UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`YITA LLC,
`Petitioner,
`
`V.
`
`MACNEIL IP LLC,
`Patent Owner.
`
`SUPPLEMENTAL DECLARATION OF BRUCE D. POPP, PhD
`
`MacNeiI Exhibit 2115
`
`Yita v. MacNeiI IP, |PR2020-01139
`
`Page 1
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 1
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`YITA LLC,
`Petitioner,
`
`V.
`
`MACNEIL IP LLC,
`Patent Owner.
`
`SUPPLEMENTAL DECLARATION OF BRUCE D. POPP, PhD
`
`MacNeiI Exhibit 2115
`
`Yita v. MacNeiI IP, |PR2020-01139
`
`Page 1
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 1
`
`
`
`BIEN FAIT
`
`Translation and Patent Services
`
`Bruce D. Popp, PhD
`ATA Certified Translator, French into English
`USPTO Registered Patent Agent
`
`I, Bruce D. Popp, hereby declare as follows:
`
`1.
`
`I possess advanced knowledge of the French and English languages.
`
`I have more than 15 years of experience translating patents and patent-related
`
`documentation from French into English.
`
`I have been an independent translator
`
`since 2002.
`
`2.
`
`I am certified by the American Translators Association for French
`
`into English translations. In 2017, I was the recipient ofthe S. Edmund Berger Prize
`
`for Excellence in Scientific and Technical Translation;
`
`3.
`
`I am a grader (for French into English) in the American Translators
`
`Association Certification Program.
`
`4.
`
`I am a registered patent agent with the United States Patent and
`
`Trademark Office (registration number 66903).
`
`5.
`
`I have in-depth knowledge of relevant sections of the European
`
`Patent Convention and French Code de la propriété industrielle.
`
`6.
`
`7.
`
`I have translated over 500 French and European patents to English.
`
`I was awarded a PhD degree in Astronomy by Harvard University
`
`in 1985 and an AB in Physics, magna cum laude, by Cornell University in 1979.
`
`8.
`
`I have received the Diplo‘me approfondz' de la languefiancaise, C2
`
`.
`
`EDPOPPQ‘Db‘en'
`a1t.com
`
`660 BOAS ST., APT. 1011
`
`HARRISBURG, PA 17102
`UNITED STATES
`
`866-243-6324
`MaCNeil Exhibit 2115
`Yita v. MacNeiI IP, |PR2020-01139
`
`Page 2
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 2
`
`
`
`—2—
`
`May 21,2021
`
`level (mastery) certification in French-language abilities.
`
`9.
`
`I have authored the following publications in the previous ten years:
`
`0
`
`I currently have a book project in the field history of physics under
`
`contract with Springer with a tentative publication date in 2023.
`
`0 Henri Poincaré: From Electrons to Special Relativity, Springer, New
`
`York, 2020.
`
`0 Dealing with Terminology Drift, The ATA Chronicle, vol. XLVIII,
`
`num. 1, Jan/Feb. 2019.
`
`o The Three-Body Problem and the Equations ofDynamics: Poincaré ’s
`
`Foundational Work on Dynamical Systems Theory, Springer, New
`
`York, 2017.
`
`0 Accuracy in Patent Translation, Boston Patent Law Association
`
`Newsletter, vol. 40, issue 3, summer 2010.
`
`0 Using Patents to Find the Terminology You Need, The ATA Chronicle,
`
`vol. XXXVIII, num. 5, May 2009.
`
`10.
`
`Bilingual dictionaries (in the case ofExhibits 2025-29, 2032-35, and
`
`2038, French-into-English dictionaries) provide
`
`suggested translations
`
`for
`
`headwords and frequently for sub-entries. They may, less often, provide usage
`
`examples and their suggested renderings in English.
`
`In the sub-entries and
`
`examples, conventionally the headword is not repeated and is replaced by a tilde (~).
`
`MacNeiI Exhibit 2115
`
`Yita v. MacNeiI IP, |PR2020-01139
`
`Page 3
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 3
`
`
`
`—3 —
`
`May 21, 2021
`
`Headword entries frequently include additional information to help users. This
`
`additional
`
`information may include a pronunciation in international phonetic
`
`alphabet (in the case of Exhibit 2025, for example, “bRid”, “kOlREt” and “R(o)boR”),
`
`grammatical or linguistic information, and other indications to distinguish between
`fields, context or connotations for which different renderings are suggested. Often
`
`this additional information is in the same language as the headword.
`
`11.
`
`Exhibit 2025 in IPR2020-01139 and IPR2020-01142 is a true and
`
`correct copy of the entries for “bride,
`
`collerette,” and “rebor ” as found in the
`
`,9 “
`
`2017 Collins Le Robert Comprehensive Dictionary: French-English, English-French
`
`© 2017 Dictionnaires Le Robert/HarperCollins Publishers.
`
`I obtained the contents
`
`of Exhibit 2025 from the Collins Le Robert Comprehensive Dictionary: French—
`
`English, English-French software application installed on my computer.
`
`12.
`
`I have been asked to prepare an English translation of the French
`
`abbreviations and words in the additional information in the entries for “bride,”
`
`“collerette,” and “rebord” in Exhibit 2025.
`
`13.
`
`In the entries for “bride,” “collerette,” and “rebor ” in Exhibit 2025,
`
`the following French abbreviations and words are used. These words and their
`
`translations into English are provided in the following table:
`
`MacNeiI Exhibit 2115
`
`Yita v. MacNeiI IP, |PR2020-01139
`
`Page 4
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 4
`
`
`
`forms
`
`emploi littéral
`
`de Vétement
`
`W
`
`cm
`
`de boutonniere
`
`de dentelle
`
`
`
`de bielle
`
`for connecting rod
`
`Médecine
`
`medicine
`
`“collerette”
`
`formes
`
`word forms
`
`—4—
`
`May 21,2021
`
`
`
`
`
`
`
`
`
`
`MaCNeil Exhibit 2115
`
`Yita V. MaCNeil IP, |PR2020-01139
`
`Page 5
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 5
`
`
`
`—5 —
`
`May 21,2021
`
`
`nom féminin
`
`Histoire = fraise
`
`
`
`
`
`
`
`
`“rebord”
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`14.
`
`As indicated above, I am a professional translator fluent in French
`
`and English and I am American Translators Association Certified for translation
`
`from French into English. I state that to the best of my knowledge and belief I have
`
`accurately translated the terms for which no French to English translation is provided
`
`from the entries for “bride,” “collerette,” and “rebord” in Exhibit 2025 from French
`
`to English and that said accurate translation is provided in the preceding table.
`
`15.
`
`Exhibit 2026 in IPR2020-01139 and IPR2020-01142 is an excerpt
`
`fiom the Collins-Robert French to English and English to French Dictionary
`
`MaCNeil Exhibit 2115
`
`Yita V. MaCNeil IP, IPR2020-01139
`
`Page 6
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 6
`
`
`
`—6—
`
`May21,2021
`
`containing the entry for “rebord.” I am personally familiar with the Collins-Robert
`
`French to English and English to French Dictionary and consider it to be a reliable
`
`source.
`
`16.
`
`I have been asked to prepare an English translation of the French
`
`abbreviations and words in the additional information in the entry for “rebor ” in
`
`Exhibit 2026.
`
`17.
`
`In the entry for “rebord” in Exhibit 2026, the following French
`
`abbreviations and words are used. These words and their translations into English
`
`are provided in the following table.
`
`“-
`
`
`
`
`
`__
`
`
`
`
`
`
`
`18.
`
`As indicated above, I am a professional translator fluent in French
`
`and English and I am American Translators Association Certified for translation
`
`from French into English. I state that to the best of my knowledge and belief I have
`
`accurately translated the terms for which no French to English translation is provided
`
`from the entry for “rebord” in Exhibit 2026 fiom French to English and that said
`
`accurate translation is provided in the preceding table.
`
`MaCNeil Exhibit 2115
`
`Yita V. MaCNeil IP, |PR2020-01139
`
`Page 7
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 7
`
`
`
`—7—
`
`May21,2021
`
`19.
`
`Exhibit 2027 in IPR2020-01139 and IPR2020-01142 is an excerpt
`
`from the Larousse French-English English-French Dictionary (Unabridged edition)
`
`containing the entry for “rebor .
`
`I am personally familiar with the Larousse
`
`,1
`
`French-English English-French Dictionary and consider it to be a reliable source.
`
`20.
`
`I have been asked to prepare an English translation of the French
`
`abbreviations and words in the additional information in the entry for “rebor ” in
`
`Exhibit 2027.
`
`21.
`
`In the entry for “rebor ” in Exhibit 2027, the following French
`
`abbreviations and words are used. These words and their translations into English
`
`are provided in the following table.
`
`English
`
`“rebord”
`
`
`
`d’un fossé, d’une étagere
`
`of a pit of a shelf
`
`d’une assiette, d’un verre
`
`22.
`
`As indicated above, I am a professional translator fluent in French
`
`and English and I am American Translators Association Certified for translation
`
`from French into English. I state that to the best of my knowledge and belief I have
`
`MacNeiI Exhibit 2115
`
`Yita v. MacNeiI IP, |PR2020-01139
`
`Page 8
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 8
`
`
`
`—8—
`
`May 21,2021
`
`accurately translated the terms for which no French to English translation is provided
`
`from the entry for “rebord” in Exhibit 2027 from French to English and that said
`
`accurate translation is provided in the preceding table.
`
`23.
`
`Exhibit 2028 in IPR2020-01139 and IPR2020-01142 is an excerpt
`
`from the Collins French Gem Dictionary French-English: English-French containing
`
`the entry for “rebord.”
`
`I am personally familiar with the Collins French Gem
`
`Dictionary French-English: English-French and consider it to be a reliable source.
`
`24.
`
`I have been asked to prepare an English translation of the French
`
`abbreviations and words in the additional information in the entry for “rebord” in
`
`Exhibit 2028.
`
`25.
`
`In the entry for “rebor ” in Exhibit 2028, the following French
`
`abbreviations and words are used. These words and their translations into English
`
`are provided in the following table.
`
`
`
`
`“rebord”
`
`
`
`
`26.
`
`As indicated above, I am a professional translator fluent in French
`
`and English and I am American Translators Association Certified for translation
`
`fi'om French into English. I state that to the best of my knowledge and belief I have
`
`accurately translated the terms for which no French to English translation is provided
`
`MaCNeil Exhibit 2115
`
`Yita V. MaCNeil IP, IPR2020-01139
`
`Page 9
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 9
`
`
`
`—9—
`
`May21,202l
`
`from the entry for “rebor ” in Exhibit 2028 fiom French to English and that said
`
`accurate translation is provided in the preceding table.
`
`27.
`
`Exhibit 2029 in IPR2020-01139 and IPR2020-01142 is an excerpt
`
`from the Dictionnaire des techniques et sciences appliquées containing the entries
`
`for “bride,” “collerette,” and “rebor .
`
`I am personally familiar with the
`
`”
`
`Dictionnaire des techniques et sciences appliquées and consider it to be a reliable
`
`source.
`
`28.
`
`I have been asked to prepare an English translation of the French
`
`abbreviations and words in the additional information in the entries for “bride”,
`
`“collerete,” and “rebor ” in Exhibit 2029.
`
`29.
`
`In the entries for “bride”, “collerete,” and “rebor ” in Exhibit 2029,
`
`the following French abbreviations and words are used. These words and their
`
`’
`
`translations into English are provided in the following table.
`
`
`
`The pipe symbol is used to
`separate sub-entries.
`
`
`
`/
`
`
`
`
`
`
`The forward slash is used to
`separate a sub-entry (and its field
`in parentheses) from the
`suggested translation(s).
`
`m... n...
`
`
`
`
`
`
`MacNeiI Exhibit 2115
`
`Yita v. MacNeiI IP, |PR2020-01139
`
`Page 10
`
`
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 10
`
`
`
`—1o—
`
`May21,2021
`
`
`
`constr. en acier
`
`steel constructlon
`
`teem
`
`p—h ‘6y.—
`
`E
`
`voir bride folle
`
`table de presse
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`MacNeiI Exhibit 2115
`
`Yita v. MacNeiI IP, |PR2020-01139
`
`Page 11
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 11
`
`
`
`—11—
`
`May21,2021
`
`bétim., béton
`
`
`
`civil engineering, concrete
`
`“collerette”
`
`feminine noun
`
`découp
`
`biére
`
`pressroom technology
`
`brewing (beer)
`
`guide d’ondes
`
`wave guide
`
`VIS
`
`tuyau
`
`instr
`
`
`
`
`
`
`
`
`screw, bolt
`
`instruments
`
`generally
`
`0r1
`
`plug
`
`switch
`
`fixed
`
`boiler dome
`
`“rebord”
`
`masculine noun
`
`folded-back edge
`
`commutateur
`
`fixée
`
`dome de chaudiere
`
` fiche
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`MaCNeHEXMbH2115
`
`Yita V. MaCNeil IP, |PR2020-01139
`
`Page 12
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 12
`
`
`
`— 12—
`
`May 21, 2021
`
`
`
`
`
`_—
`
`
`
`
`
`
`
`
`
`
`30.
`
`As indicated above, I am a professional translator fluent in French
`
`and English and I am American Translators Association Certified for translation
`
`from French into English. I state that to the best of my knowledge and belief I have
`
`accurately translated the terms for which no French to English translation is provided
`
`from the entries for “bride”, “collerete,” and “rebor ” in Exhibit 2029 fi'om French
`
`to English and that said accurate translation is provided in the preceding table.
`
`31.
`
`Exhibit 2032 in IPR2020—01139 and IPR2020—01142 is an excerpt
`
`from the Dictionnaire des techniques et sciences appliquées containing the entry for
`
`“contour.” I am personally familiar with the Dictionnaire des techniques et sciences
`
`appliquées and consider it to be a reliable source.
`
`32.
`
`I have been asked to prepare an English translation of the French
`
`abbreviations and words in the additional information in the entry for “contour” in
`
`Exhibit 2032.
`
`33.
`
`In the entry for “contour” in Exhibit 2032, the following French
`
`MacNeiI Exhibit 2115
`
`Yita v. MacNeiI IP, IPR2020-01139
`
`Page 13
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 13
`
`
`
`— 13 —
`
`May 21,2021
`
`abbreviations and words are used. These words and their translations into English
`
`are provided in the following table.
`
`“contour”
`
`The pipe symbol is used to
`separate sub-entries.
`
`The forward slash is used to
`separate a sub-entry (and its field
`in parentheses) from the
`suggested translation(s).
`
`/
`
`
`
`masculine noun
`
`feminine noun
`
`physiological correction
`
`or
`
`technology (general)
`
`computer science
`
`plural, masculine noun
`
`mechanics
`
`34.
`
`As indicated above, I am a professional translator fluent in French
`
`and English and I am American Translators Association Certified for translation
`
`from French into English. I state that to the best of my knowledge and belief I have
`
`MacNeiI Exhibit 2115
`
`Yita v. MacNeiI IP, |PR2020-01139
`
`Page 14
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 14
`
`
`
`— 14—
`
`May 21, 2021
`
`accurately translated the terms for which no French to English translation is provided
`
`from the entry for “contour” in Exhibit 2032 from French to English and that said
`
`accurate translation is provided in the preceding table.
`
`35.
`
`Exhibit 2033 in IPR2020-01 139 and IPR2020-01 142 is a screen shot
`
`of Google Translate from English Contour to French Contour.
`
`I am personally
`
`familiar with the Google Translate service.
`
`In my opinion, the translation of
`
`“contour” from English to French in Exhibit 2033 is accurate.
`
`36.
`
`Exhibit 2034 in IPR2020-01139 and IPR2020-01142 is an excerpt
`
`from the Dictionnaire des techniques ct sciences appliquées containing the entry for
`
`“topographic.” I am personally familiar with the Dictionnaire des techniques ct
`
`sciences appliquées and consider it to be a reliable source.
`
`37.
`
`I have been asked to prepare an English translation of the French
`
`abbreviations and words in the additional information in the entry for “topographic”
`
`in Exhibit 2034. Here, “topographic” is the fourth sub—entry under the headword
`
`“topo.”
`
`38.
`
`In the sub-entry for “topographic” in Exhibit 2034, the following
`
`French abbreviations and words are used. These words and their translations into
`
`English are provided in the following table.
`
`MacNeiI Exhibit 2115
`
`Yita v. MacNeiI IP, IPR2020-01139
`
`Page 15
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 15
`
`
`
`“topographic”
`
`The pipe symbol is used to
`separate sub—entries.
`
`
`
`
`
`
`— 15—
`
`May 21,2021
`
`—«
`
`/
`
`
`The forward slash is used to
`
`separate a sub-entry (and its field
`in parentheses) from the
`
`suggested translation(s).
`
`
`
`
`
`
`
`
`
`
`
`
`
`feminine noun
`
`,
`.
`,
`.
`surveying, geography,
`arp, geographic, meteorol. meteorology
`
`
`39.
`
`As indicated above, I am a professional translator fluent in French
`
`and English and I am American Translators Association Certified for translation
`
`from French into English. I state that to the best of my knowledge and belief I have
`
`accurately translated the terms for which no French to English translation is provided
`
`from the entry for “topographic” in Exhibit 2034 from French to English and that
`
`said accurate translation is provided in the preceding table.
`
`40.
`
`Exhibit 2035 in IPR2020-01 139 and IPR2020—01 142 is a screen shot
`
`of Google Translate from English Topography to French Topographic.
`
`I am
`
`personally familiar with the Google Translate service. In my opinion, the translation
`
`of “topography” from English to French in Exhibit 2035 is accurate.
`
`41.
`
`Exhibit 2038 in IPR2020-01139 and IPR2020-01142 is an excerpt
`
`from the Dictionnaire des techniques et sciences appliquées containing the entry for
`
`MacNeil Exhibit 2115
`
`Yita v. MacNeiI IP, IPR2020-01139
`
`Page 16
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 16
`
`
`
`—l6—
`
`May21,2021
`
`“relief.” I am personally familiar with the Dictionnaire des techniques et sciences
`
`appliquées and consider it to be a reliable source.
`
`42.
`
`I have been asked to prepare an English translation of the French
`
`abbreviations and words in the additional information in the entry for “relief” in
`
`Exhibit 2038.
`
`43.
`
`In the entry for “relief” in Exhibit 2038, the following French
`
`abbreviations and words are used. These words and their translations into English
`
`are provided in the following table.
`
`“—
`
`
`
`
`
`_—
`
`__
`
`
`
`
`
`
`
`
`--
`
`
`
`
`
`
`
`
`
`MacNeiI Exhibit 2115
`
`Yita v. MacNeiI IP, |PR2020-01139
`
`Page 17
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 17
`
`
`
`
`
`
`
`— 17—
`
`May21,2021
`
`
`
`
`
`44.
`
`As indicated above, I am a professional translator fluent in French
`
`and English and I am American Translators Association Certified for translation
`
`from French into English. I state that to the best of my knowledge and belief I have
`
`accurately translated the terms for which no French to English translation is provided
`
`from the entry for “relief” in Exhibit 2038 from French to English and that said
`
`accurate translation is provided in the preceding table.
`
`MacNeiI Exhibit 2115
`
`Yita v. MacNeiI IP, |PR2020-01139
`
`Page 18
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 18
`
`
`
`—18—
`
`May21,2021
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`5t
`Executed this x, t7 l / day of May, 2021.
`
`
`
`MacNeiI Exhibit 21 15
`
`Yita v. MacNeiI IP, |PR2020-01139
`
`Page 19
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 19
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
