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`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
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`UN ITED STATES DISTRICT COU RT
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`NORTHERN DISTRICT OF CALIFORNIA
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`11 APPLIED MATERIALS. INC .•
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`CASE NO. 5:20-cv-05676-EJD
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`12
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`vs.
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`Plaintiff,
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`14 DEMARAY LLC,
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`DECLARATION OF KEITH A.
`MILLER IN SUPPORT OF APPLIED
`MATERIALS, INC.'S REPLY IN
`SUPPORT OF MOTION FOR
`PRELIMINARY INJUNCTION
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`Defendant.
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`MILLER DECL. IN SUPPORT OF
`APPLIED'S MOTION FOR PRELIMINARY
`INJUNCTION
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`Case 5:20-cv-05676-EJD Document 27-9 Filed 10/09/20 Page 2 of 3
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`I, Keith A. Miller hereby declar as follows:
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`1.
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`I am a Director of ngineering at Applied Materials Inc. ("Applied'") where I have been
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`employed since 1997. I have been in this role for approximately IO years and am re pon ible for
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`engine ring and design of pplied's physical vap r deposition (PVD) proc ss chambers. Prior to
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`this role I as an ngineering Manager and Mechanical Engineer at Applied. I either have
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`personal knowledge of the fact contained in this declaration or the are based on re earch
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`conducted under my supervi ion and direction. If called upon to do o I could and would te tif
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`competently to the matter set forth herein.
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`2. I submit this declaration in upport of ppli d's Repl
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`in upport of Its Mori n for a
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`Preliminary Injunction.
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`3.
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`I understand that Demara LL
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`( 'Demaray") has tiled patent infringement suits again t
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`12 Applied s customers. Intel Corporation ("Int I'") and multiple amsung entities (collectively
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`'' am ung·) in the We t rn Di trict of T xa and ha identified Applied'
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`ndura product line
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`(specifically ··reactors that can be configured for deposition ofTaN layers (e.g. , uB RFX PVD
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`15 with the Encore [1 a(N) barrier chamber) and TiN (e.g. Cirrus ionized PVD chamber)'" in its
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`• • • • 22
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`complaint against Intel and arnsung.
`I
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`5. Applied s headquarlers are located in Santa
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`Iara California. In addition to pplied s
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`headquarter in Santa Clara Califi rnia Applied has additional facilities around the United States
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`including in Massachusetts. Montana, and Austin
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`exas. Applied also has facilities ar und the
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`25 world, including China, various countrie in urope India, Israel, Japan, Korea Singapor and
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`26 Taiwan.
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`- I -
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`JLLER DECL. [ S PPORT OF
`PPL! D'S MOTIO FOR PRELIMTNARY
`INJUN TIO
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`Case 5:20-cv-05676-EJD Document 27-9 Filed 10/09/20 Page 3 of 3
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`I
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`I • • • • -14
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`l declare under penall of perjury that the foregoing i true and correct. Executed on
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`October 9 2020.
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`By:
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`fttfL- )- ~
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`Keith A. Miller
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`- 2 -
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`PPORT OP
`MILLERD CL. I
`PPLI ED'S MO 10 FOR PRELIMfN R
`fNJ
`TIO
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`
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