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`PATENT TRIAL AND APPEAL BOARD
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`DIGITAL CHECK CORP. d/b/a ST IMAGING
`Petitioner
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`v.
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`E-IMAGEDATA CORP.
`Patent Owner
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`_____________________
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`CASE: IPR2017-00178
`U.S. PATENT NO. 9,179,019
`_____________________
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`DECLARATION OF PHILIP G. BARBONI
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`1
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`DIGITAL CHECK CORP. EXHIBIT 1010
`Page 1 of 6
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`1.
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`2.
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`I, Philip G. Barboni, do hereby declare and say:
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`I am over the age of twenty-one (21) and competent to make this
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`declaration. I am also qualified to give testimony under oath. The facts listed
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`below are within my personal knowledge.
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`3.
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`I am a consultant for Digital Check Corp. (“Digital Check”). I was
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`employed by Digital Check from 1989 to May of 2016.
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`4.
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`In 2002, Image Capture Technologies (ICT) located in Rancho
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`Cucamonga, California, was a wholly owned subsidiary of Digital Check. ICT
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`was a contract manufacturing company that created imaging products for a number
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`of companies including Minolta and Canon.
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`5.
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`I was asked to review a document marked Ex. 1009. Ex. 1009 is a
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`parts manual for the UC-6 universal microfilm carrier, specifically for the 6E, 6EC,
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`and 6ECM models having parts numbers 210000-01, -02, and -03, respectively.
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`These UC-6 models were designed to work universally with reader-printers from
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`various companies such as Minolta and Canon.
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`6.
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`Ex. 1009 was created by ICT, and I was the author of this document.
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`Ex. 1009 was prepared and maintained in the ordinary course of ICT business. In
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`the ordinary course of ICT business, Ex. 1009 was published to ICT’s distributors
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`for the UC-6 product, including Minolta and Canon. Ex. 1009 was not marked
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`confidential in any way and thus available to others outside of ICT. The listed
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`2
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`DIGITAL CHECK CORP. EXHIBIT 1010
`Page 2 of 6
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`copyright date on Page 1 of Ex. 1009 is 2002. In general, at ICT, we tried to use
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`copyright dates that reflected the actual dates of availability of particular versions
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`of our manuals.
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`7.
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`It is my recollection that this version of Ex. 1009 was available at
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`least by the end of 2002. The copyright date on Ex. 1009 confirms this
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`recollection. Thus, it is my recollection that Ex. 1009 was published in 2002 and
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`was distributed with the UC-6 products in 2002. This comports with my
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`recollection that these three UC-6 models also shipped in 2002.
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`8.
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`On these UC-6 models, the upper glass opens automatically for
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`insertion of microforms when the handle is pulled out. On page 19 of Ex. 1009 the
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`handle is labeled 3 and the upper glass is labeled 1. When the handle is pulled
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`forward, a lever at the back of the upper glass strikes a ramp which forces the glass
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`open. I have reproduced the figures on pages 4 and 19 of Ex. 1009 below and have
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`colored the lever in green and the ramps in red:
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`3
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`DIGITAL CHECK CORP. EXHIBIT 1010
`Page 3 of 6
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`4
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`DIGITAL CHECK CORP. EXHIBIT 1010
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`Page 4 of 6
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`DIGITAL CHECK CORP. EXHIBIT 1010
`Page 4 of 6
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`9.
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`I declare that all statements made of my own knowledge are true and
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`that all statements made on information and belief are believed to be true, and that
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`these statements were made with the knowledge that willful false statements and
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`the like are punishable by fine or imprisonment, or both under section 1001 of Title
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`18 of the United States Code.
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`5
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`DIGITAL CHECK CORP. EXHIBIT 1010
`Page 5 of 6
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`Philip G. Barboni
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`DIGITAL CHECK CORP. EXHIBIT 1010
`Page 6 of 6
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