`__________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________
`
`EMC CORPORATION,
`
`Petitioner,
`
`v.
`
`INTELLECTUAL VENTURES II, LLC,
`
`Patent Owner
`__________________________________
`
`Case No. IPR2016-01106
`U.S. Patent No. 6,516,442
`__________________________________
`
`DECLARATION OF BRIDGET A. SMITH IN SUPPORT OF
`PATENT OWNER’S PRELIMINARY RESPONSE TO PETITION
`
`Page 1 of 3
`
`INTELLECTUAL VENTURES EX. 2010
`EMC v. Intellectual Ventures
`IPR2016-01106
`
`
`
`IPR2016-01106
`EMC v. Intellectual Ventures
`
`I, Bridget A. Smith, do hereby declare:
`
`1.
`
`I am an attorney at the law firm of Knobbe, Martens, Olson & Bear
`
`LLP and serve as counsel for Patent Owner Intellectual Ventures II, LLC (“IV”). I
`
`submit this declaration in support of IV’s Preliminary Response. I am over twenty-
`
`one years of age and not under any legal disability. I have personal knowledge of
`
`the following facts.
`
`2.
`
`Exhibit 2002 is a copy of an electronic document entitled “Gigaplane-
`
`XB: Extending the Ultra Enterprise Family.” Exhibit 2003 is a copy of the Internet
`
`web page https://people.eecs.berkeley.edu/~culler/hoti97/.
`
`3.
`
`There is a heading in Exhibit 2003 entitled “Friday August 22, 1997.”
`
`Under that heading, there is a subheading entitled “9:30-10:30 Symmetric
`
`Multiprocessors.” Under that subheading, there is an entry entitled “A Uniform-
`
`Memory-Access Interconnect for a Very Large SMP System.” There is a hyperlink
`
`entitled “postscript” next to that entry. Clicking on the hyperlink navigates to the
`
`electronic document corresponding to Exhibit 2003.
`
`4.
`
`Exhibit 2004 is a copy of pages 4.6.6–1 through 4.6.1–8 of an
`
`electronic document entitled “JEDEC Standard No. 21–C.” Exhibit 2005 is a copy
`
`of an Internet web page showing the search results for “DIMM” on the Internet
`
`website www.jedec.org. The second entry shows a heading entitled “278 Pin
`
`Buffered SDRAM DIMM MODULE 4.6.1” dated June 1997. There is a hyperlink
`
`-1-
`
`Page 2 of 3
`
`
`
`IPR2016-01106
`EMC v. Intellectual Ventures
`
`entitled “Download MODULE 4.6.1 (/sites/default/files/docs/4_06_01.PDF)”
`
`under that heading. Clicking on the hyperlink navigates to the electronic document
`
`corresponding to Exhibit 2005.
`
`5.
`
`In signing this declaration, I understand that the declaration will be
`
`filed as evidence in a contested case before the PTAB. I acknowledge that I may
`
`be subject to cross examination in the case and that cross examination will take
`
`place within the United States. If cross examination is required of me, I will
`
`appear for cross examination within the United States during the time allotted for
`
`cross examination.
`
`6.
`
`I hereby declare that all statements made herein of my own
`
`knowledge are true and that all statements made on information and belief are
`
`believed to be true; and further that these statement were made with the knowledge
`
`that willful false statements and the like so made are punishable by fine or
`
`imprisonment, or both, under Section 1001 of Title 18 of the United States Code
`
`and that such willful false statement may jeopardize the validity of the application
`
`or any patent issued thereon.
`
`
`
`Dated: August 31, 2016
`
`
`24060624
`
`By:
`
`
`
`/Bridget A. Smith/
`Bridget A. Smith
`
`
`
`
`
`-2-
`
`Page 3 of 3
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