`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`
`
`
`
`
`DECLARATION OF SCOTT BENNETT, Ph.D.
`16 January 2017
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`SANDISK Exhibit 1010, Page 1 of 111
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`

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`TABLE OF CONTENTS
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`Page
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`I.
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`II.
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`INTRODUCTION .......................................................................................... 2
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`BACKGROUND AND QUALIFICATIONS ................................................ 2
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`III.
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`PRELIMINARIES .......................................................................................... 4
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`IV. OPINIONS REGARDING INDIVIDUAL DOCUMENTS .......................... 7
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`V.
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`ATTACHMENTS ........................................................................................10
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`VI.
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`CONCLUSION ............................................................................................11
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`
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`SANDISK Exhibit 1010, Page 2 of 111
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`I, Scott Bennett, hereby declare under penalty of perjury:
`
`I.
`
`INTRODUCTION
`
`1.
`
`I have personal knowledge of the facts and opinions set forth in this
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`declaration, I believe them to be true, and if called upon to do so, I would testify
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`competently to them. I have been warned that willful false statements and the like
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`are punishable by fine or imprisonment, or both.
`
`2.
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`I am a retired academic librarian working as a Managing Partner of
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`the firm Prior Art Documentation LLC at 711 South Race Street, Urbana, IL,
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`61801-4132. Attached as Appendix A is a true and correct copy of my
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`Curriculum Vitae describing my background and experience.
`
`3.
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`I have been retained by Baker Botts LLP. to authenticate and
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`establish the dates of public accessibility of certain documents in an inter partes
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`review proceedings for U.S. Patent No. RE45,542. For this service, I am being
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`paid my usual hourly fee. My compensation in no way depends on the substance
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`of my testimony or the outcome of this proceeding.
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`II. BACKGROUND AND QUALIFICATIONS
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`4.
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`I was previously employed as follows:
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`University Librarian, Yale University, New Haven, CT., 1994-2001;
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`Director, The Milton S. Eisenhower Library, The Johns Hopkins
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`University, Baltimore, MD, 1989-1994;
`
`
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`
`
`
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`SANDISK Exhibit 1010, Page 3 of 111
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`
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`Assistant University Librarian for Collection Management,
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`Northwestern University, Evanston, IL, 1981-1989;
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`
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`Instructor, Assistant, and Associate Professor of Library
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`Administration, University of Illinois at Urbana-Champaign, Urbana,
`
`IL, 1974-1981; and
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`
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`Assistant Professor of English, University of Illinois at Urbana-
`
`Champaign, 1967-1974.
`
`5.
`
`Over the course of my work as a librarian, professor of English,
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`researcher, and author of nearly fifty scholarly papers and other publications, I
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`have had extensive experience with cataloging records and online library
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`management systems built around Machine-Readable Cataloging (MARC)
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`standards. I also have substantial experience in authenticating printed documents
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`and establishing the date when they were accessible to researchers.
`
`6.
`
`In the course of more than fifty years of academic life, I have myself
`
`been an active researcher. I have collaborated with many individual researchers
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`and, as a librarian, worked in the services of thousands of researchers at four
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`prominent research universities. Members of my family are university
`
`researchers. Over the years, I have read some of the voluminous professional
`
`literature on the information seeking behaviors of academic researchers. And as
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`an educator, I have a broad knowledge of the ways in which students in a variety
`
`
`
`3
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`SANDISK Exhibit 1010, Page 4 of 111
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`of disciplines learn to master the bibliographic resources used in their disciplines.
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`In all of these ways, I have a general knowledge of how researchers work.
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`7.
`
`Appendix A is my full resume. Further information about my firm is
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`available at www.priorartdocumentation.com.
`
`III. PRELIMINARIES
`
`8.
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`Scope of this declaration. I am not a lawyer and I am not rendering
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`an opinion on the legal question of whether any particular document is, or is not, a
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`“printed publication” under the law.
`
`9.
`
`I am, however, rendering my expert opinion on when and how each
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`of the documents addressed herein was disseminated or otherwise made available
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`to the extent that persons interested and ordinarily skilled in the subject matter or
`
`art, exercising reasonable diligence, could have located the documents before 27
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`March 2002.
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`10. Materials considered. In forming the opinions expressed in this
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`declaration, I have reviewed the document and attachments referenced below.
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`These materials are records created in the ordinary course of business by
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`publishers, libraries, indexing services, and others. From my years of experience,
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`I am familiar with the process for creating many of these records, and I know
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`these records are created by people with knowledge of the information in the
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`record. Further, these records are created with the expectation that researchers
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`
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`4
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`SANDISK Exhibit 1010, Page 5 of 111
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`and other members of the public will use them. All materials cited in this
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`declaration and its attachments are of a type that experts in my field would
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`reasonably rely upon and refer to in forming their opinions.
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`11. Persons of ordinary skill in the art. I am told by counsel that the
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`subject matter of this proceeding relates to power management of peripheral
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`electronic devices, such as memory cards.
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`12.
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`I have been informed by counsel that the “person of ordinary skill in
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`the art at the time of the inventions” is a hypothetical person who is presumed to
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`be familiar with the relevant field and its literature at the time of the inventions.
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`This hypothetical person is also a person of ordinary creativity, capable of
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`understanding the scientific principles applicable to the pertinent field.
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`13.
`
`I am told by counsel that persons of ordinary skill in this subject
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`matter or art would have had a bachelor’s or master’s degree in electrical
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`engineering or a closely related field and two to three years of academic or
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`industry experience in the field of memory system design.
`
`14.
`
`It is my opinion that such a person would have learned though study
`
`and practice in the field and possibly through formal instruction the bibliographic
`
`resources relevant to his or her research. In the 1980s and 1990s such a person
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`would have had access to a vast array of long-established print resources in
`
`electrical/computer engineering and computer science as well as to a rich and fast
`
`
`
`5
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`SANDISK Exhibit 1010, Page 6 of 111
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`changing set of online resources providing indexing information, abstracts, and
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`full text services for electrical/computer engineering and computer science.
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`15. Library catalog records. Libraries such as the Cleveland Public
`
`Library have long maintained online catalogs of their holdings to make it easier for
`
`researchers to find and use materials in their collections.
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`16. When a book has been cataloged, it will normally be made available
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`to readers soon thereafter—normally within a few days or (at most) within a few
`
`weeks of cataloging.
`
`17.
`
`Indexing. A researcher may discover material relevant to his or her
`
`topic in a variety of ways. One common means of discovery is to search for
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`relevant information in an index of periodical and other publications. Having
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`found relevant material, the researcher will then normally obtain it online, look for
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`it in libraries, or purchase it from the publisher, a bookstore, a document delivery
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`service, or other provider.
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`18. Online indexing services commonly provide bibliographic
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`information, abstracts, and full-text copies of the indexed publications, along with
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`a list of the documents cited in the indexed publication. These services also often
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`provide lists of publications that cite a given document. A citation of a document
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`is evidence that the document was publicly available and in use by researchers no
`
`later than the publication date of the citing document.
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`
`
`6
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`SANDISK Exhibit 1010, Page 7 of 111
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`19. Prominent indexing services include:
`
`20.
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`IEEE Xplore Digital Library. The Institute of Electrical and
`
`Electronics Engineers is the world’s largest organization for the advancement of
`
`technology, with some 430,000 members in 160 countries. Known by its acronym
`
`IEEE, it has created IEEE Xplore Digital Library, which provides access to the
`
`contents of over 170 journals, more than 1,400 conference proceedings, some
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`5,100 technical standards, 2,000 eBooks, and 400 educational courses. More than
`
`3 million documents, dating from 1872, are searchable and available either through
`
`subscription or individual purchase.
`
`21. ACM Digital Library. This index is produced by the Association for
`
`Computing Machinery, the world’s largest scientific and educational computing
`
`society. AMC Digital Library contains the full text of all AMC publications,
`
`hosted full-text publications from selected publishers, and the ACM Guide to
`
`Computing Literature—a comprehensive bibliography of computing literature
`
`beginning in the 1950s with more than a million entries. All metadata in the
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`database are freely available on the Web, including abstracts, linked references,
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`citing work, and usage statistics. Full-text articles are available with subscription.
`
`IV. OPINIONS REGARDING INDIVIDUAL DOCUMENTS
`
`Document 1. PCMCIA PC Card Standard Release 2.1 (Sunnyvale, CA:
`Personal Computer Memory Card International Association, 1993).
`
`1.
`
`Authentication
`
`
`
`7
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`SANDISK Exhibit 1010, Page 8 of 111
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`22. Document 1 is a standards document first published by the Personal
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`Computer Memory Card International Association (PCMCIA) in 1990.
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`Attachment 1a is a true and correct copy of Document1’s cover, release record,
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`contents and list of tables, and the text of the first four sections from the Cleveland
`
`Public Library. The header on first contents page identifies Attachment 1a as
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`PCMCIA PC Card Standard Release 2.1, and provides, in a footer, a July 1993
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`date as the publication date for this release of the standard.
`
`23. Attachment 1b is a copy of the Cleveland Public Library’s catalog
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`record for Document 1, describing a loose-leaf publication. This record describes
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`release 2, with a publication date of 1992. The release record in Attachment 1a
`
`indicates that Release 2.01 was issued in November 1992. The record was not
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`updated when the library added release 2.1, issued in 1993, to its collection.
`
`24. Attachment 1a is in a condition that creates no suspicion about its
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`authenticity. Specifically, Document 1 is not missing any intermediate pages, the
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`text of the first two sections appears to flow seamlessly from one page to the next,
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`and there are no visible alterations to the document. Attachment 1a was found
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`within the custody of a library – a place where if authentic it would likely be. It is
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`my opinion that Attachment 1a is an authentic copy of Document 1.
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`2.
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`Public accessibility
`
`
`
`8
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`SANDISK Exhibit 1010, Page 9 of 111
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`25. The footer in Attachment 1a, mentioned above, indicates that version
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`2.1 of Document 1 was issued in July 1993. Attachment 1a has a Cleveland
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`Public Library date stamp of 28 July 1994, indicating that Document 1 was
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`processed at the library on that date. I conclude that Document 1 would have been
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`publicly available at the Cleveland Public Library by mid-August 1994.
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`26. As a standards organization, PCMCIA would have wanted the widest
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`possible distribution and use of Document 1.
`
`27. Citations of Document 1 provide evidence of such use. One paper
`
`citing Document 1 is Adam Cron, “A D&T Special Report: P1149.4 Mixed-Signal
`
`Test Bus,” IEEE Design & Test, 13,3 (September 1996): 98-101. Attachment 1c
`
`is a true and correct copy of the ACM Digital Library record for the Cron paper,
`
`with the second item in its list of references being a citation of Document 1.
`
`28. Another paper citing Document 1 is G. Welling and B. R. Badrinath,
`
`“An Architecture for Exporting Environment Awareness to Mobile Computing
`
`Applications,” IEEE Transactions on Software Engineering, 24,5 (May 1998):
`
`391-400. Attachment 1d is a true and correct copy of the IEEE Xplore Digital
`
`Library item record for the Welling and Badrinath paper. Attachment 1e is a true
`
`and correct copy of the IEEE Xplore Digital Library item record of the references
`
`cited by the Welling and Badrinath paper, with the first item in its list of
`
`references being a citation of Document 1.
`
`
`
`9
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`SANDISK Exhibit 1010, Page 10 of 111
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`3.
`
`Conclusion
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`29. Based on the evidence presented here—library cataloging and
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`citations—it is my opinion that Document 1 is an authentic document that
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`was publicly available in at least one library by mid-August 1994. The
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`citation evidence presented here indicates that Document 1 was in actual use by
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`researchers at least by September 1996.
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`V. ATTACHMENTS
`
`30. The attachments attached hereto are true and correct copies of the
`
`materials identified above. Helen Sullivan is a Managing Partner in Prior Art
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`Documentation Services LLC (see http://www.priorartdocumentation.com/hellen-
`
`sullivan/ ). One of her primarily responsibilities in our partnership is to secure the
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`bibliographic documentation used in attachments to our declarations.
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`31. Ms. Sullivan and I work in close collaboration on the bibliographic
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`documentation needed in each declaration. I will sometimes request specific
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`bibliographic documents or, more rarely, secure them myself. In all cases, I have
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`carefully reviewed the bibliographic documentation used in my declaration. My
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`signature on the declaration indicates my full confidence in the authenticity,
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`accuracy, and reliability of the bibliographic documentation used.
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`32. Each Attachment has been marked with an identifying label on the
`
`top of each page. However, no alterations other than these noted labels appear in
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`
`
`10
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`SANDISK Exhibit 1010, Page 11 of 111
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`these attachments, unless otherwise noted. All attachments were created on 9-28
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`December 2016 and all URLs referenced in this declaration were available 15
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`December 2016.
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`VI. CONCLUSION
`
`33.
`
`I reserve the right to supplement my opinions in the future to respond
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`to any arguments that Patent Owner or its expert(s) may raise and to take into
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`account new information as it becomes available to me.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed this 16th day of January 2017 in Urbana, Illinois.
`
`
`
`
`____________________________
`Scott Bennett
`
`
`
`11
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`SANDISK Exhibit 1010, Page 12 of 111
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`Appendix A
`
`SCOTT BENNETT
`Yale University Librarian Emeritus
`
`711 South Race
`Urbana, Illinois 61801-4132
`2scottb@prairienet.org
`217-367-9896
`
`
`
`EMPLOYMENT
`
`
`Retired, 2001. Retirement activities include:
` Managing Partner in Prior Art Documentation Services, LLC, 2015-. This firm provides
`documentation services to patent attorneys; more information is available at
`http://www.priorartdocumentation.com
` Consultant on library space design, 2004- . This consulting practice is rooted in a research,
`publication, and public speaking program conducted since I retired from Yale University in
`2001. I have served more than 50 colleges and universities in the United States and abroad
`with projects ranging in likely cost from under $50,000 to over $100 million. More
`information is available at http://www.libraryspaceplanning.com/
` Senior Advisor for the library program of the Council of Independent Colleges, 2001-2009
` Member of the Wartburg College Library Advisory Board, 2004-
` Visiting Professor, Graduate School of Library and Information Science, University of
`Illinois at Urbana-Champaign, Fall 2003
`
`
`University Librarian, Yale University, 1994-2001
`
`Director, The Milton S. Eisenhower Library, The Johns Hopkins University, Baltimore, Maryland,
`1989-1994
`
`Assistant University Librarian for Collection Management, Northwestern University, Evanston,
`Illinois, 1981-1989
`
`Instructor, Assistant and Associate Professor of Library Administration, University of Illinois at
`Urbana-Champaign, 1974-1981
`
`Assistant Professor of English, University of Illinois at Urbana-Champaign, 1967-1974
`
`Woodrow Wilson Teaching Intern, St. Paul’s College, Lawrenceville, Virginia, 1964-1965
`
`EDUCATION
`
`
`University of Illinois, M.S., 1976 (Library Science)
`Indiana University, M.A., 1966; Ph.D., 1967 (English)
`Oberlin College, A.B. magna cum laude, 1960 (English)
`
`
`
`HONORS AND AWARDS
`
`
`
`12
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`SANDISK Exhibit 1010, Page 13 of 111
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`
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`Morningside College (Sioux City, IA) Doctor of Humane Letters, 2010
`
`American Council of Learned Societies Fellowship, 1978-1979; Honorary Visiting Research
`Fellow, Victorian Studies Centre, University of Leicester, 1979; University of Illinois Summer
`Faculty Fellowship, 1969
`
`Indiana University Dissertation Year Fellowship and an Oberlin College Haskell Fellowship, 1966-
`1967; Woodrow Wilson National Fellow, 1960-1961
`
`
`PROFESSIONAL ACTIVITIES
`
`American Association for the Advancement of Science: Project on Intellectual Property and
`Electronic Publishing in Science, 1999-2001
`
`American Association of University Professors: University of Illinois at Urbana-Champaign
`Chapter Secretary and President, 1975-1978; Illinois Conference Vice President and President, 1978-
`1984; national Council, 1982-1985, Committee F, 1982-1986, Assembly of State Conferences
`Executive Committee, 1983-1986, and Committee H, 1997-2001 ; Northwestern University Chapter
`Secretary/Treasurer, 1985-1986
`
`Association of American Universities: Member of the Research Libraries Task Force on
`Intellectual Property Rights in an Electronic Environment, 1993-1994, 1995-1996
`
`Association of Research Libraries: Member of the Preservation Committee, 1990-1993; member of
`the Information Policy Committee, 1993-1995; member of the Working Group on Copyright, 1994-
`2001; member of the Research Library Leadership and Management Committee, 1999-2001; member
`of the Board of Directors, 1998-2000
`
`Carnegie Mellon University: Member of the University Libraries Advisory Board, 1994
`
`Center for Research Libraries: Program Committee, 1998-2000
`
`Johns Hopkins University Press: Ex-officio member of the Editorial Board, 1990-1994; Co-
`director of Project Muse, 1994
`
`Library Administration and Management Association, Public Relations Section, Friends of the
`Library Committee, 1977-1978
`
`Oberlin College: Member of the Library Visiting Committee, 1990, and of the Steering Committee
`for the library’s capital campaign, 1992-1993; President of the Library Friends, 1992-1993, 2004-
`2005; member, Friends of the Library Council, 2003-
`
`Research Society for Victorian Periodicals: Executive Board, 1971-1983; Co-chairperson of the
`Executive Committee on Serials Bibliography, 1976-1982; President, 1977-1982
`
` A
`
` Selected Edition of W.D. Howells (one of several editions sponsored by the MLA Center for
`Editions of American Authors): Associate Textual Editor, 1965-1970; Center for Editions of
`American Authors panel of textual experts, 1968-1970
`
`Victorian Studies: Editorial Assistant and Managing Editor, 1962-1964
`
`
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`13
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`SANDISK Exhibit 1010, Page 14 of 111
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`Wartburg College: member, National Advisory Board for the Vogel Library, 2004-
`
`Some other activities: Member of the Illinois State Library Statewide Library and Archival
`Preservation Advisory Panel; member of the Illinois State Archives Advisory Board; member of a
`committee advising the Illinois Board of Higher Education on the cooperative management of
`research collections; chair of a major collaborative research project conducted by the Research
`Libraries Group with support from Conoco, Inc.; active advisor on behalf of the Illinois
`Conference AAUP to faculty and administrators on academic freedom and tenure matters in northern
`Illinois.
`
`Delegate to Maryland Governor’s Conference on Libraries and Information Service; principal in
`initiating state-wide preservation planning in Maryland; principal in an effort to widen the use of
`mass deacidification for the preservation of library materials through cooperative action by the
`Association of Research Libraries and the Committee on Institutional Cooperation; co-instigator
`of a campus-wide information service for Johns Hopkins University; initiated efforts with the
`Enoch Pratt Free Library to provide information services to Baltimore’s Empowerment Zones;
`speaker or panelist on academic publishing, copyright, scholarly communication, national and
`regional preservation planning, mass deacidification.
`
`Consultant for the University of British Columbia (1995), Princeton University (1996), Modern
`Language Association, (1995, 1996), Library of Congress (1997), Center for Jewish History
`(1998, 2000-), National Research Council (1998); Board of Directors for the Digital Library
`Federation, 1996-2001; accreditation visiting team at Brandeis University (1997); mentor for
`Northern Exposure to Leadership (1997); instructor and mentor for ARL’s Leadership and
`Career Development Program (1999-2000)
`
`At the Northwestern University Library, led in the creation of a preservation department and in the
`renovation of the renovation, for preservation purposes, of the Deering Library book stacks.
`
`At the Milton S. Eisenhower Library, led the refocusing and vitalization of client-centered services;
`strategic planning and organizational restructuring for the library; building renovation planning.
`Successfully completed a $5 million endowment campaign for the humanities collections and
`launched a $27 million capital campaign for the library.
`
`At the Yale University Library, participated widely in campus-space planning, university budget
`planning, information technology development, and the promotion of effective teaching and learning;
`for the library has exercised leadership in space planning and renovation, retrospective conversion of
`the card catalog, preservation, organizational development, recruitment of minority librarians,
`intellectual property and copyright issues, scholarly communication, document delivery services
`among libraries, and instruction in the use of information resources. Oversaw approximately $70
`million of library space renovation and construction. Was co-principal investigator for a grant to plan
`a digital archive for Elsevier Science.
`
`Numerous to invitations speak at regional, national, and other professional meetings and at alumni
`meetings. Lectured and presented a series of seminars on library management at the Yunnan
`University Library, 2002. Participated in the 2005 International Roundtable for Library and
`Information Science sponsored by the Kanazawa Institute of Technology Library Center and the
`Council on Library and Information Resources.
`
`
`
`
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`14
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`SANDISK Exhibit 1010, Page 15 of 111
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`PUBLICATIONS
`
`
`“Putting Learning into Library Planning,” portal: Libraries and the Academy, 15, 2 (April 2015),
`215-231.
`
`“How librarians (and others!) love silos: Three stories from the field “ available at the Learning
`Spaces Collaborary Web site, http://www.pkallsc.org/
`
`“Learning Behaviors and Learning Spaces,” portal: Libraries and the Academy, 11, 3 (July 2011),
`765-789.
`
`“Libraries and Learning: A History of Paradigm Change,” portal: Libraries and the Academy, 9, 2
`(April 2009), 181-197. Judged as the best article published in the 2009 volume of portal.
`
`“The Information or the Learning Commons: Which Will We Have?” Journal of Academic
`Librarianship, 34 (May 2008), 183-185. One of the ten most-cited articles published in JAL, 2007-
`2011.
`
`“Designing for Uncertainty: Three Approaches,” Journal of Academic Librarianship, 33 (2007), 165–
`179.
`
`“Campus Cultures Fostering Information Literacy,” portal: Libraries and the Academy, 7 (2007),
`147-167. Included in Library Instruction Round Table Top Twenty library instruction articles
`published in 2007
`
`“Designing for Uncertainty: Three Approaches,” Journal of Academic Librarianship, 33 (2007),
`165–179.
`
` “First Questions for Designing Higher Education Learning Spaces,” Journal of Academic
`Librarianship, 33 (2007), 14-26.
`
`“The Choice for Learning,” Journal of Academic Librarianship, 32 (2006), 3-13.
`
`With Richard A. O’Connor, “The Power of Place in Learning,” Planning for Higher Education, 33
`(June-August 2005), 28-30
`
`“Righting the Balance,” in Library as Place: Rethinking Roles, Rethinking Space (Washington, DC:
`Council on Library and Information Resources, 2005), pp. 10-24
`
`Libraries Designed for Learning (Washington, DC: Council on Library and Information Resources,
`2003)
`
`“The Golden Age of Libraries,” in Proceedings of the International Conference on Academic
`Librarianship in the New Millennium: Roles, Trends, and Global Collaboration, ed. Haipeng Li
`(Kunming: Yunnan University Press, 2002), pp. 13-21. This is a slightly different version of the
`following item.
`
`“The Golden Age of Libraries,” Journal of Academic Librarianship, 24 (2001), 256-258
`
`“Second Chances. An address . . . at the annual dinner of the Friends of the Oberlin College Library
`November 13 1999,” Friends of the Oberlin College Library, February 2000
`
`15
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`
`
`
`
`
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`SANDISK Exhibit 1010, Page 16 of 111
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`
`“Authors’ Rights,” The Journal of Electronic Publishing (December 1999),
`http://www.press.umich.edu/jep/05-02/bennett.html
`
`“Information-Based Productivity,” in Technology and Scholarly Communication, ed. Richard Ekman
`and Richard E. Quandt (Berkeley, 1999), pp. 73-94
`
`“Just-In-Time Scholarly Monographs: or, Is There a Cavalry Bugle Call for Beleaguered Authors and
`Publishers?” The Journal of Electronic Publishing (September 1998),
`http://www.press.umich.edu/jep/04-01/bennett.html
`
`“Re-engineering Scholarly Communication: Thoughts Addressed to Authors,” Scholarly Publishing,
`27 (1996), 185-196
`
`“The Copyright Challenge: Strengthening the Public Interest in the Digital Age,” Library Journal, 15
`November 1994, pp. 34-37
`
`“The Management of Intellectual Property,” Computers in Libraries, 14 (May 1994), 18-20
`
`“Repositioning University Presses in Scholarly Communication,” Journal of Scholarly Publishing, 25
`(1994), 243-248. Reprinted in The Essential JSP. Critical Insights into the World of Scholarly
`Publishing. Volume 1: University Presses (Toronto: University of Toronto Press, 2011), pp. 147-153
`
`“Preservation and the Economic Investment Model,” in Preservation Research and Development.
`Round Table Proceedings, September 28-29, 1992, ed. Carrie Beyer (Washington, D.C.: Library of
`Congress, 1993), pp. 17-18
`
`“Copyright and Innovation in Electronic Publishing: A Commentary,” Journal of Academic
`Librarianship, 19 (1993), 87-91; reprinted in condensed form in Library Issues: Briefings for Faculty
`and Administrators, 14 (September 1993)
`
`with Nina Matheson, “Scholarly Articles: Valuable Commodities for Universities,” Chronicle of
`Higher Education, 27 May 1992, pp. B1-B3
`
`“Strategies for Increasing [Preservation] Productivity,” Minutes of the [119th] Meeting [of the
`Association of Research Libraries] (Washington, D.C., 1992), pp. 39-40
`
`“Management Issues: The Director’s Perspective,” and “Cooperative Approaches to Mass
`Deacidification: Mid-Atlantic Region,” in A Roundtable on Mass Deacidification, ed. Peter G. Sparks
`(Washington, D.C.: Association of Research Libraries, 1992), pp. 15-18, 54-55
`
`“The Boat that Must Stay Afloat: Academic Libraries in Hard Times,” Scholarly Publishing, 23
`(1992), 131-137
`
`“Buying Time: An Alternative for the Preservation of Library Material,” ACLS Newsletter, Second
`Series 3 (Summer, 1991), 10-11
`
`“The Golden Stain of Time: Preserving Victorian Periodicals” in Investigating Victorian Journalism,
`ed. Laurel Brake, Alex Jones, and Lionel Madden (London: Macmillan, 1990), pp. 166-183
`
`
`16
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`
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`SANDISK Exhibit 1010, Page 17 of 111
`
`

`

`“Commentary on the Stephens and Haley Papers” in Coordinating Cooperative Collection
`Development: A National Perspective, an issue of Resource Sharing and Information Networks, 2
`(1985), 199-201
`
`“The Editorial Character and Readership of The Penny Magazine: An Analysis,” Victorian
`Periodicals Review, 17 (1984), 127-141
`
`“Current Initiatives and Issues in Collection Management,” Journal of Academic Librarianship, 10
`(1984), 257-261; reprinted in Library Lit: The Best of 85
`
`“Revolutions in Thought: Serial Publication and the Mass Market for Reading” in The Victorian
`Periodical Press: Samplings and Soundings, ed. Joanne Shattock and Michael Wolff (Leicester:
`Leicester University Press, 1982), pp. 225-257
`
`“Victorian Newspaper Advertising: Counting What Counts,” Publishing History, 8 (1980), 5-18
`
`“Library Friends: A Theoretical History” in Organizing the Library’s Support: Donors, Volunteers,
`Friends, ed. D.W. Krummel, Allerton Park Institute Number 25 (Urbana: University of Illinois
`Graduate School of Library Science, 1980), pp. 23-32
`
`“The Learned Professor: being a brief account of a scholar [Harris Francis Fletcher] who asked for
`the Moon, and got it,” Non Solus, 7 (1980), 5-12
`
`“Prolegomenon to Serials Bibliography: A Report to the [Research] Society [for Victorian
`Periodicals],” Victorian Periodicals Review, 12 (1979), 3-15
`
`“The Bibliographic Control of Victorian Periodicals” in Victorian Periodicals: A Guide to Research,
`ed. J. Don Vann and Rosemary T. VanArsdel (New York: Modern Language Association, 1978), pp.
`21-51
`
`“John Murray’s Family Library and the Cheapening of Books in Early Nineteenth Century Britain,”
`Studies in Bibliography, 29 (1976), 139-166. Reprinted in Stephen Colclough and Alexis Weedon,
`eds., The History of the Book in the West: 1800-1914, Vol. 4 (Farnham, Surrey: Ashgate, 2010), pp.
`307-334.
`
`with Robert Carringer, “Dreiser to Sandburg: Three Unpublished Letters,” Library Chronicle, 40
`(1976), 252-256
`
`“David Douglas and the British Publication of W. D. Howells’ Works,” Studies in Bibliography, 25
`(1972), 107-124
`
`as primary editor, W. D. Howells, Indian Summer (Bloomington: Indiana University Press, 1971)
`
`“The Profession of Authorship: Some Problems for Descriptive Bibliography” in Research Methods
`in Librarianship: Historical and Bibliographic Methods in Library Research, ed. Rolland E. Stevens
`(Urbana: University of Illinois Graduate School of Library Science, 1971), pp. 74-85
`
`edited with Ronald Gottesman, Art and Error: Modern Textual Editing (Bloomington: Indiana
`University Press, 1970)--also published in London by Methuen, 1970
`
`
`
`
`17
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`SANDISK Exhibit 1010, Page 18 of 111
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`

`

`“Catholic Emancipation, the Quarterly Review, and Britain’s Constitutional Revolution,” Victorian
`Studies, 12 (1969), 283-304
`
`as textual editor, W. D. Howells, The Altrurian Romances (Bloomington: Indiana University Press,
`1968); introduction and annotation by Clara and Rudolf Kirk
`
`as associate textual editor, W. D. Howells, Their Wedding Journey (Bloomington: Indiana University
`Press, 1968); introduction by John Reeves
`
`“A Concealed Printing in W. D. Howells,” Papers of the Bibliographic Society of America, 61
`(1967), 56-60
`
`editor, Non Solus, A Publication of the University of Illinois Library Friends, 1974-1981
`
`editor, Robert B. Downs Publication Fund, University of Illinois Library, 1975-1981
`
`
`Reviews, short articles, etc. in Victorian Studies, Journal of English and German Philology,
`Victorian Periodicals Newsletter, Collection Management, Nineteenth-Century Literature, College &
`Research Libraries, Scholarly Publishing Today, ARL Newsletter, Serials Review, Library Issues,
`S[ociety for] S[cholarly] P[ublishing] Newsletter, and Victorian Britain: An Encyclopedia
`
`
`
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`18
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`SANDISK Exhibit 1010, Page 19 of 111
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`

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`Attachment 1a: Copy of Document 1 from the Cleveland Public Library
`
`SANDISK Exhibit 1010, Page 20 of 111
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`

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`Attachment 1a: Copy of Document 1 from the Cleveland Public Library
`
`SANDISK Exhibit 1010, Page 21 of 111
`
`

`

`Attachment 1a: Copy of Document 1 from the Cleveland Public Library
`
`SANDISK Exhibit 1010, Page 22 of 111
`
`

`

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