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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Robert Bosch LLC and Daimler AG,
`Petitioner
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`V.
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`Orbital Engine Company Pty Limited,
`Patent Owner
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`Patent No. 5,655,365
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`DECLARATION OF CATHERINE ALEXANDROVNA VASSILKOVA
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`Page 1 of 6
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`BOSCH-DAIMLER EXHIBIT 1016
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`Page 1 of 6
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`BOSCH-DAIMLER EXHIBIT 1016
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`1.
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`I am currently a co-owner of Independence Legal Support
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`(“Independence”), P.O. Box 1807 Greenbelt, MD 20768. Although I am being
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`compensated as part of my employment with Independence, no part of my
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`compensation depends on the outcome of this proceeding, and I have no other
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`interest in this proceeding.
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`2.
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`In 2007, I received a Bachelor of Arts in Economics from the
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`University of Maryland, College Park. Since 2011, I have been employed by
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`Independence. As part of my standard work duties, I am regularly asked to search
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`for and collect documents, including research papers, from libraries, including the
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`Library of Congress and other university and college libraries.
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`3.
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`On October 13, 2015, I received two requests to retrieve specific
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`publications from Alana Bevan, an Information Resource Librarian, at the law firm
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`of Finnegan, Henderson, Farabow, Garrett & Duimer LLP, who I understand is
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`counsel to Robert Bosch LLC in this proceeding before the United States Patent
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`and Trademark Office.
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`4.
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`I was asked to outline my efforts to find these publications.
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`Page 2 of 6
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`Page 2 of 6
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`5.
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`First, Ms. Bevan asked Independence to provide copies of the relevant
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`portion of a publication titled “IIEC: Inter-Industry Emission Control, Progress
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`Report, May 1972” (“IIEC”). According to the WorldCat database, Ms. Bevan
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`told Independence that the IIEC publication was available at many university
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`libraries including Penn State, Indiana University, Michigan State University,
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`Texas A&M, University of Arizona, Cleveland State University, West Virginia
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`University, Case Western Reserve University, University of Kentucky, and UC
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`Berkeley.
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`6.
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`Specifically, Ms. Bevan asked us to scan the following from the IIEC
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`publication: cover page, copyright page, Table of Contents (in its entirety), all
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`pages within the publication that contained the following paper: “Methods for Fast
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`Catalytic System Warm Up During Vehicle Cold Starts” by Bernhardt and
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`Hoffinan (SAE technical paper 720481)(“Bemhardt”), and a date
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`received/processed stamp from the library, if possible.
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`7.
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`On October 15th, 2015, I retrieved a copy of the IIIEC publication
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`from the University of Kentucky. Specifically, on October 14th, 2015 I submitted
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`a request by email for Title/copyright/table of contents/date-stamp (showing the
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`Page 3 of 6
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`Page 3 of 6
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`date of receipt by the library) pages + "Methods for fast catalytic system warm-up
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`during vehicle cold starts", by W.E. Bernhardt [and] E. Hoffmann from IIEC :
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`inter-industry emission control: progress report, May 1972 to the University of
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`Kentucky W.T. Young Library Interlibrary Loan Department. The librarian with
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`the University of Kentucky W.T. Young Library Interlibrary Loan Department
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`instructed that we complete and return a copy of the American Library Association
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`Interlibrary Loan Request Form to process our request. The completed ALA form
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`was submitted by email on October 14th, 2015 and the requested copy was
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`received from the University of Kentucky W.T. Young Library Interlibrary Loan
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`Department librarian in PDF format by email on October 15th, 2015.
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`8.
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`On October 15, 2015, I sent a copy of the relevant portions of the
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`IIEC Report containing Bernhardt to Ms. Bevan at Finnegan. A copy of what I
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`received from the University of Kentucky, which I sent to Ms. Bevan, is attached
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`as Ex. 1012.
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`9.
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`Second, on October 13, 2015, Ms. Bevan asked Independence to V
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`provide copies of the relevant portion of a publication titled SAE 1972
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`Page 4 of 6
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`Page 4 of 6
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`Transactions - V81-A (“SAE 1972 Transactions”) that included the Bernhardt
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`reference from the Library of Congress.
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`10.
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`On October 14th, 2015, Sara Elspeth Callahan, a co-owner of
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`Independence, retrieved a copy of the SAE 1972 Transactions publication from the
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`Library of Congress. Specifically, Sara Elspeth Callahan requested the print
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`volume from the stack collection at the Library of Congress, received the volume
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`from a staff member, and scarmed the copy.
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`1.
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`On October 14, 2015, Sara Elspeth Callahan sent a copy of the
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`relevant portions of the SAE 1972 Transactions journal containing Bernhardt to
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`Ms. Bevan at Finnegan. A copy of what Sara Elspeth Callahan received from the
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`Library of Congress, which she sent to Ms. Bevan, is attached as Ex. 1013.
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`2.
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`The copy of the SAE 1972 Transactions journal received from Library
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`of Congress includes on the second page Library of Congress Catalog Card
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`Number: 12-14987, as well as a stamp dated May 24, 1974 stating “Copyright
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`Office - Copy - Library of Congress.” In addition, at the top of the second page,
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`the following handwriting is provided: “TL,, .S6, v. 81, sect. 3, 1972.” In addition,
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`the Bernhardt paper is listed in the Table of Contents on the third page as
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`Page 5 of 6
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`Page 5 of 6
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`document number 720481. On the first page of the Bernhardt paper starting on the
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`fifth page, this same. document number, 720481, is listed.
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`13.
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`I declare that all statements made herein of my knowledge are true,
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`and that all statements made on information and belief are believed to be true, and
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`that these statements were made with the knowledge that willful false statements
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`and the like so made are punishable by fine or imprisonment, or both, under
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`Section 1001 of Title 18 of the United States Code.
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`Dated:
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`Ngyember 6, 2015
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`By: 4,
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