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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`In re: Inter Partes Review of:
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`U.S. Pat. No. 7,116,710
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`U.S. Pat. No. 7,421,032
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`U.S. Pat. No. 7,421,781
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`and U.S. Pat. No. 8,284,833
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`Inventor: Hui Jin, et al
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`:
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`IPR No. Unassigned
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`Assignee: California Institute of Technology
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`Common Title:
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`Serial Concatenation of Interleaved Convolutional Codes
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`Forming Turbo-Like Codes
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
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`Box 1450
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`Alexandria, Virginia 223 13-1450
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`Submitted Electronically via the Patent Review Processing System
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`DECLARATION OF PAUL H. SIEGEL
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`Apple 1020
`Apple 1020
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`Declaration of Paul“H. Siegel
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`I, Paul H. Siege], declare as follows:
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`1.
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`I am over the age of 18 and am legally competent to make this
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`declaration. I make this declaration based upon my own personal knowledge.
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`2.
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`I am currently a Professor at the University of California, San
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`Diego, in the Department of Electrical and Computer Engineering, the Jacobs
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`School of Engineering, and the Center for Memory and Recording Research.
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`3.
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`I have been asked to provide a statement of certain facts related to
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`work I did together with Henry D. Pfister relating to the serial concatenation of
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`rate—l codes through uniform random interleavers.
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`4.
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`Beginning in early 1999, I collaborated with Dr. Pfister, then a
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`Ph.D student of mine, to show that improved error—correcting codes can be
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`constructed from simple components, e.g., by serially concatenating an
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`arbitrary outer code of rate r < l and m identical rate-1 inner codes.
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`5.
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`The result of that collaboration was a presentation at the 1999
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`Allerton Conference on Communications, Control and Computing, in Allerton,
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`Illinois (“l999 Allerton Conference”) in September 1999. This conference was
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`held September 22-24, 1999, and was open to the public for attendance. Any
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`person who wanted to attend and was able to pay the attendance fee could
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`attend. The 1999 Allerton Conference was considered one of two primary
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`conferences on the topic of iterative decoding during the time. The 1999
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`Allerton conference itself, as well as the proceedings that took place there,
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`were publicized and generally known to those who were interested in topics
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`relating to error-correcting codes and iterative decoding.
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`6.
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`At the 1999 Allerton Conference, I presented a series of slides
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`relating to my work with Dr. Pfister on a class of codes based on serial
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`concatenation of a rate-r code with m 2 1, uniformly interleaved rate-1 codes.
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`In these slides, I discussed an example of these codes, called 21 “Repeat-
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`Accumulate-Accumulate” (or “RAA”) code. An RAA code is is similar to an
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`RA code (Divsalar, et al., Allerton ’98) to which an additional accumulator has
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`been added. I compared RAA codes to RA codes and concluded that the RAA
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`codes were able to achieve a lower word-error—probability than the RA codes,
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`demonstrating that the performance of RA codes could be improved by
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`including an additional accumulator. This presentation was entitled “The
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`Serial Concatenation of Rate—l Codes Through Uniform Random Interleavers,”
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`and I presented it in the IIA: Coding Theory: Iterative Decoding and Turbo
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`Codes Session on September 22, 1999, the first day of the conference. A true
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`and accurate copy of the slides that I presented at the 1999 Allerton Conference
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`is attached as Exhibit 1.
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`I hereby declare that all statements made herein of my own knowledge are
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`true and that all statements made on information or belief are believed to be
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`true; and further that these statements were made with the knowledge that
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`willful false statements and the like so made are punishable by fine or
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`imprisonment, or both, under Section 1001 of Title 18 of the United States
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`Code.
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`Dated:
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`“/91 /
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`Java W
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`/
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`Paul H. Siegel
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`ActiveUS 159440043v.1