`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`ST. JUDE MEDICAL, INC., ST JUDE MEDICAL S.C., INC. AND
`PACESETTER, INC.
`
`Petitioners
`v.
`
`ATLAS IP, LLP
`
`Patent Owner
`
`Patent No. 5,371,734
`Issue Date: December 4, 1994
`
`Title: Medium Access Control Protocol For Wireless Network
`
`DECLARATION OF DR. KADATHUR S. NATARAJAN
`
`ST. JUDE 1012
`
`1
`
`
`
`
`
`
`
`I, Kadathur S. Natarajan, hereby declare as follows:
`
`1. I have been contacted by St. Jude Medical, Inc. and asked to prepare a
`
`declaration discussing the publication and distribution of "Medium
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`Access Control Protocol for Wireless LANs (An Update)," (1992)
`
`("Natarajan 1992").
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`2. I hold a Bachelor of Technology degree in Electrical Engineering
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`(Electronics) from the Indian Institute of Technology, in Madras,
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`India; a Master of Engineering (with Distinction) in Computer
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`Science and Control Systems from the School of Automation, Indian
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`Institute of Science, in Bangalore, India; a Master of Science in
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`Computer & Information Science from The Ohio State University in
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`Columbus, Ohio; and a Ph.D. in Computer and Information Science
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`from The Ohio State University in Columbus, Ohio.
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`3. Over the course of my career spanning over 30 years, I have worked
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`in the field of broadband wireless and IP-based networking
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`architectures and systems, including for Cisco, Motorola and IBM.
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`4. From 1983 until 1993, I was a Research Staff Member at the IBM
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`Thomas J. Watson Research Center in Yorktown Heights, New York.
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`During that time, I pioneered the research and development for IBM
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`Wireless Radio LAN networks and product based on ISM Band Slow
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`2
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`
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`
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`Frequency Hopping Spread Spectrum operation.
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`5. During this same time period I also proposed several key MAC
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`protocol and architecture contributions and was acknowledged by the
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`IEEE 802 as a major contributor to the base 802.11 standard.
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`6. I first became involved with the 802.11 working group of the Institute
`
`of Electrical and Electronics Engineers (IEEE), which was formed for
`
`establishing standards for wireless LANS, in January 1991. I was a
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`voting member of the group, which status I obtained by attending a
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`certain number of consecutive meetings (I believe two or three), and
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`maintained by continuing regular attendance at future meetings.
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`7. Between 1991 and 1993 I contributed the following eight papers to
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`the 802.11 Working Group:
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`a) Medium Access Control Protocol for Radio LANs, IEEE 802.11
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`Working Group paper, 802.11/91-74, July 1991.
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`b) Battery Efficient Operation of Radio MAC Protocol, IEEE
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`802.11 Working Group Paper, 802.11/91-102, Sept. 1991.
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`c) Medium Access Control Protocol for Radio LANs: An Update,
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`IEEE 802.11 Working Group paper, 802.11/92-39, March 1992.
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`d) Selection Criteria for Frequency Hopping Pattern Set, IEEE
`
`802.11 Working Group paper 802.11/92-84, July 1992.
`
`3
`
`
`
`
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`e) Adhoc-Networks: A Viewpoint, IEEE 802.11/93-3, Jan. 1993.
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`f) Registration Scenarios for Wireless LAN MAC Protocol, IEEE
`
`802.11 Working Group paper, 802.11/93-2, Jan. 1993.
`
`g) MAC Protocol for Wireless LAN: 2nd Update, IEEE 802.11
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`Working Group paper, 802.11/93-62, May 1993.
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`h) MAC Criteria for Wireless LAN, IEEE 802.11 Working Group
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`paper, 802.11/93-63, May 1993.
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`8. I co-authored the 1991 "Medium Access Control Protocol for Radio
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`LANs" and Natarajan 1992 with Chi Chi Huang and David F. Bantz,
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`who were also at the time employed at the IBM Thomas J. Watson
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`Research Center.
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`9. I presented Natarajan 1992 ((c) in paragraph 7 above) to the IEEE
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`802.11 Working Group at the March 1992 meeting in Irvine,
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`California.
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`10. In presenting Natarajan 1992 to the IEEE 802.11 Working Group, I
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`understood that the information contained in the article would not be
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`maintained as confidential. Rather, from my perspective, and that of
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`my employer at the time IBM, it was deemed as a disclosure to the
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`public at large.
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`11. The procedures of the working group required that a presenter bring
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`4
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`
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`
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`sufficient cepies of the article being presented for each person
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`attending the meeting (typically one copy per person). I recall
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`bringing copies of Natarajan 1992 for the attendees of the March 1992
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`meeting. This was consistent with my practice and routine in
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`presenting papers to the IEEE 802.11 Working Group during this time
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`frame.
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`I declare under penalty of perjury under the laws of the United States
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`of America that the foregoing is true and correct. All statements made of my
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`own knowledge are true and that all statements made on information and
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`belief are believed to be true. I understand that willful false statements and
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`the like are punishable by fine or imprisonment, or both (18 U.S.C. § 1001).
`
`Kadathur S. Nataraian
`
`5
`
`
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