AFFIDAVIT OF DR. BRUCE HAJEK
`
`I, Dr. Bruce Hajek, declare as follows:
`
`1.
`
`I am employed by the University of Illinois at Urbana-Champaign
`
`(“UIUC”). My address is 105 Coordinated Science Laboratory MC 228, 1308 W.
`
`Main St. Urbana Illinois 61801.
`
`2.
`
`I received B.S. Math and MS. EE degrees from University of Illinois in
`
`1976 and 1977 respectively, and Ph.D. EE from University of California Berkeley
`
`in 1979.
`
`I joined the University of Illinois at Urbana-Champaign in 1979.
`
`3.
`
`I am a Center for Advanced Study Professor of Electrical and Computer
`
`Engineering, Professor of the Coordinated Science Laboratory, and Hoef’t Chair of
`
`Engineering at the University of Illinois.
`
`4.
`
`For over 50 years, the University of Illinois at Urbana-Champaign has
`
`hosted the Annual Allerton Conference on Communication, Control, and
`
`Computing (“Allerton Conference”) at the Allerton Retreat Center. The Allerton
`
`Conference includes several days of technical programs by scholars on various
`
`technical subjects relating to the fields of communication, control and computing.
`
`All papers presented at the Allerton Conference are published in official
`
`Conference Proceedings each year.
`
`1
`
`Apple vs. Caltech
`IPR2017-00219
`Apple 1232
`
`Apple vs. Caltech
`IPR2017-00219
`Apple 1232
`
`1
`
`
`
`I, Dr. Bruce Hajek, declare as follows:
`
`1.
`
`I am employed by the University of Illinois at Urbana-Champaign
`
`(“UIUC”). My address is 105 Coordinated Science Laboratory MC 228, 1308 W.
`
`Main St. Urbana Illinois 61801.
`
`2.
`
`I received B.S. Math and MS. EE degrees from University of Illinois in
`
`1976 and 1977 respectively, and Ph.D. EE from University of California Berkeley
`
`in 1979.
`
`I joined the University of Illinois at Urbana-Champaign in 1979.
`
`3.
`
`I am a Center for Advanced Study Professor of Electrical and Computer
`
`Engineering, Professor of the Coordinated Science Laboratory, and Hoef’t Chair of
`
`Engineering at the University of Illinois.
`
`4.
`
`For over 50 years, the University of Illinois at Urbana-Champaign has
`
`hosted the Annual Allerton Conference on Communication, Control, and
`
`Computing (“Allerton Conference”) at the Allerton Retreat Center. The Allerton
`
`Conference includes several days of technical programs by scholars on various
`
`technical subjects relating to the fields of communication, control and computing.
`
`All papers presented at the Allerton Conference are published in official
`
`Conference Proceedings each year.
`
`1
`
`Apple vs. Caltech
`IPR2017-00219
`Apple 1232
`
`Apple vs. Caltech
`IPR2017-00219
`Apple 1232
`
`1
`
`
`
`5.
`
`I have been involved with the Allerton Conference in a number of official
`
`capacities since at least 1979, and have attended the conference nearly every year
`
`since 1976. I have also served as co—chair for the conference six times in 1985,
`
`1988, 1998, 1999, 2011, and 2012.
`
`6.
`
`Both from my own participation in the conference (as a presenter and author
`
`of conference papers), and from my service as co-chair of the Allerton Conference,
`
`I have become thoroughly familiar with the schedule and practices of the Allerton
`
`Conference as they relate to the submission of papers, presentation of papers at the
`
`conference, and the publication of the Conference Proceedings.
`
`7.
`
`The Allerton Conference is held on an annual basis during the fall, typically
`
`at the end of September or in early October. The Allerton Conference is open to
`
`the public for attendance. Any person who wants to attend, and is able to pay the
`
`attendance fee, can attend the Allerton Conference. The 1998 and 1999 Allerton
`
`Conferences were among the premiere conferences on the topic of error correction
`
`coding theory, and those who were interested in this topic would have been aware
`
`of these conferences. Before each Allerton Conference, the conference issues a
`
`call for papers on particular areas of technical interest. The deadline for initial
`
`paper submissions is in the summer before the conference. Toward the end of the
`
`summer, at least a month prior to the conference, authors are notified whether their
`
`2
`
`
`
`papers are accepted for presentation at the Conference Proceedings. Those authors
`
`then present their paper during the conference itself.
`
`8.
`
`Authors must deposit their final papers with the conference Secretariat on
`
`the Friday morning after the conference is over. Conference staff assemble the
`
`papers and then sends the assembled papers to a publisher for printing. The printed
`
`copies of the Conference Proceedings are shipped to all conference participants
`
`and any members of the public (including individuals and/or institutions) who have
`
`ordered a copy of the Conference Proceedings. Copies of the Conference
`
`Proceedings are also made available for purchase from the conference Secretariat
`
`by any member of the public as soon as printing is complete.
`
`9.
`
`It takes no more than four to five months from the end of the conference to
`
`the final publication and shipment of the complete Conference Proceedings.
`
`Accordingly, the complete Conference Proceedings are published by no later than
`
`February of the year following the conference. I am aware of no instance in which
`
`the Conference Proceedings were not published by February of the year following
`
`the conference — i.e., the Conference Proceedings for the 36th Annual Allerton
`
`Conference, held in September 1998, were published no later than February 1999,
`
`and the Conference Proceedings for the 37th Annual Allerton Conference, held in
`
`September 1999, were published no later than February 2000.
`
`3
`
`
`
`10.
`
`In addition, from the time that conference staff sends the assembled papers
`
`to the local publisher for publication, it only takes about 10 weeks for the publisher
`
`to print and ship the Conference Proceedings. As noted above, any member of the
`
`public can purchase a copy of the Conference Proceedings from the conference
`
`Secretariat as of the date printing is complete.
`
`11. Attached as Appendix A is a true and accurate copy of a purchase order
`
`letter from Dr. Sreenivas (the co-chair of the 1999 conference) to Ms. Anderson at
`
`the Purchasing Division of the University of Illinois at Urbana-Champaign for the
`
`37th Annual Allerton Conference on Communications Control and Computing
`
`Proceedings (“Sreenivas Purchase Order”). The Sreenivas Purchase Order is dated
`
`December 8, 1999, and I understand that Angie Marie Ellis (Office Manager,
`
`Decision and Control Laboratory University of Illinois at Urbana-Champaign)
`
`obtained the purchase order from the Allerton Conference records. The Sreenivas
`
`Purchase Order confirms that the conference staff sent the assembled papers for the
`
`37"1 Annual Allerton Conference to the local publisher for publication on or about
`
`December 8, 1999.
`
`12.
`
`Based on my experience, the Sreenivas Purchase Order is the final order
`
`from the conference before printing. Accordingly, printing of the 37th Annual
`
`Allerton Conference on Communications Control and Computing Proceedings was
`
`complete, and the Conference Proceedings shipped, about 10 weeks after the date
`
`4
`
`
`
`of this letter. Even accounting for possible delays due to the December holidays,
`
`the publication would have been done within 10 weeks after the date of this letter.
`
`13.
`
`Based on my experience, this record confirms that the proceedings of the
`
`37th Annual Allerton Conference on Communications Control and Computing
`
`were published and shipped no later than February 2000.
`
`
`
`5
`
`
`
`APPENDIX A
`
`6
`
`
`
`R. S. Sreenivas
`
`217/333—7735
`e—mail: rsree@uiuc.edu
`
`December 8, 1999
`
`Ms. Joan Anderson
`
`Purchasing Division
`University of Illinois at Urbana—Champaign
`207 Henry Administration Building, MC—364
`Campus Mail
`
`Re: Printing of the 37th Annual Allerton Conference on Communication, Control
`and Computing Proceedings
`
`Dear Ms. Anderson:
`
`I have reviewed the printing quotation, #Q—9192, for the printing of the 37th Annual Allerton
`Conference on Communication, Control and Computing proceedings.
`I accept the low bid from Cushing—
`Malloy, option A for $8,417.00 The final page count is 1363. The cover color is India.
`
`Quote #Q—9192 and this memo has been referenced as attachments in the EOS request number.
`
`If
`
`you have any questions, please contact either the Allerton Conference secretary, Becky Lonberger,
`becky@contorl.csl.uiuc.edu, phone 3—0282 or myself.
`
`Sincerely,
`
`R. S. Sreenivas
`
`7
`
`
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