`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`
`
`BIOTRONIK, INC.,
`Petitioner
`
`v.
`
`ATLAS IP, LLC,
`Patent Owner
`
`Patent No. 5,371,734
`Issued: December 6, 1994
`Filed: January 29, 1993
`Inventor: Michael A. Fischer
`
`
`
`Title: MEDIUM ACCESS CONTROL PROTOCOL FOR WIRELESS
`NETWORK
`
`
`
`
`
`
`
`
`
`
`
`Inter Partes Review No. IPR2015-00534
`
`
`
`
`
`
`
`
`
`
`
`
`
`DECLARATION OF DR. KADATHUR S. NATARAJAN
`
`
`
`
`
`
`
`
`
`
`
`Petitioner Biotronik, Inc. - Ex. 1012, p. 1
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`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
`
`Petitioner Biotronik, Inc. - Ex. 1012, p. 2
`
`
`
`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
`
`Access Control Protocol for Wireless LANs (An Update)," (1992)
`
`("Natarajan 1992").
`
`2. I hold a Bachelor of Technology degree in Electrical Engineering
`
`(Electronics) from the Indian Institute of Technology, in Madras,
`
`India; a Master of Engineering (with Distinction) in Computer
`
`Science and Control Systems from the School of Automation, Indian
`
`Institute of Science, in Bangalore, India; a Master of Science in
`
`Computer & Information Science from The Ohio State University in
`
`Columbus, Ohio; and a Ph.D. in Computer and Information Science
`
`from The Ohio State University in Columbus, Ohio.
`
`3. Over the course of my career spanning over 30 years, I have worked
`
`in the field of broadband wireless and IP-based networking
`
`architectures and systems, including for Cisco, Motorola and IBM.
`
`4. From 1983 until 1993, I was a Research Staff Member at the IBM
`
`Thomas J. Watson Research Center in Yorktown Heights, New York.
`
`During that time, I pioneered the research and development for IBM
`
`Wireless Radio LAN networks and product based on ISM Band Slow
`
`
`
`2
`
`Petitioner Biotronik, Inc. - Ex. 1012, p. 3
`
`
`
`
`
`Frequency Hopping Spread Spectrum operation.
`
`5. During this same time period I also proposed several key MAC
`
`protocol and architecture contributions and was acknowledged by the
`
`IEEE 802 as a major contributor to the base 802.11 standard.
`
`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
`
`voting member of the group, which status I obtained by attending a
`
`certain number of consecutive meetings (I believe two or three), and
`
`maintained by continuing regular attendance at future meetings.
`
`7. Between 1991 and 1993 I contributed the following eight papers to
`
`the 802.11 Working Group:
`
`a) Medium Access Control Protocol for Radio LANs, IEEE 802.11
`
`Working Group paper, 802.11/91-74, July 1991.
`
`b) Battery Efficient Operation of Radio MAC Protocol, IEEE
`
`802.11 Working Group Paper, 802.11/91-102, Sept. 1991.
`
`c) Medium Access Control Protocol for Radio LANs: An Update,
`
`IEEE 802.11 Working Group paper, 802.11/92-39, March 1992.
`
`d) Selection Criteria for Frequency Hopping Pattern Set, IEEE
`
`802.11 Working Group paper 802.11/92-84, July 1992.
`
`3
`
`Petitioner Biotronik, Inc. - Ex. 1012, p. 4
`
`
`
`
`
`e) Adhoc-Networks: A Viewpoint, IEEE 802.11/93-3, Jan. 1993.
`
`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
`
`Working Group paper, 802.11/93-62, May 1993.
`
`h) MAC Criteria for Wireless LAN, IEEE 802.11 Working Group
`
`paper, 802.11/93-63, May 1993.
`
`8. I co-authored the 1991 "Medium Access Control Protocol for Radio
`
`LANs" and Natarajan 1992 with Chi Chi Huang and David F. Bantz,
`
`who were also at the time employed at the IBM Thomas J. Watson
`
`Research Center.
`
`9. I presented Natarajan 1992 ((c) in paragraph 7 above) to the IEEE
`
`802.11 Working Group at the March 1992 meeting in Irvine,
`
`California.
`
`10. In presenting Natarajan 1992 to the IEEE 802.11 Working Group, I
`
`understood that the information contained in the article would not be
`
`maintained as confidential. Rather, from my perspective, and that of
`
`my employer at the time IBM, it was deemed as a disclosure to the
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`public at large.
`
`11. The procedures of the working group required that a presenter bring
`
`4
`
`Petitioner Biotronik, Inc. - Ex. 1012, p. 5
`
`
`
`
`
`5
`
`Petitioner Biotronik, Inc. - Ex. 1012, p. 6
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