`____________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________
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`HUGHES NETWORK SYSTEMS, LLC and
`HUGHES COMMUNICATIONS, INC.,
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`Petitioners,
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`v.
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`CALIFORNIA INSTITUTE OF TECHNOLOGY,
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`Patent Owner.
`____________________________
`
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`Case IPR2015-00060 (Patent 7,421,032)
`Case IPR2015-00067 (Patent 7,116,710)
`____________________________
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`DECLARATION OF AARON THOMPSON
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`Hughes, Exh. 1067, p. 1
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`I, Aaron Thompson, declare:
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`1.
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`I am currently employed by Wilmer Cutler Pickering Hale and Dorr
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`LLP as a Senior Associate. I have personal knowledge of the facts set forth herein,
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`and, if called to testify in person, could and would testify competently thereto. I
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`have been involved with the pending district court case captioned California
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`Institute of Technology v. Hughes Communications, Inc. et al., No. 13-CV-07245
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`(CACD) (the “Caltech litigation”) since at least February 10, 2014 on behalf of
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`Hughes Network System, LLC and Hughes Communications, Inc. (“Hughes”).
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`2.
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`I am over the age of 18, have never been convicted of a felony or
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`crime of moral turpitude and am legally competent to make this declaration.
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`3.
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`On January 13, 2015, the California Institute of Technology produced,
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`for the first time, an email dated December 8, 1999 from Dr. Brendan Frey to Dr.
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`Dariush Divsalar. That email was reproduced in the Caltech Litigation in the
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`Expert Report of Dr. Brendan Frey at page 52, lines 1 to 11. Neither Hughes nor
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`counsel for Hughes had possession of that email or awareness of its existence prior
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`Caltech’s production of that email on January 13, 2015.
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`4.
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`I hereby declare that all statements made herein of my own
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`knowledge are true and that all statements made on information or belief are
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`believed to be true; and further that these statements were made with the
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`knowledge that willful false statements and the like so made are punishable by fine
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`
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`2
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`Hughes, Exh. 1067, p. 2
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`
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`or imprisonment, or both, under Section 1001 of Title 18 of the United States Code
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`and that such willful false statements may jeopardize the results of these
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`proceedings.
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`Dated: May 27, 2015
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`Aaron Thompson
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`3
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`Hughes, Exh. 1067, p. 3
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