`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`SONY CORPORATION,
`Petitioner
`
`v.
`RAYTHEON COMPANY,
`Patent Owner
`_______________
`
`Case IPR2015-01201
`
`Patent 5,591,678
`_______________
`
`DECLARATION OF MICHELLE C. BATES
`
`000001
`
`Raytheon 2001
`
`
`
`I, Michelle C. Bates, hereby declare as follows:
`1.
`I am over eighteen (18) years of age and in all respects fully competent
`to make this Declaration. I have personal knowledge of the facts, as stated herein,
`and all are true and correct.
`2.
`I am Manager, Export/Import Licensing, and an Empowered Official
`at Raytheon Company (“Raytheon”)
`3.
`I have been informed that in the present proceeding Sony Corporation
`(“Sony”) has filed a petition challenging the validity of the ‘678 patent.
`4.
`I have also been informed that in order to defend against Sony’s
`challenges, Raytheon must submit documents that were previously determined to
`be governed by The International Traffic in Arms Regulations (“ITAR”), 22 C.F.R.
`Parts 120-130, including documents related to the conception and reduction to
`practice of the inventions claimed in the ‘678 patent and the commercial success of
`the inventions. I will refer to those documents herein as the “ITAR Documents.”
`5.
`Raytheon Company is a technology and innovation leader that has
`developed technologies for numerous applications, including for national defense.
`Raytheon is a major defense contractor for the United States and much of the
`technology and information developed at Raytheon is subject to strict
`confidentiality requirements and regulations, including the ITAR.
`6.
`I am familiar with the ITAR, and part of my responsibilities at
`Raytheon are to work with counsel to ensure that Raytheon complies with the
`ITAR. Raytheon takes its obligations and commitment to national security very
`
`000002
`
`
`
`seriously. Raytheon has developed internal protocols, with the assistance of
`counsel specializing in the ITAR, for determining whether documents are subject
`to the ITAR. Once Raytheon determines that documents are governed by the
`ITAR, they must be treated according to the ITAR.
`7.
`If Raytheon ITAR restricted information is compromised, Raytheon
`has both an interest and a duty in making sure a proper disclosure is filed with
`DDTC. Raytheon’s practice, before providing ITAR restricted information to third
`parties such as vendors, is to require the third party to notify Raytheon in the event
`of any potential ITAR violation. Such notification allows Raytheon to assist in any
`corrective measures necessitated by the infraction.
`
`I declare under the penalty of perjury under the laws of the United States of
`
`America that the foregoing is true and correct.
`Michelle C Bates
`______________________________
`
`Date: February 19, 2016
`
`Digitally signed by Michelle C Bates
`DN: c=US, o=IdenTrust ACES Business Representative,
`ou=RAYTHEON COMPANY, cn=Michelle C Bates,
`0.9.2342.19200300.100.1.1=A01097C000001466C86D8920
`00049D5
`Date: 2016.02.19 16:29:11 -05'00'
`
`000003
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