`Declaration of Shuichi Matsuda
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`KAWASAKI RAIL CAR, INC.
`Petitioner,
`
`v.
`
`SCOTT BLAIR,
`Patent Owner.
`__________________
`CASE: To Be Assigned
`
`Patent No. 6,700,602
`__________________
`DECLARATION OF SHUICHI MATSUDA
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW OF
`U.S. PATENT NO. 6,700,602
`
`
`
`
`
`
`1
`
`
`P. 1
`
`KAWASAKI-1017
`
`
`
`Case No.: To Be Assigned
`Declaration of Shuichi Matsuda
`
`I, Shuichi Matsuda, make the following declaration based on my personal knowledge:
`1.
`I am General Manager for Japan Train Operation Association (“JTOA”),
`located at Higashi-Ueno 1-12-2, Taitou-ku,Tokyo. I have held the position of General
`Manager for one year. I began working for JTOA in 2015 and have worked for JTOA
`continuously since that time.
`2. My responsibilities include management of the overall operation of the
`JTOA, including direct or indirect supervision of JTOA employees.
`3.
`JTOA publishes the Japan Train Operation Association Magazine (“JTOA
`Magazine”), a monthly periodical which is published on the first day of each month.
`4.
`As the general manager, my responsibilities include overseeing the
`publication and distribution of the JTOA Magazine.
`5.
`I am familiar with JTOA’s normal business practices in 1995, which are
`similar to the practices that have been in place during my tenure at JTOA. I have gained
`this familiarity through the normal course of business, including discussions with my
`
`
`
`
`
`2
`
`
`P. 2
`
`
`
`Case No.: To Be Assigned
`Declaration of Shuichi Matsuda
`
`predecessors at JTOA and review of JTOA’s business records.
`6.
`Exhibit KAWASAKI-1002 is a true and correct copy of JTOA Magazine,
`Volume 37, issue no. 3, published on March 1, 1995.
`7.
`In 1995, it was JTOA’s normal business practice to publish an issue of the
`JTOA Magazine on the publication date indicated in the issue.
`8.
`In 1995, it was JTOA’s normal business practice to use a printing company
`to mail copies of an issue of the JTOA Magazine to members of the JTOA within one
`week after the issue was published.
`9.
` In 1995, the JTOA had more than 25,500 members who would have
`received copies of the JTOA Magazine from the printing company. In 1995, anyone
`could have become a member of the JTOA. There were no restrictions on who could
`become a member of the JTOA.
`10.
`In 1995, a person who was not a member of JTOA could have obtained
`Exhibit KAWASAKI-1002 by placing an order directly with JTOA.
`
`
`
`
`
`3
`
`
`P. 3
`
`
`
`Case No.: To Be Assigned
`Declaration of Shuichi Matsuda
`
`I hereby declare that all statements made herein of my own knowledge are true
`and that all statements made on information and belief are believed to be true; and further
`that these statements were made with the knowledge that willful false statements and the
`like so made are punishable by fine or imprisonment, or both, under Section 1001 of Title
`18 of the United States Code.
`
`Executed July 6, 2016 in Japan
`
`
`
`
`[signature of]
`Shuichi Matsuda
`
`
`
`4
`
`
`P. 4
`
`
`
`w @etertt tremetetteee me.
`“£700 Seventh Avenue, Suite '2 t {)0 maif@Watentl‘ransiationseem
`Seattte, WA 98101, USA httpzllmvw.Patenttransiationspom
`Fax: 2063—2996692 Tel: 206»357~8508
`
`Certification of Translation
`
`Translator's Declaration: July 11, 2016
`
`I, Martin Cross, hereby declare:
`
`That i possess advanced knowledge of the Japanese and English languages. My
`qualifications are as follows:
`
`0
`
`a
`
`over 25 years as a Japanese—English translatOr focusing primarily on patents,
`and technical and scientific documents;
`co-author of the Japanese Patent Translator's Handbook, published by
`American Translators Association;
`a United States district court recognition as an expert in Japanese technical
`translation for patent litigation; and
`- work experience including design and testing of electronic circuits for
`Research and Development Laboratories Waterloo Ltd.
`
`The attached translation is, to the best of my knowledge and belief, a true and accurate
`translation from Japanese to English of Exhibit 1016 - Declaration of Shuichi Matsuda. I
`understand that willful false statements and the like are punishable by fine or
`imprisonment, or both (18 U.S.C. 1001), and may jeopardize the validity of the
`application 'or any patent issuing thereon. I declare under penalty of perjury that all
`statements made herein of my own knowledge are true, and all statements made on
`information and belief are believed to be true.
`
`Martin Cross
`
`,
`
`
`
`P.5
`
`
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