvale, CA. During my employment at AMD, I
`
`obtained publicly available technical documents through my attendance at trade
`
`shows, industry conferences, vendor and distributor meetings, and through my
`
`requests for technical information via industry press and trade journals. In
`
`addition, during my subsequent tenure at Bay Networks, Broadcom Corp., and
`
`
`
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`U.S. Patent No. 9,019,838
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`other employers, I also obtained technical documents, including updated versions
`
`of the documents I obtained during my employment at AMD. I have retained some
`
`of these technical documents from the time I acquired them, at or around the dates
`
`printed on the documents, through the present. I have retained full control of these
`
`documents and kept them in my personal possession from the time I acquired them
`
`through the present, storing them either at my workplace or home office.
`
`Petitioners’ Exhibits 1021, 1022, 1023, and 1024 are examples of such technical
`
`documents.
`
`9.
`
`Petitioners’ Exhibit 1021 is a data sheet for the Level One LXT914
`
`Flexible Quad Ethernet Repeater. It is dated June 1997. Exhibit 1021, at 1. I
`
`obtained a copy of a February 1994 version of this document at or around February
`
`1994 when it was publicly available, and I have had it in my possession since that
`
`time through the present. See Exhibit A to this Declaration. I found the June 1997
`
`version of this data sheet online on the Internet Archive website at the following
`
`URL:
`
`https://web.archive.org/web/19970703205726/http://www.level1.com:80/pdf/914.p
`
`df. Because the June 1997 version is a higher resolution, color copy and provides
`
`the same information I found to be relevant in the February 1994 version, I used
`
`the June 1997 version to prepare Exhibit 1021. According to this website, the
`
`Internet Archive first captured the landing page for this June 1997 version of the
`
`
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`U.S. Patent No. 9,019,838
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`“LTX914 Flexible Quad Ethernet Repeater” datasheet (Version 2.2) on July 3,
`
`1997. See Exhibit B to this Declaration, at 1. The text “19970703” in the URL
`
`indicates it was captured on July 3, 1997. See Internet Archive, “How can I tell
`
`when the pages from the Wayback Machine were archived?”, Frequently Asked
`
`Questions, available at https://archive.org/legal/faq.php (“Archive FAQ”)2. I was
`
`directed to this landing page when selecting the link “LXT914” at the page of the
`
`Internet
`
`Archive
`
`website
`
`at
`
`the
`
`following
`
`URL:
`
`https://web.archive.org/web/19970703204815/http://www.level1.com:80/products.
`
`html, which I understand was captured by the Internet Archive on July 3, 1997.
`
`See Exhibit B to this Declaration, at 2, 4. The text “19970703” in the URL
`
`indicates it was captured on July 3, 1997. See Archive FAQ.
`
`10. Petitioners’ Exhibit 1022 is the LAN Isolation Transformer Catalog
`
`from Pulse, a Technitrol Company. It is dated May 1998. Exhibit 1022, at 1. I
`
`obtained a copy of this document at or around May 1998 when it was publicly
`
`available, and I have had it in my possession since that time through the present.
`
`See Exhibit K to this Declaration. I found a copy of the Catalog online at the
`
`following URL: http://www.ele.uri.edu/iced/protosys/hardware/datasheets/sys-
`
`card/network/PulseE-PE-64108-pulse-transformer-32100.pdf.
`
` Because
`
`the
`
`
`2 Capture or archive dates from the Internet Archive indicate that the page
`captured or archived was publicly available on the Internet on that date.
`
`
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`U.S. Patent No. 9,019,838
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`Catalog at this URL is a higher resolution, color copy of the hard copy of the
`
`Catalog in my possession, I used it to prepare Exhibit 1022. While the Catalog is
`
`dated May 1998, it describes Pulse Engineering parts that were publicly available
`
`before April 10, 1998. Exhibit 1022, at 1 (“5/98”). For example, the Pulse LAN
`
`Isolation Transformer Catalog provides information about the PE68810 and
`
`PE68820. Exhibit 1022, at 5. These parts are referenced in the Level One
`
`LXT914 Flexible Quad Ethernet Repeater datasheet (Exhibit 1021), which is dated
`
`June 1997. Exhibit 1021, at 19.
`
`11.
`
`In addition, Table 22 in the February 1994 version of the LXT914
`
`datasheet lists the Pulse Engineering PE68007 and PE68008 as transformers
`
`compatible with the LXT914. See Exhibit A to this Declaration, at page 3-106.
`
`The datasheet for the Pulse Engineering “10Base-T Transformers” designed for
`
`use with Level One’s LXT914 Multiport Repeater Chip, is dated June 1994 and
`
`attached as Exhibit C to this Declaration. See Exhibit C, at page 2 (“6/94”). It
`
`provides a schematic for the LXT914 with the PE68007 and PE68008 (id.) that is
`
`similar to the schematic for the LXT914 with the PE68810 and PE68820 (Exhibit
`
`1022, at 5). Both schematics show a “Typical 10Base-T Application Circuit” for
`
`the LXT914. Exhibit 1022, at 5; Exhibit, C at 2. Both schematics show that the
`
`10BASE-T transmit and receive connections do not include either Bob Smith
`
`Terminations or Common Mode Chokes. Id. The schematic in the June 1994
`
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`U.S. Patent No. 9,019,838
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`Pulse Engineering “10Base-T Transformers” datasheet also indicates that the PE-
`
`68008 and the PE-68820 are electrically interchangeable, and that the PE-68007
`
`and PE-68810 are also electrically interchangeable. Exhibit C, at page 2.
`
`12. Petitioners’ Exhibit 1023 is excerpts from the Valor Electronics
`
`Products Catalog from Valor Electronics, Inc. It is dated 1992. Exhibit 1023, at 4.
`
`I obtained a copy of this Valor Electronics Products Catalog at or around January
`
`1992 when it was publicly available, and I have had it in my possession since that
`
`time through the present. I prepared Exhibit 1023 by scanning excerpts from the
`
`Valor Electronics Products Catalog.
`
`13. Petitioners’ Exhibit 1024 is a Halo TD43-2006K Drawing. It is dated
`
`December 18, 1996. Exhibit 1024, at 1. I obtained a copy of this document during
`
`my employment at AMD where I worked from March 1988 through April 1997.
`
`Exhibit 1013. This document was publicly available at least as early as April
`
`1997. I prepared Exhibit 1024 by scanning the Halo TD43-2006K Drawing.
`
`14.
`
`I understand Patent Owner has submitted a declaration from Mr.
`
`Clyde Camp regarding Patent Owner Exhibits 2040 through 2046. Mr. Camp has
`
`declared that “[w]hile [he] was not a member of 802.3af, [he] was personally
`
`aware that this work was being done and [he is] familiar with the record-keeping
`
`system and policies used by IEEE 802 LAN/MAN Standards Committee including
`
`802.3af.” Exhibit 2048, ¶3. Mr. Camp also has declared that “[t]he 802.3af
`
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`U.S. Patent No. 9,019,838
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`Committee maintained a record of its proceedings by 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 visitors in the 802.af Committee and
`
`the documents were kept in the course of its 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 is still accessible from
`
`the
`
`IEEE
`
`802 LAN/MAN Standards Committee’s main website,
`
`http://www.ieee802.org/.” Exhibit 2048, ¶4. Mr. Camp has declared that Patent
`
`Owner’s Exhibits 2040 through 2046 are some of the documents maintained on the
`
`website http://www.ieee802.org/ and has provided URL links for each of the
`
`Exhibits in his declaration. Exhibit 2048, ¶¶ 5-11.
`
`15. To locate Petitioners’ Exhibits 1030 and 1036 through 1042, I visited
`
`http://www.ieee802.org/ and followed the link from there for the page “802.3
`
`Ethernet Working Group.” From that page, I next followed the link under
`
`“Archive information of completed work” for the page “IEEE Std 802.3af-2003,
`
`DTE Power via MDI.” From that page, I next followed the link for the page
`
`“IEEE P802.3af public area.“ It is on the page “IEEE P802.3af public area,”
`
`where I found meeting materials for the “IEEE802.3af DTE Power via MDI Task
`
`Force,” including the documents that are Petitioners Exhibits 1030 and 1036
`
`
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`Third Declaration of Ian Crayford in Support of Petition for Inter Partes Review of
`U.S. Patent No. 9,019,838
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`through 1042. As Mr. Camp did for Patent Owner’s Exhibits 2040 through 2046, I
`
`have provided in this Declaration the URL links from http://www.ieee802.org/
`
`(“the IEEE Website”) for each of Petitioners’ Exhibits 1030 and 1036 through
`
`1042.
`
`16.
`
`I also understand that Patent Owner has submitted a declaration from
`
`paralegal Steven Johnson. Exhibit 2054. Mr. Johnson has declared that he located
`
`copies of Exhibits 2040 through 2046 on the Internet Archive, www.archive.org.
`
`Exhibit 2054, ¶¶1-2. Mr. Johnson has provided URL links to the Internet Archive
`
`for Exhibits 2040 through 2046 along with PDFs of the pages located at those URL
`
`links. Exhibit 2054, ¶¶3-13, Exs. A-G.
`
`17. To locate Petitioners’ Exhibits 1030 and 1036 through 1042 on the
`
`Internet Archive, I visited www.archive.org and searched for these documents. As
`
`Mr. Johnson did for Patent Owner’s Exhibits 2040 through 2046, I have provided
`
`in this Declaration the URL links from www.archive.org for each of Petitioners’
`
`Exhibits 1030 and 1036 through 1042, and I have attached PDFs of the pages
`
`located at those URL links. See Exhibits D through H to this Declaration.
`
`18. One of the documents maintained on the IEEE Website is a copy of
`
`slides titled “Power, Detection and Discovery over the Existing Ethernet Wiring,”
`
`presented in July 2000, by CMS Technologies. Petitioners’ Exhibit 1030 is copy
`
`of
`
`that
`
`document.
`
` The web
`
`address
`
`for
`
`that
`
`document
`
`is
`
`
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`Third Declaration of Ian Crayford in Support of Petition for Inter Partes Review of
`U.S. Patent No. 9,019,838
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`http://www.ieee802.org/3/af/public/jul00/austermann_1_0700.pdf. According to
`
`the
`
`Internet
`
`Archive
`
`website,
`
`https://web.archive.org/web/20070711112523/http://www.ieee802.org/3/af/public/j
`
`ul00/austermann_1_0700.pdf, the Internet Archive first captured the landing page
`
`of that document on July 11, 2007. The text “20070711” in the URL indicates it
`
`was captured on July 11, 2007. See Archive FAQ. I was directed to this landing
`
`page when selecting the link “Power on the 802.3 connection” at the page of the
`
`Internet
`
`Archive
`
`website
`
`at
`
`the
`
`following
`
`URL:
`
`https://web.archive.org/web/20010212022229/http://www.ieee802.org:80/3/af/publ
`
`ic/jul00/index.html, which I understand was captured by the Internet Archive on
`
`February 12, 2001. See Exhibit D to this Declaration, at 1. The text “20010212”
`
`in the URL indicates it was captured on February 12, 2001. See Archive FAQ.
`
`19. One of the documents maintained on the IEEE Website is a copy of
`
`slides titled “Welcome to the November 1999 Meeting of the 802.3 DTE Power
`
`via MDI Study Group,” presented in November 1999, by Steve Carlson, the Chair
`
`of the IEEE 802.3 DTE Power via MDI Study Group. Petitioners’ Exhibit 1036 is
`
`copy of
`
`that document.
`
` The web address
`
`for
`
`that document
`
`is
`
`http://www.ieee802.org/3/power_study/public/nov99/agenda_1199.pdf.
`
`According
`
`to
`
`the
`
`Internet
`
`Archive
`
`website,
`
`https://web.archive.org/web/20030507223735/http://www.ieee802.org:80/3/power
`
`
`
`
`- 9 -
`
`
`
`Juniper Ex 1048-p. 14
`Juniper v ChriMar
`IPR2016-01397
`
`
`
`Third Declaration of Ian Crayford in Support of Petition for Inter Partes Review of
`U.S. Patent No. 9,019,838
`
`_study/public/nov99/agenda_1199.pdf, the Internet Archive first captured the
`
`landing page of that document on May 7, 2003. The text “20030507” in the URL
`
`indicates it was captured on May 7, 2003. See Archive FAQ. I was directed to this
`
`landing page when selecting the link “Agenda and Introductory Remarks” at the
`
`page
`
`of
`
`the
`
`Internet Archive website
`
`at
`
`the
`
`following URL:
`
`https://web.archive.org/web/20001212033500/http://www.ieee802.org:80/3/power
`
`_study/public/nov99/index.html, which I understand was captured by the Internet
`
`Archive on December 12, 2000. See Exhibit E to this Declaration, at 1. The text
`
`“20001212” in the URL indicates it was captured on December 12, 2000. See
`
`Archive FAQ.
`
`20. One of the documents maintained on the IEEE Website is a copy of
`
`slides titled “DTE power over MDI - DTE Discovery Process Proposal,” presented
`
`in November 1999, by Robert Muir of Level One. Petitioners’ Exhibit 1037 is
`
`copy of
`
`that document.
`
` The web address
`
`for
`
`that document
`
`is
`
`www.ieee802.org/3/power_study/public/nov99/muir_1_1199.pdf. According to
`
`the
`
`Internet
`
`Archive
`
`website,
`
`https://web.archive.org/web/20030721062428/http://ieee802.org:80/3/power_study
`
`/public/nov99/muir_1_1199.pdf, the Internet Archive first captured the landing
`
`page of that document on July 21, 2003. The text “20030721” in the URL
`
`indicates it was captured on July 21, 2003. See Archive FAQ. I was directed to
`
`
`
`
`- 10 -
`
`
`
`Juniper Ex 1048-p. 15
`Juniper v ChriMar
`IPR2016-01397
`
`
`
`Third Declaration of Ian Crayford in Support of Petition for Inter Partes Review of
`U.S. Patent No. 9,019,838
`
`this landing page when selecting the link “DTE Discovery Process Proposal” at the
`
`page
`
`of
`
`the
`
`Internet Archive website
`
`at
`
`the
`
`following URL:
`
`https://web.archive.org/web/20001212033500/http://www.ieee802.org:80/3/power
`
`_study/public/nov99/index.html, which I understand was captured by the Internet
`
`Archive on December 12, 2000. See Exhibit E to this Declaration, at 1. The text
`
`“20001212” in the URL indicates it was captured on December 12, 2000. See
`
`Archive FAQ.
`
`21. Another of the documents maintained on the IEEE Website is a copy
`
`of slides titled “Power over the MDI,” presented in January 2000, by Howard
`
`Frazier, Karl Nakamura and Roger Karam of Cisco Systems. Petitioners’ Exhibit
`
`1038 is copy of that document. The web address for that document is
`
`http://www.ieee802.org/3/power_study/public/jan00/frazier_1_0100.pdf.
`
`According
`
`to
`
`the
`
`Internet
`
`Archive
`
`website,
`
`https://web.archive.org/web/20030722153005/http://ieee802.org:80/3/power_study
`
`/public/jan00/frazier_1_0100.pdf, the Internet Archive first captured the landing
`
`page of that document on July 22, 2003. The text “20030722” in the URL
`
`indicates it was captured on July 22, 2003. See Archive FAQ. I was directed to
`
`this landing page when selecting the link “Power over the MDI” at the page of the
`
`Internet
`
`Archive
`
`website
`
`at
`
`the
`
`following
`
`URL:
`
`https://web.archive.org/web/20001212014700/http://www.ieee802.org:80/3/power
`
`
`
`
`- 11 -
`
`
`
`Juniper Ex 1048-p. 16
`Juniper v ChriMar
`IPR2016-01397
`
`
`
`Third Declaration of Ian Crayford in Support of Petition for Inter Partes Review of
`U.S. Patent No. 9,019,838
`
`_study/public/jan00/index.html, which I understand was captured by the Internet
`
`Archive on December 12, 2000. See Exhibit F to this Declaration, at 1. The text
`
`“20001212” in the URL indicates it was captured on December 12, 2000. See
`
`Archive FAQ.
`
`22. Another of the documents maintained on the IEEE Website is a copy
`
`of slides titled “Common mode Rejection Through Center Tap of Magnetics,”
`
`presented in March 2000, by Roger Karam of Cisco Systems. Petitioners’ Exhibit
`
`1039 is copy of that document. The web address for that document is
`
`http://www.ieee802.org/3/af/public/mar00/karam_1_0300.pdf. According to the
`
`Internet
`
`Archive
`
`website,
`
`https://web.archive.org/web/20030929000813/http://www.ieee802.org:80/3/af/publ
`
`ic/mar00/karam_1_0300.pdf, the Internet Archive first captured the landing page
`
`of that document on September 29, 2003. The text “20030929” in the URL
`
`indicates it was captured on September 29, 2003. See Archive FAQ. I was
`
`directed to this landing page when selecting the link “Common mode Rejection
`
`Through Center Tap of Magnetics” at the page of the Internet Archive website at
`
`the
`
`following
`
`URL:
`
`https://web.archive.org/web/20010212021939/http://www.ieee802.org:80/3/af/publ
`
`ic/mar00/index.html, which I understand was captured by the Internet Archive on
`
`
`
`
`- 12 -
`
`
`
`Juniper Ex 1048-p. 17
`Juniper v ChriMar
`IPR2016-01397
`
`
`
`Third Declaration of Ian Crayford in Support of Petition for Inter Partes Review of
`U.S. Patent No. 9,019,838
`
`February 12, 2001. See Exhibit G to this Declaration, at 1. The text “20010212”
`
`in the URL indicates it was captured on February 12, 2001. See Archive FAQ.
`
`23. Another of the documents maintained on the IEEE Website is a copy
`
`of slides titled “Why Power Over Signal Pairs?” presented in March 2000, by
`
`Michael Nootbaar of TDK Semiconductor. Petitioners’ Exhibit 1040 is copy of
`
`that
`
`document.
`
`
`
`The web
`
`address
`
`for
`
`that
`
`document
`
`is
`
`http://www.ieee802.org/3/af/public/mar00/nootbaar_3_0300.pdf. According to the
`
`Internet
`
`Archive
`
`website,
`
`https://web.archive.org/web/20030928215001/http://www.ieee802.org:80/3/af/publ
`
`ic/mar00/nootbaar_3_0300.pdf, the Internet Archive first captured the landing page
`
`of that document on September 28, 2003. The text “20030928” in the URL
`
`indicates it was captured on September 28, 2003. See Archive FAQ. I was
`
`directed to this landing page when selecting the link “Why Power over the Signal
`
`Pairs?” at the page of the Internet Archive website at the following URL:
`
`https://web.archive.org/web/20010212021939/http://www.ieee802.org:80/3/af/publ
`
`ic/mar00/index.html, which I understand was captured by the Internet Archive on
`
`February 12, 2001. See Exhibit G to this Declaration, at 2. The text “20010212”
`
`in the URL indicates it was captured on February 12, 2001. See Archive FAQ.
`
`24. Another of the documents maintained on the IEEE Website is a copy
`
`of slides titled “User Requirements for Cabling Support?” presented in May 2000,
`
`
`
`
`- 13 -
`
`
`
`Juniper Ex 1048-p. 18
`Juniper v ChriMar
`IPR2016-01397
`
`
`
`Third Declaration of Ian Crayford in Support of Petition for Inter Partes Review of
`U.S. Patent No. 9,019,838
`
`by Robert Love and Dave Kooistra of IBM. Petitioners’ Exhibit 1041 is copy of
`
`that
`
`document.
`
`
`
`The web
`
`address
`
`for
`
`that
`
`document
`
`is
`
`http://www.ieee802.org/3/af/public/may00/love_1_0500.pdf. According to the
`
`Internet
`
`Archive
`
`website,
`
`https://web.archive.org/web/20030929121816/http://www.ieee802.org:80/3/af/publ
`
`ic/may00/love_1_0500.pdf, the Internet Archive first captured the landing page of
`
`that document on September 29, 2003. The text “20030929” in the URL indicates
`
`it was captured on September 29, 2003. See Archive FAQ. I was directed to this
`
`landing page when selecting the link “User Requirements for Cabling Support” at
`
`the page of
`
`the
`
`Internet Archive website at
`
`the
`
`following URL:
`
`https://web.archive.org/web/20010212022058/http://www.ieee802.org:80/3/af/publ
`
`ic/may00/index.html, which I understand was captured by the Internet Archive on
`
`February 12, 2001. See Exhibit H to this Declaration, at 1. The text “20010212”
`
`in the URL indicates it was captured on February 12, 2001. See Archive FAQ.
`
`25. Another of the documents maintained on the IEEE Website is a copy
`
`of slides titled “Power over the MDI using the two Signal Pairs,” presented in May
`
`2000, by Karl Nakamura and Roger Karam of Cisco Systems. Petitioners’ Exhibit
`
`1042 is copy of that document. The web address for that document is
`
`http://www.ieee802.org/3/af/public/may00/nakamura_2_0500.pdf. According to
`
`the
`
`
`
`
`Internet
`
`Archive
`
`website,
`
`- 14 -
`
`
`
`Juniper Ex 1048-p. 19
`Juniper v ChriMar
`IPR2016-01397
`
`
`
`Third Declaration of Ian Crayford in Support of Petition for Inter Partes Review of
`U.S. Patent No. 9,019,838
`
`https://web.archive.org/web/20030518155916/http://www.ieee802.org:80/3/af/publ
`
`ic/may00/nakamura_2_0500.pdf, the Internet Archive first captured the landing
`
`page of that document on May 18, 2003. The text “20030518” in the URL
`
`indicates it was captured on May 18, 2003. See Archive FAQ. I was directed to
`
`this landing page when selecting the link “Power over the MDI using the two
`
`Signal Pairs” at the page of the Internet Archive website at the following URL:
`
`https://web.archive.org/web/20010212022058/http://www.ieee802.org:80/3/af/publ
`
`ic/may00/index.html, which I understand was captured by the Internet Archive on
`
`February 12, 2001. See Exhibit H to this Declaration, at 1. The text “20010212”
`
`in the URL indicates it was captured on February 12, 2001. See Archive FAQ.
`
`26. Petitioners’ Exhibit 1031 is a Belden Technical Paper titled “Conduit
`
`and MetiaTwistTM” by Stephen H. Lampen of the Belden & Wire Company. The
`
`document is dated August 25, 1997. According to the Internet Archive website,
`
`https://web.archive.org/web/19971014055920/http://www.belden.com:80/products
`
`/tbcondmt.htm, the Internet Archive first captured the landing page of that
`
`document on October 14, 1997, meaning this document was publicly available at
`
`least as early as that date. See Exhibit I to this Declaration, at 1. The text
`
`“19971014” in the URL indicates it was captured on October 14, 1997. See
`
`Archive FAQ.
`
`
`
`
`- 15 -
`
`
`
`Juniper Ex 1048-p. 20
`Juniper v ChriMar
`IPR2016-01397
`
`
`
`Third Declaration of Ian Crayford in Support of Petition for Inter Partes Review of
`U.S. Patent No. 9,019,838
`
`
`27. Petitioners’ Exhibit 1033 is excerpts from “IEEE Std 100-1996, The
`
`IEEE Standard Dictionary of Electrical and Electronics Terms, Sixth Edition,”
`
`Published in 1996 as indicated by its title “IEEE Std 100-1996.” See also, Exhibit
`
`1033, at 4-5 (“1996”). Accordingly, this document was publicly available at least
`
`as early as January 1, 1997. I prepared Exhibit 1033 from a copy of this dictionary
`
`available in the Library of Irell & Manella LLP, at 1800 Avenue of the Stars, Suite
`
`900, Los Angeles, CA 90067. Id. at 3. The stamp on the dictionary indicates it has
`
`been at this location since February 9, 1998. Id. at 3.
`
`28. Petitioners’ Exhibit 1035 is excerpts from the document titled
`
`“TransTalk™ 9000 Digital Wireless System MDW 9030P Wireless Pocketphone
`
`Installation and Use” by Lucent Technologies, Bell Labs Innovation. The
`
`document is dated March 1997. Exhibit 1035, at 1. It is available at the following
`
`URL: http://downloads.avaya.com/css/P8/documents/003679336. I was directed to
`
`this page when selecting the link “TransTalk- 9000 Digital Wireless System MDW
`
`9030P Wireless Pocketphone Installat...” at the Avaya Support website at the
`
`following
`
`URL:
`
`https://support.avaya.com/search-
`
`landing/?query=TransTalk+9000+Digital+Wireless+System+MDW+9030P+Wirel
`
`ess+Pocketphone+Installation+and+Use. See Exhibit J to this Declaration, at 1.
`
`According to this Avaya Support website, the “TransTalk™ 9000 Digital Wireless
`
`
`
`
`- 16 -
`
`
`
`Juniper Ex 1048-p. 2
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