`Guardian Alliance Technologies, Inc. v. Miller
`
`1
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`
`
`Case No. Unassigned
`Patent 10,043 ,188
`
`Attorney Docket No. 2993.003
`
`I, Thomas Ward, declare as follows:
`
`1.
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`From March 2008 to present, I have served as one of the managing
`
`partners of Background Solutions, LLC. During that time, my responsibilities have
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`generally included, at times on a limited basis, administration, sales, product
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`development and personnel management.
`
`2.
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`I have a Bachelor of Science in Criminal Justice Administration and
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`Political Science from Brigham Young University and a Masters of Public
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`Administration (MFA) from Brigham Young University.
`
`3.
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`From September 1979 until March 2008, I was a Police Officer in the
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`Dallas (TX) Police Department, reaching the rank of Assistant Chief of Police and
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`serving in that position from October 1999 to March 2008.
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`4.
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`As a managing partner of Background Solutions, I have been a
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`member of the Background Solutions product development team, which initially
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`included Rick Harris and Brian Harvey, to develop the Background AssistantTM
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`background investigation software.
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`5.
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`Background Solutions began development of the Background
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`AssistantTM background investigation software in 2006, with product sales being
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`generated in mid—2009 based on company records.
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`6.
`
`In conjunction with the development of the Background AssistantTM
`
`2
`
`
`
`Case No. Unassigned
`Patent 10,043 ,188
`
`Attorney Docket No. 2993.003
`
`background investigation software, the product development team outsourced the
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`production of a power point Video demonstration (EX. 1021) of the Background
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`AssistantTM background investigation software for marketing purposes. This
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`presentation was developed by Mary Hancock.
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`7.
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`Once the power point video presentation (with sound) was purchased,
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`I played the Background AssistantTM product video (EX. 1002) for the seminar
`attendees. I had embedded the Video in my background investigation seminar
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`power point presentation. I used the video to explain to seminar attendees that an
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`electronic solution for police background investigations was available through the
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`Background Assistant software.
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`8.
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`At these seminars, I also distributed a product brochure advertising
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`the Background AssistantTM background investigation software, which provides
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`the URL for the Background Solutions website, www.backgroundsolutions.com.
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`9.
`
`The Background AssistantTM product Video (EX. 1002) describing the
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`Background AssistantTM background investigation software and its various features
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`was made available to the public at the URL, www.backgroundsolutions.com. The
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`Background Solutions website contained a link to the same Background
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`AssistantTM product video presented at the above-described law enforcement and
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`background investigation seminars.
`
`3
`
`
`
`Case No. Unassigned
`Patent 10,043,188
`
`Attorney Docket No. 2993.003
`
`10.
`
`The copy I provided of the Background Assistant video is true and
`
`correct.
`
`11.
`
`The Background AssistantTM product, included the ability to
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`“[a]utomatically generate law enforcement correspondence based on applicant
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`address data. Background Assistant, using information from National Public
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`Safety Information Bureau, producers of the Law Enforcement Directory, has
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`embedded public safety address information in the application that automatically
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`prints to correspondence documents.” Law Enforcement Correspondence was
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`generated within a designated radius based on applicant address history.
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`12. Amongst other customers, Background Solutions provided the
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`Background AssistantTM product and background investigation services to King
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`County (WA) Sheriffs Department.
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`13. All statements made herein are of my own knowledge are true; all
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`statements made on information and belief are believed to be true; and these
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`statements were made with the knowledge that willful false statements and the like
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`are punishable by fine or imprisonment or both under 18 U.S.C. § 1001.
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`Date: October 10, 2019
`
`Thomas Ward
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`4
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