`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________
`
`
`NINTENDO CO., and NINTENDO OF AMERICA INC.,
`Petitioners
`
`v.
`
`ANCORA TECHNOLOGIES, INC.,
`Patent Owner
`__________
`
`Case IPR2021-01338
`Patent No. 6,411,941
`______________
`
`ROKU, INC. and VIZIO, INC.,
`Petitioners,
`
`v.
`
`ANCORA TECHNOLOGIES, INC.,
`Patent Owner.
`__________
`
`Case IPR2021-01406
`U.S. Patent No. 6,411,941 B1
`
`
`
`
`DECLARATION OF MIKI MULLOR
`
`
`THIRD-PARTY CONFIDENTIAL - PARTY ACCESS LIMITED
`Page 1
`
`IPR2021-01406
`ANCORA EX2030
`
`
`
`THIRD-PARTY CONFIDENTIAL - PARTY ACCESS LIMITED
`
`
`IPR2021-01338 and IPR20211406
`U.S. Pat. No. 6,411,941
`
`
`I, Miki Mullor, hereby declare as follows:
`
`1. I am making this declaration relating to papers to be submitted with the
`
`Patent Owner Response in the Inter Partes review of U.S. Patent No.
`
`6,411,941 (“the ’941 patent”) having case numbers IPR2021-01138 and
`
`IPR2021-01406.
`
`2. I am the founder of Ancora Technologies, Inc. (“Ancora”) and have been
`
`the 100 percent shareholder of Ancora since its inception.
`
`3. Exhibit 2027 is a true and correct copy of a Joint Press Release jointly
`
`created and released by Ancora and American Megatrends Inc. (“AMI”) on
`
`or about February 14, 2005. The Joint Press Release has been maintained by
`
`Ancora in its normal course of business as a business record and is publicly
`
`available at https://www.webwire.com/ViewPressRel.asp?aId=1465.
`
`4. The Joint Press Release references Ancora’s Platform Security Anchor
`
`(“PSA”) technology. Ancora developed this software jointly with AMI
`
`between 2004 and 2005 to implement the technology claimed in the ’941
`
`patent. More specifically, the PSA software included a software element that
`
`operated on the OS of the device to set up a verification structure (including
`
`at least one license record) in erasable, non-volatile memory of the device’s
`
`BIOS. The PSA software also included a software element that verified a
`
`Page 2 of 4
`
`THIRD-PARTY CONFIDENTIAL - PARTY ACCESS LIMITED
`Page 2
`
`IPR2021-01406
`ANCORA EX2030
`
`
`
`THIRD-PARTY CONFIDENTIAL - PARTY ACCESS LIMITED
`
`
`IPR2021-01338 and IPR20211406
`U.S. Pat. No. 6,411,941
`
`program residing in the device’s volatile memory by using at least the
`
`verification structure in the BIOS and acting on the program according to
`
`the verification.
`
`5. Exhibits 2029 and 2031 are true and correct copies of license agreements
`
`reached between Ancora and respective third-party companies. These
`
`agreements have been maintained by Ancora in its normal course of business
`
`as business records.
`
`6. Exhibit 2032 is a redacted version of a license agreement reached between
`
`Ancora and a third-party company. The unredacted version of the agreement
`
`has been maintained by Ancora in its normal course of business as a business
`
`record.
`
`7.
`
`
`
`
`
`
`
`
`
`8. I hereby declare under penalty of perjury that all statements made herein of
`
`my own knowledge are true, and that all statements made herein on
`
`information and belief are believed to be true.
`
`9. I hereby acknowledge that any willful false statement made in this
`
`Page 3 of 4
`
`THIRD-PARTY CONFIDENTIAL - PARTY ACCESS LIMITED
`Page 3
`
`IPR2021-01406
`ANCORA EX2030
`
`
`
`THIRD-PARTY CONFIDENTIAL - PARTY ACCESS LIMITED
`
`
`IPR2021-01338 and IPR20211406
`U.S. Pat. No. 6,411,941
`
`declaration is punishable under 18 U.S.C. § 1001 by fine or imprisonment
`
`of not more than five (5) years, or both.
`
`
`
`Executed on: ___________
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`_________________________________
`
`Miki Mullor
`
`Page 4 of 4
`
`THIRD-PARTY CONFIDENTIAL - PARTY ACCESS LIMITED
`Page 4
`
`IPR2021-01406
`ANCORA EX2030
`
`
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