Mariellen F. Calter
`
` Associate University Librarian &
` Chief of Staff
`
` Cecil H. Green Library
`
`
` Stanford, California
`
`
` 94305-6004
`
` mcalter@stanford.edu
` telephone 650-725-5813
` fax 650-725-4902
`
`
`
`The Stanford University Libraries
`
`DECLARATION OF MARIELLEN F. CALTER
`
`I, Mariellen F. Calter, declare:
`
`1. I have personal knowledge of the facts set forth herein, and if called to testify, I could
`and would competently testify to the same.
`2. I am Associate University Librarian & Chief of Staff for the Stanford University
`Libraries (“SUL”), located at Stanford University, Stanford, CA 94305.
`3. I have worked at SUL in my current role for over five years, and have worked for SUL
`for over eleven years.
`4. The SUL catalog is available to the general public and searchable by subject, author,
`and keyword. Though the interface has changed, the catalog has generally been
`searchable by subject, author, and keyword through its history.
`5. SUL holds a copy of the Journal of the Electrochemical Society, volume 132, number
`3, published by The Electrochemical Society in March of 1985. That work includes
`the article Transient Behavior during Film Removal in Diffusion-Controlled Plasma
`Etching, by Richard C. Alkire and Demetre J. Economou.
`6. SUL holds a copy of the Journal of the Electrochemical Society, volume 137, number
`3, published by The Electrochemical Society in March of 1990. That work includes
`the article Analysis of Nonuniformities in the Plasma Etching of Silicon with CF4/O2,
`by Alan S. Kao and Harvey E. Stenger Jr.
`7. SUL holds a copy of IEEE Transactions on Semiconductor Manufacturing, volume 5,
`number 3, published by IEEE in August of 1992. That work includes the article
`Modeling of a High Throughput Hot-Wall Reactor for Selective Epitaxial Growth of
`Silicon, by C. Galewski and W.G. Oldham.
`8. SUL holds a copy of The Journal of Applied Physics, volume 52, number 5, published
`by the American Institute of Physics in May of 1981. That work includes the article
`The Reaction of Fluorine Atoms with Silicon, by D. L. Flamm, V. M. Donnelly, and J.
`A. Mucha.
`9. I am familiar with the policies and procedures of the Library as they relate to the
`receipt, cataloging, and tracking of books. Although I was not an employee of the
`Stanford University Libraries at the time these proceedings were acquired by the
`Library, on information and belief, the process for receiving, cataloging, and tracking
`these books is something I am able to describe, although not from direct personal
`knowledge.
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`Samsung Exhibit 1016
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`10. It has been common practice within SUL to stamp journals on the date of receipt.
`Journals are typically, though not in all cases, made available to the public within one
`week of receipt. Three of the four journals listed above are stamped with a received
`date during the month of publication. The fourth, The Journal of Applied Physics, is
`stamped with a received date in July of 1981. Based on our common practice and the
`indicated received dates, it is my belief that each of these journals was made available
`to visitors to the library within three months of its indicated date of publication.
`I understand that willful false statements and the like are punishable by fine or imprisonment, or
`both under Section 1001 of Title 18 of the United States Code and may jeopardize the validity of
`the application or any patent issuing thereon. I declare that all statements made of my knowledge
`are true, and that all statements made on information and belief are believed to be true.
`Executed this 1st day of November, 2016.
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`Mariellen F. Calter
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