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`Sony Corp. v. Raytheon Co.
`IPR2015-01201
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`I, John L. Abramic, hereby declare as follows:
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`I.
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`I am over eighteen (18) years of age and in all respects fully
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`competent to make this Declaration. I have personal knowledge of the facts, as
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`stated herein, and all are true and correct.
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`2.
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`I am an attorney at Steptoe & Johnson, LLP, and I am counsel of
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`record for the Patent Owner in the present proceeding.
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`3.
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`In connection with Patent Owner’s Response in the present
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`proceeding, and to rebut the challenges made in the Petition, Patent Owner is
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`submitting Exhibits 2010-2014, and 2036, all of which relate to the conception and
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`reduction to practice of the inventions claimed in U.S. Patent No. 5,591,678 (“678
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`Patent”). These documents have been determined by Raytheon to be subject to
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`The International Traffic in Arms Regulations (“ITAR”), 22 CPR. Parts 120-130.
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`4.
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`In connection with Patent Owner’s Response in the present
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`proceeding, and to rebut the challenges made in the Petition, Patent Owner is
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`submitting Exhibits 2008 and 2009, which are invention disclosure forms
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`describing confidential research and development activities conducted at Hughes
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`Aircraft Company (“Hughes”). The documents, which contain information about
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`Hughes’s research and development and about Hughes’s internal protocols for
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`invention disclosure, expressly state that they contain Hughes proprietary
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`information.
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`Raytheon2066-0002
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`Raytheon2066-0002
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`S.
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`In connection with Patent Owner’s Response in the present
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`proceeding, and to rebut the challenges made in the Petition, Patent Owner is
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`submitting Exhibits 2015-2017, and 2038, all of which are declarations that refer
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`to, and include information from, one or more of Exhibits 2010-2014, and 2036,
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`which have been determined by Raytheon to be subject to ITAR. Exhibits 2015-
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`2017, and 2038 also refer to and include information from Exhibits 2008 and 2009.
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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 1 1, 2016
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`~
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`[
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`/’ 0*
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`Raythe0n2066-0003
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`Raytheon2066-0003