Raytheon2046-0001
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`Sony Corp. v. Raytheon Co.
`IPR2015-01201
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`
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`Sony Corp. v. Raytheon Co.
`IPR2015-01201
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`2.
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`I am familiar with the record keeping policies and procedures of
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`Raytheon and I direct all of the SAS division’s records management. My duties
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`include managing inactive records and document storage processes.
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`3.
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`I understand that Raytheon acquired Hughes Aircraft Company
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`(“Hughes”) in 1997.
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`I further understand that as part of that acquisition, Raytheon
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`acquired certain patents, including U.S. Patent No. 5,591,678 (“the ’678 Patent”),
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`as well as certain documents related to the ’67 8 Patent and to Hughes’ research and
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`development (“R&D”) programs. Documents related to Hughes’ R&D programs
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`include Independent Research and Development (“IR&D” or “[RAD”) Technical
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`Plans, white papers, invention disclosures, and lab notebooks. Raytheon’s SAS
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`division has internal responsibility within Raytheon for these R&D documents and
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`for the ’678 Patent.
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`4.
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`I and my staff at the Office of Records Management conducted the
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`search for the records relating to Hughes’ R&D programs.
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`5.
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`I and my staff at the Office of Records Management have knowledge
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`of the locations where those documents are physically stored. The records from
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`Hughes’ R&D progams, including documents associated with the ’678 Patent, are
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`stored at Raytheorfs SAS facility in McKinney, Texas, other SAS facilities across
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`the United States of America, as well as third-party facilities, run by Iron
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`Mountain, located across the United States of America.
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`Raytheon2046-0002
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`Raytheon2046-0002
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`6.
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`In the course of Raytheon’s discovery investigation related to Civil
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`Action Nos. 2:15-CV-34l—.TRG—RSP, 2:l5—CV-342—JRG—RSP, both pending in the
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`United States District Court for the Eastern District of Texas, and IPR20l5—0l201,
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`I, or staff working at my direction, collected the IRAD documents, white paper,
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`invention disclosures, and lab notebook that are listed in Appendix A to this
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`declaration. These particular documents have been stored at an Iron Mountain
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`facility both prior to, and subsequent to, Raytheorfs acquisition of Hughes.
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`7.
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`I and my staff have reviewed the documents listed in Appendix A.
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`I
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`and my staff found the documents listed in Appendix A, and each of these
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`documents was in a condition that created no suspicion as to its authenticity. The
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`documents listed in Appendix A were found in Iron. Mountain facilities, which is
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`where I and my staff expect to find old Hughes documents. Each of the documents
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`listed in Appendix A is at least twenty (20) years old.
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`8.
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`Based on my work at Raytheon, I have learned, and I understand, that
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`the documents listed in Appendix A, were made at or near the time listed on the
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`documents by — or from information transmitted by — an employee at Hughes
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`Aircraft with knowledge of that activity.
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`I have further learned and understand that
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`each of the documents listed in Appendix A was generated and maintained as a
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`practice in the ordinary course of Hughes’ business.
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`I, and my predecessors at the
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`Office of Records Management, have been the custodians of the documents listed
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`Raytheon2046-0003
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`Raytheon2046-0003
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`
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`in Appendix A and have maintained these materials in the ordinary course of
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`Raytheon°s business since the 1997 acquisition of Hughes by Raytheon.
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`9.
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`My staff provided the original copies of these documents to Mr.
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`William Mclnnis, Licensing Manager at Raytheon, whom I understand provided
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`copies of these documents to Raytheon’s attorneys at Steptoe & Johnson, LLP.
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`I
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`understand that Mr. Mclnnis presently has custody of the original documents.
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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 l‘
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`,2016
`
`O5‘5ViWv’\ QL
`
`Arthur J. Medrano
`
`Raytheon2046-0004
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`Raytheon2046-0004
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`APPENDIX A
`
`
`
`2009
`
`Exhibit Description
`Hughes Aircraft Invention Disclosure: Thermal Expansion Material
`2008
`(TEM) Readout Chips, dated Aug. 8, 1990 “1990 Invention
`Disclosure” – [Bates numbered RAY00000176-184]
`[PROTECTIVE ORDER MATERIAL - SEALED]
`Hughes Aircraft Invention Disclosure: One step method of
`transferring thin film devices onto alternate substrates,dated Nov.
`11, 1992, “1992 Invention Disclosure”– [Bates numbered
`RAY00000185-88] [PROTECTIVE ORDER MATERIAL -
`SEALED]
`Hughes Aircraft Independent Research and Development Technical
`Plan 1991, Vol. 3 “1991 IRAD” (excerpts) – [Bates numbered
`RAY00004572-5004] [PROTECTIVE ORDER MATERIAL
`(ITAR)- SEALED]
`Hughes Aircraft Independent Research and Development Technical
`Plan 1991, Vol. 3 “1992 IRAD” (excerpts) – [Bates numbered
`RAY00005005-5424] [PROTECTIVE ORDER MATERIAL
`(ITAR) - SEALED]
`Hughes Aircraft 1991 IR&D Technical Plan, “1991 IRAD
`Appendices (Distribution List)” (excerpts) – RAY00007358-7651]
`[PROTECTIVE ORDER MATERIAL – (ITAR) - SEALED]
`Hughes Aircraft 1992 IR&D Technical Plan, “1992 IRAD
`Appendices (Distribution List)” (excerpts) – [Bates numbered
`RAY00007652-7941] [PROTECTIVE ORDER MATERIAL
`(ITAR) - SEALED]
`Lab Notebook No. LN1260 of Joe Bendik, dated Jan. 15, 1992
`[PROTECTIVE ORDER MATERIAL (ITAR) SEALED]
`Hughes Aircraft Technology Center, Monolithic 3-D Packaging
`Approach Applied to WSI Associative String Processor (WASP),
`“1990 Research Proposal and White Paper” [PROTECTIVE
`ORDER MATERIAL (ITAR) - SEALED]
`
`2010
`
`2011
`
`2012
`
`2013
`
`2014
`
`2036
`
`1
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