`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SONY CORPORATION,
`Petitioner
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`V.
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`RA YTHEON COMPANY,
`Patent Owner
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`Case IPR2015-01201
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`Patent 5,591,678
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`DECLARATION OF DAVID ROBINSON
`REGARDING THE ACTUAL REDUCTION TO PRACTICE OF
`U.S. PATENT NO. 5,591,678
`
`I, David A. Robinson, declare:
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`1.
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`I am over eighteen years of age and in all respects fully competent to
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`make this Declaration. I have personal knowledge of the facts, as stated herein, and
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`all are true and correct.
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`2.
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`During the timeframe of 1990-1994,1 was employed as an engineer at
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`Raytheon2018-0001
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`Sony Corp. v. Raytheon Co.
`IPR2015-01201
`
`
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`the Carlsbad Research Center (CRC) for Hughes Aircraft Company. The CRC was
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`part of the Hughes Microelectronics Center (HMC). During these years, I worked
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`with various CRC personnel, including Ron Finnila, Joe Bendik, Joe Tyra, and
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`Gerard (Jerry) Malloy.
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`3.
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`During this timeframe, I was aware of the work being done by Ron
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`Finnila, Joe Bendik, and Jerry Malloy at the CRC, including work related to silicon
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`on silicon dioxide on silicon wafers (i.e., SOI wafers).
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`4.
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`I have reviewed Exhibit 2009, RAYOOOOO185-88, which is an
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`invention disclosure form ("1992 Invention Disclosure"). I signed this document as
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`a witness on November 18, 1992 and it was recorded by Hughes Aircraft on
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`November 20, 1992.
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`5.
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`I affirm that the signature on the bottom of pages numbered
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`RAYOOOOO 186-188 is mine. By signing my name, I affirmed that I had read and
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`understood the 1992 Invention Disclosure. I believed this affirmation to be true at
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`the time of execution, and I have no reason to doubt it now.
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`I declare under the penalty of perjury under the laws of the United States of
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`America that the foregoing is true and correct.
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`Date: March 7, 2016
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`2
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`Raytheon2018-0002