ZIPIT EX. 2018, pg. 1
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`Case No. IPR2019—01568
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`Patent No. 7,894,837
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`I, RAFAEL HEREDIA, hereby declare as follows:
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`1.
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`My name is Rafael “Ralph” Heredia and I am one of the named
`
`inventors of US. Patent Nos. 7,292,870 and 7,894,837, both of which are assigned
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`to Zipit Wireless, Inc. (“Zipit”).
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`2.
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`I am a co—founder of Zipit and I am presently employed as the Vice
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`President of Business Development for Zipit.
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`3.
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`Zipit sold a first-generation instant messaging device known as the Zipit
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`Wireless Messenger and/or “Zippy,” which was launched in 2004. I understand a
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`photograph of the Zippy device has been marked as Exhibit 2019, which is a true
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`and accurate representation of the Zippy instant messaging device. Zipit also sold
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`a second—generation instant messaging device known as the Zipit Wireless Instant
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`Messenger 2 and/or “Z2,” which was launched in 2007. I understand a photograph
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`of the Z2 device has been marked as Exhibit 2020, which is a true and accurate
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`representation of the Z2 instant messaging device.
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`4.
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`Zipit’s first—generation instant messaging device, Zippy, and Zipit’s
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`second—generation instant messaging device, Z2, included the same functionality
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`with respect to instant messaging.
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`ZIPIT EX. 2018, pg. 2
`ZIPIT EX. 2018, pg. 2
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`Case No. IPR2019—01568
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`Patent No. 7,894,837
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`5.
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`I was responsible for supervising the author of the Zipit Wireless
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`Messenger Getting Started Guide and Users Guide (which I understand has been
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`marked as Exhibit 2021).
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`I also was responsible for providing the raw materials to
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`the author and proof reading the users guide. Exhibit 2021 is a true and accurate
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`copy of the Zipit Wireless Messenger Getting Started Guide and Users Guide.
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`6.
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`I was responsible for supervising the author of the Zipit Wireless
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`Messenger 2 User Guide (which I understand has been marked as Exhibit 2022). I
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`also was responsible for providing the raw materials to the author and proof
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`reading the users guide. Exhibit 2022 is a true and accurate copy of the Zipit
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`Wireless Messenger 2 Users Guide.
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`7.
`
`Claim 11 of the ’837 patent reads on both the Zipit and Z2 instant
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`messaging devices and operation. Both the Zipit and Z2 devices did the following:
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`
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`Zipit’s Zippy and Z2 Instant
`’837 Claim 11
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`Messaging_Devices And Methods
`Zipit’s Zippy and Z2 performed
`11. A method for managing wireless
`methods for managing wireless
`network access and instant messaging
`network access and instant messaging
`through a wireless access point with a
`through a wireless access point with a
`handheld instant messaging terminal
`comprising:
`handheld instant messaging terminal
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`(Zippy and Z2).
`Zipit’s Zippy and Z2 generated textual
`generating textual characters and
`characters and graphical symbols
`graphical symbols in response to
`(graphical emoticons) in response to
`manipulation of keys on a data entry
`device of a handheld instant messaging manipulation of keys on a data entry
`terminal;
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`
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`
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`ZIPIT EX. 2018, pg. 3
`ZIPIT EX. 2018, pg. 3
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`Case No. IPR2019—01568
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`Patent No. 7,894,837
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`device of a handheld instant messaging
`terminal (Zippy and Z2).
`Ex. 2020, Zippy;
`Ex. 2021, Zipit Wireless Messenger
`Getting Started Guide And Users
`Guide at 4, 5, 12, and 16;
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`Ex. 2020, Z2; and
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`displaying the generated textual
`characters and graphical symbols on a
`display of the handheld instant
`messaging terminal;
`
`Ex. 2022, Zipit Wireless Messenger 2
`User Guide at 1, 3, and 16 (Exhibit
`
`pages 1, 2, and 5).
`Zipit’s Zippy and Z2 displayed the
`generated textual characters and
`graphical symbols on a display of the
`handheld instant messaging terminal
`(Zippy and Z2). Ex. 2019, Zippy;
`Ex. 2021, Zipit Wireless Messenger
`Getting Started Guide And Users
`Guide at 4, 5, 12, and 16;
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`
`
`
`
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`generating data messages with the
`generated textual characters and
`graphical symbols in accordance with
`at least one instant messaging protocol
`that is compatible with an instant
`messaging service;
`
`Ex. 2020, Z2; and
`
`Ex. 2022, Zipit Wireless Messenger 2
`User Guide at 1, 3, and 15-17 (Exhibit
`pages 1, 2, and 5).
`Zipit’s Zippy and Z2 generated data
`messages with the generated textual
`characters and graphical symbols in
`accordance with at least one instant
`
`messaging protocol that is compatible
`with an instant messaging service.
`Ex. 2019, Zippy;
`Ex. 2021, Zipit Wireless Messenger
`Getting Started Guide And Users
`Guide at 3, 6-11,14,16, and 19;
`
`Ex. 2020, Z2; and
`Ex. 2022, Zipit Wireless Messenger 2
`User Guide at i, ii, 1, 2, 6—19, 32, and
`35 (Exhibit pages 1, 2—6, 9, and 10).
`Wirelessly transmitting the generated
`Zipit’s Zippy and Z2 Wirelessly
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`data messages to a Wireless network
`transmitted the generated data
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`ZIPIT EX. 2018, pg. 4
`ZIPIT EX. 2018, pg. 4
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`
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`access point through an Internet
`protocol communications module and
`Wireless transceiver in the handheld
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`instant messaging terminal; and
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`controlling a conversation session in
`accordance with the at least one instant
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`messaging protocol being implemented
`with a control module located Within
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`the handheld instant messaging
`terminal.
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`
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`Case No. lPR2019—01568
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`Patent No. 7,894,837
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`messages to a Wireless network access
`point through an Internet protocol
`communications module and Wireless
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`transceiver in the handheld instant
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`messaging terminal (Zippy and Z2).
`Ex. 2019, Zippy;
`EX. 2021, Zipit Wireless Messenger
`Getting Started Guide And Users
`Guide at 3,6-11,14, 16, and 19;
`
`Ex. 2020, Z2; and
`EX. 2022, Zipit Wireless Messenger 2
`User Guide at i, ii, 1, 2, 6—19, 32, and
`35 (Exhibit pages 1, 2—6, 9, and 10).
`Zipit’s Zippy and Z2 controlled a
`conversation session in accordance
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`with the at least one instant messaging
`protocol being implemented with a
`control module located Within the
`
`handheld instant messaging terminal
`(Zippy and Z2).
`EX. 2019, Zippy;
`EX. 2021, Zipit Wireless Messenger
`Getting Started Guide And Users
`Guide at 3, 6-11, 14, 16, and 19;
`
`
`
`EX. 2020, 22; and
`Ex. 2022, Zipit Wireless Messenger 2
`User Guide at i, ii, 1, 2, 6-19, 32, and
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`35 (Exhibit pages 1, 2-6, 9, and 10).
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`
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`I declare under penalty of perjury under the laws of the United States of
`
`America the foregoing is true and correct.
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`Executed this 1St day of June, 2020.
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`ZIPIT EX. 2018, pg. 5
`ZIPIT EX. 2018, pg. 5
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`ZIPIT EX. 2018, pg. 6
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