`
`I, Dr. Bruce Hajek, declare as follows:
`
`1.
`
`Iam employed by the University of Illinois at Urbana-Champaign
`
`(“UIUC”). My address is 105 Coordinated Science Laboratory MC 228, 1308 W.
`
`Main St. UrbanaIllinois 61801.
`
`2.
`
`I received B.S. Math and M.S. 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.
`
`lama Center for Advanced Study Professor of Electrical and Computer
`
`Engineering, Professor of the Coordinated Science Laboratory, and Hoeft Chair of
`
`Engineering at the University ofIllinois.
`
`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 presentedat the Allerton Conference are published in official
`
`Conference Proceedings each year.
`
`|
`
`Apple vs. Caltech
`IPR2017-00701
`Apple 1132
`
`Apple vs. Caltech
`IPR2017-00701
`Apple 1132
`
`
`
`5.
`
`[have been involved with the Allerton Conference in a numberofofficial
`
`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 myservice 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 Conferenceis held on an annualbasis during thefall, typically
`
`at the end of Septemberor in early October. The Allerton Conference is open to
`
`the public for attendance. Any person who wantsto attend, andis able to pay the
`
`attendance fee, can attend the Allerton Conference. The 1998 and 1999 Allerton
`
`Conferences were amongthe premiere conferenceson the topic of error correction
`
`coding theory, and those who wereinterested 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 forinitial
`
`paper submissionsis in the summerbefore 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 conferenceitself.
`
`8.
`
`Authors must deposit their final papers with the conference Secretariat on
`
`the Friday morningafter the conference is over. Conference staff assemble the
`
`papers and then sends the assembled papersto a publisher for printing. The printed
`
`copies of the Conference Proceedings are shippedto all conference participants
`
`and any membersofthe 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 memberofthe 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 Proceedingsfor 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 weeksfor the publisher
`
`to print and ship the Conference Proceedings. As noted above, any memberofthe
`
`public can purchase a copy of the Conference Proceedings from the conference
`
`Secretariat as of the date printing is complete.
`
`11. Attached as AppendixAis 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 Orderis 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 confirmsthat the conference staff sent the assembled papersfor the
`
`37" Annual Allerton Conferenceto the local publisher for publication on or about
`
`December8, 1999.
`
`12.
`
`Based on my experience, the Sreenivas Purchase Orderis 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 Decemberholidays,
`
`the publication would have been done within 10 weeksafter the date of this letter.
`
`13.
`
`Based on my experience, this record confirmsthat the proceedings of the
`
`37th Annual Allerton Conference on Communications Control and Computing
`
`were published and shipped nolater than February 2000.
`
`Date:
`
`Signed:
`
`5
`
`
`
`APPENDIX A
`
`6
`
`
`
`R. S. Sreenivas
`
`217/333-7735
`e-mail: rsree@uiuc.edu
`
`December 8, 1999
`
`Ms. Joan Anderson
`Purchasing Division
`University ofIllinois at Urbana-Champaign
`207 Henry Administration Building, MC-364
`Campus Mail
`
`Re: Printing of the 37Annual Allerton Conference on Communication, Control
`and Computing Proceedings
`
`Dear Ms. Anderson:
`
`| have reviewed the printing quotation, #Q-9192, for the printing of the 37Annual Allerton
`Conference on Communication, Control and Computing proceedings.
`| accept the low bid from Cushing-
`Malloy, option A for $8,417.00 The final page countis 1363. The covercoloris India.
`
`If
`Quote #Q-9192 and this memo has been referenced as attachments in the EOS request number.
`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
`
`