`________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________________
`ADVANCED ENERGY INDUSTRIES INC..,
`PETITIONER,
`v.
`RENO TECHNOLOGIES INC.,
`PATENT OWNER.
`________________________________
`
`Case IPR2021-01397
`Patent 10,707,057
`________________________________
`
`DECLARATION OF DENIS SHAW
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW OF U.S.
`PATENT NO. 10,707,057
`
`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1016
`
`
`
`I, Denis Shaw, hereby declare as follows:
`
`I.
`
`INTRODUCTION
`1.
`I am over the age 18 and can competently testify to the facts set out in
`
`this declaration.
`
`2.
`
`Unless otherwise indicated below, the statements in this declaration
`
`are based upon my personal knowledge and beliefs.
`
`3.
`
`I am currently Vice President, Integrated Solutions at Advanced
`
`Energy Industries, Inc. (“AEI”). In the 2012 timeframe addressed in this
`
`declaration, my title was Director of Worldwide Applications Technology at AEI.
`
`4.
`
`In my role with AEI, I often attend conferences and trade shows to
`
`market new products and technology developed by AEI. One such event that I
`
`personally attended was SEMICON West 2012, held July 12-14, 2012, at the
`
`Moscone Center in San Francisco, CA. SEMICON West is a large annual global
`
`tradeshow and conference for the semiconductor and microelectronics industry.
`
`5.
`
`In 2012, I believe SEMICON West would have been attended by well
`
`over ten thousand people in the industry. The attendees would have included many
`
`engineers, physicists, and other scientists, including those who worked for AEI’s
`
`competitors and customers, interested to learn about the latest technology in the
`
`semiconductor industry. I have a PhD in electrical engineering with over 20 years
`
`of industry experience and met with many others at SEMICON West 2012 having
`
`1
`
`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1016
`
`
`
`similar levels of knowledge and experience, including those with expertise in radio
`
`frequency match networks used with plasma processing applications.
`
`6.
`
`Like many other companies at SEMICON West 2012, AEI had a
`
`booth to market AEI products to potential customers or other interested parties that
`
`were in attendance. One of the products prominently displayed and marketed at
`
`AEI’s booth at SEMICON West 2012 was the Navigator® II matching network.
`
`As part of the marketing focus on Navigator® II, AEI created a Navigator® II
`
`matching network poster, including a three foot by four foot version to display at
`
`the show. I worked in AEI’s booth all three days over July 10-12, 2012 where the
`
`Navigator® II poster was on display all three days.
`
`7.
`
`The Navigator® II poster would have been highly visible to all
`
`SEMICON West 2012 attendees visiting AEI’s booth or those simply walking past
`
`in the nearby public areas as the purpose was to market the Navigator® II products
`
`to the attendees. All attendees at the conference, including AEI’s competitors,
`
`could have viewed and copied the Navigator® II poster, including writing down
`
`notes. There were no restrictions or conditions on viewing the Navigator® II poster
`
`such as private showings, non-disclosure agreements, or otherwise. I openly
`
`discussed the Navigator® II product, including the various details and performance
`
`attributes shown on the poster, with many interested attendees.
`
`2
`
`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1016
`
`
`
`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1016
`
`
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