`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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` Taiwan Semiconductor Manufacturing Company, Ltd.
`Petitioner
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`v.
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`GODO KAISHA IP BRIDGE 1
`Patent Owner
`____________
`
`Case IPR2016-01379
`Patent 6,197,696
`____________
`
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`
`
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`DECLARATION OF SEUNG WOO HUR
`I, Seung Woo Hur, make the following Declaration pursuant to 28 U.S.C.
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`§ 1746:
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`1.
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`I am an attorney with the law firm of Ropes & Gray LLP. I have
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`worked at Ropes & Gray LLP since 2013.
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`2.
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`I provide this Declaration in connection with Patent Owner’s
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`Preliminary Response to the above-captioned Petition for Inter Partes Review of U.S.
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`Patent No. 6,197,696. Unless otherwise stated, the facts stated in this Declaration are
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`based on my personal knowledge.
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`3.
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`Exhibit 2001 is a true and correct copy of an excerpt from N. Sclater &
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`J. Markus, McGraw-Hill Electronics Dictionary (6th ed. 1997). This document was
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`1
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`IP Bridge Exhibit 2006
`TSMC v. IP Bridge
`IPR2016-01379
`Page 00001
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`obtained from the library of Ropes & Gray LLP. An exhibit label and page numbers
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`have been added to the bottom of this document but no other alterations have been
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`made.
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`4.
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`Exhibit 2002 is a true and correct copy of an excerpt from R. F. Graf,
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`Modern Dictionary of Electronics (6th ed.1984), as filed in the concurrent case Godo
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`Kaisha IP Bridge 1 v. Broadcom Ltd., et al., Case. No. 2:16-cv-134 (D.I. 67-2). This
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`document was obtained by downloading it from the docket of that case on Public
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`Access to Court Electronic Records. An exhibit label and page numbers have been
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`added to the bottom of this document but no other alterations have been made.
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`5.
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`Exhibit 2003 is a true and correct copy of an excerpt from R. F. Graf,
`
`Modern Dictionary of Electronics (7th ed. 1999). This document was obtained from
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`the library of Ropes & Gray LLP. An exhibit label and page numbers have been
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`added to the bottom of this document but no other alterations have been made.
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`6.
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`Exhibit 2004 is a true and correct copy of an excerpt from S. M. Kaplan,
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`Wiley Electrical and Electronics Engineering Dictionary (2004). This document was
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`obtained from the library of Ropes & Gray LLP. An exhibit label and page numbers
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`have been added to the bottom of this document but no other alterations have been
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`made.
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`7.
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`Exhibit 2005 is a true and correct copy of the October 7, 2016
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`Preliminary Constructions in Godo Kaisha IP Bridge 1 v. Broadcom Ltd., et al., Case. No.
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`2:16-cv-134. This document was received from Patent Owner’s Counsel, who
`2
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`Page 00002
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`obtained it from the District Court for the Eastern District of Texas. An exhibit label
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`and page numbers have been added to the bottom of this document but no other
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`alterations have been made.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed on October 20, 2016
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`at New York, NY
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`Seung Woo I-lur
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`Page 00003
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`Page 00003