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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`______________________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________________
`
`
`EARLY WARNING SERVICES, LLC
`Petitioner
`
`v.
`
`WEPAY GLOBAL PAYMENTS LLC
`Patent Owner
`
`_______________________
`
`
`
`Patent No. D. 930,702 S
`Issue Date: Sep. 14, 2021
`Title: DISPLAY SCREEN PORTION WITH
`ANIMATED GRAPHICAL USER INTERFACE
`
`_______________________
`
`Case No. PGR2022-00031
`____________
`
`
`DECLARATION OF KATHLEEN R. GEYER
`
`1
`
`Samsung, Exh. 1033, p. 1
`
`
`
`
`
`I, Kathleen R. Geyer, declare as follows:
`
`1. My name is Kathleen R. Geyer. I am an associate with Kilpatrick
`
`Townsend & Stockton LLP, the law firm that represents Petitioner Early Warning
`
`Services, LLC. I am over the age of twenty-one and competent to make this
`
`declaration based on my personal knowledge.
`
`2.
`
`On March 23, 2022, I emailed DCS Synthesis Pte Ltd. at the email
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`address listed on their website: possales@synthesis.bz requesting their assistance
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`in providing an authentication declaration for the YouTube video:
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`https://www.youtube.com/watch?v=bc84sn1xTRc. On March 29, 2022, I sent a
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`follow-up email. I received no response to either email.
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`3.
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`On March 23, 2022, I contacted DCS Synthesis Pte Ltd. through their
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`contact form at https://www.synthesis.bz/contact-us/ requesting their assistance in
`
`providing an authentication declaration for the YouTube video:
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`https://www.youtube.com/watch?v=bc84sn1xTRc. I did not receive any follow-up
`
`communications regarding this request.
`
`4.
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`On March 23, 2022, I sent a LinkedIn message to Jimmy Teo, who
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`lists himself as the Group CEO at DCS SYNTHESIS PTE LTD. I did not receive a
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`response to my LinkedIn message.
`
`
`
`2
`
`Samsung, Exh. 1033, p. 2
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`
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`5.
`
`On March 23, 2022, I emailed the New York office of the Monetary
`
`Authority of Singapore at the email address listed on their website:
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`newyorkrep@mas.gov.sg requesting their assistance in providing an authentication
`
`declaration for the YouTube video:
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`https://www.youtube.com/watch?v=bc84sn1xTRc. On March 29, 2022, I sent a
`
`follow-up email. I received no response to either email.
`
`6.
`
`On March 22, 2022, I emailed Google’s Conflict Waivers to request a
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`declaration from a YouTube custodian of records to confirm the date each video
`
`was posted and made publicly available. On April 1, 2022, a Google employee
`
`responded stating that “YouTube won’t perform the request voluntarily, a
`
`subpoena is required.”
`
`7.
`
`Attached as Exhibit 1005 to the Petition is a true and correct copy of
`
`screen captures of the YouTube video
`
`https://www.youtube.com/watch?v=1VmJm9imBp4&t=3s taken at every second of
`
`the video.
`
`8.
`
`Attached as Exhibit 1006 to the Petition is a true and correct copy of
`
`the screen captures of the YouTube video
`
`https://www.youtube.com/watch?v=bc84sn1xTRc taken at every second of the
`
`video. Screen captures were obtained using MS Word’s Picture Format Sharpen
`
`Tool. Attached as Exhibit 1072 to the Petition is a true and correct copy of the
`
`
`
`3
`
`Samsung, Exh. 1033, p. 3
`
`
`
`YouTube video https://www.youtube.com/watch?v=bc84sn1xTRc captured using
`
`Camtasia 2020.
`
`9.
`
`Attached as Exhibit 1007 to the Petition is a true and correct copy of
`
`the screen captures of the YouTube video
`
`https://www.youtube.com/watch?v=tDqvQFJB8GA taken at every second of the
`
`video. Attached as Exhibit 1073 to the Petition is a true and correct copy of the
`
`YouTube video https://www.youtube.com/watch?v=bc84sn1xTRc captured using
`
`Camtasia 2020.
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`10. Attached as Exhibit 1048 to the Petition is a true and correct copy of
`
`the screen captures of the YouTube video
`
`https://www.youtube.com/watch?v=djNDc7m9YoI&t=55s taken at every second
`
`of the video. Attached as Exhibit 1074 to the Petition is a true and correct copy of
`
`the YouTube video https://www.youtube.com/watch?v=bc84sn1xTRc captured
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`using Camtasia 2020.
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`11. Attached as Exhibit 1009 to the Petition is a true and correct copy of
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`the Wayback Machine page:
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`https://web.archive.org/web/20200331192535/https:/www.mas.gov.sg/developmen
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`t/e-payments/sgqr. This page contains an embedded YouTube video titled “SGQR
`
`– Singapore Quick Response Code.” When I click to play the video on the
`
`
`
`4
`
`Samsung, Exh. 1033, p. 4
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`
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`Wayback Machine page, the video loads, displaying the following page (which is
`
`annotated as noted below):
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`
`
`When I click on the YouTube link to view this video on YouTube (circled in red),
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`the Wayback Machine notes that it has not archived the URL:
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`https://www.youtube.com/watch?v=1VmJm9imBp4&feature=emb_logo. See
`
`https://web.archive.org/web/20200331192536/https://www.youtube.com/watch?v=
`
`1VmJm9imBp4&feature=emb_logo. This link is identical to the link for Ex. 1005,
`
`except for the “&feature-emb_logo,” but directs to the same YouTube page when
`
`entered into the URL bar on a browser.
`
`
`
`5
`
`Samsung, Exh. 1033, p. 5
`
`
`
`12. Attached at Exhibit 1050 to the Petition is a true and correct copy of
`
`the Complaint filed in Wepay Global Payments LLC v. Amazon.com, Inc., No.
`
`1:22-cv-01061 (N.D. Ill.).
`
`13. Attached as Exhibit 1051 to the Petition is a true and correct copy of
`
`Exhibit 2 to the Complaint filed in Wepay Global Payments LLC v. Amazon.com,
`
`Inc., No. 1:22-cv-01061 (N.D. Ill.).
`
`14. Attached as Exhibit 1052 to the Petition is a true and correct copy of
`
`the Complaint filed in Wepay Global Payments LLC v. Apple Inc., No. 6:22-cv-
`
`00223 (W.D. Tex.).
`
`15. Attached as Exhibit 1053 to the Petition is a true and correct copy of
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`Exhibit 3 to the Complaint filed in Wepay Global Payments LLC v. Apple Inc., No.
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`6:22-cv-00223 (W.D. Tex.).
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`16. Attached as Exhibit 1054 to the Petition is a true and correct copy of
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`the Complaint filed in Wepay Global Payments LLC v. Bank of America, N.A.,
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`1:2022-cv-00105 (N.D. Ill.).
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`17. Attached as Exhibit 1055 to the Petition is a true and correct copy of
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`Exhibit 2 to the Complaint filed in Wepay Global Payments LLC v. Bank of
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`America, N.A., 1:2022-cv-00105 (N.D. Ill.).
`
`
`
`6
`
`Samsung, Exh. 1033, p. 6
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`
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`18. Attached as Exhibit 1056 to the Petition is a true and correct copy of
`
`the Complaint filed in Wepay Global Payments LLC v. JPMorgan Chase Bank,
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`N.A., 1:22-cv-00103 (N.D. Ill.).
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`19. Attached as Exhibit 1057 to the Petition is a true and correct copy of
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`Exhibit 2 to the Complaint filed in Wepay Global Payments LLC v. JPMorgan
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`Chase Bank, N.A., 1:22-cv-00103 (N.D. Ill.).
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`20. Attached as Exhibit 1058 to the Petition is a true and correct copy of
`
`the Complaint filed in Wepay Global Payments LLC v. McDonald's Corporation,
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`1:22-cv-01064 (N.D. Ill.).
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`21. Attached as Exhibit 1059 to the Petition is a true and correct copy of
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`Exhibit 2 the Complaint filed in Wepay Global Payments LLC v. McDonald's
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`Corporation, 1:22-cv-01064 (N.D. Ill.).
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`22. Attached as Exhibit 1060 to the Petition is a true and correct copy of
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`the Complaint filed in Wepay Global Payments LLC v. PayPal, Inc., 6:21-cv-
`
`01094 (W.D. Tex.).
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`23. Attached as Exhibit 1061 to the Petition is a true and correct copy of
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`Exhibit 3 to the Complaint filed in Wepay Global Payments LLC v. PayPal, Inc.,
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`6:21-cv-01094 (W.D. Tex.).
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`
`
`7
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`Samsung, Exh. 1033, p. 7
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`
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`24. Attached as Exhibit 1062 to the Petition is a true and correct copy of
`
`the Complaint filed in Wepay Global Payments LLC v. PNC Bank, N.A., 1:21-cv-
`
`05052 (N.D. Ill.).
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`25. Attached as Exhibit 1063 to the Petition is a true and correct copy of
`
`Exhibit 2 to the Complaint filed in Wepay Global Payments LLC v. PNC Bank,
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`N.A., 1:21-cv-05052 (N.D. Ill.).
`
`26. Attached as Exhibit 1064 to the Petition is a true and correct copy of
`
`the Complaint filed in Wepay Global Payments LLC v. Samsung Electronics Co.,
`
`Ltd. et al., 6:21-cv-01095 (W.D. Tex.).
`
`27. Attached as Exhibit 1065 to the Petition is a true and correct copy of
`
`Exhibit 3 to the Complaint filed in Wepay Global Payments LLC v. Samsung
`
`Electronics Co., Ltd. et al., 6:21-cv-01095 (W.D. Tex.).
`
`28. Attached as Exhibit 1066 to the Petition is a true and correct copy of
`
`the Complaint filed in Wepay Global Payments LLC v. Tesla, Inc., 6:22-cv-00224
`
`(W.D. Tex.).
`
`29. Attached as Exhibit 1067 to the Petition is a true and correct copy of
`
`Exhibit 3 to the Complaint filed in Wepay Global Payments LLC v. Tesla, Inc.,
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`6:22-cv-00224 (W.D. Tex.).
`
`
`
`8
`
`Samsung, Exh. 1033, p. 8
`
`
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`30. Attached as Exhibit 1068 to the Petition is a true and correct copy of
`
`the Complaint filed in Wepay Global Payments LLC v. Wal-Mart Stores, Inc.,
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`1:2022-cv-01062 (N.D. Ill.).
`
`31. Attached as Exhibit 1069 to the Petition is a true and correct copy of
`
`Exhibit 2 to the Complaint filed in Wepay Global Payments LLC v. Wal-Mart
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`Stores, Inc., 1:2022-cv-01062 (N.D. Ill.).
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`32.
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`I declare that all statements made herein of my knowledge are true,
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`and that all statements made on information and belief are believed to be trued, and
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`that these statements were made with the knowledge that willful false statements
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`and the like so made are punishable by fine or imprisonment, or both, under
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`Section 1001 of Title 18 of the United States Code.
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`
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`Dated: 4/5/2022
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`By: /s/ Kathleen R. Geyer
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`Kathleen R. Geyer
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`
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`
`
`9
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`Samsung, Exh. 1033, p. 9
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`
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