`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`LSI CORPORATION and AVAGO TECHNOLOGIES U.S., INC.
`Petitioner,
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`v.
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`REGENTS OF THE UNIVERSITY OF MINNESOTA
`Patent Owner.
`
`Case No. IPR2017-01068
`Patent No. 5,859,601
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`DECLARATION OF EDWARD J. MAYLE
`I, Edward J. Mayle, hereby declare as follows:
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`1.
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`I am back-up counsel for Petitioners in this case. I am a member of the
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`Colorado, Washington, D.C., Federal Circuit, and Tenth Circuit bars.
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`2.
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`Exhibit 1014 is a document produced by Patent Owner (“UMN”) bearing
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`Bates Numbers UMN_0001330-47.
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`LSI Corp. Exhibit 1039
`Page 1
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`
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`3.
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`Exhibit 1015 is a letter dated May 11, 1999 from UMN to Lucent
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`Technologies, produced by UMN bearing Bates Numbers UMN_0000916.
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`4.
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`Exhibit 1016 is a document produced by UMN bearing Bates Numbers
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`UMN_0001655.
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`5.
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`Exhibit 1017 is a document produced by UMN bearing Bates Numbers
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`UMN_0001202-03.
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`6.
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`Exhibit 1018 is an attachment to Exhibit 1017, produced by UMN bearing
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`Bates Numbers UMN_0001204-05.
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`7.
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`Exhibit 1019 is a document produced by UMN bearing Bates Numbers
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`UMN_0001072-74.
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`8.
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`Exhibit 1020 is a letter dated March 12, 2009 from Proskauer Rose LLP to
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`UMN, produced by UMN bearing Bates Numbers UMN_0001055-57.
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`9.
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`Exhibit 1021 is an attachment to Exhibit 1020, produced by UMN bearing
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`Bates Numbers UMN_0001058-60.
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`10.
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`Exhibit 1022 is the KAIST, Department of Electrical Engineering, Annual
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`Report 2010/2011.
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`11.
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`Exhibit 1023 is an article, B. Brickner and J. Moon, Design of a Rate 6/7
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`Maximum Transition Run Code, IEEE Transactions on Magnetics, Vol. 33, No. 5,
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`September 1997.
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`LSI Corp. Exhibit 1039
`Page 2
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`
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`12.
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`Exhibit 1024 is U.S. Patent No. 5,949,357, “Time-Varying Maximum-
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`Transition-Run Codes for Data Channels.”
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`13.
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`Exhibit 1025 is U.S. Patent No. 6,278,748, “Rate 5/6 Maximum Transition
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`Run Code for Read Channels.”
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`14.
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`Exhibit 1026 is U.S. Patent No. 7,006,019, “Rate-7/8 Maximum Transition
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`Rune Code Encoding and Decoding Method and Apparatus.”
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`15.
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`Exhibit 1027 is U.S. Patent No. 7,057,536, “Rate-13/15 Maximum
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`Transition Run Code Encoding and Decoding Method and Apparatus.”
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`16.
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`Exhibit 1029 is the May 7, 2018 deposition transcript of Prof. Steven W.
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`McLaughlin.
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`17.
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`Exhibit 1032 is U.S. Patent No. 4,501,000, “Method of Coding Binary
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`Data.”
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`18.
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`Exhibit 1033 is U.S. Patent No. 5,537,382, “Partial Response Coding for a
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`Multi-Level Optical Recording Channel.”
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`19.
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`Exhibit 1034 is the September 15, 2020 deposition transcript of Dr. Jaekyun
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`Moon.
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`20.
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`Exhibit 1035 is the September 17, 2020 deposition transcript of Prof. Steven
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`W. McLaughlin.
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`LSI Corp. Exhibit 1039
`Page 3
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`
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`21.
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`Exhibit 1036 is excerpts of Plaintiff’s Memorandum of Law in Opposition to
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`Motion for Judgement on the Pleadings Under 35 U.S.C. § 101, Case No. 5:18-cv-
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`00821-EJD-NMC, Dkt. 201 (April 9, 2018).
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`Executed on October 13, 2020 in Denver, Colorado.
`
`/s/ Edward J. Mayle
`Edward J. Mayle
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`74063462V.1
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`LSI Corp. Exhibit 1039
`Page 4
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`