`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`MARVELL SEMICONDUCTOR, INC.,
`Petitioner,
`
`v.
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`UNILOC 2017 LLC,
`Patent Owner.
`____________
`
`IPR2019-01349
`Patent 7,016,676
`____________
`
`
`DECLARATION OF SYLVIA D. HALL-ELLIS, PH.D.
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`Marvell Semiconductor, Inc. - Ex. 1012, Page 0001
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`I.
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`INTRODUCTION
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`1. My name is Sylvia D. Hall-Ellis. I have been retained by Marvell
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`Semiconductor, Inc. in connection with petitions it is preparing for inter partes
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`review.
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`2.
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`I have written this declaration to provide my expert opinion regarding
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`the authenticity and public availability of a conference paper. My declaration sets
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`forth my opinions in detail and provides the basis for my opinions regarding the
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`public availability of this publication.
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`3.
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`I reserve the right to supplement or amend my opinions, and bases for
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`them, in response any additional evidence, testimony, discovery, argument, and/or
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`other additional information that may be provided to me after the date of this
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`declaration.
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`4.
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`I am being compensated for my time spent working on this matter at
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`my normal consulting rate of $300 per hour, plus reimbursement for any additional
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`reasonable expenses. My compensation is not in any way tied to the content of this
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`declaration, the substance of my opinions, or the outcome of the proceedings. I
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`have no other interests in this proceeding or with any of the parties.
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`5.
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`All of the materials that I considered are discussed explicitly in this
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`declaration.
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`II. QUALIFICATIONS
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`6.
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`I am currently an Adjunct Professor in the School of Information at
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`San José State University. I obtained a Masters of Library Science from the
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`University of North Texas in 1972 and a Ph.D. in Library Science from the
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`University of Pittsburgh in 1985. Over the last forty-five years, I have held various
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`positions in the field of library and information resources. I was first employed as
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`a librarian in 1966, and have been involved in the field of library sciences since,
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`holding numerous positions.
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`7.
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`I am a member of the American Library Association (ALA) and its
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`Association for Library Collections & Technical Services (ALCTS) Division, and I
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`served on the Committee on Cataloging: Resource and Description (which wrote
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`the new cataloging rules) and as the chair of the Committee for Education and
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`Training of Catalogers and the Competencies and Education for a Career in
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`Cataloging Interest Group. I also served as the Chair of the ALCTS Division’s
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`Task Force on Competencies and Education for a Career in Cataloging.
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`Additionally, I have served as the Chair for the ALA Office of Diversity’s
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`Committee on Diversity and as a member of the Editorial Board for the ALCTS
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`premier cataloging journal, Library Resources and Technical Services.
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`8.
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`I have also given over one hundred presentations in the field,
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`including several on library cataloging systems and Machine-Readable Cataloging
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`(“MARC”) standards. My current research interests include library cataloging
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`systems, metadata, and organization of electronic resources.
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`9. My full curriculum vitae is attached hereto as Appendix A to this
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`declaration.
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`III. LIBRARY CATALOGING PRACTICES
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`10.
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`I am fully familiar with the library cataloging standard known as the
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`MARC standard, which is an industry-wide standard method of storing and
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`organizing library catalog information.1 MARC was first developed in the 1960’s
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`by the Library of Congress. A MARC-compatible library is one that has a catalog
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`consisting of individual MARC records for each of its items. Today, MARC is the
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`primary communications protocol for the transfer and storage of bibliographic
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`metadata in libraries.2
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`
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`1 The full text of the standard is available from the Library of Congress at
`http://www.loc.gov/marc/bibliographic/.
`2 Almost every major library in the world is MARC-compatible. See, e.g., MARC
`Frequently Asked Questions (FAQ), Library of Congress,
`https://www.loc.gov/marc/faq.html (last visited July 6, 2019) (“MARC is the
`acronym for Machine-Readable Cataloging. It defines a data format that emerged
`from a Library of Congress-led initiative that began nearly forty years ago. It
`provides the mechanism by which computers exchange, use, and interpret
`bibliographic information, and its data elements make up the foundation of most
`library catalogs used today.”). MARC is the ANSI/NISO Z39.2-1994 (reaffirmed
`2016) standard for Information Interchange Format.
`-3-
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`11. A MARC record comprises several fields, each of which contains
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`specific data about the work. Each field is identified by a standardized, unique,
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`three-digit code corresponding to the type of data that follow. For example, a
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`work’s title is recorded in field 245, the primary author of the work is recorded in
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`field 100, an item’s International Standard Book Number (“ISBN”) is recorded in
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`field 022, an item’s International Standard Serial Number (“ISSN”) is recorded in
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`field 022, an item’s Library of Congress call number is recorded in field 050, and
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`the publication date is recorded in field 260 under the subfield “c.” If a work is a
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`periodical, then its publication frequency is recorded in field 310, and the
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`publication dates (e.g., the first and last publication) are recorded in field 362,
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`which is also referred to as the enumeration/chronology field.
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`12. The library that created the record is recorded in field 040 in subfield
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`“a” with a unique library code. When viewing the MARC record online via Online
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`Computer Library Center’s (“OCLC”) bibliographic database, hovering over this
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`code with the mouse reveals the full name of the library. I used this method of
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`“mousing over” the library codes in the OCLC database to identify the originating
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`library for the MARC records discussed in this declaration. Where this “mouse
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`over” option was not available, I consulted the Directory of OCLC Libraries in
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`order to identify the institution that created the MARC record.3
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`13. MARC records also include several fields that include subject matter
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`classification information. An overview of MARC record fields is available
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`through the Library of Congress.4 For example, 6XX fields are termed “Subject
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`Access Fields.”5 Among these, for example, is the 650 field; this is the “Subject
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`Added Entry – Topical Term” field.6 The 650 field is a “[s]ubject added entry in
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`which the entry element is a topical term.” These entries “are assigned to a
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`bibliographic record to provide access according to generally accepted thesaurus-
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`building rules (e.g., Library of Congress Subject Headings (LCSH), Medical
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`Subject Headings (MeSH)).” Further, MARC records include call numbers, which
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`themselves include a classification number. For example, the 050 field is the
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`“Library of Congress Call Number.” 7 A defined portion of the Library of
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`Congress Call Number is the classification number, and “source of the
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`classification number
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`is Library of Congress Classification and
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`the LC
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`Classification-Additions and Changes.” Thus, included in the 050 field is a subject
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`3 https://www.oclc.org/en/contacts/libraries.html.
`4 http://www.loc.gov/marc/bibliographic/.
`5 http://www.loc.gov/marc/bibliographic/bd6xx.html.
`6 http://www.loc.gov/marc/bibliographic/bd650.html.
`7 http://www.loc.gov/marc/bibliographic/bd050.html.
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`matter classification. Each item in a library has a single classification number. A
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`library selects a classification scheme (e.g., the Library of Congress Classification
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`scheme just described or a similar scheme such as the Dewey Decimal
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`Classification scheme) and uses it consistently. When the Library of Congress
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`assigns the classification number, it appears as part of the 050 field. If a local
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`library assigns the classification number, it appears in a 090 field. In either
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`scenario, the MARC record includes a classification number that represents a
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`subject matter classification.
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`14. The OCLC was created “to establish, maintain and operate a
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`computerized library network and to promote the evolution of library use, of
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`libraries themselves, and of librarianship, and to provide processes and products
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`for the benefit of library users and libraries, including such objectives as increasing
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`availability of library resources to individual library patrons and reducing the rate
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`of rise of library per-unit costs, all for the fundamental public purpose of furthering
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`ease of access to and use of the ever-expanding body of worldwide scientific,
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`literary and educational knowledge and information.” 8 Among other services,
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`
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`8 Third Article, Amended Articles of Incorporation of OCLC Online Computer
`Library Center, Incorporated (available at
`https://www.oclc.org/content/dam/oclc/membership/articles-of-incorporation.pdf).
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`OCLC and its members are responsible for maintaining the WorldCat database9
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`(used by independent and institutional libraries throughout the world.
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`15. OCLC also provides its members online access to MARC records
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`through its OCLC bibliographic database. When an OCLC member institution
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`acquires a work, it creates a MARC record for this work in its computer catalog
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`system in the ordinary course of its business. MARC records created at the Library
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`of Congress are tape-loaded into the OCLC database through a subscription to
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`MARC Distribution Services daily or weekly. Once the MARC record is created
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`by a cataloger at an OCLC member institution or is tape-loaded from the Library
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`of Congress, the MARC record is then made available to any other OCLC
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`members online, and therefore made available to the public. Accordingly, once the
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`MARC record is created by a cataloger at an OCLC member institution or is tape-
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`loaded from the Library of Congress or another library anywhere in the world, any
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`publication corresponding to the MARC record has been cataloged and indexed
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`according to its subject matter such that a person interested in that subject matter
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`could, with reasonable diligence, locate and access the publication through any
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`library with access to the OCLC bibliographic database or through the Library of
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`Congress.
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`9 http://www.worldcat.org/.
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`16. When an OCLC member institution creates a new MARC record,
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`OCLC automatically supplies the date of creation for that record. The date of
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`creation for the MARC record appears in the fixed field (008), characters 00
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`through 05. The MARC record creation date reflects the date on which, or shortly
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`after which, the item was first acquired or cataloged. Initially, field 005 of the
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`MARC record is automatically populated with the date the MARC record was
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`created in year, month, day format (YYYYMMDD) (some of the newer library
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`catalog systems also include hour, minute, second (HHMMSS)). Thereafter, the
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`library’s computer system may automatically update the date in field 005 every
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`time the library updates the MARC record (e.g., to reflect that an item has been
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`moved to a different shelving location within the library). Field 005 is visible
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`when viewing a MARC record via an appropriate computerized interface, but
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`when a MARC record is printed to hardcopy, no “005” label appears. The initial
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`field 005 date (i.e., the date the MARC record was created) does appear, however,
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`next to the label “Entered.”10 The date upon which the most recent update to field
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`
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`10 In this declaration, I sometimes refer to the “Entered” entry as field 008,
`characters 00-05. Field 005 is visible when viewing a MARC record via an
`appropriate computerized interface. But when a MARC record is printed directly
`to hardcopy from the OCLC database, the “005” label is not shown. The date in
`the 005 field instead appears next to the label “Replaced.”
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`005 occurred also appears, next to the label “Replaced.” Thus, when an item’s
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`MARC record has been printed to hardcopy—as is the case with the exhibits to this
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`declaration—the date reflected next to the label “Entered” is necessarily on or after
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`the date the library first cataloged and indexed the underlying item.
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`17. Once one library has cataloged and indexed a publication by creating
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`a MARC record for that publication, other libraries that receive the publication do
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`not create additional MARC records—the other libraries instead rely on the
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`original MARC record. They may update or revise the MARC record to ensure
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`accuracy, but they do not replace or duplicate it. This practice does more than save
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`libraries from duplicating labor. It also enhances the accuracy of MARC records.
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`Further, it allows librarians around the world to know that a particular MARC
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`record is authoritative (in contrast, a hypothetical system wherein duplicative
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`records were created would result in confusion as to which record is authoritative).
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`18. The date of creation of the MARC record by a cataloger at an OCLC
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`member institution reflects when the underlying item is accessible to the public.
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`Upwards of two-thirds to three-quarters of book sales to libraries come from a
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`jobber or wholesaler for online and print resources. These resellers make it their
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`business to provide books to their customers as fast as possible, often providing
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`turnaround times of only a single day after publication. Libraries purchase a
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`significant portion of the balance of their books directly from publishers
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`themselves, which provide delivery on a similarly expedited schedule. In general,
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`libraries make these purchases throughout the year as the books are published and
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`shelve the books as soon thereafter as possible in order to make the books available
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`to their patrons. Thus, books are generally available at libraries across the country
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`within just a few days of publication.
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`19. Catalogers can create MARC records for all types of print, online, and
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`digital resources. For example, MARC records cover serial publications, including
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`both serially published monographs and journals. OCLC hosts MARC records for
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`more than 320 million serial publications. Serial publications are those
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`publications that have the same collective title but are intended to be continued
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`indefinitely with enumeration such as a volume or issue number (e.g., magazines,
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`journals, etc.). In the OCLC bibliographic database, the first issue of the serial
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`publication is typically cataloged (i.e., a corresponding MARC record is created),
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`but the date is left open-ended with the use of a punctuation mark such as a dash.
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`OCLC serial publication MARC records represent the entire run of the serial title.
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`With knowledge of the first issue published, future issues can be predicted based
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`on the information provided in the MARC record, for example in field 362. In my
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`extensive professional experience, is it highly unusual for a library to stop
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`collecting and shelving a serial publication prior to the end of its publication run.
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`If a subscription to a serial publication ends its run or is cancelled before the end of
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`its run, the library will denote that it has stopped receiving new volumes by filling
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`in the end date in the MARC record.
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`20. The handling of printed journal subscriptions is shown on the covers
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`of individual issues. As was the best practice among libraries, issues arrived at a
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`central facility and were immediately received, verified as part of a subscription,
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`checked in, and stamped with the institution’s name and date. Determining that the
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`issue was part of the library subscription ensured that the entire set of publications
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`for the year had been received so that they could be professionally bound and
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`retained. This process also verified that all of the published issues arrived so that
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`the library staff did not have to request or claim an issue that did not arrive as
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`expected. In large public libraries with branches and multi-campus libraries within
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`academic institutions, the journals were sorted and delivered to the subscribing
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`unit. The issues were frequently stamped again to acknowledge receipt. The new
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`issue was placed in the public area; the older issue was stored so that it remained
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`available.
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`21. The foregoing process has been standard library practice longer than I
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`have been working in the profession. I first learned the steps in the process in the
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`late 1970s and later supervised it. Although the checking in process has become
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`automated and now links electronically to holdings records for the MARC record
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`for each serial title, the manual stamping and placing the issue in a public area has
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`not changed for 50 years. Unless I note otherwise below in reference to a specific
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`serial publication, it is my expert opinion that this standard protocol was followed
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`for each of the serial publications discussed below.
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`22.
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`In preparing this declaration, I used authoritative databases, such as
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`the OCLC bibliographic database, the Library of Congress Online Catalog,
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`Scopus, and Google Scholar, to confirm citation details of the various publications
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`discussed. Unless I note otherwise below in reference to a specific serial
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`publication, it is my expert opinion that this standard protocol was followed for
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`each of the serial publications discussed below.
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`23.
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`Indexing. A researcher may discover material relevant to his or her
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`topic in a variety of ways. One common means of discovery is to search for
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`relevant information in an index of periodical and other publications. Having
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`found relevant material, the researcher will then normally obtain it online, look for
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`it in libraries, or purchase it from the publisher, a bookstore, a document delivery
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`service, or other provider. Sometimes, the date of a document’s public
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`accessibility will involve both indexing and library date information. However,
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`date information for indexing entries is often unavailable. This is especially true
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`for online indices.
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`24.
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`Indexing services use a wide variety of controlled vocabularies to
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`provide subject access and other means of discovering the content of documents.
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`The formats in which these access terms are presented vary from service to service.
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`25. Online
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`indexing
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`services
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`commonly provide bibliographic
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`information, abstracts, and full-text copies of the indexed publications, along with
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`a list of the documents cited in the indexed publication. These services also often
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`provide lists of publications that cite a given document. A citation of a document
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`is evidence that the document was publicly available and in use by researchers no
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`later than the publication date of the citing document.
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`26. Prominent indexing services include the following:
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`a.
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`ACM Digital Library. This index is produced by the Association for
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`Computing Machinery, the world’s largest scientific and educational computing
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`society. AMC Digital Library contains the full text of all AMC publications,
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`hosted full-text publications from selected publishers, and the ACM Guide to
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`Computing Literature—a comprehensive bibliography of computing literature
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`beginning in the 1950s with more than a million entries. All metadata in the
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`database are freely available on the Web, including abstracts, linked references,
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`citing work, and usage statistics. Full-text articles are available with subscription.
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`b.
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`IEEE Xplore. This scholarly research database includes indexes,
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`abstracts, and full text for articles and papers on computer science, electrical
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`engineering, and electronics.
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` The database mainly covers material from
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`the Institute of Electrical and Electronics Engineers (IEEE) and the Institution of
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`Engineering and Technology. The IEEE Xplore digital library provides Web
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`access to more than 4.3-million full text documents from some of the world's most
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`highly cited publications. The content comprises over 180 journals, over 1,400
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`conference proceedings, more than 3,800 technical standards, over 1,800 eBooks
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`and over 400 educational courses. Approximately 20,000 new documents are
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`added to IEEE Xplore each month. Abstracts are free to access, but access to full
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`text requires a subscription or institutional login.
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`IV. PRELIMINARIES
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`27.
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`Scope of this declaration. I am not an attorney and will not offer
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`opinions on the law. I am, however, rendering my expert opinion on the
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`authenticity of the documents referenced herein and on when and how each of
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`these documents was disseminated or otherwise made available to the extent that
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`persons interested and ordinarily skilled in the subject matter or art, exercising
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`reasonable diligence, could have located the documents.
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`28.
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`I am informed by counsel that a printed publication qualifies as
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`publicly accessible as of the date it was disseminated or otherwise made available
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`such that a person interested in and ordinarily skilled in the relevant subject matter
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`could locate it through the exercise of ordinary diligence.
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`29. While I understand that the determination of public accessibility under
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`the foregoing standard rests on a case-by-case analysis of the facts particular to an
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`individual publication, I also understand that a printed publication is rendered
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`“publicly accessible” if it is cataloged and indexed by a library such that a person
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`interested in the relevant subject matter could locate it (i.e., I understand that
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`cataloging and indexing by a library is sufficient, though there are other ways that
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`a printed publication may qualify as publicly accessible). One manner of sufficient
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`indexing is indexing according to subject matter category. I understand that the
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`cataloging and indexing by a single library of a single instance of a particular
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`printed publication is sufficient, even if the single library is in a foreign country. I
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`understand that, even if access to a library is restricted, a printed publication that
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`has been cataloged and indexed therein is publicly accessible so long as a
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`presumption is raised that the portion of the public concerned with the relevant
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`subject matter would know of the printed publication. I also understand that the
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`cataloging and indexing of information that would guide a person interested in the
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`relevant subject matter to the printed publication, such as the cataloging and
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`indexing of an abstract for the printed publication, is sufficient to render the
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`printed publication publicly accessible.
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`30.
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`I understand that routine business practices, such as general library
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`cataloging and indexing practices, can be used to establish an approximate date on
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`which a printed publication became publicly accessible.
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`31. Persons of ordinary skill in the art. I am told by counsel that the
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`subject matter of this proceeding relates to wireless communications.
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`32.
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`I have been informed by counsel that a “person of ordinary skill in the
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`art at the time of the inventions” is a hypothetical person who is presumed to be
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`familiar with the relevant field and its literature at the time of the inventions. This
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`hypothetical person
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`is also a person of ordinary creativity, capable of
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`understanding the scientific principles applicable to the pertinent field.
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`33.
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`I am told by counsel that persons of ordinary skill in this subject
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`matter or art would have had a Bachelor’s Degree in Electrical Engineering,
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`Computer Science, or a related subject and one or more years of experience
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`working with wireless networks and related standards, and would have had an
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`understanding of work being done by companies within the field of wireless
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`networks and related standards, including, e.g., systems or protocols for shared
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`access of wireless networks by different protocols. I am also told by counsel that a
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`person with less formal education but more relevant practical experience may also
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`meet this standard.
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`34.
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`It is my opinion that such a person would have been engaged in
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`research, learning though study and practice in the field and possibly through
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`formal instruction the bibliographic resources relevant to his or her research. In the
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`1990s and early 2000s such a person would have had access to a vast array of long-
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`established print resources in electrical engineering as well as to a rich set of online
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`resources providing indexing information, abstracts, and full text services for
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`electrical engineering.
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`V. Document 1: Exhibit 1007 (“AKAIWA”)
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`35. Attached hereto as Exhibit 1007 is a true and correct copy of the
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`conference paper “An Integrated Voice and Data Radio Access System” by
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`Yoshihiko Akaiwa, Toshio Nomura, and Shinji Minami (hereafter “Akaiwa”). The
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`IEEE VTS 42nd Vehicular Technology Conference was held May 10-13, 1992, in
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`Denver, Colorado, as indicated on the title page. Akaiwa paper was published in
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`the conference proceedings volume Frontiers of Technology: From Pioneers to the
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`21st Century -- Vehicular Technology Society 42nd VTS Conference, volume 1 on
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`pages 255-258.
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`36. Attached hereto as Exhibit 1007 is a true and correct copy of the print
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`issue of the conference proceedings volume Frontiers of Technology: From
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`Pioneers to the 21st Century -- Vehicular Technology Society 42nd VTS
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`Conference with a hand-written receipt date, and an ownership stamp affixed at the
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`Linda Hall Library. Therefore, this proceedings volume was available to users at
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`the Linda Hall Library.
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`37. Attached hereto as Attachment 1a is a true and correct copy of the
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`MARC record for the conference proceedings volume Frontiers of Technology:
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`From Pioneers to the 21st Century -- Vehicular Technology Society 42nd VTS
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`Conference at the Linda Hall Library. The library ownership is indicated by the
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`presence of the library’s code (LHL) in the 049 field. I personally identified and
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`retrieved the MARC record that is Attachment 1a.
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`38. The MARC record for the conference proceedings volume Frontiers
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`of Technology: From Pioneers to the 21st Century -- Vehicular Technology Society
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`42nd VTS Conference shows that it was cataloged at the Linda Hall Library on
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`September 24, 1992, as shown in field 008 (“920924”). Therefore, this volume
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`would have been available to users at the Linda Hall Library on or shortly after that
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`date.
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`39. Attachment 1a further includes an entry in field 090 (“TK6570.M6 ‡b
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`I23 1992”)—as described above, this includes a subject matter classification
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`number consistent with the Library of Congress classification system (analogous to
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`the Dewey Decimal classification system). Attachment 1a further includes three
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`English language field 650 entries reading “Electronics in transportation ‡v
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`Congresses” (see Attachment 1b, Library of Congress subject heading
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`sh2008119337), “Mobile communication systems ‡v Congresses” (see Attachment
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`1c, Library of Congress subject heading sh2008107882), and “Artificial satellites
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`in telecommunication ‡v Congresses” (see Attachment 1d, Library of Congress
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`subject heading sh2007101479). Thus, as of its cataloging, the publication
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`corresponding to the MARC record attached hereto as Attachment 1a was indexed
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`according to its subject matter by virtue of at least two independently sufficient
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`classifications: the field 090 entry and the field 650 entries. Further, as of
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`September 24, 1992, the MARC record attached hereto as Attachment 1a was
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`accessible through any library with access to the OCLC bibliographic database or
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`the online catalog at a library that purchased this volume, which means that the
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`corresponding publication was publicly available on or before that same date
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`through any library with access to the OCLC bibliographic database or through an
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`individual library.
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`40. Attached hereto as Attachment 1e is a true and correct copy of the
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`MARC record for the conference proceedings volume Frontiers of Technology:
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`From Pioneers to the 21st Century -- Vehicular Technology Society 42nd VTS
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`Conference obtained from the OCLC bibliographic database. This MARC record
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`is OCLC record number 26662120. Attachment 1e indicates that the conference
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`proceedings volume Frontiers of Technology: From Pioneers to the 21st Century -
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`- Vehicular Technology Society 42nd VTS Conference was cataloged at the
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`University of Maryland Libraries on September 24, 1992, as shown in field 008
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`(“920924”). The library continues to update this MARC record and enhanced the
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`MARC record to meet current cataloging rules. The MARC record was most
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`recently updated on March 11, 2019, as shown in field 005 (“190311”). In view of
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`Attachment 1e, the conference proceedings volume Frontiers of Technology: From
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`Pioneers to the 21st Century -- Vehicular Technology Society 42nd VTS
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`Conference was publicly on September 24, 1992, or shortly thereafter.
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`41. Attachment 1e further includes an entry in field 050 (“TL272.5 ‡b
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`.I18 1992”)—as described above, this includes a subject matter classification
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`number consistent with the Library of Congress classification system (analogous to
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`the Dewey Decimal classification system). Attachment 1e further includes three
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`English language field 650 entries reading “Electronics in transportation ‡v
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`Congresses” (see Attachment 1b, Library of Congress subject heading
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`sh2008119337), “Mobile communication systems ‡v Congresses” (see Attachment
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`1c, Library of Congress subject hea