`Patent 8,717,758
`Declaration of Robert Humphrey
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`ACCO Brands Corporation and
`ACCO Brands USA LLC
`Petitioners
`
`v.
`
`Think Products, Inc.
`Patent Owner
`
`_______________
`
`Case IPR2015-01146
`Patent 8,717,758
`_______________
`
`DECLARATION OF ROBERT HUMPHREY
`
`Ex. 1015 - Page 1 of 4
`
`ACCO Brands
`Exhibit 1015
`ACCO Brands v. Think Products
`IPR2015-01152
`
`
`
`I, Robert Humphrey, declare as follows:
`
`1.
`
`From 1994 to present, I have been employed by ACCO Brands
`
`Corporation and Kensington (which is part of ACCO Brands Corporation) and
`
`have held various positions of increasing responsibility concerning marketing and
`
`product management. My responsibilities have generally included managing
`
`marketing and sales activities, such as overseeing marketing and product
`
`development initiatives and managing the expense budgets and personnel required
`
`to support such initiatives.
`
`2.
`
`From 2009 to 2011, I held the title of Director – Security Products,
`
`Global Business for Kensington. My responsibilities during this time included
`
`working with development and operational teams to launch the ClickSafe® line of
`
`computer lock products.
`
`3.
`
`Kensington began the development of the ClickSafe Keyed Laptop
`
`Lock, the first of the ClickSafe line of computer lock products, in 2009 and
`
`officially launched it on October 12, 2010.
`
`4.
`
`Kensington developed a ClickSafe website to promote the ClickSafe
`
`line of computer lock products, and this website was made available to the public
`
`at the URL http://www.clickittokeepit.comon October 12, 2010. This website
`
`contained a link to a ClickSafe product video (Ex. 1013) demonstrating the use
`
`and functionality of the ClickSafe® Keyed Laptop Lock. As corroborated by the
`
`Ex. 1015 - Page 2 of 4
`
`
`
`Internet Archive, the ClickSafe website was continuously available to the public
`
`from the launch date until at least September 3, 2011.
`
`5.
`
`Ex. 1016 and Ex. 1017 are screenshots of the Internet Archive
`
`(http://web.archive.org) snapshots, taken on October 16, 2010 and September 3,
`
`2011, respectively, of the ClickSafe website homepage
`
`(http://www.clickittokeepit.com). These two exhibits correctly depict the
`
`homepage of ClickSafe website as of these two dates, except that the link to the
`
`ClickSafe product video is not active on these archive pages, although those links
`
`were active to launch the linked video during the time that the website was in
`
`operation (from October 12, 2010 to at least September 3, 2011).
`
`6.
`
`The first snapshot of the ClickSafe website taken by the Internet
`
`Archive was on October 16, 2010 as shown in Ex. 1016. This is consistent with my
`
`recollection of the ClickSafe website first being made available to the public a few
`
`days earlier, on October 12, 2010.
`
`7.
`
`The ClickSafe product video is also available on YouTube at the
`
`URL https://www.youtube.com/watch?v=CgdVMaOeNro, and has been available
`
`from at least November 29, 2010 to the present.
`
`8.
`
`Ex. 1018 is a screenshot of the current web page from YouTube that
`
`contains the ClickSafe product video (Ex. 1013).
`
`2
`
`Ex. 1015 - Page 3 of 4
`
`
`
`9.
`
`Ex. 1013 is a true and correct copy of the ClickSafe product video
`
`that has been continuously available to the public through the ClickSafe website
`
`and/or YouTube since October 12, 2010.
`
`10.
`
`Ex. 1014 is a true and correct depiction of still frames from the
`
`ClickSafe product Video (Ex. 1013), with red annotations added.
`
`11.
`
`All statements made herein of my own knowledge are true; all
`
`statements made on information and belief are believed to be true; and these
`
`statements were made with the knowledge that willful false statements and the like
`
`are punishable by fine or imprisonment or both under 18 U.S.C. § 1001.
`
`Date: April 30, 2015
`
`Robert Humphrey
`
`
`
`
`Ex. 1015 - Page4 of4
`
`Ex. 1015 - Page 4 of 4
`
`
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