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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SONY CORPORATION,
`Petitioner
`
`V.
`
`RA YTHEON COMPANY,
`Patent Owner
`
`Case IPR2015-01201
`
`Patent 5,591,678
`
`DECLARATION OF DAVID ROBINSON
`REGARDING THE ACTUAL REDUCTION TO PRACTICE OF
`U.S. PATENT NO. 5,591,678
`
`I, David A. Robinson, declare:
`
`1.
`
`I am over eighteen 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.
`
`During the timeframe of 1990-1994,1 was employed as an engineer at
`
`Raytheon2018-0001
`
`Sony Corp. v. Raytheon Co.
`IPR2015-01201
`
`

`
`the Carlsbad Research Center (CRC) for Hughes Aircraft Company. The CRC was
`
`part of the Hughes Microelectronics Center (HMC). During these years, I worked
`
`with various CRC personnel, including Ron Finnila, Joe Bendik, Joe Tyra, and
`
`Gerard (Jerry) Malloy.
`
`3.
`
`During this timeframe, I was aware of the work being done by Ron
`
`Finnila, Joe Bendik, and Jerry Malloy at the CRC, including work related to silicon
`
`on silicon dioxide on silicon wafers (i.e., SOI wafers).
`
`4.
`
`I have reviewed Exhibit 2009, RAYOOOOO185-88, which is an
`
`invention disclosure form ("1992 Invention Disclosure"). I signed this document as
`
`a witness on November 18, 1992 and it was recorded by Hughes Aircraft on
`
`November 20, 1992.
`
`5.
`
`I affirm that the signature on the bottom of pages numbered
`
`RAYOOOOO 186-188 is mine. By signing my name, I affirmed that I had read and
`
`understood the 1992 Invention Disclosure. I believed this affirmation to be true at
`
`the time of execution, and I have no reason to doubt it now.
`
`I declare under the penalty of perjury under the laws of the United States of
`
`America that the foregoing is true and correct.
`
`Date: March 7, 2016
`
`2
`
`Raytheon2018-0002

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