UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`YITA LLC,
`Petitioner,
`
`V.
`
`MACNEIL IP LLC,
`Patent Owner.
`
`SUPPLEMENTAL DECLARATIONOF BRUCED. POPP, PhD
`
`MacNeil Exhibit 2115
`
`Yita v. MacNeil IP, IPR2020-01139
`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 DECLARATIONOF BRUCED. POPP, PhD
`
`MacNeil Exhibit 2115
`
`Yita v. MacNeil IP, IPR2020-01139
`Page 1
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 1
`
`
`
`BIEN FAIT
`Translation and Patent Services
`
`Bruce D. Popp, PhD
`ATACertified Translator, French into English
`USPTO Registered Patent Agent
`
`I, Bruce D. Popp, hereby declare as follows:
`
`1.
`
`I possess advanced knowledgeofthe 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 independenttranslator
`
`since 2002.
`
`2.
`
`I am certified by the American Translators Association for French
`
`into English translations. In 2017, I wasthe 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 amaregistered 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 Codede 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 Dipléme approfondi de la languefrancaise, C2
`660 BoasST., APT. 1011
`p>Popp@bien-
`HARRISBURG, PA 17102
`866-243-6324
`ait.com
`UNITED STATES
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 2
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 2
`
`
`
`—-2-
`
`May 21, 2021
`
`level (mastery) certification in French-languageabilities.
`
`9.
`
`I have authored the following publications in the previousten years:
`
`I currently have a book project in the field history of physics under
`
`contract with Springer with a tentative publication date in 2023.
`
`e Henri Poincaré: From Electrons to Special Relativity, Springer, New
`
`York, 2020.
`
`e Dealing with Terminology Drift, The ATA Chronicle, vol. XLVIII,
`
`num. 1, Jan/Feb. 2019.
`
`e The Three-Body Problem and the Equations ofDynamics: Poincaré’s
`
`Foundational Work on Dynamical Systems Theory, Springer, New
`
`York, 2017.
`
`e Accuracy in Patent Translation, Boston Patent Law Association
`
`Newsletter, vol. 40, issue 3, summer 2010.
`
`e 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 headwordis not repeated andis replacedbya tilde (~).
`
`MacNeil Exhibit 2115
`
`Yita v. MacNeil IP, IPR2020-01139
`Page 3
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 3
`
`
`
`—3-
`
`May21, 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,”
`
`99 66
`
`“collerette,” and “rebord” as found in the
`
`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 “rebord” in Exhibit 2025,
`
`the following French abbreviations and words are used. These words and their
`
`translations into English are provided in the followingtable:
`
`MacNeil Exhibit 2115
`
`Yita v. MacNeil IP, IPR2020-01139
`Page 4
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 4
`
`
`
`-4-
`
`May 21, 2021
`
`
`
`
`
`
`
`
`
`
`
`
`
`om
`
`SWeoe
`
`emploilittéral
`
`de vétement
`
`a c
`
`o
`
`de boutonniére
`
`de dentelle
`
`de bielle
`
`for connecting rod
`
`Médecine
`
`medicine
`
`“collerette”
`
`formes
`
`word forms
`
`
`
`
`
`MacNeil Exhibit 2115
`
`Yita v. MacNeil IP, IPR2020-01139
`Page 5
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 5
`
`
`
`—5-
`
`May 21, 2021
`
`
`
`
`
`
`
`
`
`
`ms
`
`nom masculin
`
`d’assiette, tuyau, plat, pot
`
`du puits, falaise
`
`de corniche,table, buffet
`
`de vétement
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`14.
`
`Asindicated 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 knowledgeandbelief 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
`
`from 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 considerit to be a reliable
`
`source.
`
`16.
`
`I have been asked to prepare an English translation of the French
`
`abbreviations and wordsin the additional information in the entry for “rebord” in
`
`Exhibit 2026.
`
`17.
`
`In the entry for “rebord” in Exhibit 2026, the following French
`
`abbreviations and words are used. These words andtheir translations into English
`
`are provided in the followingtable.
`
`“rebord”
`
`assiette, pot
`
`plate, pot
`
`
`
`
`
`
`
`
`ee
`
`
`puits, falaise, table
`
`well, cliff, table
`
`18.
`
`Asindicated 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 ofmy knowledgeandbelief I have
`
`accurately translated the terms for which no Frenchto English translation is provided
`
`from the entry for “rebord” in Exhibit 2026 from French to English and that said
`
`accurate translation is provided in the precedingtable.
`
`MacNeil Exhibit 2115
`
`Yita v. MacNeil IP, IPR2020 -01139
`Page 7
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 7
`
`
`
`—T-
`
`May 21, 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 “rebord.”
`
`39
`
`I am personally familiar with the Larousse
`
`French-English English-French Dictionary and considerit to be a reliable source.
`
`20.
`
`I have been asked to prepare an English translation of the French
`
`abbreviations and wordsin the additional information in the entry for “rebord” in
`
`Exhibit 2027.
`
`21.
`
`In the entry for “rebord” in Exhibit 2027, the following French
`
`abbreviations and words are used. These words and their translations into English
`
`are providedin the following table.
`
`
`
`eat
`
`
`
`d’une fenétre
`
`of a window
`
`“rebord”
`
`
`
`
`
`
`
`eeee
`
`
`
`22.
`
`Asindicated 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
`
`MacNeil Exhibit 2115
`
`Yita v. MacNeil IP, IPR2020 -01139
`Page 8
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 8
`
`
`
`—8-
`
`May21, 2021
`
`accurately translated the terms for which no Frenchto Englishtranslation is provided
`
`from the entry for “rebord” in Exhibit 2027 from French to English and that said
`
`accurate translation is provided in the precedingtable.
`
`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 considerit 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 “rebord” in Exhibit 2028, the following French
`
`abbreviations and words are used. These words andtheir translations into English
`
`are provided in the followingtable.
`
`
`
`
`“rebord”
`
`
`
`
`26.
`
`Asindicated 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 andbelief 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-
`
`May 21, 2021
`
`from the entry for “rebord” in Exhibit 2028 from French to English and that said
`
`accurate translation is provided in the precedingtable.
`
`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 “rebord.”
`
`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 “rebord” in Exhibit 2029.
`
`29.
`
`In the entries for “bride”, “collerete,” and “rebord” in Exhibit 2029,
`
`the following French abbreviations and words are used. These words and their
`
`—
`
`translations into English are provided in the followingtable.
`
`
`
`
`
`
`ThepipesymbolisOEto
`
`
`separate sub-entries.
`
`
`The forward slash is used to
`separate a sub-entry (andits field
`in parentheses) from the
`suggested translation(s).
`
`feminine noun
`
`
`
`
`
`
`
`
`
`
`
`
`MacNeil Exhibit 2115
`
`Yita v. MacNeil IP, IPR2020-01139
`Page 10
`
`
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 10
`
`
`
`—10-
`
`May 21, 2021
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`MacNeil Exhibit 2115
`
`Yita v. MacNeil IP, IPR2020-01139
`Page 11
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`ea a
`a a
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 11
`
`
`
`—ll-
`
`May21, 2021
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`“collerette”
`
`jeaeaoO
`
`déme de chaudiére
`
`“rebord”
`
`bord replié
`
`folded-back edge
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`MacNeil Exhibit 2115
`
`Yita v. MacNeil IP, IPR2020-01139
`Page 12
`
`
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 12
`
`
`
`Pe
`
`
`
`
`
`
`
`
`
`—~12-
`
`May 21, 2021
`
`
`
`
`
`
`
`
`30.
`
`Asindicated 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 andbelief I have
`
`accurately translated the terms for which no Frenchto English translation is provided
`
`from the entries for “bride”, “collerete,” and “rebord” in Exhibit 2029 from French
`
`to English and that said accurate translation is provided in the precedingtable.
`
`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 techniqueset sciences
`
`appliquées and considerit 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
`
`MacNeil Exhibit 2115
`
`Yita v. MacNeil IP, IPR2020-01139
`Page 13
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 13
`
`
`
`“contour”
`
`The pipe symbolis used to
`separate sub-entries.
`
`The forward slash is used to
`separate a sub-entry (andits field
`in parentheses) from the
`suggested translation(s).
`
`/
`
`—13-
`
`May 21, 2021
`
`abbreviations and words are used. These wordsandtheir translations into English
`
`are providedin the followingtable.
`
`
`
`34.
`
`Asindicated 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 knowledgeandbelief I have
`
`MacNeil Exhibit 2115
`
`Yita v. MacNeil IP, IPR2020-01139
`Page 14
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 14
`
`
`
`—14-
`
`May21, 2021
`
`accurately translated the terms for which no Frenchto Englishtranslation is provided
`
`from the entry for “contour” in Exhibit 2032 from French to English and that said
`
`accurate translation is provided in the precedingtable.
`
`35.
`
`Exhibit 2033 in IPR2020-01139 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 techniqueset sciences appliquées containing the entry for
`
`“topographie.” I am personally familiar with the Dictionnaire des techniques et
`
`sciences appliquées and considerit to be a reliable source.
`
`37.
`
`I have been asked to prepare an English translation of the French
`
`abbreviations and wordsin the additional information in the entry for “topographie”
`
`in Exhibit 2034. Here, “topographie” is the fourth sub-entry under the headword
`
`“topo.”
`
`38.
`
`In the sub-entry for “topographie” in Exhibit 2034, the following
`
`French abbreviations and words are used. These words andtheir translations into
`
`English are provided in the following table.
`
`MacNeil Exhibit 2115
`
`Yita v. MacNeil IP, IPR2020-01139
`Page 15
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 15
`
`
`
`-15-
`
`May 21, 2021
`
`ee
`
`
`
`
`
`“topographie”
`
`The pipe symbolis 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).
`
`
`
`
`feminine noun
`
`
`
`
`
`
`
`
`,
`.
`nee
`surveying, geography,
`arp, géographie, météorol. meteorology
`
`
`39.
`
`Asindicated 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 knowledgeandbelief I have
`
`accurately translated the terms for which no Frenchto English translation is provided
`
`from the entry for “topographie” in Exhibit 2034 from French to English and that
`
`said accurate translation is provided in the precedingtable.
`
`40.
`
`Exhibit 2035 in IPR2020-01 139 and IPR2020-01 142 is a screen shot
`
`of Google Translate from English Topography to French Topographie.
`
`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. MacNeil IP, IPR2020-01139
`Page 16
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 16
`
`
`
`— 16-
`
`May21, 2021
`
`“relief.” I am personally familiar with the Dictionnaire des techniques et sciences
`
`appliquées and considerit 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 andtheir translations into English
`
`are providedin the followingtable.
`
`
`
`ee
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`=
`
`'Sst
`
`smo
`
`géol.
`
`geology
`
`MacNeil Exhibit 2115
`
`Yita v. MacNeil IP, IPR2020-01139
`Page 17
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 17
`
`
`
`
`
`
`
`—17-
`
`May 21, 2021
`
`
`
`
`
`44.
`
`Asindicated above, I am a professionaltranslator 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 knowledgeandbelief I have
`
`accurately translated the terms for which no Frenchto Englishtranslation is provided
`
`from the entry for “relief? in Exhibit 2038 from French to English and that said
`
`accurate translation is provided in the precedingtable.
`
`MacNeil Exhibit 2115
`
`Yita v. MacNeil IP, IPR2020-01139
`Page 18
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 18
`
`
`
`—18-
`
`May21, 2021
`
`I declare underpenalty of perjury that the foregoing is true and correct.
`
`st
`Executed this _.\’!~_ day of May,2021.
`
`
`
`MacNeil Exhibit 2115
`
`Yita v. MacNeil IP, IPR2020-01139
`Page 19
`
`MacNeil Exhibit 2115
`Yita v. MacNeil IP, IPR2020-01139
`Page 19
`
`
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