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`IPR2018-00533
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SMR AUTOMOTIVE SYSTEMS USA, INC.,
`Petitioner,
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`v.
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`MAGNA MIRRORS OF AMERICA, INC.,
`Patent Owner.
`
`
`Case IPR2018-00533
`Patent No. 8,783,882
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`DECLARATION OF NIALL LYNAM IN SUPPORT OF PATENT OWNER
`MAGNA MIRRORS OF AMERICA, INC.’S PRELIMINARY RESPONSE
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`Patent Owner Magna - Ex. 2011, Cover
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`IPR2018-00533
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`Niall R. Lynam declares as follows:
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`1.
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`I am the sole named inventor of U.S. Pat. No. 8,783,882 (“the ‘882
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`patent”).
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`2.
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`During the prosecution of the ‘882 patent, I submitted a declaration.
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`Ex. 1006, 184-86. In my prior declaration, I declared, inter alia, that I “conceived
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`of the claimed invention of at least the independent claims.” Id. I hereby reaffirm
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`that I solely conceived of the claimed inventions of independent claims 1, 15, and
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`18 of the ‘882 patent.
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`3.
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`I also declared in my prior declaration that “I am the sole named
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`inventor of … the present application.” Id., 186. I hereby reaffirm that I am
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`properly named as the sole inventor of the ‘882 patent. I solely conceived of the
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`inventions of each of the dependent claims (claims 2-14, 16-17, and 19-20), in
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`addition to the claimed inventions of claims 1, 15, and 18.
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`4.
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`I noted in my prior declaration that I am also “the sole named inventor
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`of … U.S. Patent No. 6,522,451” (“the ‘451 patent”). I hereby reaffirm that I was
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`properly named as sole inventor of the ‘451 patent. I solely conceived of the
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`inventions disclosed in the ‘451 patent.
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`5.
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`I understand that the petitioners in this proceeding contend that the
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`claims of the ‘882 patent are anticipated and/or rendered obvious by U.S. Patent
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`Appl. Pub. No. 2002/0072026 (“Lynam ‘026”), which issued as U.S. Pat. No.
`1
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`Patent Owner Magna - Ex. 2011, p. 1
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`IPR2018-00533
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`6,717,712 (“the ‘712 patent”). I am named as an inventor of Lynam ‘026, along
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`with two co-inventors, Hans Fuchs and John Lindahl. Messrs. Fuchs and Lindahl
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`were named as co-inventors on Lynam ‘026 and the ‘712 patent because they
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`contributed the concept of a “frame element assembly,” as seen in, for example,
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`claim 1 of the ‘712 patent. The frame element assembly was an alternative to the
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`single backing plate element that is claimed in the ‘882 patent. Messrs. Fuchs and
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`Lindahl did not invent any of the claimed inventions of the ‘882 patent.
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`2
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`Patent Owner Magna - Ex. 2011, p. 2
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`IPR2018-00533
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`All statements made herein of my own knowledgearetrue, andall
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`statements made on information and belief are believed to be true. Further, I am
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`awarethat these statements are made with the knowledgethat willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under 18 U.S.C. § 1001. I declare under penalty of perjury that the foregoing is
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`true and correct.
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`Niall R. Lynam
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