`
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`FedEx Corp.
`Petitioner
`
`V.
`
`Intellectual Ventures II LLC and Roelsis Wireless LLC,
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`Patent Owner
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`us. Patent No. 9341535
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`Declaration of Timothyr Jones
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`1 of4
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`FedEx Exhibit 1018
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`1.
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`INTRODUCTION
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`1.
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`I, Timothy .lones. submit this declaration to state my opinions on the
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`matters described below.
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`2.
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`[ am currently employed as Managing Director ofCorporate Sales at
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`FedEx Services in Pittsburgh. Pennsylvania. 1 have held this position since Eflflt}.
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`3.
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`From around lSPE until EDGE), I was employed as Vice President of
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`National Accounts at Roadway Package Systems (“RPS“) in Pittsburgh,
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`Pennsylvania. While employed as 1|v'ice President ofHational Accounts at RPS, [
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`was personally involved in the management and distribution of materials used by
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`sales professionals at RPS. Cine oi" these materials was the “RPS Multicode Ear
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`lCode Label Guide” {Ere JUGS}. hereinafter Mattie-ode.
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`4.
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`I prepared this Declaration on behalf of FedEx Corp. in connection
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`with the Petition for Inter Fortes Review of U.S. Patent No. 9,fl4?.53b, which is to
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`be filed concurrently with this Declaration.
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`IL New
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`5.
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`As the ‘Vice President of National Accounts at RPS, [ was personally
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`involved in the distribution of Mirirr‘code.
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`6.
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`Based on my personal knowledge. as explained below, Motricoo'e was
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`publicly available and widely distributed to members of the interested public at
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`least by 199?.
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`20f4
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`.-..
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`E
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`
`
`Ill. MULTrcooE
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`T.
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`Muln‘eode was a material for use by sales professionals at RPS.
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`In 199?, l and Robert Leroy at RPS coordinated about Slit-tit] sales professionals at
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`RPS. Each of these sales professional was responsible for about It} sales accounts.
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`8.
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`As part oftheir efforts, our national sales professionaEs distributed
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`materials, including Mrrhfcode, to current customers, potential customers, and
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`other industry professionals, such as those responsible for the shipping, logistics
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`and distribution of a variety of goods (at the wholesale and retail level} and in a
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`variety of fields (“industry professionals“). 1 have personal knowledge that copies
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`of Moltfcoo'e were distributed by sales professionals to current and potential
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`customers including l C Penney, Kmart, 1|atalrnart, 3M, Nordstrorn‘s, Fred Meyer,
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`and Mauriees by at least I99?
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`9.
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`Additionally, I have personal knowledge that copies of Manic-ode
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`were distributed by RPS sales professionals to current customers, potential
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`customers, and other industry professionals at trade shows and conferences by at
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`least 1997. For example, I have personal knowledge that in 199T Mafrr'code was
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`taken to and distributed at a number of trade shows and conferences, including
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`those hosted by the National Shippers Strategic Transportation Council
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`[“nasstrac“), International Mass Retail Association [now the Retail Industry
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`3of4
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`
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`Leaders Association), and some book publishers. fit Eflnft‘rcnccs or trade shows
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`in [991 a representative of RPS, such as our Vice President of Marketing Bram
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`Johnson, our 1’ ice President oFSales Edward DiSalvo, or our President Daniel
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`Sullivan, would speak at the conference or trade show, and sales professionals
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`would distribute copies of Muiricode to conference or trade show attendees. I
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`personally distributed copies of Mrrlrr'eode at such trade shows and conferences
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`in 199?.
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`it}.
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`Thus, 1 have personal knowledge that, at least by 199?, Manic-ode was
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`distributed to customers, potential customers, and other industry professionals. fly
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`at least 199?, Mulrieede was publicly available to any interested party, and RPS
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`imposed no requirement for confidentiality on those receiving copies of Malricon'e.
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`W. Concwsrus
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`l l.
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`l hereby declare that all statements made herein of my own
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`knowledge are true, and that all statements made on information and belief are
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`believed to be true and that such statements are made with the knowledge that
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`willful false statements and the like are punishable by fine or imprisonment, or
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`both, under Section lflfl] of Title 13 of the United States Code.
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`Dated1August31, EDIT
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`By:
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`f
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`Timothy Jones
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`4of4
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