UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GOOGLE LLC,
`Petitioner,
`V.
`SECURE COMMUNICATION TECHNOLOGIES, LLC,
`
`Patent Owner.
`
`Case IPR2025-01181
`
`U.S. Patent No. 11,334,918
`
`DECLARATION OF JAMES PROCTOR, JR. IN SUPPORT OF
`PATENT OWNER’S BRIEF IN SUPPORT OF DISCRETIONARY DENIAL
`
`SCT Exhibit 2001
`[PR2026-00098
`
`
`
`
`
`
`
`
`I, James Proctor, Jr., hereby declare as follows:
`
`1. My name is James Proctor, Jr. 1 am a co-inventor of the patent
`challenged in this proceeding. I submit this declaration in support of Patent Owner
`Secure Communication Technologies, LLC’s (“SCT”) Brief in Support of
`Discretionary Denial. I have personal knowledge of the facts and statements herein.
`I am competent to testify to the matters stated in this declaration, and each of the
`facts and statements set forth below is true and correct.
`
`2. In November 2011, I emailed Kyle Enright, who I understand to have
`then been the Head of Business Development for Mobile Payments at Google, about
`the inventions disclosed in the family of the patent challenged in Petitioner Google
`LLC’s (“Google) IPR petition. A true and accurate copy of that email is included
`with SCT’s Brief as Exhibit 2002.
`
`3. On February 9, 2012, I emailed Amar Mehta, who I understand to have
`then been an attorney at Google, concerning the patent family to which the
`challenged patent belongs. A true and accurate copy of that email is included with
`SCT’s Brief as Exhibit 2004.
`
`4. I declare that all statements made herein of my own knowledge are true
`and that all statements made on information and belief are believed to be true, and
`further that these statements were made with the knowledge that willful false
`
`statements and the like so made are punishable by fine or imprisonment, or both,
`
`Declaration of James Proctor, Jr. In Support of
`Patent Owner’s Brief in Support of Discretionary Denial
`1
`SCT Exhibit 2001
`[PR2026-00098
`
`
`
`
`
`
`
`
`under Section 1001 of Title 18 of the United States Code.
`
`Executed this 8th day of September, 2025, in Laconia, NH
`
`WAl
`
`James Proctor, Jr.
`
`Declaration of James Proctor, Jr. In Support of
`Patent Owner’s Brief in Support of Discretionary Denial
`2
`SCT Exhibit 2001
`[PR2026-00098
`
`
`
`
`
`
`
`
`