UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`GOOGLE LLC,
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`Petitioner,
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`v.
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`ARIGNA TECHNOLOGY LIMITED,
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`Patent Owner.
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`
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`Case No. IPR2022-00685
`U.S. Patent No. 6,603,343
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`Declaration of Shauna L. Wiest Regarding Oswald
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`Page 1 of 13
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`GOOGLE EXHIBIT 1015
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`GOOGLE LLC,
`
`Petitioner,
`
`v.
`
`ARIGNA TECHNOLOGY LIMITED,
`
`Patent Owner.
`
`
`
`
`
`
`
`
`Case No. IPR2022-00685
`U.S. Patent No. 6,603,343
`
`
`
`
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`
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`Declaration of Shauna L. Wiest Regarding Oswald
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`Page 1 of 13
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`GOOGLE EXHIBIT 1015
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`I.
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`Introduction
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`Declaration of Shauna L. Wiest
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`1.
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`I have prepared this Declaration in connection with the Petition for
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`Inter Partes Review of U.S. Patent No. 6,603,343 which I understand will be
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`filed concurrently with this Declaration.
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`2.
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`I am currently a senior research analyst with the Research &
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`Information Services team at Finnegan, Henderson, Farabow, Garrett & Dunner,
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`LLP, located at 901 New York Avenue, NW, Washington, DC 20001-4413.
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`3.
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`I am over eighteen years of age, and I am competent to make this
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`Declaration. I make this Declaration based on my own personal knowledge, and
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`my knowledge of library science practices.
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`4.
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`I earned a Master of Science in Library Science from the University
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`of North Carolina at Chapel Hill in 1999, and a Bachelor of Arts in Political
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`Science from the University of California at San Diego in 1985. I have worked
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`as a law librarian for over twenty years. I have been employed in the Research
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`& Information Services Department at Finnegan, Henderson, Farabow, Garrett
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`& Dunner, LLP since 2021. Before that, from 2000-2015, I was employed as a
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`Law Librarian at Stoel Rives LLP, and from 2015-2016, I was employed as a
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`Competitive Intelligence Specialist for Nossaman LLP.
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`2
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`Page 2 of 13
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`II.
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`Standard Library Practice for Receiving, Cataloging, and Making
`Materials Publicly Available
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`Declaration of Shauna L. Wiest
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`5.
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`I have knowledge of and experience with standard library practices
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`regarding the receipt, cataloging, shelving of materials, including making
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`materials available to the public. I have knowledge of and experience with the
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`Machine-Readable Cataloging (MARC) system, an industry-wide standard that
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`libraries use to catalog materials.
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`6.
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`The MARC system was developed during the 1960s to standardize
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`bibliographic records so they could be read by computers and shared among
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`libraries. By the mid-1970s, MARC had become the international standard for
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`bibliographic data and cataloguing. It is still used today.
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`7. Many libraries provide public access to their MARC records via the
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`Internet and/or their electronic cataloging systems at the library. The MARC record
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`system uses a specific three-digit numeric code (from 001-999) to identify each field
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`in a catalog record. For example, field tag 008 provides the six-digit date the item
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`was catalogued (Date entered on file). The first six characters of field tag 008 are
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`always in the “YYMMDD” format. Field tag 245 identifies the full title statement
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`for the work; field tag 260 identifies the place of publication, name of publisher, and
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`copyright date of the publication; field tag 310 denotes the current frequency of the
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`publication; and field tag 362 identifies the dates of publication and/or sequential
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`designation for the item.
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`3
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`Page 3 of 13
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`Based on standard library practice, when a library receives an item, it
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`Declaration of Shauna L. Wiest
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`8.
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`stamps the item with the library name and often with a date that is within a few days
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`or weeks of receipt. Next, the library will catalog the item within a matter of a few
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`days or weeks of receiving it.
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`9.
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`Generally, after an item is cataloged, the public may access the item by
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`searching a catalog and either requesting or electronically accessing the item from
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`the library. Standard library practice is to make the item available to the public within
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`a few days or weeks of cataloging it.
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`III. MARC Records for Oswald
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`10. As detailed below, I have reviewed the Library of Congress MARC
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`record for G. Oswald, “Application of Multiple Varactor Diodes to AM and FM
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`Tuners,” 1968 IEEE International Solid-State Circuits Conference, Digest of
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`Technical Papers (Library of Congress Card No.: 59-44023), February 14-16,
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`1968. (“Oswald”). The Oswald reference was presented as Paper 13.3 during
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`Session XIII: Consumer Electronics held on February 16, 1968, 1:30-4:30PM.
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`Oswald appears on page 138 in the Digest of Technical Papers (Library of
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`Congress Card No.: 59-44023). Exhibit 1009 to the concurrently filed Petition
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`is a true and accurate copy of Oswald.
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`11. Appendix A to this declaration is a true and accurate copy of the
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`MARC catalog record from The Library of Congress for its copy and holdings of
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`4
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`Page 4 of 13
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`Digest of technical papers / International Solid-State Circuits containing Oswald,
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`Declaration of Shauna L. Wiest
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`downloaded from https://lccn.loc.gov/59044023.
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`12.
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`In The Library of Congress MARC record, the fixed data elements of
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`MARC field tag 008 are listed as 780328d19601968. As discussed above, the first
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`six characters “780328” are in typical “YYMMDD” format and indicate that Digest
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`of technical papers / International Solid-State Circuits containing Oswald was
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`catalogued by The Library of Congress on March 28, 1978. Based on standard
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`library practices, Oswald would have been shelved and made available to the public
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`a few days or weeks after March 28, 1978.
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`13.
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`In The Library of Congress MARC catalog record, field tag 245
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`denotes the title and statement of responsibility for the work as “Digest of technical
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`papers / |c International Solid-State Circuits Conference.”
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`14.
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`In The Library of Congress MARC catalog record, field tag 260 denotes
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`information relating to the place of publication, name of publisher, and date of
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`publication and distribution as “|a New York, N.Y. : |b Lewis Winner, |c 1960-1968.”
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`Subfield code “a” refers to the place of publication. Subfield code “b” refers to the
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`name of the publisher. Subfield code “c” refers to date of publication, which for this
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`record is 1960-1968.
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`15.
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`In The Library of Congress MARC catalog record, Field tag 362
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`identifies the dates of publication and/or sequential designation, which for this
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`record is 1960-1968.
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`5
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`Page 5 of 13
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`16. Based on this evidence, it is my opinion that Exhibit 1009 is an
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`Declaration of Shauna L. Wiest
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`authentic document, which was made publicly accessible and publicly available a
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`few days or weeks after March 28, 1978.
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`IV. U.S. Copyright Records for Oswald
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`17. The United States Copyright Office, a part of the Library of
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`Congress, is the official U.S. government body that maintains records of
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`copyright registrations in the United State, including providing public access to
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`an online Copyright Catalog. The records contained in this catalog are publicly
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`accessible and are routinely used by copyright title researchers who are
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`attempting to clear a chain of title for copyrighted works.
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`18. Appendix B to this declaration is a true and accurate copy of the U.S.
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`Copyright Office record for its copy of Oswald downloaded from its Proof of
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`Concept (Virtual Card Catalog) (Time-Period: 1955-1970; Drawer Label: DIG-
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`DIGIS; Card Number: .0625) available here: https://copyright.gov/vcc/.
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`19. Appendix B establishes that Oswald was copyright protected on
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`February 14, 1968. Appendix B also establishes that Oswald existed and was made
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`available to researchers a few days or weeks after February 14, 1968.
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`20. Based on this evidence, it is my opinion that Exhibit 1009 is an
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`authentic document, which was made publicly accessible to and in actual use by
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`researchers no later than March 1, 1968.
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`6
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`Page 6 of 13
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`V. Conclusion
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`Declaration of Shauna L. Wiest
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`21.
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`In signing this Declaration, I understand it will be filed as evidence
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`in a contested case before the Patent Trial and Appeal Board of the United States
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`Patent and Trademark Office. I understand I may be subject to cross-
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`examination in this case and that cross-examination will take place within the
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`United States. If cross-examination is required of me, I will appear for cross-
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`examination within the United States during the time allotted for cross-
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`examination.
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`22.
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`I declare that all statements made herein of my knowledge are true, that
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`all statements made on information and belief are believed to be true, and that these
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`statements were made with the knowledge that willful false statements and the like
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`so made are punishable by fine or imprisonment, or both, under Section 1001 of Title
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`18 of the United States Code.
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`
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`Executed on March 9, 2022, in Washington, DC.
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`Shauna L. Wiest
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`7
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`Page 7 of 13
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`APPENDIX A
`APPENDIX A
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`Page 8 of 13
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`Page 8 of 13
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`2/15/22, 2:48 PM
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`LC Catalog - Item Information (MARC Tags)
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`
`
` 1 of 1
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`PERIODICAL OR NEWSPAPER
`
`Digest of technical papers
`
`Full Record
`
`MARC Tags
`
`000
`001
`005
`008
`010
`016
`022
`035
`040
`
`042
`050
`082
`111
`210
`222
`245
`260
`300
`310
`336
`337
`338
`362
`530
`590
`650
`650
`650
`650
`
`02727cas a2200577 a 4500
`11152631
`20220212065701.0
`780328d19601968nyuar 1 a0eng c
` |a 59044023 |z sc 79003639
`__
` |a 012754112 |2 Uk
`7_
` |a 0074-8587 |l 0074-8587 |2 1
`0_
` |a (OCoLC)ocm03756407
`__
` |a TOL |b eng |c TOL |d FUG |d DLC |d NSD |d OCL |d DLC |d NST |d DLC |d NST |d OCL |d DLC |d NST |d DLC |d
`__
` MYG |d OCLCQ |d MYG |d OCLCQ |d CNMBL |d UKMGB |d OCLCF |d OCLCO |d OCL |d OCLCO |d OCLCQ |d OC
`LCO
` |a pcc |a nsdp
` |a TK7870 |b .I58
` |a 621.3815/05
` |a International Solid-State Circuits Conference.
` |a Dig. tech. pap. - Int. Solid-State Circuits Conf.
` |a Digest of technical papers - International Solid-State Circuits Conference
` |a Digest of technical papers / |c International Solid-State Circuits Conference.
` |a New York, N.Y. : |b Lewis Winner, |c 1960-1968.
` |a 9 volumes : |b illustrations ; |c 29 cm
` |a Annual
` |a text |b txt |2 rdacontent
` |a unmediated |b n |2 rdamedia
` |a volume |b nc |2 rdacarrier
` |a 1960-1968.
` |a Also issued online in PDF.
` |a SERBIB/SERLOC merged record
` |a Semiconductors |v Congresses.
` |a Integrated circuits |v Congresses.
` |a Solid state electronics |v Congresses.
` |a Physique de l'état solide.
`
`__
`00
`0_
`2_
`0_
`_0
`10
`__
`__
`__
`__
`__
`__
`0_
`__
`__
`_0
`_0
`_0
`_6
`
`https://catalog.loc.gov/vwebv/staffView?searchId=22150&recPointer=0&recCount=25&searchType=1&bibId=11152631
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`1/3
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`2/15/22, 2:48 PM
`650
`650
`650
`655
`776
`780
`785
`
`850
`859
`890
`906
`920
`985
`991
`991
`991
`991
`992
`
`LC Catalog - Item Information (MARC Tags)
` |a Integrated circuits. |2 fast |0 (OCoLC)fst00975535
` |a Semiconductors. |2 fast |0 (OCoLC)fst01112198
` |a Solid state electronics. |2 fast |0 (OCoLC)fst01125449
` |a Conference papers and proceedings. |2 fast |0 (OCoLC)fst01423772
` |i Online version: |a International Solid-State Circuits Conference. |t Digest of technical papers |w (OCoLC)763151191
` |a Solid-State Circuits Conference. |t Digest of technical papers |x 0277-7983 |w (OCoLC)7621910
` |a IEEE International Solid-State Circuits Conference. |t Digest of technical papers |x 0193-6530 |w (DLC)
`81644810 |w (OCoLC)2675897
` |a AzTeS |a CSt |a CU-S |a DLC |a NSyU |a NcD |a NcRS |a PPD |a ViBlbV |a ViU
` |u http://ieeexplore.ieee.org/xpl/conhome.jsp?punumber=1000708
` |a Digest of technical papers (International Solid-State Circuits Conference) New York, N.Y. |i 59-44023
` |a 7 |b cbc |c serials |d 2 |e ncip |f 19 |g n-oclcserc
` |a Keep 2
` |e eserial 200406
` |b c-GenColl |h TK7870 |i .I58 |w SERIALS
` |b c-GenColl |h TK7870 |i .I58 |p 00010317630 |t Copy 2 |v 1978 * 8888 |w CCF
` |b c-GenColl |h TK7870 |i .I58 |p 00001493425 |t Copy 1 |v 25 * 8888 |w CCF
` |b c-GenColl |h TK7870 |i .I58 |p 0002305257A |t Copy 1 |v 28 1985 * 8888 |w CCF
` |b B/L |w SERLOC
`
`_7
`_7
`_7
`_7
`08
`00
`00
`
`__
`41
`__
`__
`__
`__
`__
`__
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`Request this Item
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` LC Find It
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`Item Availability
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`CALL NUMBER
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`Request in
`
`Status
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`CALL NUMBER
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`Request in
`
`Status
`
`Older receipts
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`CALL NUMBER
`
`TK7870 .I58
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`Jefferson or Adams Building Reading Rooms
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`Not Charged
`
`TK7870 .I58
`Copy 2
`
`Jefferson or Adams Building Reading Rooms
`
`Not Charged
`
`1978 * 8888
`
`TK7870 .I58
`Copy 1
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`Request in
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`Status
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`Older receipts
`
`LC Catalog - Item Information (MARC Tags)
`Jefferson or Adams Building Reading Rooms
`
`Not Charged
`
`25 * 8888
`28 1985 * 8888
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`https://catalog.loc.gov/vwebv/staffView?searchId=22150&recPointer=0&recCount=25&searchType=1&bibId=11152631
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`APPENDIX B
`APPENDIX B
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`Page 12 of 13
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`Page 12 of 13
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`2/15/22, 3:12 PM
`Cardbrowser Print
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`Card Browser
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`Property of U.S. Copyright Office
`
`Time-Period: 1955-1970
`Drawer Label: DIG-DIGIS
`Card Number: .0625
`Card Content: Digest of technical papers ... February 14-15- 16, 1968. INTERNATIONAL SOLID-STATE CIRCUITS CONFERENCE, UNIVERSITY
`OF PENNSYL- VANIA, 1968. Digest of technical papers ... February 14-15-16, 1968. Vol.11. Editor: J. A. A. Raper. 1st ed. New York, L. Winner. 176 p.
`Appl. author: Institute of Electrical & Electronics Engineers. � Institute of Electrical & Electronics Engi- neers, Inc.; 14Feb68; A68672. 1. Title. 2.
`Institute of Electrical & Electronics Engineer rnc. lp- 69-1
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`1/1
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`Page 13 of 13
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