IPR2020-01176
`U.S. Patent 9,666,105
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner
`
`v.
`
`ULTRAVISION TECHNOLOGIES, LLC.,
`Patent Owner
`____________
`
`Case IPR2020-01176
`Patent 9,666,105
`____________
`
`DECLARATION OF CRENA PACHECO IN SUPPORT OF
`PETITIONER FOR INTER PARTES REVIEW OF U.S. PATENT 9,666,105
`
`I, Crena Pacheco, make the following declaration pursuant to 28 U.S.C.
`
`§1746:
`
`1.
`
`2.
`
`I am a Senior IP Paralegal at the law firm of Ropes & Gray LLP.
`
`I provide this Declaration in connection with the above-identified
`
`Inter Partes Review proceeding that is before the United States Patent and
`
`Samsung Exhibit 1008
`Samsung Elecs. Co., Ltd. v. Ultravision Techns., LLC
`IPR2020-01176
`Page 00001
`
`
`U.S. Patent 9,666,105
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner
`
`v.
`
`ULTRAVISION TECHNOLOGIES, LLC.,
`Patent Owner
`____________
`
`Case IPR2020-01176
`Patent 9,666,105
`____________
`
`DECLARATION OF CRENA PACHECO IN SUPPORT OF
`PETITIONER FOR INTER PARTES REVIEW OF U.S. PATENT 9,666,105
`
`I, Crena Pacheco, make the following declaration pursuant to 28 U.S.C.
`
`§1746:
`
`1.
`
`2.
`
`I am a Senior IP Paralegal at the law firm of Ropes & Gray LLP.
`
`I provide this Declaration in connection with the above-identified
`
`Inter Partes Review proceeding that is before the United States Patent and
`
`Samsung Exhibit 1008
`Samsung Elecs. Co., Ltd. v. Ultravision Techns., LLC
`IPR2020-01176
`Page 00001
`
`
`
`IPR2020-01176
`U.S. Patent 9,666,105
`
`Trademark Office (“USPTO”). Unless otherwise stated, the facts stated in this
`
`Declaration are based on my personal knowledge.
`
`3.
`
`Exhibit 1006 is a true and correct copy of Preliminary Construction in
`
`Ultravision Techs., LLC v. Govision, LLC, Case No. 2:18-cv-00100-JRG-RSP
`
`(E.D. Tex.) (consolidated). This document has been marked with an exhibit label
`
`and page numbers on each page. However, no alterations, other than these noted
`
`markings, have been made to this document.
`
`4.
`
`Exhibit 1007 is a true and correct copy of Patent Owner’s ’105
`
`Infringement Contentions served in Ultravision Techs., LLC v. Samsung Elecs.
`
`Co., Case No. 2:20-cv-00053-JRG-RSP (E.D. Tex.), Appendix 11. This document
`
`has been marked with an exhibit label and page numbers on each page. However,
`
`no alterations, other than these noted markings, have been made to this document.
`
`5.
`
`Exhibit 1016 is a true and correct copy of Vegas LED Screen
`
`Installation Manual 2011. This document was downloaded at my direction from
`
`https://www.vegasledscreens.com/downloads/file/26-led-screen-installation-
`
`manual-extended.html. This document has been marked with an exhibit label and
`
`page numbers on each page. However, no alterations, other than these noted
`
`markings, have been made to this document.
`
`6.
`
`Exhibit 1017 is a true and correct copy of Barco NX Series Brochure
`
`2009. This document was downloaded at my direction from
`
`-2-
`
`IPR2020-01176 Page 00002
`
`
`
`http://www.barco.com/~/media/Downloads/Brochures/2008/NX%20Series.pdf.
`
`IPR2020-01176
`U.S. Patent 9,666,105
`
`
`This document has been marked with an exhibit label and page numbers on each
`
`page. However, no alterations, other than these noted markings, have been made
`
`to this document.
`
`7.
`
`Exhibit 1018 is a true and correct copy of Barco NX Installation
`
`Manual 2010. This document was downloaded at my direction from
`
`https://cdn.hackaday.io/files/277991189352416/NX%20Rental%20installation.pdf.
`
`This document has been marked with an exhibit label and page numbers on each
`
`page. However, no alterations, other than these noted markings, have been made
`
`to this document.
`
`8.
`
`Exhibit 1019 is a true and correct copy of Louis M. Brill, Retrofitting
`
`Print Billboards with their LED Digital Counterparts, Feb. 15, 2010. This
`
`document was downloaded at my direction from
`
`http://www.signindustry.com/led/articles/2010-02-15-LB-
`
`RetrofittingPrintBillboardsToLED.php3. This document has been marked with an
`
`exhibit label and page numbers on each page. However, no alterations, other than
`
`these noted markings, have been made to this document.
`
`9.
`
`Exhibit 1020 is a true and correct copy of 2012 Watchfire “Price
`
`Watcher” Fact Sheet. This document was downloaded at my direction from
`
`http://www.uvbrand.com/pdf/Price%20Watcher%20Fact%20Sheet.pdf. This
`
`
`
`-3-
`
`IPR2020-01176 Page 00003
`
`
`
`document has been marked with an exhibit label and page numbers on each page.
`
`IPR2020-01176
`U.S. Patent 9,666,105
`
`
`However, no alterations, other than these noted markings, have been made to this
`
`document.
`
`10. Exhibit 1027 is a true and correct copy of Dominic Michael Xavier,
`
`Development of a Large Scale Flexible LED Display Matrix for the Screen
`
`Industry (Feb. 2, 2013) (Master of Engineering thesis, Queensland University of
`
`Technology). This document was downloaded at my direction from
`
`https://core.ac.uk/download/pdf/16294705.pdf. This document has been marked
`
`with an exhibit label and page numbers on each page. However, no alterations,
`
`other than these noted markings, have been made to this document.
`
`11. Exhibit 1028 is a true and correct copy of Mitsubishi Electric DLP
`
`Video Walls. This document was downloaded at my direction from:
`
`https://www.mitsubishielectric-displaysolutions.com/products/dlp-video-wall. This
`
`document has been marked with an exhibit label and page numbers on each page at
`
`the bottom right corner. However, no alterations, other than these noted markings,
`
`have been made to this document.
`
`12. Exhibit 1029 is a true and correct copy of Evan Blass, “Cowboys' new
`
`stadium to get over 20,000 square feet of video screen,” Engadget (Dec. 13, 2006).
`
`This document was downloaded at my direction from:
`
`https://www.engadget.com/2006-12-13-cowboys-new-stadium-to-get-over-20-000-
`
`
`
`-4-
`
`IPR2020-01176 Page 00004
`
`
`
`square-feet-of-video-scr.html. This document has been marked with an exhibit
`
`IPR2020-01176
`U.S. Patent 9,666,105
`
`
`label and page numbers on each page at the bottom right corner. However, no
`
`alterations, other than these noted markings, have been made to this document.
`
`13. Exhibit 1030 is a true and correct copy of Abbey Klassen, “Digital
`
`Technologies Put Time on Side of Outdoor Advertising,” AdAge (Apr. 11, 2005)
`
`(“AdAge”). This document was downloaded at my direction from:
`
`https://adage.com/article/news/digital-technologies-put-time-side-outdoor-
`
`advertising/102859. This document has been marked with an exhibit label and
`
`page numbers on each page at the bottom right corner. However, no alterations,
`
`other than these noted markings, have been made to this document.
`
`14.
`
`I understand that willful false statements and the like are punishable
`
`by fine or imprisonment, or both. If called to testify as to the truth of the matters
`
`stated herein, I could and would testify competently.
`
`15.
`
`I declare under penalty of perjury that the foregoing is true and
`
`correct. Executed this 26th day of August, 2020, in Boston, Massachusetts.
`
`
`
`
`
`
`
`
`
`
`By: /Crena Pacheco/
`Name: Crena Pacheco
`
`-5-
`
`IPR2020-01176 Page 00005
`
`
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