e.Digital

Flash-R™ patent portfolio e.Digital's Flash-R™ patent portfolio contains fundamental technology essential to the utilization of flash memory in today's large and growing portable electronic products market.
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Case Nos. IPR2015-01470, -01471, -01472, -01473, -01474 and -01475 28 lists. (Ex. 1007 at ¶ [0052].) The only discussion Miluzzo offers of a more refined dissemination of information about a user’s context is in ¶ [0053] in a vague reference to the “Virtual Walls” model without further elaboration of how to implement it. 69. The above-referenced dependent claims on the other hand teach varying levels of information being shared that relates to a specific social template selected. (See, e.g., Table 2 of the disputed patents.) 70. For example, a social template for a “Mother-and-baby-sleeping” social signature will result in a father having location, duration of state, and estimated sleep time. While a friend may be shared the fact that the baby is sleeping, and work may be shared “Do not disturb.” (’522 patent at 16:27-66.) However, a different selected social template, such as a “car crash,” might result in detailed information being sent to emergency services, such as time of impact and location, while a separate alert of the crash may be sent to family and friends. (Id. at 21:15-24.) 71. The claimed subject matter of these dependent claims therefore allows for significantly more complex distribution of information than would basic privacy settings that share on/off information as taught by Miluzzo and Robarts. For these reasons, key elements are missing from the combination of Miluzzo and Robarts. e.Digital Corporation Exhibit 2015 - Page 30 Case Nos. IPR2015-01470, -01471, -01472, -01473, -01474 and -01475 29 IX. Conclusion In signing this declaration, I recognize that the declaration will be filed as evidence in a contested case before the Patent Trial and Appeal Board of the United States Patent and Trademark Office. I also recognize that I may be subject to cross-examination in the case and that cross-examination will take place within the United States. If cross-examination is required of me, I will appear at the allotted time and agreed place. I hereby declare that all the statements made herein are of my own knowledge and are true and that all statements made on information and belief are believed to be true; and further that these statements sere made with the knowledge that willful false statements and the like so made are punishable by fine or imprisonment, or both under Section 1001 of Title 18 of the United States Code. Executed this 23rd day of March 2016 in San Francisco, California. _________________________ Scott M. Nettles

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sman998
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