UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`XILINX, INC.,
`Petitioners,
`
`v.
`
`SAINT REGIS MOHAWK TRIBE,
`Patent Owner.
`_____________
`
`Case IPR2018-01395
`Patent 9,153,311 B1
`_____________
`
`DECLARATION OF MARK WOLLGAST
`
`Patent Owner Saint Regis Mohawk Tribe
`Ex. 2004, p. 1
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`XILINX, INC.,
`Petitioners,
`
`v.
`
`SAINT REGIS MOHAWK TRIBE,
`Patent Owner.
`_____________
`
`Case IPR2018-01395
`Patent 9,153,311 B1
`_____________
`
`DECLARATION OF MARK WOLLGAST
`
`Patent Owner Saint Regis Mohawk Tribe
`Ex. 2004, p. 1
`
`
`
`
`
`I, Mark Wollgast, declare as follows:
`
`1. I am more than twenty-one years of age, competent to present this affidavit, and
`
`have personal knowledge of the facts set forth herein.
`
`2. I am currently the Engineering Program Manager (EPM) at Lockheed Martin.I
`
`am in charge of the Tactical Reconnaissance and Counter-Concealment Radar
`
`(TRACER) program, which was developed for the U.S. Army’s Intelligence and
`
`Information Warfare Directorate, based at Aberdeen Proving Grounds, Md.
`
`3. I work closely with the Department of Defense.
`
`4. The Department of Defense’s most critical missions rely heavily on advanced
`
`cutting-edge technology from American companies who perform their development
`
`and manufacturing in the United States.
`
`5. Many of these companies are small businesses that can move much faster than
`
`the very large contractors.
`
`6. As such, they can often invent and field new technology at much faster pace
`
`than Lockheed Martin for example.
`
`7. SRC/DirectStream is a perfect example of such a company.
`
`8. They have been producing groundbreaking processor technology for over two
`
`decades and have been a key supplier to Lockheed Martin for more than 12 years.
`
`Patent Owner Saint Regis Mohawk Tribe
`Ex. 2004, p. 2
`
`
`
`9. SRC/DirectStream is the sole source vendor of processors used in both our
`
`TRACER program and another program that requires extremely high-performance
`
`signal processing in a very limited SWAP (size, weight, and power) environment.
`
`10. The TRACER system operates in a tactical capacity which means that it must
`
`collect and process large volumes of radar information in real-time and within a
`
`SWAP environment that meets the US Army unmanned aerial vehicle (UAV)
`
`requirements.
`
`11. The compact high-performance design of the SRC/DirectStream FPGA
`
`processors are what has made this application possible on the UAV class of air
`
`vehicles
`
`12. Ongoing counter-terrorism and counter-insurgency operations present tough
`
`challenges that our forces must face each day.
`
`13. They need surveillance and reconnaissance capabilities that provide a long-
`
`term stare at specific geographic locations so they can detect environmental changes,
`
`patterns, and asymmetric tactics.
`
`14. TRACER has been operational outside the continental United States
`
`(OCONUS) for 10 years performing surveillance operations as part of the U.S.
`
`Southern Command’s mission requirements.
`
`Patent Owner Saint Regis Mohawk Tribe
`Ex. 2004, p. 3
`
`
`
`15. SRC/DirectStream’s processors have allowed these surveillance operations to
`
`produce images of targets on the ground in real-time as the aircraft fly's the mission
`
`plan.
`
`16. This means there is actionable information available immediately as opposed
`
`to systems that must rely on image processing to be performed post mission by large
`
`server class computing hardware located in a data center.
`
`17. The success of TRACER in the U.S. Southern Command (SOUTHCOM) area
`
`of operation has been very favorable.
`
`18. The unique radar capability coupled with the high-performance processing has
`
`resulted in the detection of rebel forces, drug cartel activities, and related terrorism
`
`that occurs in the dense jungles of that region.
`
`19. Currently SRC/DirectStream is under a sole source contract by Lockheed
`
`Martin on behalf of the U.S Southern Command to produce an even more advanced
`
`version of the current TRACER processor expected to be delivered in 2019.
`
`20. This system will have five times the current processing capability while being
`
`just 1/3 the physical size and consuming half the power.
`
`21. These performance, size and power consumption improvements continue to
`
`demonstrate SRC/DirectStream’s leading edge capabilities that Lockheed Martin’s
`
`own procurement process showed no other vendor could match.
`
`Patent Owner Saint Regis Mohawk Tribe
`Ex. 2004, p. 4
`
`
`
`22. In my opinion, it is in the best security interests of the United States as a
`
`whole, and Lockheed Martin in particular, to keep companies like SRC/DirectStream
`
`healthy and unencumbered so they can stay focused on technology development that
`
`they have proven they can do best.
`
`23. In my opinion, our national security interests are not served by requiring
`
`SRC/Directstream to spend time or money defending against inter partes review
`
`proceedings
`
`24. I hereby declare that all statements made herein of my own knowledge are true
`
`and further that all statements herein are made with knowledge 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.
`
`
`
`Dated: September 10, 2018
`
`
`
`
`By:
`
`
`
`
`
`Mark T. Wollgast
`
`
`
`
`
`
`
`
`
`
`
`
`
`Patent Owner Saint Regis Mohawk Tribe
`Ex. 2004, p. 5
`
`
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