I, Shahriar Rokhsaz, hereby declare as follows:
`
`1.
`
`I am over the age of 18 and have personal knowledge of each of the
`
`matters set forth in this declaration, and if called as a witness, would testify
`
`competently to them.
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`2.
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`I am the CEO and President of Axzon, Inc. (“Axzon”), formerly
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`known as RFMicron, Inc. (“RFMicron”). I was the founder of RFMicron in
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`August 2006. RFMicron (now Axzon) has been in the business of making, selling,
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`and using sensor integrated circuits (ICs) which use radio frequency identification
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`(RFID) protocol, since August 2006.
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`3.
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`The Magnus UHF RFID sensor Tag IC (“Magnus”) was one such
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`RFID IC designed and developed by RFMicron, and I was involved in the
`
`development and design of that IC.
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`4.
`
`Attached as Appendix A is a true and correct copy of a purchase order
`
`that RFMicron received from
`
`. The purchase order, dated
`
`September 27, 2013, is for the sale of
`
`
`
`
`
`
`
` RFMicron received the purchase order
`
`from
`
` on September 30, 2013, and it has been maintained in
`
`RFMicron’s files, as is RFMicron’s regular practice for purchase orders.
`
`- 1 -
`
`NXP EX 1013
`NXP v. Impinj
`
`
`
`1.
`
`I am over the age of 18 and have personal knowledge of each of the
`
`matters set forth in this declaration, and if called as a witness, would testify
`
`competently to them.
`
`2.
`
`I am the CEO and President of Axzon, Inc. (“Axzon”), formerly
`
`known as RFMicron, Inc. (“RFMicron”). I was the founder of RFMicron in
`
`August 2006. RFMicron (now Axzon) has been in the business of making, selling,
`
`and using sensor integrated circuits (ICs) which use radio frequency identification
`
`(RFID) protocol, since August 2006.
`
`3.
`
`The Magnus UHF RFID sensor Tag IC (“Magnus”) was one such
`
`RFID IC designed and developed by RFMicron, and I was involved in the
`
`development and design of that IC.
`
`4.
`
`Attached as Appendix A is a true and correct copy of a purchase order
`
`that RFMicron received from
`
`. The purchase order, dated
`
`September 27, 2013, is for the sale of
`
`
`
`
`
`
`
` RFMicron received the purchase order
`
`from
`
` on September 30, 2013, and it has been maintained in
`
`RFMicron’s files, as is RFMicron’s regular practice for purchase orders.
`
`- 1 -
`
`NXP EX 1013
`NXP v. Impinj
`
`
`
`5.
`
`Attached as Appendix B is a true and correct copy of a letter that
`
`RFMicron sent to
`
` acknowledging receipt of the purchase order. The
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`letter was sent on October 1, 2013, and includes standard terms and conditions of
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`sale. RFMicron’s letter to
`
` has been maintained in RFMicron’s files,
`
`as is RFMicron’s regular practice for such letters.
`
`6.
`
`Appendix C is a true and correct copy of a datasheet that was prepared
`
`and used by RFMicron to market the Magnus IC. The datasheet was created by
`
`my team involved in the design and engineering of Magnus and has been
`
`maintained in RFMicron’s files, as is RFMicron’s regular practice for such
`
`datasheets. The datasheet of Appendix C was created in 2013, prior to RFMicron’s
`
`offer for sale to
`
`, and on September 29, 2013, RFMicron emailed a
`
`copy of the datasheet to
`
`. See Appendix D.
`
`7.
`
`Appendix E is a true and correct copy of documentation prepared by
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`RFMicron in 2010 detailing the auto-tuning technology of Magnus. The tuning
`
`documentation of Appendix E was created by the designer of Magnus’ tuning
`
`block (John Paulos). The document has been maintained in RFMicron’s files, as is
`
`RFMicron’s regular practice for such technical documents.
`
`8.
`
`Appendix F is a true and correct copy of circuit schematics for the
`
`Magnus IC. The circuit schematics were created by me and other persons involved
`
`in the design and engineering of Magnus. The circuit schematics were created as
`
`
`
`- 2 -
`
`
`
`NXP EX 1013
`NXP v. Impinj
`
`
`
`part of the regular design and development process of RFMicron and maintained in
`
`RFMicron’s files, as is RFMicron’s regular practice for such schematics. All of
`
`the circuit schematics of Appendix F were created prior to RFMicron’s offer for
`
`sale to
`
`, and some of the schematics show dates of last modification
`
`in the year 2012. See Appendix F at 3, 4, 8.
`
`9.
`
`Appendix G is a true and correct copy of a document that describes
`
`testing of the Magnus IC performed by RFMicron. The document is dated
`
`November 22, 2013, and was created by Brian Young, who held the positions
`
`Director of Engineering and Director of Solutions and Applications at RFMicron.
`
`The document was created as part of the regular testing processes of RFMicron and
`
`maintained in RFMicron’s files, as is RFMicron’s regular practice for such
`
`technical documents.
`
`10. The Magnus IC offered for sale to Radiant RFID operated in
`
`accordance with the hardware specifications, functionalities, and modes of
`
`operation of the Datasheet, Tuning Documentation, Circuit Schematics, and
`
`Testing Documentation of Appendices C, D, E, F, and G. The documents of
`
`Appendices C, D, E, F, and G are true and accurate depictions and descriptions of
`
`the Magnus IC offered for sale to
`
` based on my personal knowledge
`
`of the IC and its development. Magnus was complete at the time at the time of
`
`RFMicron’s offer for sale to
`
`. The documents of Appendices C, E,
`
`
`
`- 3 -
`
`
`
`NXP EX 1013
`NXP v. Impinj
`
`
`
`and F were all created prior to RFMicron’s offer for sale to
`
`, and
`
`Appendix D shows that the completed product had been tested and fabricated at the
`
`time of the offer for sale to
`
`.
`
`
`
`
`
`
`
`- 4 -
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`
`
`NXP EX 1013
`NXP v. Impinj
`
`
`
`I declare that all statements made herein on my own knowledge are true and
`
`that all statements made on information and belief are believed to be true, and
`
`further, that these statements were made with the knowledge that willful false
`
`statements and the like so made are punishable by fine or imprisonment, or both,
`
`under Section 1001 of Title 18 of the United States Code.
`
`
`
`Executed in Austin/Texas on this 27th day of September 2021.
`
`
`_________________________________
`Shahriar Rokhsaz
`
`- 5 -
`
`
`
`
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`
`
`NXP EX 1013
`NXP v. Impinj
`
`
`
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`Appendix A
`Appendix A
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`NXP EX 1013
`NXPv. Impinj
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`NXP EX 1013
`NXP v. Impinj
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`Appendix B
`Appendix B
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`NXP EX 1013
`NXPv. Impinj
`
`NXP EX 1013
`NXP v. Impinj
`
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`Appendix C
`Appendix C
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`NXP EX 1013
`NXPv. Impinj
`
`NXP EX 1013
`NXP v. Impinj
`
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`Appendix D
`Appendix D
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`NXP EX 1013
`NXPv. Impinj
`
`NXP EX 1013
`NXP v. Impinj
`
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`Appendix E
`Appendix E
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`NXP EX 1013
`NXPv. Impinj
`
`NXP EX 1013
`NXP v. Impinj
`
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`Appendix F
`Appendix F
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`NXP EX 1013
`NXPv. Impinj
`
`NXP EX 1013
`NXP v. Impinj
`
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`Appendix G
`Appendix G
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`NXP EX 1013
`NXPv. Impinj
`
`NXP EX 1013
`NXP v. Impinj
`
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