UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`AMAZON.COM, INC. AND AMAZON WEB SERVICES, LLC,
`Petitioner
`
`V.
`
`PERSONALIZED MEDIA COMMUNICATIONS, LLC,
`
`Patent Owner
`
`
`Case No. TBD
`
`Patent 7,801,304
`
`
`DECLARATION OF ANNEMARIE MATTHEYSE IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT 7,801,304
`
`Amazon EX. 1011
`
`IPR Petition - USP 7,801,304
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`AMAZON.COM, INC. AND AMAZON WEB SERVICES, LLC,
`Petitioner
`
`V.
`
`PERSONALIZED MEDIA COMMUNICATIONS, LLC,
`
`Patent Owner
`
`
`Case No. TBD
`
`Patent 7,801,304
`
`
`DECLARATION OF ANNEMARIE MATTHEYSE IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT 7,801,304
`
`Amazon EX. 1011
`
`IPR Petition - USP 7,801,304
`
`
`
`Declaration of Annemarie Mattheyse in support of
`Amazon IPR Petition — U.S. Pat. 7,801,304
`
`I.
`
`I, Annemarie Mattheyse, have been asked by Knobbe, Martens, Olson
`
`& Bear, LLP, counsel for Amazon.com, Inc. and Amazon Web Services, LLC
`
`(“Amazon”), to make this declaration. The following is based on my personal
`
`knowledge, as well as my expert knowledge as a French/English translator.
`
`2.
`
`I have performed this work for salaried compensation as part of the
`
`duties of my job. Landon IP is being paid $80 per hour for my services in
`
`connection with this declaration. My compensation in no way depends on the
`
`outcome of this proceeding.
`
`3.
`
`I currently work for Landon IP, Inc. as a project manager and
`
`translator. My business address is 1725 Jamieson Avenue, Alexandria, Virginia,
`
`22314.
`
`4.
`
`I am fluent in English and French, including technical terminology. I
`
`have worked two-and-a—half months at Landon IP as a translation project manager.
`
`Prior to working at Landon IP, I worked at JPD Systems, LLC of Fredericksburg,
`
`VA for two—and—a—half years as an in—house translator, editor, and project manager.
`
`I received a bachelor’s degree in French from Stellenbosch University in
`
`Stellenbosch, South Africa. I have been working as a translator of technical and
`
`general texts for nearly nine years. Based on my training and experience, I
`
`consider myself an expert as a French/English translator.
`
`5.
`
`In preparing this declaration, I considered the following materials:
`
`I
`
`
`
`Declaration of Annemarie Mattheyse in support of
`Amazon IPR Petition — U.S. Pat. 7,801,304
`
`a.
`
`b.
`
`U.S. Patent No. 4,337,483 (“Guillou”) (Exhibit 1007); and
`
`International Patent Application No. WO 80/01636 (“Guillou
`
`PCT”) (Exhibit 1010).
`
`6.
`
`I have reviewed both Guillou and Guillou PCT in their entirety,
`
`including the cover pages, the abstracts, the figures, and the specifications.
`
`7.
`
`Figures l—l0 of Guillou appear to be identical to Figures 1-10 of
`
`Guillou PCT, except that Figures 1-5 and 7-10 of Guillou have additional English
`
`annotations that are missing from the corresponding figures of Guillou PCT.
`
`8.
`
`In my opinion, the specification of Guillou is substantively identical
`
`to Guillou PCT. That is, Guillou can be said to be a proper English translation of
`
`Guillou PCT. Put another way, if I were to provide a translation of the
`
`specification of Guillou PCT in English, it would be substantively similar if not
`
`identical to the specification of Guillou.
`
`9.
`
`The following cross-reference table, showing how the specification of
`
`Guillou corresponds to the specification of Guillou PCT, was prepared by my staffl
`
`
`
`reviewed in detail by me, and found to be true by me.
`
`
`
` I Col. 1, lines 7-9
`
`lines 10-19
`
`lines 20-22
`
`lines 23-27
`
`lines 4-22
`
`lines 23-27
`
`lines 28-32
`
`
`
`Declaration of Annemarie Mattheyse in support of
`Amazon IPR Petition - U.S. Pat. 7,801,304
`
`fines 28-33
`lines 34-37
`
`lines 38-40
`
`lines 41-42
`
`lines 43-46
`
`lines 47-50
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`lines 51-53
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`lines 54-62
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`lines 63-66
`lines 67-68
`
`Col. 2, lines 1-4
`lines 5-6
`
`[_
`
`line 7
`lines 8-11
`lines 12-19
`lines 20-23
`lines 24-27
`lines 28-43
`lines 44-49
`
`lines 50-61
`
`C01. 2, line 62 - col. 3, line 17
`Col. 3, lines 18-25
`lines 26-35
`lines 36-47
`lines 48-61
`lines 62-68
`
`Col. 4, lines 1-21
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`lines 22-30
`lines 31-38
`
`lines 39-53
`
`lines 54-64
`Col. 4, line 68 — col 5. line 7
`Col. 5, lines 8-16
`lines 17-25
`lines 26-28
`lines 29-39
`fines 40-46
`lines 47-52
`
`‘fine 2, fines 1-6
`lines 7-10
`
`lines 11-13
`
`lines 14-16
`
`lines 17-20
`
`lines 21-24
`
`lines 25-27
`
`lines 28-36
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`Page 3, lines 1-4
`lines 5-6
`
`lines 7-10
`lines 11-13
`
`line 14
`lines 15-19
`lines 20-27
`lines 28-30
`Page 3, line 31 - page 4, line 3
`Page 4, lines 4-17
`lines 18-24
`
`lines 25-35
`
`Page 5, lines 1-26
`lines 27-36
`Page 6, lines 1-13
`lines 14-24
`Page 6, line 25 — page 7, line 4
`Page 7, lines 5-12
`
`’_1
`
`lines 13-35
`
`Page 8, lines 1-10
`lines 11-19
`
`lines 20-37
`
`Page 9, lines 1-12
`lines 13-22
`lines 23-32
`1 Page 9, line 33 — page 10, line 7
`1
`lines 8-10
`1
`lines 11-22
`1
`fines 23-29
`1
`fines 30-36
`
`3
`
`1
`|
`1
`
`1
`
`
`
`Declaration of Annemarie Mattheyse in support of
`Amazon IPR Petition — U.S. Pat. 7,801,304
`
`1
`
`1
`1_
`
`lines 53-60
`Col. 5, line 61 — col. 6, line 2
`Col. 6, lines 3-12
`lines 13-16
`lines 17-26
`lines 27-36
`
`lines 37-43
`
`1 Page 10, lines 1-10
`lines 11-20
`lines 21-31
`lines 32-36
`Page 12, lines 1-11
`lines 12-24
`
`lines 25-33
`
`1
`
`lines 44-66
`C01. 6, line 67 — col. 7, line 7
`(:61. 7, lines 8-42
`lines 43-63
`Col. 7, line 64 — col. 8, line 4
`Col. 8, lines 5-14 ‘
`lines 15-24
`
`lines 25-32
`lines 33-48
`lines 49-58
`
`No equivalent paragraph in the English.
`Col. 8, line 59 — col. 9, line 2
`Col. 9, lines 3-12
`No equivalent paragraph in the English,
`Col. 9, lines 15-44
`lines 48-68
`Col. 10, lines 1-36
`lines 37-66
`C61. 10, line 67 — 661. 11, line 18
`Col. 11, lines 19-35
`lines 36-51
`lines 52-61
`1 Col. 11, line 62 — col. 12, line 3
`1 C61. 12, lines 4-18
`1
`fines 19-40
`1
`lines 41-57
`1 C61. 12, line 58 — 661.13, fine 8
`Col. 13, lines 9-24
`lines 25-56
`Col. 13, line 57 — col. 14, line 19
`C61. 14, fines 20-35
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`Page 12, line 34 — page 13, line 23
`Page 13, line 24-34
`1 Page 14 - page 15 fine 7
`Page 15, lines 8-35
`Page 16, lines 1-12
`lines 13-22
`lines 23-33
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`Page 16, line 34 — page 17, line 5
`1 Page 17, lines 6-23
`lines 24-35
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`Page 18, lines 1-9
`lines 10-23
`lines 24-34
`1 Page 19, lines 1-8
`Page 19, line 9 — page 20, line 9
`Page 20, lines 10-35
`Page 21, line 1 ~ page 22, line12
`Page 22, line 13 - page 23, line 13
`1 Page 23, fines 14-33
`Page 23, line 34 — page 24, line 15
`Page 24, lines 16-30
`Page 24, line 31 - page 25, line 5
`Page 25, lines 6-16
`lines 17-34
`1 Page 26, lines 1-21
`1
`fines 22-37
`Page 27, lines 1-21
`Page 27, line 22 — page 28, line 4
`Page 28, line 5 — page 29, line 3
`Page 29, lines 4-38
`1 Page 30, lines 1-13
`
`4
`
`
`
`Declaration of Annemarie Mattheyse in support of
`Amazon IPR Petition — U.S. Pat. 7,801,304
`
`Page 32, line 8 — page 33, line 25
`
`
`Page 30, line 14 - page 31, line 3
`
`Page 31, lines 4-18
`Page 31, line 19 - page 32, line 7
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`
`lines 26-36
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`Page 34, lines 1-9
`lines 10-35
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`Page 35, lines 1-25
`Page 35, line 26 — page 36, line 2
`Page 36, lines 3-23
`Page 36, line 24 — page 37, line 4
`Page 37, lines 5-14
`lines 15-23
`Page 37, line 24 - page 38, line 27
`Page 38, line 28 — page 39, line 14
`(French patent application no.
`EN 76/27212, filed on 9/6/1976,
`referenced in French text but not
`
`in English.)
`Page 39, line 15-37
`(French patent applications nos.
`EN 75/18314 and EN 74/13136,
`
`
`
`
`
`
`
`
`
`
`
`
`
`filed on 4/16/1974, referenced in
`French text but not in English.)
`
`Page 40, lines 1-23
`(French patent application no.
`EN 76/212 referenced in French
`
`
`
`text but not in English.)
`Page 40, line 24 - pa e 41, line 9
`Page 41, line 10-19
`1 Page 41, line 20 — page 42, line 5
`1 Page 42, lines 6-31
`Page 42, line 32 — page 43, line 27
`Page 43, line 28 —— page 44, line 6
`No eguivalent in the French text.
`
`
`
`
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`lines 36-62
`Col. 14, line 63 — col. 15, line 10
`Col. 15, lines 11-35
`Col. 15, line 36 — col. 16, line 17
`lines 18-29
`
`lines 30-38
`lines 39-62
`
`Col. 16, line 63 - col. 17, line18
`Col. 17, lines 19-33
`lines 34-52
`lines 53-68
`| Col. 18, lines 1-9
`L
`lines 10-18
`
`lines 19-55
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`Col. 18, line 56 - col. 19, line 3
`
`Col. 19, lines 4-22
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`lines 23-40
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`lines 41-63
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`Col. 19, line 64 — col. 20, line 5
`Col. 20, lines 6-27
`lines 28-52
`Col. 20, line 53 - col. 21, line 14
`
`C01. 21, lines 15-28
`Col. 21, lines 29-32
`
`
`
`Declaration of Annemarie Mattheyse in support of
`Amazon IPR Petition — U.S. Pat. 7,801,304
`
`10.
`
`I declare under penalty of perjury under the laws of the United States
`
`of America that the foregoing is true and correct.
`
`September 11, 2014
`
`By:
`
`
`reek/LM f»M«~—~)
`Annemarie Matthey e
`
`18844411
`
`
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