Exhibit 2038
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`Exhibit 2038
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`Exhibit 2038
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`DECLARATION OF DR. TIEJUN WANG UNDER 37 CFR § 1.131
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`I, Tiejun Wang, Ph.D, make the following declaration from my own
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`personal knowledge and, if called upon, I can and will competently testify under
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`oath. I am over 18 years of age, and declare as follows:
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`1.
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`I am an inventor of the inventive subject matter described in U.S.
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`Patent No. 7,899,492 and its continuations, which are titled "Method, System and
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`Apparatus for Displaying the Multimedia Information from Wireless
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`Communication Networks" which issued from non-provisional U.S. patent
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`application no. 11/165,341, filed on June 24, 2005 (the "Patent"). The Patent
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`claims priority to a provisional application Ser. No. 60/588, 358 filed on July 16,
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`2004, which is titled "A method and system for displaying the multimedia
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`information from wireless communications or portable IT devices" (the
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`"Provisional Application").
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`2.
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`No later than March 30, 2004, I, along with my co-inventors,
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`conceived of the inventive subject matter described in the Patent, more specifically
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`the invention recited in the issued claims (the "Claims") in the Patent. Following
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`conception, I, along with my co-inventors, (sometimes collectively referred to as
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`"we" hereafter), diligently engaged in preparation of the Provisional Application
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`for filing with the U.S. Patent and Trademark Office.
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`1
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`VIS EXHIBIT 2038
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`Page 1 of 9
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`3.
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`Prior to March 30, 2004 through July 16, 2004, I, along with my co-
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`inventors, engaged diligently in researching industry operation for prior art and
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`potential market applications of our invention. We searched diligently in global
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`journal and publication databases for latest research efforts related with our
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`invention.
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`4.
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`Prior to March 30, 2004, and continuing through July 16, 2004, I
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`focused my research on technical issues related with our invention. I studied many
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`latest publications in IEEE journals and updated my co-inventors of the pioneering
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`research in the field of our invention over our routine conference calls and in
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`person meetings.
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`5.
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`Exhibit 2025 and Exhibit 2026 attached hereto, are documents
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`authored by me before March 30, 2004, evidencing the conception and design of
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`the inventive subject matter. Exhibits 2025, 2026, and 2011 include various
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`examples evidencing the conception and design of the inventive subject matter.
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`6.
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`Exhibit 2025 illustrates many key concepts for the invention such as a
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`"decoder" connected with an "encoder" "6 M bits/second" "JPEG" "X 264"
`.
`'
`'
`'
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`"buffer", "LCD TV", "video" "audio", "DVI", "HDMI", and "HDMI cable".
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`7.
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`Exhibit 2026 illustrates the background of the conception during
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`2003-2004 period of time. Prior March 30, 2004, I, along with my co-inventors,
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`envisioned next generation cellular network, 3G, would bring multimedia
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`2
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`Page 2 of 9
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`information to cellular communications. In connection with my research, I, along
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`with my co-inventors, took stock of development of 2G, 2.5G, and 3G and
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`identified a problem caused by small screens of cellular phones for multimedia
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`information enjoyment.
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`8.
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`Exhibit 2026 illustrates an example of our conception of our
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`inventions including processing of a high-resolution multimedia signal received
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`through a mobile terminal for production of corresponding multimedia information
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`on a separate external display. The high-resolution multimedia information in our
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`invention may include 3D image, videos, GPS, Internet content, TV program,
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`online games, and video games. Exhibit 2026 indicates the market applications of
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`our invention include vehicles and entertainment industry in addition to
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`telecommunications. Exhibit 2026 lists a few exemplary application environments
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`for our invention including a vehicle, a hotel room, and any public area with a
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`large display for multimedia information content.
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`9.
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`Fig 1 and Fig 2 on page 4 of Exhibit 2026 compare an embodiment of
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`our invention with a prior art example. The figure at the top of page 1 of
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`Exhibit 2026 describes exemplary applications and system structure of our
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`invention. Fig 3 on page 7 of Exhibit 2026 provides an exemplary flow chart for
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`our invention including: a mobile terminal receives multimedia information
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`through communications with a base station; a video signal processor processes the
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`3
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`Page 3 of 9
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`multimedia information; and the video signal processor provides the processed
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`multimedia information and drives a separate external monitor for displaying the
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`processed multimedia information, etc.
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`10. Exhibit 2026 presents an example of a video signal processor for
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`processing a video signal for the high-resolution multimedia information content
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`received through a cellular network. The video signal processor can be included
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`inside a cellular phone or can reside in an external device connecting a cellular
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`phone with an external display.
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`11. During the conception and reduction to practice of our invention, we
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`consulted our forme:r lawyer, Mr. Baigeng Jiang, regarding our invention. I, along
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`with my co-inventor, Dr. Tiehong Wang, and my wife, Mrs. Ning Wang, visited
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`Mr. Jiang on Chinese New Year holiday at Mr. Jiang' s house in San Diego.
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`Chinese New Year of that year took place on January 22, 2004, which confirms
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`that Exhibits 2025 and 2026 were created before March 30th, 2004. During our
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`meeting, we showed Mr. Jiang Exhibits 2025 and 2026 and described our
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`invention. Mr. Jiang suggested us to file a patent application on our invention. We
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`asked Mr. Jiang about challenges and prospects for intellectual property
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`development and commercialization for our invention. Mr. Jiang suggested us to
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`talk to a lawyer specialized in patent law.
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`4
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`Page 4 of 9
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`12.
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`In the time period between our meeting with Mr. Jiang around January
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`22nd, 2004 and the provisional application filing date of July 16, 2004, we
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`diligently pursued efforts to file the Provisional Application, including talking to
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`many patent lawyers and working to gather information for our patent application.
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`We discussed in depth with multiple patent lawyers about global patent application
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`and prosecution strategy for our inventions. We learned about filing a US patent
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`application and associated cost. We further learned by talking to these lawyers that
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`we could file a provisional application without hiring a lawyer. As examples of our
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`efforts during this time period, we bought and borrowed books and searched online
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`regarding how to file a provisional and a non-provisional patent application in the
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`US, China, and the world.
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`13. After our meeting with Mr. Jiang during Chinese New Year holiday of
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`2004 and before we filed the Provisional Application, I focused my research on
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`improving digital data rate of wireless communication system through time(cid:173)
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`varying wireless fading channel and other technical issues related with our
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`invention. Exhibits 2027, 2029, 2030, and 2031 are examples of my research
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`developed in the midst of our diligent efforts to further advance our invention and
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`prepare the Provisional Application:
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`5
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`Page 5 of 9
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`•
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`"Performance degradation of OFDM system due to Doppler
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`spreading" was published in IEEE Transactions on Wireless Communications, vol.
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`5, pp, 1422-1432, June 2006 (Exhibit 2029).
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`•
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`"Techniques for suppression of Intercarrier Interference in OFDM
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`systems" was published in proc. the IEEE Wireless Communications &
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`Networking Conference (WCNC '05), pp. 39-44, March 2005 (Exhibit 2030).
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`•
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`"Interference analysis of filtered multitone modulation over time-
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`varying frequency-selective fading channels" was published in IEEE Transactions
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`on Communications, pp, 717-727, April 2007 (Exhibit 2031).
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`•
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`Exhibit 2027 is a copy of my research pater titled "Analysis of per-
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`channel equalized filtered multitone modulations over time-varying fading
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`channels." This paper was awarded "the Best Paper" Award at the IEEE
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`PIMRC '06 in Helsinki, Finland (Exhibit 2028). The research was later published in
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`IEEE Transactions on Communications, pp, 71 7-727, April 2007 (Exhibit 2031)
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`and has been cited popularly.
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`14. My research on time-varying fading channel estimation, channel
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`coding for frequency selective fading channel, and FMT filtering to enhance
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`OFDM wireless communication system helped us improve the structure and
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`optimize the operation of our invented system based on a solid understanding of
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`multimedia information transmission over wireless networks.
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`6
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`Page 6 of 9
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`15. My research results developed after our meeting with Mr. Jiang and
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`prior to our filing of the Provisional Application support our view of multimedia
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`information applications over wireless communication networks and the potential
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`of our invention. My technical research work during the period also allowed me to
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`greatly assist our efforts in diligently preparing the Provisional Application.
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`16. Our diligent efforts are also reflected by our routine meetings and
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`phone calls which took place multiple times every week during March 30, 2004 -
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`July 16, 2004 period on discussion of our invention details and preparation of our
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`Provisional Application. We also considered and discussed the structures needed to
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`organize the features of our invention into the formal requirements of a US patent
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`application. Exhibit 2011 demonstrates our effort for drafting the Provisional
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`Application.
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`1 7. Our diligent efforts are also reflected by our efforts on keeping track
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`of leading research and publications in the field of our invention. I routinely
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`updated my co-inventors of my research findings and relevant leading technical
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`efforts from both industry and academia over our phone calls and meetings during
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`March 30, 2004 - July 16, 2004 period.
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`18. The inventive concepts stated in Exhibit 2025 and 2026 were
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`conceived and in the possession of us prior to March 30, 2004. I, along with my
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`co-inventors, diligently worked to reduce the invention to practice by studying
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`7
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`Page 7 of 9
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`relevant pioneering researches and writing and filing the Provisional Application.
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`Our diligent efforts to reduce the invention to practice started prior March 30, 2004
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`and continued without any break through the filing of the Provisional Application.
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`19. The patent has been successfully licensed to Samsung Electronics Co.,
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`Ltd and LG Electronics, Inc. While the fact of their existence is not confidential,
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`the terms of these licenses are confidential, thus copies of these licenses cannot be
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`publicly disclosed.
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`20. The Patent is assigned to Virginia Innovation Sciences, Inc. Upon
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`information and belief, I understand that Exhibits 20 11, 2025, and 2026 are
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`proprietary and confidential records of Virginia Innovation Sciences, Inc. and that
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`by providing these exhibits in this proceeding Virginia Innovation Sciences, Inc.
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`does not intend to waive confidentiality to any other confidential records of
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`Virginia Innovation Sciences, Inc. Upon information and belief, I understand that
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`Virginia Innovation Sciences, Inc. is not waiving its attorney-client privilege as to
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`any information covered by the privilege and related to the inventive subject matter
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`or this Patent. To the extent that I also have such privilege, I do not waive our
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`attorney-client privilege as to any information related to the inventive subject
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`matter.
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`21.
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`I declare under penalty of perjury that all statements made herein are
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`of my own knowledge and are true; and that these statements were made with the
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`8
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`Page 8 of 9
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`knowledge that willful false statements and the like so made are punishable by fine
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`or imprisonment, or both, under Section 1001 of Title 18 of the United States
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`Code, and that such willful false statements may jeopardize the validity of the
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`Patent or any patent issuing thereon.
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`January 16, 2018
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`Tie jun Wang, Ph.D.
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`9
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`Page 9 of 9
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