UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`MICROSOFT CORPORATION.
`Petitioner,
`
`v.
`
`SAINT REGIS MOHAWK TRIBE,
`Patent Owner
`
`Patent No. 7,620,800
`Issued: November 17, 2009
`Filed: April 9, 2007
`Inventors: Jon M. Hupenthal, David E. Caliga
`MULTI-ADAPTIVE PROCESSING SYSTEMS AND
`TECHNIQUES FOR ENHANCING PARALLELISM AND
`PERFORMANCE OF COMPUTATIONAL FUNCTIONS
`____________________
`Inter Partes Review No. IPR2018-01605
`Inter Partes Review No. IPR2018-01606
`Inter Partes Review No. IPR2018-01607
`
`
`
`
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`
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`DECLARATION OF DR. STEPHEN TRIMBERGER
`________________________
`
`Title:
`
`
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`Petitioner Microsoft Corporation – Ex. 1068, Cover
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`
`
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`
`MICROSOFT CORPORATION.
`Petitioner,
`
`v.
`
`SAINT REGIS MOHAWK TRIBE,
`Patent Owner
`
`Patent No. 7,620,800
`Issued: November 17, 2009
`Filed: April 9, 2007
`Inventors: Jon M. Hupenthal, David E. Caliga
`MULTI-ADAPTIVE PROCESSING SYSTEMS AND
`TECHNIQUES FOR ENHANCING PARALLELISM AND
`PERFORMANCE OF COMPUTATIONAL FUNCTIONS
`____________________
`Inter Partes Review No. IPR2018-01605
`Inter Partes Review No. IPR2018-01606
`Inter Partes Review No. IPR2018-01607
`
`
`
`
`
`
`
`DECLARATION OF DR. STEPHEN TRIMBERGER
`________________________
`
`Title:
`
`
`
`Petitioner Microsoft Corporation – Ex. 1068, Cover
`
`
`
`
`
`I, Stephen Trimberger, Ph.D., do hereby declare and state, that all statements made
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`herein of my own knowledge are true and that all statements made on information
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`and belief are believed to be true; and further that these statements were made with
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`the knowledge that willful false statements and the like so made are punishable by
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`fine or imprisonment, under Section 1001 of Title 18 of the United States Code.
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`
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`Executed on: August 27, 2018
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`Stephen Trimberger
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`
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`Petitioner Microsoft Corporation – Ex. 1068, p. i
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`
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`I, Stephen Trimberger, Ph.D, state and declare as follows:
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`1.
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`I am over the age of 18, of sound mind, and capable of making this
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`declaration.
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`2.
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`I am submitting this declaration based on my own personal knowledge
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`of the facts stated here, and I am not being compensated by Microsoft for drafting
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`this declaration. I am, however, being compensated by Microsoft in a related
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`matter for which I have been retained as an expert consultant.
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`3.
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`I am presently the Director of The Trimberger Family Foundation
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`where I manage operations of a charitable foundation, including overseeing
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`investments, legal and accounting professionals. I am also Glenn L. Martin
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`Visiting Research Engineer at the University of Maryland, where I am
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`investigating new semiconductor technologies. I am employed at the United States
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`Defense Advanced Research Projects Agency where I am investigating new
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`semiconductor technologies. I was formerly employed by Xilinx, Inc. from 1988
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`to 2017 culminating in a position in Xilinx Research Labs. In that capacity, I was
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`responsible for corporate technology vision and leadership, and led a research
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`group investigating various aspects of semiconductor devices, including power
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`optimization, die stacking, variation, hardware security, defect tolerance, and
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`multi-context FPGA architecture and software.
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`Petitioner Microsoft Corporation – Ex. 1068, p. 1
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`
`
`I. Papers Presented at 1997 Institute of Electrical and Electronics
`Engineers FPGAs for Custom Computing Machines (FCCM)
`Symposium
`As a result of my work in FPGAs at Xilinx, I attended nearly every
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`4.
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`IEEE FCCM Symposium from 1995 to 2004. The Symposiums are held yearly.
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`5.
`
`The paper Carl Ebeling et al., “Mapping Applications to the RaPiD
`
`Configurable Architecture” IEEE Symposium on FPGAs for Custom Computing
`
`Machines. April 16-18, 1997 Napa Valley, California: 106-115 (“RaPiD”) was
`
`presented and published at the 1997 IEEE Symposium on FPGAs for Custom
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`Computing Machines in California on April 16-18, 1997 (“1997 IEEE FCCM
`
`Symposium” or “IEEE Symposium”)1. RaPiD is attached to this declaration and
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`labeled Exhibit 1009, and also includes true and correct copies of the proceeding
`
`cover page, title pages, copyright pages, table of contents, and the RaPiD article
`
`itself.
`
`
`1 I note that the cover of the proceedings states the title as “IEEE Symposium on FPGAs for
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`Custom Computing Machines,” while the title page states “The 5th Annual IEEE Symposium on
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`Field-Programmable Custom Computing Machines,” and the header on the Table of Contents
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`states “Symposium on Field-Programmable Custom computing Machines – FCCM’97.” The
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`symposium is commonly referred to as “FCCM’97.” Since no other IEEE symposiums have a
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`similar title, all titles have been used by researchers without confusion.
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`Petitioner Microsoft Corporation – Ex. 1068, p. 2
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`
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`6.
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`Exhibit 1009 is in a condition that creates no suspicion about its
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`authenticity. Exhibit 1009 could be found in a number of libraries and with the
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`Institute of Electrical and Electronics Engineers (“IEEE”), for example. This
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`particular version of Exhibit 1009 appears to have been found within the custody
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`of the Library of Congress, as evidenced by the stamp on its pages. The Library of
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`Congress is one of a number of places a document such as Exhibit 1009 would
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`likely be found.
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`7.
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`The paper Michael Rencher and Brad L. Hutchins, “Automated
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`Target Recognition on Splash 2” IEEE Symposium on FPGAs for Custom
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`Computing Machines. April 16-18, 1997 Napa Valley, California: 192-200
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`(“Chunky SLD”) was also presented and published at the 1997 IEEE FCCM
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`Symposium. Chunky SLD is attached to this declaration and labeled Exhibit 1011,
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`and also includes true and correct copies of the proceeding cover page, title pages,
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`copyright pages, table of contents, and the Chunky SLD article itself.
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`8.
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`Exhibit 1011 is in a condition that creates no suspicion about its
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`authenticity. Exhibit 1011 could be found in a number of libraries and with the
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`IEEE, for example. This particular version of Exhibit 1011 appears to have been
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`found within the custody of the British Library’s Boston Spa facility, as evidenced
`
`Petitioner Microsoft Corporation – Ex. 1068, p. 3
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`
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`by the stamp on its pages. The British Library’s Boston Spa facility is one of a
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`number of places a document such as Exhibit 1011 would likely be found.
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`9.
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`I attended the 1997 IEEE FPGA Symposium and presented a paper
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`that I co-authored that was published in the proceedings. The paper was entitled
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`“A Time-Multiplexed FPGA,” (RaPiD, v). Based on my roles with the 1997 IEEE
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`FCCM Symposium, and my participation in prior and later symposiums, I am
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`familiar with the process by which authors were able to present and publish their
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`papers to the attendees of the 1997 IEEE FCCM Symposium. I am also familiar
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`with the process by which papers presented at the 1997 IEEE FCCM Symposium
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`were made available to the public for purchase by the IEEE.
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`10. Registration was required in order to attend the 1997 IEEE FPGA
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`Symposium. Although there were special rates for IEEE members and students,
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`any member of the pubic would have been able to register to attend the IEEE
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`Symposium. Printed copies of the papers to be presented were organized and
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`bound by the IEEE, and those bound copies were made available to each of the
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`registrants. Exhibits 1009 and 1011 are copies of the cover page and various
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`bibliography and table of content pages of the bound papers (including the RaPiD
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`and Chunky SLD papers) that were presented and made available that attendees of
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`the 1997 IEEE FCCM Symposium. Exhibits 1009 and 1011 were thus accessible
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`Petitioner Microsoft Corporation – Ex. 1068, p. 4
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`
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`to an interested body of the public at least by April 16, 1997. The bound papers
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`include a table of contents that organized the papers presented at the IEEE
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`Symposium by subject matter. There were no confidentiality restrictions
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`associated with Exhibits 1009 or 1011, and those that attended the Symposium
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`were free to take the copies with them.
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`11. Copies of Exhibits 1009 and 1011 were also made available to other
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`interested members of the public through the IEEE. Copies of Exhibits 1009 and
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`1011 could be ordered directly by letter to the IEEE Order Department or by
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`Phone, Fax, or email to “cs.books@computer.org.” (RaPiD, iv). IEEE is a well-
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`recognized and reputable engineering organization, and those interested in the
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`subject matter of Exhibits 1009 and 1011 knew it to be a resource of valuable
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`information.
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`12. Copies of the Exhibits 1009 and 1011 would have been also kept in
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`many academic and industrial libraries. As mentioned above, I managed the
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`Xilinx technical library at the time and kept the complete version of these
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`documents (and many other proceedings) in our library. Xilinx engineers, of
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`which there were approximately 500 in 1997, had access to the library. The library
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`that I kept was organized in a way that persons interested in Exhibits 1009 and
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`1011 could easily locate them.
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`Petitioner Microsoft Corporation – Ex. 1068, p. 5
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`
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`Exhibit # Reference Name
`1009
`C. Ebeling, D. Cronquist, P. Franklin, J. Secosky and, S. Berg,
`“Mapping Applications to the RaPiD Configurable Architecture”, in
`Proc. of Int. Symp. on Field-Programmable Custom Computing
`Machines (FCCM), pp. 106–115, 1997 (“RaPiD”)
`
`1011
`
`Rencher, et al., “Automated Target Recognition on SPLASH 2”, IEEE
`Symposium on Field-Programmable Custom Computer Machines,
`1997, 192-200 (“Chunky SLD”)
`
`
`
`Petitioner Microsoft Corporation – Ex. 1068, p. 6
`
`
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