`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`
`MICRON TECHNOLOGY, INC., AND MICRON MEMORY JAPAN, INC.,
`Petitioners
`
`v.
`
`MASSACHUSETTS INSTITUTE OF TECHNOLOGY,
`Patent Owner
`________________________
`
`Case IPR2015-01087
`U.S. Patent No. 6,057,221
`________________________
`
`Transmittal of English Translation Affidavit
`
`
`
`
`
`
`
`UPDATED TABLE OF EXHIBITS
`
`
`Description
`Submission of Reorganization Claim to Tokyo District Court
`(October 31, 2012)
`English Translation of Submission of Reorganization Claim to Tokyo
`District Court (October 31, 2012)
`Reorganization Claim Certificate of Receipt from Tokyo District
`Court (August 10, 2015)
`English Translation of Reorganization Claim Certificate of Receipt
`from Tokyo District Court (August 10, 2015)
`English Translation of Reorganization Claim Certification of Receipt
`Request (August 10, 2015)
`Petition to Tokyo District Court for Claim Assessment (December
`22, 2012)
`English Translation of Petition to Tokyo District Court for Claim
`Assessment (December 22, 2012)
`Trustee/MMJ Acknowledgement of Formal Service of the Petition
`for Claim Assessment (December 26, 2012) (and translations)
`Tokyo District Court Certificate of Receipt of Petition for Claim
`Assessment (August 10, 2015)
`English Translation of Certificate of Receipt of Petition for Claim
`Assessment Request (August 10, 2015)
`Ex Parte Reexamination Application No. 90/011,607
`Elpida News Release: Notice on Petition for Commencement of
`Corporate Reorganization Proceedings and Uncollectibility of Debts
`of Our Subsidiary (February 27, 2012)
`Opinion Staying Litigation in the United States, In re Elpida
`Memory, Inc., Case No. 12-10947 (Bankr. D. Del.)(November 20,
`2012)
`Tokyo District Court Notice of Result of Investigation (November
`14, 2012)
`Tokyo District Court Decision Regarding Corporate Reorganization
`
`Exhibit #
`2001
`
`2001ET
`
`2002
`
`2002ET
`
`2003
`
`2004
`
`2004ET
`
`2005
`
`2006
`
`2007
`
`2008
`2009
`
`2010
`
`2011
`
`2012
`
`
`
`
`
`Case No. IPR2015-01087
`
`(October 20, 2014)
`English Translation of Tokyo District Court Decision Regarding
`Corporate Reorganization (October 20, 2014)
`Micron Memory Japan, Inc’s Answer to Amended Complaint, MIT v.
`Micron, Case No. 1:15cv10374 FDS (U.S.D.M) (May 14, 2015)
`R.G. Sterne et al., “Reexamination Practice with Concurrent District
`Court Litigation or Section 337 USITC Investigations,” 2011
`Definition of “Plan View”, available at http://www.merriam-
`webster.com
`S. Wolf et al., “Silicon Processing for the VLSI Era, Volume 1:
`Process Technology,” Second Edition, Lattice Press (2000)
`United States Patent No. 6,218,733
`Conductive Materials or Metal Conductivity, available at
`http://www.tibtech.com/conductivity.php
`K. Kawabata and T. Muto, “Electrical Properties of Titanium Nitride
`Thin Films Deposited by Reactive Sputtering,” Electrocomponent
`Science and Technology, 1981, Vol. 8, p. 249
`V. Mortet et al., “Titanium Nitride Grown by Sputtering for Contacts
`on Boron-Doped Diamond,” Plasma Process. Polym. 2007, 4, S139-
`S143
`Titanium nitride, available at
`http://en.wikipedia.org/wiki/Titanium_nitride
`Titanium – Comparison of Properties with Other Metals, available at
`http://www.amazon.com/article.aspx?ArticleID=1298
`S. Wolf, “Microchip Manufacturing,” Lattice Press (2004)
`Resistivity, Conductivity and Temperature Coefficients for some
`Common Materials, available at
`http://www.engineeringtoolbox.com/resistivity-conductivity-
`d_418.html
`Affidavit of Takayasu Koga Pursuant to C.F.R. § 42.63(b)
`
`2012ET
`
`2013
`
`2014
`
`2015
`
`2016
`
`2017
`2018
`
`2019
`
`2020
`
`2021
`
`2022
`
`2023
`2024
`
`2025
`
`
`
`
`
`
`
`
`
`Case No. IPR2015-01087
`
`
`
`Patent Owner hereby submits the Affidavit of Takayasu Koga as Exhibit
`
`2025 and additional English language translations as Exs. 2001ET, 2002ET,
`
`2004ET, and 2012ET. An updated Exhibit List is provided herewith for all exhibits
`
`filed by Patent Owner in this proceeding.
`
`
`
`Respectfully submitted,
`
`by: /Steven J. Pollinger/
`Steven J. Pollinger
`Registration No. 35,326
`Ramzi R. Khazen
`Registration No. 55,810
`
`Counsel for Massachusetts Institute of
`Technology
`
`Dated: August 13, 2015
`
`
`
`
`
`
`
`
`
`Case No. IPR2015-01087
`
`CERTIFICATE OF SERVICE (C.F.R. § 42.6(E)(4)
`A copy of the Patent Owner’s Transmittal of English Translation
`
`Affidavit has been served via electronic mail on the following counsel of record
`
`for Petitioners:
`
`David J. Cooperberg
`dcooperberg@kenyon.com
`Thomas Makin
`tmakin@kenyon.com
`Rose Cordero Prey
`rcordero@kenyon.com
`Kenyon & Kenyon LLP
`One Broadway
`New York, NY 10004
`Telephone: 212.425.7200
`Facsimile: 212.425.5288
`
`
`Dated: August 13, 2015
`
`
`
`Respectfully submitted,
`
`by: /Steven J. Pollinger/
`Steven J. Pollinger
`Registration No. 35,326
`Ramzi R. Khazen
`Registration No. 55,810
`
`Counsel for Massachusetts Institute of
`Technology
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