I, Ron Britvich, make the following Declaration pursuant to 28 U.S.C. § 1746:
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`1. I currently reside at 2020 Coffer Ln, Placerville, CA, 95667. I am providing
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`this Declaration in connection with the pending Inter Partes review
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`proceedings currently instituted against certain U.S. Patents owned by
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`Worlds, Inc.
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`2. Unless otherwise stated, the facts presented in this Declaration are based on
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`my personal knowledge.
`
`3. I am currently retained as a consultant to Worlds, Inc. (formerly Knowledge
`
`Adventure Worlds), the patent owner of the patents-at-issue in these
`
`proceedings. I am being paid shares of company stock for my work. My
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`payment does not depend upon the outcome in these cases.
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`4. I joined Knowledge Adventure Worlds on January 30, 1995. I worked
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`primarily out of my home in Carlsbad, California while developing a
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`customizable virtual environment program known as both ActiveWorlds and
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`AlphaWorld.
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`5. During my employment with Knowledge Adventure Worlds, I occasionally
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`traveled to San Francisco, California to collaborate with the team developing
`
`the Worlds Chat program, and on occasion members of that team traveled to
`
`my home to collaborate with me. Additionally, my code for ActiveWorlds
`
`was uploaded to the company’s servers, and so the Worlds Chat team was
`
`IPR2015-01264, -01268, -01269, -01319, -01321, -01325
`EX. 2019
`Page 1 of 7
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`
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`1. I currently reside at 2020 Coffer Ln, Placerville, CA, 95667. I am providing
`
`this Declaration in connection with the pending Inter Partes review
`
`proceedings currently instituted against certain U.S. Patents owned by
`
`Worlds, Inc.
`
`2. Unless otherwise stated, the facts presented in this Declaration are based on
`
`my personal knowledge.
`
`3. I am currently retained as a consultant to Worlds, Inc. (formerly Knowledge
`
`Adventure Worlds), the patent owner of the patents-at-issue in these
`
`proceedings. I am being paid shares of company stock for my work. My
`
`payment does not depend upon the outcome in these cases.
`
`4. I joined Knowledge Adventure Worlds on January 30, 1995. I worked
`
`primarily out of my home in Carlsbad, California while developing a
`
`customizable virtual environment program known as both ActiveWorlds and
`
`AlphaWorld.
`
`5. During my employment with Knowledge Adventure Worlds, I occasionally
`
`traveled to San Francisco, California to collaborate with the team developing
`
`the Worlds Chat program, and on occasion members of that team traveled to
`
`my home to collaborate with me. Additionally, my code for ActiveWorlds
`
`was uploaded to the company’s servers, and so the Worlds Chat team was
`
`IPR2015-01264, -01268, -01269, -01319, -01321, -01325
`EX. 2019
`Page 1 of 7
`
`
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`able to view my code. I did not personally work on Worlds Chat, but
`
`because ActiveWorlds and Worlds Chat were both virtual world programs
`
`where users could interact with other users, the Worlds Chat team
`
`encountered some of the same problems I encountered in the development of
`
`ActiveWorlds, and we discussed possible solutions for overcoming these
`
`problems.
`
`6. The team developing the Worlds Chat program included David Leahy,
`
`Judith Challinger, Mitra Ardon, and Bo Adler, and other programmers
`
`working under them.
`
`7. During my meetings with this Worlds Chat team, I learned that this team
`
`developed a solution to the potential crowding problem that can occur in a
`
`virtual world. They described to me a procedure for limiting the amount of
`
`data transmitted from the server down to a particular client. Due to the
`
`reduced data being sent to this particular client, the client did not have to
`
`process as much data and this obviously reduced the processing burden on
`
`the client. Additionally, at the time, networks were slow compared to 2016
`
`standards. By reducing the data transmitted to a particular client, the time
`
`required to transmit updates on the virtual world also was reduced. The
`
`tradeoff with this solution was that the processing burden on the server
`
`IPR2015-01264, -01268, -01269, -01319, -01321, -01325
`EX. 2019
`Page 2 of 7
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`
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`increased, since the server had to determine which updates to transmit to
`
`each client.
`
`8. During my visits to Worlds headquarters in San Francisco, I observed a
`
`demo of the Worlds Chat program, which allowed multiple avatars
`
`associated with different clients to interact with each other both visually and
`
`textually. Specifically, the avatars could see each other in the virtual world,
`
`and move relative to each other and see the other avatar’s change in position
`
`and orientation. Also, the avatars could communicate with each other via a
`
`typing “chat” function.
`
`9. The demo was run on personal computers, acting as clients, connected to a
`
`server overseeing the virtual world. The view displayed on each personal
`
`computer was a perspective or point of view of an avatar associated with that
`
`particular personal computer. This demo was shown to me before the official
`
`public release of the Worlds Chat program.
`
`10. My recollection is that from early April 1995 until April 25, 1995, both
`
`ActiveWorlds and Worlds Chat software were available for download
`
`through an anonymous ftp site, though Worlds did not officially and publicly
`
`offer the Worlds Chat software for download by the public until April 25,
`
`1995.
`
`IPR2015-01264, -01268, -01269, -01319, -01321, -01325
`EX. 2019
`Page 3 of 7
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`
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`11. On April 25, 1995, Worlds, Inc. publicly announced the availability of
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`Worlds Chat for download from Worlds’ webpage (kaworlds.com). This
`
`announcement was made by press release through Business Wire.
`
`12. Attached as Exhibit 2021 is a true and accurate copy of the Press Release
`
`issued by Worlds, Inc. on April 25, 1995.
`
`13. To the best of my recollection, the statements in the Press Release were
`
`accurate at the time they were made.
`
`14. As I explained above, during my employment with Worlds, Inc. beginning
`
`in January 1995, I worked occasionally with the inventors of the patents-at-
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`issue in these inter partes review proceedings. I also observed working
`
`demonstrations of their Worlds Chat program, and learned how they
`
`implemented certain solutions including their “crowd control” feature.
`
`15. In 2010, I received copies of archived code from the CEO of Worlds, Inc.,
`
`Thom Kidrin.
`
`16. Mr. Kidrin also asked me, in connection with my consulting work for
`
`Worlds, Inc., to review this code for certain features.
`
`17. Based on his instructions, I reviewed both client-side and server-side code.
`
`18. Based on my review, I submit the following conclusions about client-side
`
`code:
`
`IPR2015-01264, -01268, -01269, -01319, -01321, -01325
`EX. 2019
`Page 4 of 7
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`
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`a. I inspected the FROBVPLA.CPP C++ code module that determines
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`what objects (or portions thereof) are visible to a client-user according
`
`to the associated avatar’s field of view. A true and accurate copy of
`
`this code module is provided as exhibit 2034.
`
`b. To the extent that the claims of the patents-at-issue require a client to
`
`establish a field of view of an avatar, and to display the virtual world
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`from that field of view (including the objects or other avatars in that
`
`field of view), this code module performs the same function.
`
`c. This code was used in Worlds Chat clients.
`
`d. The copyright of this code is from 1994, and therefore was written
`
`and implemented before April 11, 1995.
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`19. Based on my review, I submit the following conclusions about server-side
`
`code:
`
`a. The Worlds Chat server repository was created on October 11, 1995.
`
`That repository includes a CHANGELOG with entries back to March
`
`27, 1995.
`
`b. Based on the CHANGELOG of the server-side code, the Worlds Chat
`
`programming team wrote and logged in code to perform the step of
`
`the server sending selected positional updates to each client.
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`IPR2015-01264, -01268, -01269, -01319, -01321, -01325
`EX. 2019
`Page 5 of 7
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`c. On April 11, 1995, the CHANGELOG entry indicates that the server
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`implemented crowd-control server-side filtering using the distances
`
`between users’ avatars. A true and accurate copy of this
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`CHANGELOG is attached as Ex. 2036.
`
`d. This code was included in the RSRoom.cc code, attached as Ex. 2035.
`
`This code is described as a method that “returns a list of m Users that
`
`are “close” to the given location.”
`
`e. It is consistent with the business habits that a programmer who has
`
`written code and recorded it in a CHANGELOG has already compiled
`
`the code and tested its function.
`
`f. Therefore, I believe that the appearance of this note in the change log
`
`indicates that the server sending selected positional updates based on
`
`location, rather than all positional updates, to a client was
`
`implemented in Worlds Chat no later than April 11, 1995.
`
`20. In 2008-2009, I actively spent about six months searching for prior art that
`
`would potentially invalidate the Worlds patents-at-issue. I contacted the
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`Article One Partners organization in an attempt to win the $50,000.00
`
`bounty that they offered for invalidating prior art. However, Article One
`
`Partners rejected my attempts, and I became convinced that the Worlds
`
`patents are solid.
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`IPR2015-01264, -01268, -01269, -01319, -01321, -01325
`EX. 2019
`Page 6 of 7
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`
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`21. I make this declaration of my own personal knowledge, and declare under
`
`penalty of perjury under the laws of the United States of America that the
`
`foregoing is true and correct.
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`Executed on this 14th day of March, 2016, at Placerville, CA.
`
`
`
`_________________________
`
`Ron Britvich
`
`IPR2015-01264, -01268, -01269, -01319, -01321, -01325
`EX. 2019
`Page 7 of 7
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