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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`__________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`__________________
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`SONY CORPORATION
`Petitioner
`
`Patent No. 7,477,284
`Issue Date: Jun. 13, 2009
`Title: SYSTEM AND METHOD FOR CAPTURING AND VIEWING
`STEREOSCOPIC PANORAMIC IMAGES
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`__________________
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`Inter Partes Review No. IPR2013-00327
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`__________________________________________________________________
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`DECLARATION OF KOUICHI MATSUDA
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`1
`
`Petition for Inter Partes Review of
`U.S. Pat. No. 7,477,284
`IPR2013‐00327
`EXHIBIT
`Sony‐
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`
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`I, Kouichi Matsuda, do hereby make the following declaration:
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`1.
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`The statements contained in this declaration are based on my personal
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`knowledge.
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`I am a Chief Distinguished Researcher at Sony Corporation and have been
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`employed by Sony since 1995.
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`I have a Master’s degree in artificial
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`intelligence and a Doctorate in distributed virtual environment technology.
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`In November 1997, I was a Researcher at the Architecture Laboratory and
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`my job responsibilities included research relating to Virtual reality.
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`From June 1997 until approximately 2001, I served as an operating director
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`of SIG-CyberSpace ("SIG—CS") — a special interest group of an academic
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`society named the Virtual Reality Society of Japan (“VRS”).
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`In the November 1997 time frame, VRS was an academic society for
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`individuals (mostly engineers, scientists and students) interested in virtual
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`reality and related technologies, including 3D technology. SIG-CS
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`organized symposiums and meetings, and its objective was to offer a forum
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`for discussing academic research regarding virtual reality applications such
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`as networked communities.
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`As a matter of general practice during my tenure as an operating director, the
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`symposiums and meetings that were organized by SIG-CS were open to
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`members, students, and the general public, and information and materials
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`distributed at such events were publicly available and not subject to any
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`confidentiality restrictions. Both members and non-members also had
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`access to printed materials related to SIG-CS symposiums and meetings.
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`VRS had a website that could be viewed by any interested member of the
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`general public, and information and announcements about SIG-CS
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`symposiums and meetings were posted on this website.
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`I was operating director of SIG-CS on November 27, 1997, when SIG-CS
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`held a meeting at the Landmark Tower in Yokohama City, Kanagawa
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`Prefecture. The preparations for this meeting included the following:
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`planning the subjects to be presented, handling registration of applications,
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`choosing and organizing the papers that would be presented and the order of
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`such presentations, collecting papers that corresponded with the planned
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`presentations prior to the meeting, organizing the papers into a booklet that
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`would be distributed to meeting participants, and ordering copies of the
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`booklet for distribution.
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`For the November 27, 1997 meeting, a program was created that included
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`information about the date, time, and location of the meeting. It also
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`included additional information about the meeting, such as the authors and
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`titles of the five papers that would be presented, as well as registration
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`
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`information and participation fees for members, students, and the general
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`public.
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`Attached as Exhibit lM is a copy of an email that I received on November
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`17, 1997 containing the program for the November 27, 1997 meeting. As
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`indicated, applications for participation were accepted at the venue on the
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`day of the event. The participant fees were 2,000 yen for the general public
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`and 1,000 yen for students. SIG—CS members were admitted free.
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`At the November 27, 1997 meeting, copies of a booklet containing the five
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`papers presented at the meeting were made available to participants. The
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`participants included SIG-CS members as well as other individuals who
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`were interested in the subjects of the papers being presented. The booklet
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`was entitled “Virtual Reality Society of Japan Research Report” and was
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`dated November 27, 1997. The booklet included a table of contents at the
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`beginning, which identified the five papers presented at the November 27,
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`1997 meeting. The booklet was not marked or treated as confidential.
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`Attached as Exhibit 2M is a copy of that booklet. To enable non-Japanese
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`speaking members of the public to understand the contents of these five
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`papers, and to facilitate searches by non-Japanese speakers for the papers,
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`SIG-CS requested that the authors of each of the five papers provide English
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`
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`titles and abstracts for their papers, and those English titles and abstracts
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`were included in the booklet.
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`10.
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`It was general practice for SIG-CS to print copies of conference materials
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`for distribution at the conference, and to send any remaining copies after the
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`conference to universities. For the November 27, 1997 meeting, 100 copies
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`of the booklet were printed for distribution, 30 were distributed at the
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`meeting, and the remaining copies were given to Professor Okada of Keio
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`University for further distribution.
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`11.
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`Attached as Exhibit 3M is a copy of an email to the SIG-CS expert
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`committee (of which I was a member), dated October 30, 1997, which
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`includes meeting minutes from an October 30, 1997 committee meeting. As
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`the minutes indicate, copies of the booklet for the November 27, 1997
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`meeting were printed by Sankyo Printing in units of 100 copies.
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`12.
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`Attached as Exhibit 4M is a copy of an email sent to the SIG-CS expert
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`committee, dated February 12, 1998, containing minutes from a February 11,
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`1998 committee meeting. As the minutes indicate, 70 copies of the booklet
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`from the November 27, 1997 meeting were sent to Keio University.
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`13.
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`Symposium and meeting materials were generally available and could be
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`obtained after a symposium or a meeting by contacting VRS. Any requests
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`
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`for copies of the booklet fi'om the November 27, 1997 meeting were directed
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`to Professor Okada, and the booklet could be purchased from him directly.
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`I declare under penalties of perjury set out in 18 U.S.C. § 1001 that the foregoing
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`statements are true and correct to the best of my knowledge.
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`Executed on March (£6, 2013.
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`6sz @f
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