`
`FUJITSU NETWORK COMMUNICATIONS, INC.
`Petitioner
`
`V.
`
`THOMAS SWAN & CO. LTD.
`
`Patent Owner
`
`Inter Partes Review Case No. Unassigned
`
`DECLARATION OF LOUISE CLARKE
`
`I, LOUISE CLARKE, declare as follows:
`
`I am over the age of eighteen (18) years of age and competent to make this
`
`declaration.
`
`I am Deputy Superintendent of the Manuscripts Reading Room at
`
`Cambridge University Library (“CUL”).
`
`I began working at CUL as a book
`
`fetcher in 1988 and continued in that position until 1990. From 1990 until 2001, I
`
`worked at CUL in cataloguing. In September 2001, I became Deputy
`
`Superintendent of the Manuscripts Reading Room at CUL. Since then, I have been
`
`responsible for processing and cataloguing theses at CUL.
`
`._.1_
`
`FNC 1015
`
`
`
`four theses specified below were added to the CUL catalogue for the public to
`
`access.
`
`0
`
`Tan, Kim Leong, Dynamic Holography Using Ferroelectric Liquid
`
`Crystal on Silicon Spatial Light Modulators (February 1999) (“Tan
`
`Thesis”)
`
`Parker, Michael Charles, Dynamic Holograms for Wavelength
`
`Division Multiplexing (November 1996) (“Parker Thesis”)
`
`Warr, Stephen Thomas, Frec-Space Switching for Optical Fibre
`
`Networks (July 1996) (“Warr Thesis”)
`
`Cohen, Adam David, Spatial Light Modulator Technologies for WDM
`
`0
`
`0
`
`0
`
`(April 1998) (“Cohen Thesis”)
`
`(together, “the Theses”).
`
`Ireviewed the catalogue entries for each of the Theses and was able to see
`
`that the Theses were approved by the Board of Graduate Studies on the foliowing
`
`respective dates:
`
`0
`
`0
`
`Tan Thesis — 15 June 1999 (author/title published in the Cambridge
`
`University Reporter on Wednesday 30 Tune 1999)
`
`Parker Thesis — 18 March 1997 (author/tide published in the
`
`Cambridge University Reporter on Wednesday 23 April 1997)
`
`_2_
`
`
`
`Cambridge University Reporter on Wednesday 15 January 1997)
`
`0
`
`Cohen Thesis — 24 July 1998 (author/title published in the Cambridge
`
`University Reporter on Wednesday 5 August 1998)
`
`The Theses were added to the CUL catalogue prior to the update of the CUL
`
`catalogue to the Voyager Library Management System in 2002.
`
`Prior to 2002, the CUL catalogue was maintained in an inmhouse database.
`
`Because I was responsible for adding theses to the CUL catalogue since September
`
`2001, I personally used the iii-house database and am familiar with how theses
`
`were added to the CUL catalogue in the course of regularly conducted activity of
`
`CUL’s business using that system, which was in place from the 19903 until the
`
`implementation of the Voyager Library Management System in 2002.
`
`During that time period, it was common and regular practice for a thesis to
`
`be added to the CUL catalogue approximately one month after the date on which
`
`the thesis was approved by the Board of Graduate Studies. In accordance with the
`
`common practice during this time period, the Board of Graduate Studies would
`
`regularly provide an electronic file to CUL that included bibliographic information
`
`of recently approved theses and upon receipt, the bibliographic information for
`
`these theses would be loaded from the electronic file into the CUL catalogue in the
`
`in-house database. Theses added to the CUL catalogue in the in—house database
`
`_3_
`
`
`
`searching the CUL catalogue. Upon being added to the CUL catalogue, theses
`
`themselves were shelved in CUL and made freely available to the general public.
`
`Based on my personal knowledge and experience, and because these are
`
`standard records of CUL’s regularly conducted activity, it is my true and
`
`reasonable belief that each of the Theses would have been added to the CUL
`
`catalogue for the public to access approximately one month from the above
`
`respective dates on which each of the Theses was approved by the Board of
`
`Graduate Studies.
`
`Moreover, I am highly confident that the Theses were added to the CUL
`
`catalogue and records of the Theses were available for the public to access using
`
`the CUL catalogue in the in—house database by no later than six months from the
`
`above respective dates on which each of the Theses was approved by the Board of
`
`Graduate Studies.
`
`I declare under penalty of perjury under the laws of the United States of
`
`America that the foregoing is true and correct.
`
`Executed at Cambridge, England on the Eday of August, 2014.
`
`By: Wfifi/M/W
`
`LOUISE CLARKE
`
`
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