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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
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`SONY CORPORATION,
`Petitioner
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`v.
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`RAYTHEON COMPANY,
`Patent Owner
`_______________
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`Case IPR2016-00209
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`Patent 5,591,678
`_______________
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`DECLARATION OF JOHN J. DRAB
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`Sony Corp. v. Raytheon Co.
`IPR2016-00209
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`Raytheon2008-0001
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`DECLARATION OF JOHN J. DRAB
`REGARDING THE RAYTHEON’S USE OF U.S. PATENT NO. 5,591,678
`I, John J. Drab, declare:
`1.
`to make this Declaration. I have personal knowledge of the facts, as stated herein,
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`I am over eighteen (18) years of age and in all respects fully competent
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`and all are true and correct.
`2.
`I understand that Sony Corporation (“Sony”) filed a petition for inter
`partes review of Raytheon Company’s (“Raytheon”) patent, as captioned above,
`that challenges the validity of the U.S. Patent No. 5,591,678 (“’678 Patent”). I also
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`understand that Raytheon opposes Sony’s challenge.
`3.
`Lompoc and serve a technology director from Silicon detector and 3D integration
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`I am a Sr. Principle at Raytheon Vision Systems. I work in Goleta and
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`I have read and understand the ’678 Patent. I am also familiar with
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`work that occurs at our Lompoc laboratory.
`4.
`semiconductor fabrication processes used by Raytheon.
`5.
`government contracts. These contracts include space-based systems for defense
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`A vast majority of Raytheon’s revenues derive from military and
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`and exploration programs. As part of its business, Raytheon identified a
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`commercial opportunity for the process disclosed in the ’678 Patent in fabricating
`high-resolution sensors for government defense work and space programs.1
`One example was the BepiColombo space telescope2 wherein the ’678
`6.
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`1 See Ex. 2009, RAY8078-86.
`2 See id at 78.
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`2
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`Raytheon2008-0002
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`Patent was used to manufacture a microelectronic device that was incorporated into
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`a sensor module. Specifically, the methods set forth in claims-1..=3, 6-7,-10-L4, and...__ __ _
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`devices one of the microelectronic 17 of the '678 Patent were used to manufacture
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`sold for the BepiColombo project. This microelectronic device is a
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`high-resolution, radiation-hardened, visible-range sensor.3
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`7. The Si:PiN detector used in the BepiColombo space telescope began
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`a silicon etchable wafer includes with a bonded silicon wafer.4 This bonded silicon
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`wafer is layer, an Si02 etch-stop layer, and a silicon wafer layer. The detector
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`5 (Id. at 81, Fig. 5).
`hybridized to a readout wafer using Direct Bond Interconnects.
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`These interconnects allow the detector and readout wafers to electrically
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`communicate
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`with each other.6 The device is then thinned to its etch-stop layer.
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`The result is an extremely high-resolution sensor, with other desirable
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`characteristics such as noise immunity, small size, and radiation hardness.
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`8. Raytheon's ability to fabricate high-resolution image sensors using the
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`'678 Patent's process led to successful contracts from the European Space Agency
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`and the United States Air Force.
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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: June l4 , 2016
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`3
`See id at 79.
`4 See id.
`5 Id. at 81, Fig. 5
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`6 RA Y00008078, 79.
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`3
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`Raytheon2008-0003
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