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`Case 5:20-cv-09341-EJD Document 145-1 Filed 04/01/22 Page 1 of 3
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`IRELL & MANELLA LLP
`Morgan Chu (70446)
`MChu@irell.com
`Benjamin W. Hattenbach (186455)
`BHattenbach@irell.com
`Samuel K. Lu (171969)
`SLu@irell.com
`Olivia L. Weber (319918)
`OWeber@irell.com
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067-4276
`Telephone:
`(310) 277-1010
`Facsimile:
`(310) 203-7199
`
`FOLIO LAW GROUP PLLC
`C. Maclain Wells (221609)
`Maclain@foliolaw.com
`2376 Pacific Ave.
`San Francisco, CA 94115
`(415) 562-8632
`
`Attorneys for Defendant
`DEMARAY LLC
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`
`APPLIED MATERIALS, INC.,
`
`
`Plaintiff,
`
`vs.
`
`
`
`
`DEMARAY LLC,
`
`
` Case No. 5:20-cv-09341-EJD
`
`
`DECLARATION OF C. MACLAIN
`WELLS IN SUPPORT OF DEMARAY
`LLC'S RESPONSIVE CLAIM
`
`CONSTRUCTION BRIEF
`
`
`
`Defendant.
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`WELLS DECLARATION ISO DEMARARY LLC'S
`RESPONSIVE CLAIM CONSTRUCTION BRIEF
`(Case No. 5:20-cv-09341-EJD)
`
`
`

`

`Case 5:20-cv-09341-EJD Document 145-1 Filed 04/01/22 Page 2 of 3
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`DECLARATION OF C. MACLAIN WELLS
`I, C. Maclain Wells, hereby declare as follows:
`1.
`I am an attorney at the law firm of Folio Law Group PLLC, counsel for Defendant
`
`Demaray LLC ("Demaray"). I am a member in good standing of the State Bar of California and
`have been duly licensed to practice law before all of the courts of the State of California. I submit
`this declaration in support of Demaray's responsive claim constructive brief. I have personal
`knowledge of the matters set forth in this declaration and, if called as a witness, could testify to its
`contents.
`Attached as Exhibit A is a copy of U.S. Patent No. 7,381,657 ("the '657 Patent").
`2.
`Attached as Exhibit B is a copy of U.S. Patent No. 7,544,276 ("the '276 Patent").
`3.
`Attached as Exhibit C is a copy of the August 17, 2021 Claim Construction Order
`4.
`entered in Demaray LLC v. Intel Corp., Case No. 6:20-cv-00634-ADA (W.D. Tex.), and in
`Demaray LLC v. Samsung Electronics Co., Ltd. et al., Case No. 6:20-cv-00636-ADA (W.D. Tex.).
`Attached as Exhibit D is a copy of the February 27, 2022 Claim Construction
`5.
`Order entered in Demaray LLC v. Intel Corp., Case No. 6:20-cv-00634-ADA (W.D. Tex.), and in
`Demaray LLC v. Samsung Electronics Co., Ltd. et al., Case No. 6:20-cv-00636-ADA (W.D. Tex.).
`Attached as Exhibit E is Intel and Samsung's Responsive Claim Construction Brief
`6.
`in Demaray LLC v. Intel Corp., Case No. 6:20-cv-00634-ADA (W.D. Tex.), Dkt. 58; and
`Demaray LLC v. Samsung Electronics Co., Ltd. et al., Case No. 6:20-cv-00636-ADA (W.D. Tex.),
`Dkt. 62.
`Attached as Exhibit F is a copy of U.S. Patent No. 6,350,353. The document is
`7.
`cited on the face of the '657 and '276 Patents.
`Attached as Exhibit G is a copy of a white paper by Scholl, titled "Power supplies
`8.
`for pulsed plasma technologies: State-of-the-art and outlook." The document is cited on the face of
`the face of the '657 and '276 Patents, and was produced in the Western District of Texas cases, at
`DEFTS-PA_002936.
`9.
`Attached hereto as Exhibit H is a copy of Advanced Energy Industries, Inc.'s Pinnacle
`Plus+ 10 kW (325-650 Vdc) Master/Slave AE Bus, DeviceNet, MDXL User, UHF Output User
`
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`- 1 -
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`WELLS DECLARATION ISO DEMARARY LLC'S
`RESPONSIVE CLAIM CONSTRUCTION BRIEF
`(Case No. 5:20-cv-09341-EJD)
`
`
`

`

`Case 5:20-cv-09341-EJD Document 145-1 Filed 04/01/22 Page 3 of 3
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`Manual (June 2002), which was filed in Demaray LLC v. Intel Corp., Case No. 6:20-cv-00634-
`ADA (W.D. Tex.) at Docket 61-9.
`Attached as Exhibit I is an excerpt from the Modern Dictionary of Electronics (7th
`10.
`
`ed.), which Demaray produced in Demaray LLC v. Intel Corp., Case No. 6:20-cv-00634-ADA
`(W.D. Tex.) at DEMINT00003506.
`Attached as Exhibit J is a copy of a white paper by Scholl, titled "Power Systems
`11.
`for Reactive Sputtering of Insulating Films." The document is cited on the face of the '657 and
`'276 Patents, and was produced in the Western District of Texas cases at DEFTS-PA_003056.
`Attached as Exhibit K is the Declaration of Dr. Alexander D. Glew in Support of
`12.
`Demaray's Claim Construction brief, which has been served on Applied.
`13.
`I represented Demaray as its counsel in responding to all four of Applied's inter
`partes review petitions. As such, I am familiar with Applied's petitions and other filings in these
`matters. In IPR2021-00103, IPR2021-00104, IPR2021-00105, and IPR2021-00106, Applied did
`not seek construction of "narrow band rejection filter, "pulsed DC power" or "pulsed DC power
`supply, "a method of depositing an insulating film on a substrate, comprising," "the insulating
`film," or "insulating substrate."
`
`
`Executed on April 1, 2022 in San Francisco, California. I declare under penalty of perjury
`that the foregoing is true and correct.
`
`By: /s/ C. Maclain Wells
`C. Maclain Wells
`Attorneys for Defendant DEMARAY LLC
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`WELLS DECLARATION ISO DEMARARY LLC'S
`RESPONSIVE CLAIM CONSTRUCTION BRIEF
`(Case No. 5:20-cv-09341-EJD)
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