`U.S. Patent No. 9,537,071
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
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`VIZIO, INC.,
`Petitioner
`
`v.
`
`NICHIA CORPORATION,
`Patent Owner
`_______________
`
`Case No. IPR2018-00437
`Patent 9,537,071
`_______________
`
`
`
`DECLARATION OF DRAGO N. GREGOV
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`VIZIO Ex. 1040 Page 00001
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`Case No. IPR2018-00437
`U.S. Patent No. 9,537,071
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`I, Drago N. Gregov, make the following Declaration pursuant to 28 U.S.C.
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`§ 1746:
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`1.
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`I am a Litigation Paralegal Specialist at the law firm of
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`Ropes & Gray LLP.
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`2.
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`I provide this Declaration in connection with the above-identified
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`Inter Partes Review proceeding requested at the United States Patent and
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`Trademark Office by VIZIO, Inc. Unless otherwise stated, the facts stated in this
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`Declaration are based on my personal knowledge.
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`3.
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`Exhibit 1018 hereto is a true and correct copy of excerpts from the
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`File History of U.S. Patent Application No. 15/360,316 (U.S. Patent No.
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`10,115,870) to Hirofumi Ichikawa, Masaki Hayashi, Shimpei Sasaoka and
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`Tomohide Miki, which I downloaded on December 6, 2018 from the United States
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`Patent and Trademark Office (“USPTO”) Patent Application Information Retrieval
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`(“PAIR”) website and which is a record of the USPTO to which all parties have
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`access. An exhibit label and page numbers on all pages have been added to the
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`bottom of this document but no other alterations have been made.
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`4.
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`Exhibit 1020 hereto is a true and correct copy of United States Patent
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`Publication No. 2005/0151149 by Chee Wai Chia, Peng Koay and Lye Yee Wong,
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`which I downloaded on December 6, 2018 from the United States Patent and
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`Trademark Office (“USPTO”) Patent Application Information Retrieval (“PAIR”)
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`2
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`VIZIO Ex. 1040 Page 00002
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`Case No. IPR2018-00437
`U.S. Patent No. 9,537,071
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`website and which is a record of the USPTO to which all parties have access. An
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`exhibit label and page numbers on all pages have been added to the bottom of this
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`document but no other alterations have been made.
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`5.
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`Exhibit 1021 hereto is a true and correct copy of United States Patent
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`Publication No. 2004/0126913 by Ban P. Loh, which I downloaded on December
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`6, 2018 from the United States Patent and Trademark Office (“USPTO”) Patent
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`Application Information Retrieval (“PAIR”) website and which is a record of the
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`USPTO to which all parties have access. An exhibit label and page numbers on all
`
`pages have been added to the bottom of this document but no other alterations have
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`been made.
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`6.
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`Exhibit 1022 hereto is a true and correct copy of United States Patent
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`Publication No. 2005/0269587 by Ban P. Loh and Gerald H. Negley, which I
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`downloaded on December 6, 2018 from the United States Patent and Trademark
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`Office (“USPTO”) Patent Application Information Retrieval (“PAIR”) website and
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`which is a record of the USPTO to which all parties have access. An exhibit label
`
`and page numbers on all pages have been added to the bottom of this document but
`
`no other alterations have been made.
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`7.
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`Exhibit 1029 hereto is a true and correct copy of U.S. Patent No.
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`10,115,870 to Hirofumi Ichikawa, Masaki Hayashi, Shimpei Sasaoka and
`
`Tomohide Miki, which I downloaded on December 10, 2018 from the United
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`3
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`VIZIO Ex. 1040 Page 00003
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`
`
`Case No. IPR2018-00437
`U.S. Patent No. 9,537,071
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`
`States Patent and Trademark Office (“USPTO”) Patent Application Information
`
`Retrieval (“PAIR”) website and which is a record of the USPTO to which all
`
`parties have access. An exhibit label and page numbers on all pages have been
`
`added to the bottom of this document but no other alterations have been made.
`
`8.
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`Exhibit 1030 hereto is a true and correct copy of U.S. Patent No.
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`6,770,498 to Cheng-Hsiang Hsu, which I downloaded on December 6, 2018 from
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`the United States Patent and Trademark Office (“USPTO”) Patent Application
`
`Information Retrieval (“PAIR”) website and which is a record of the USPTO to
`
`which all parties have access. An exhibit label and page numbers on all pages
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`have been added to the bottom of this document but no other alterations have been
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`made.
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`9.
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`Exhibit 1031 hereto is a true and correct copy of Japanese Patent
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`Publication No. JP2007-235085 by Naoyuki Urasaki, which I downloaded on
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`December 7, 2018 from the European Patent’s Office (“EPO”) Espacenet search
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`page http://worldwide.espacenet.com (a record of the EPO to which all parties
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`have access), and a true and correct copy of a translation of the text of that
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`document and a certification of accuracy regarding that translation provided by
`
`Geotext Translations, Inc. An exhibit label and page numbers on all pages have
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`been added to the bottom of this document but no other alterations have been
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`made.
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`4
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`VIZIO Ex. 1040 Page 00004
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`10. Exhibit 1032 hereto is a true and correct copy of Japanese Patent
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`Case No. IPR2018-00437
`U.S. Patent No. 9,537,071
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`Publication No. JP2006-156704 by Masafumi Kuramoto and Tomohisa Kishimoto,
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`which I downloaded on December 7, 2018 from the European Patent’s Office
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`(“EPO”) Espacenet search page http://worldwide.espacenet.com (a record of the
`
`EPO to which all parties have access), and a true and correct copy of a translation
`
`of the text of that document and a certification of accuracy regarding that
`
`translation provided by Geotext Translations, Inc. An exhibit label and page
`
`numbers on all pages have been added to the bottom of this document but no other
`
`alterations have been made.
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`11. Exhibit 1033 hereto is a true and correct copy of Japanese Patent
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`Publication No. JP2001-036154 by Ryoma Suenaga and YoichiMatsuoka, which I
`
`downloaded on December 7, 2018 from the European Patent’s Office (“EPO”)
`
`Espacenet search page http://worldwide.espacenet.com (a record of the EPO to
`
`which all parties have access), and a true and correct copy of a translation of the
`
`text of that document and a certification of accuracy regarding that translation
`
`provided by Geotext Translations, Inc. An exhibit label and page numbers on all
`
`pages have been added to the bottom of this document but no other alterations have
`
`been made.
`
`12. Exhibit 1034 hereto is a true and correct copy of U.S. Patent No.
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`6,433,277 to Thomas P. Glenn, which I downloaded on December 7, 2018 from
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`5
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`VIZIO Ex. 1040 Page 00005
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`
`
`Case No. IPR2018-00437
`U.S. Patent No. 9,537,071
`
`
`the United States Patent and Trademark Office (“USPTO”) Patent Application
`
`Information Retrieval (“PAIR”) website and which is a record of the USPTO to
`
`which all parties have access. An exhibit label and page numbers on all pages
`
`have been added to the bottom of this document but no other alterations have been
`
`made.
`
`13. Exhibit 1035 hereto is a true and correct copy of Japanese Patent
`
`Publication No. JPH7-99345 to Kousuke Matoba et al., which I downloaded on
`
`December 7, 2018 from the European Patent’s Office (“EPO”) Espacenet search
`
`page http://worldwide.espacenet.com (a record of the EPO to which all parties
`
`have access), and a true and correct copy of a translation of the text of that
`
`document and a certification of accuracy regarding that translation provided by
`
`Geotext Translations, Inc. An exhibit label and page numbers on all pages have
`
`been added to the bottom of this document but no other alterations have been
`
`made.
`
`14. Exhibit 1039 hereto is a true and correct copy of an excerpt from the
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`“IEEE Standard Glossary of Computer Hardware Terminology”, IEEE Std 610.10-
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`1994, October 12, 1995. An exhibit label and page numbers on all pages have
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`been added to the bottom of this document but no other alterations have been
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`made.
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`6
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`VIZIO Ex. 1040 Page 00006
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`Case No. IPR2018-00437
`USS. Patent No. 9,537,071
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`15.
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`Ihave been warnedthat willful false statements andthe like are
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`punishable by fine or imprisonment, or both. I makethis declaration of my own
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`personal knowledge,andall statements are true.
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`If called to testify as to the
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`matters stated herein, I could and would testify competently.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed this 11th day of December, 2018, at East Palo Alto, California.
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`a Drago N. out
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`VIZIO Ex. 1040 Page 00007
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`VIZIO Ex. 1040 Page 00007
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