`
`___________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________________________________
`
`MACRONIX INTERNATIONAL CO., LTD., MACRONIX ASIA LIMITED,
`MACRONIX (HONG KONG) CO., LTD. and MACRONIX AMERICA, INC.
`Petitioners
`
`v.
`
`SPANSION LLC
`Patent Owner
`
`___________________________________
`
`Case No. IPR2014-00898
`Patent Number 7,151,027
`
`Before the Honorable DEBRA K. STEPHENS, JUSTIN T. ARBES, and
`RICHARD E. RICE, Administrative Patent Judges.
`
`
`
`DECLARATION OF HAN XU
`
`I, Han Xu, make the following Declaration pursuant to 28 U.S.C. § 1746:
`
`1.
`
`I am an attorney with the law firm of Ropes & Gray LLP. I have
`
`worked at Ropes & Gray LLP since 2008.
`
`2.
`
`I provide this Declaration in connection with Patent Owner Spansion
`
`LLC.’s Response in the above-captioned Inter Partes Review proceeding. Unless
`
`otherwise stated, the facts stated in this Declaration are based on my personal
`
`knowledge.
`
`
`
`1
`
`Spansion Exhibit 2012
`Macronix et al v. Spansion
`IPR2014-00898
`Page 00001
`
`
`
`3.
`
`Exhibit 2001 is a true and correct copy of Deposition Exhibit 2001 from
`
`the Deposition of Mr. Dhaval Brahmbhatt (Sept. 24, 2014). An exhibit label and page
`
`numbers have been added to the bottom of this document but no other alterations
`
`have been made.
`
`4.
`
`Exhibit 2002 is a true and correct copy of Deposition Exhibit 2002 from
`
`the Deposition of Mr. Dhaval Brahmbhatt (Sept. 24, 2014). An exhibit label and page
`
`numbers have been added to the bottom of this document but no other alterations
`
`have been made.
`
`5.
`
`Exhibit 2003 is a true and correct copy of Deposition Exhibit 2003 from
`
`the Deposition of Mr. Dhaval Brahmbhatt (Sept. 24, 2014). An exhibit label and page
`
`numbers have been added to the bottom of this document but no other alterations
`
`have been made.
`
`6.
`
`Exhibit 2004 is a true and correct copy of the Transcript of Deposition
`
`of Dr. Dhaval Brahmbhatt (July 3, 2014). An exhibit label and page numbers have
`
`been added to the bottom of this document but no other alterations have been made.
`
`7.
`
`Exhibit 2005 is a true and correct copy of an excerpt from the
`
`Transcript of Deposition of Dr. Dhaval Brahmbhatt (July 2, 2014). An exhibit label
`
`and page numbers have been added to the bottom of this document but no other
`
`alterations have been made.
`
`
`
`2
`
`Page 00002
`
`
`
`8.
`
`Exhibit 2008 is a true and correct copy of the Transcript of Deposition
`
`of Dr. Dhaval Brahmbhatt (Sept. 24, 2014). An exhibit label and page numbers have
`
`been added to the bottom of this document but no other alterations have been made.
`
`9.
`
`Exhibit 2009 is a true and correct copy of Yuzuriha et al., A 14-ns 1-Mbit
`
`CMOS SRAM with Variable Bit Organization, IEEE Journal of Solid-State Circuits, Vol.
`
`23, No. 5, October 1988. An exhibit label and page numbers have been added to the
`
`bottom of this document but no other alterations have been made.
`
`10. Exhibit 2010 is a true and correct copy of Certified Translation of
`
`Excerpts of JP 2003-078040 and Accompanying Appendices. An exhibit label and
`
`page numbers have been added to the bottom of this document but no other
`
`alterations have been made.
`
`11. Exhibit 2011 is a true and correct copy of JP Application 2001-263736,
`
`issued as JP Patent No. 2003-78040. An exhibit label and page numbers have been
`
`added to the bottom of this document but no other alterations have been made.
`
`12. Exhibit 2013 is a true and correct copy of Deposition Exhibit 2000 from
`
`the Deposition of Mr. Dhaval Brahmbhatt (Sept. 24, 2014). An exhibit label and page
`
`numbers have been added to the bottom of this document but no other alterations
`
`have been made.
`
`
`
`
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`3
`
`Page 00003
`
`
`
`Executed on October 3, 2014
`
`
`
`
`
`
`
`
`
`
`
`at Tokyo, Japan
`
`/Han Xu/
`
`
`
`
`
`
`
`Han Xu
`
`
`
`4
`
`Page 00004
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