`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MICRON TECHNOLOGY, INC., AND MICRON MEMORY JAPAN, fNC.,
`
`Petitioners
`
`V.
`
`MASSACHUSETTS INSTITUTE OF TECHNOLOGY,
`Patent Owner
`
`Case: IPR2015—0l087
`
`U.S. PatentNo. 6,057,221
`
`DECLARATION OF DAVID COOPEREBRG
`
`Micron Technology, Inc. at al., Petitioners - Ex. 1052
`Micron Technology, inc. and Micron Memory Japan. Inc. v. Massachusetts Institute of Technology
`|PR2015-01037
`1
`
`
`
`1, David J. Cooperberg, hereby declare as follows:
`
`1.
`
`I have been lead counsel for petitioners Micron Technology, Inc.
`
`(“Micron”) and Micron Memory Japan, Inc. (“Micron Memory Japan” or
`
`“MMJ”) (collectively “Petitioners”) in connection with IPR2015—01087.
`
`I have
`
`been an associate at the law firm of Kenyon & Kenyon LLP through December
`
`4, 2015 and am registered to practice before the United States Patent and
`
`Trademark Office, as well as in the states of New York and New Jersey.
`
`I have
`
`personal knowledge of the facts set forth herein and if called upon to testify to
`
`them I can do so.
`
`2.
`
`I downloaded a file containing the report marked Exhibit 1028 from
`
`the URL “ ttp://smithsonianchips.si.edu/ice/cd/93l l 300.pd ’ prior to May 4,
`
`2015. Exhibit 1028 is a true and correct copy of this report.
`
`3.
`
`I downloaded a file containing the report marked Exhibit 1029 from
`
`the URL “ ttp://smithsonianchips.si.edu/ice/cd/97 l 2 573.pd ’ prior to May 4,
`
`2015. Exhibit 1029 is a true and correct copy of this report.
`
`4.
`
`I downloaded a file containing the report marked Exhibit 1030 from
`
`the URL “http://smithsonianchips.si.edu/ice/cd/9706 540.pd ’ prior to May 4,
`
`2015. Exhibit 1030 is a true and correct copy of this report.
`
`5.
`
`Exhibit 1031 is a true and correct copy ofa printout I made of the
`
`web page available at the URL
`
`
`
`1’.
`
`‘http://www.intelcomfpressroom/archive/releases/1997/dp0l0897.htm” on
`
`April 14, 2015.
`
`6.
`
`Exhibit 1032 is a true and correct copy of a printout I made of the
`
`web page available at the URL
`
`“http://www.intel.com/pressroom/kits/guickreffam.htm#pentium” on April 14,
`
`2015.
`
`7.
`
`I downloaded a file containing the report marked Exhibit 1033 from
`
`the URL “ ttp://smithsonianchips.si.edu/ice/cd/9709 551.pd ’ prior to May 4,
`
`2015. Exhibit 1033 is a true and correct copy of this report.
`
`8.
`
`I downloaded a file containing the report marked Exhibit 1034 from
`
`the URL “ ttp://smithsonianchips.si.edu/ice/cd/9702 524.pd ’ prior to May 4,
`
`2015. Exhibit 1034 is a true and correct copy of this report.
`
`9.
`
`On November 25, 2015, I visited the URL http://whois.icann.org/en
`
`and performed a lookup on the domain name “smithsonianchips.si.edu.” Exhibit
`
`1048 is a true and correct copy of a printout I made on November 25, 2015 of the
`
`results contained in a webpage available at the URL
`
`“http://whois.icann.org/'en/lookup?name=smithsonianchips.si.edu” on that date.
`
`10. On November 25, 2015, I visited the webpage located at
`
`http://smithsonianchipssi.edu/ using Microsofi Internet Explorer. Petitioner’s
`
`Exhibit 1049 is a true and correct copy of the printout of that webpage that 1
`
`
`
`generated using the Adobe Acrobat webpage conversion program from within
`
`Microsoft Internet Explorer.
`
`1 1.
`
`Also on November 25, 2015, I followed the link identified by “ICE -
`
`Integrated Circuit Engineering Cogporation” on the webpage depicted in Ex. 1049.
`
`Exhibit 1050 is a true and correct copy of the webpage at that link that I generated
`
`using the Adobe Acrobat webpage conversion program from within Microsoft
`
`Internet Explorer.
`
`12. Also on November 25, 2015, I followed the link identified by “Series
`
`4, Construction Analysis” on the webpage depicted in Ex. 1050. Exhibit 1051 is a
`
`true and correct copy of the webpage at that link that I generated using the Adobe
`
`Acrobat webpage conversion program from within Microsoft Internet Explorer.
`
`13.
`
`I hereby declare that all statements made herein of my own knowledge
`
`are true, and that all statements made on information and belief are believed to be
`
`true. I further declare that these statements were made with the knowledge that
`
`willful false statements are punishable by fine or imprisonment, or both, under
`
`Section 1001 of Title 18 of the United States Code.
`
`Respectfully submitted,
`
`
`
`Dated December 7, 2015
`
`David J - Cooperberg
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