Ex Parte 5872952 et al - Page 27




              Appeal No. 2005-2512                                                                                         
              Reexamination Control No. 90/006,431                                                                         

                                                  may exist in the                                                         
                                                  design.  A layout                                                        
                                                  display and query                                                        
                                                  tool called                                                              
                                                  ChipViewer shows                                                         
                                                  the relationship of                                                      
                                                  simulation results to                                                    
                                                  the power network                                                        
                                                  layout.                                                                  
              RailMill PB at 4.                                                                                            
                     The Second Ho Declaration, on the other hand, appears to treat ChipViewer as                          
              separate from “RailMill,” explaining that the integrated combination of RailMill and                         
              ChipViewer was released as Archer’s “Arcadia” product:                                                       
                            2.  The invention that became the ‘952 patent was conceived and                                
                     reduced to practice in the United States while my co-inventor and I were                              
                     employed by Epic Design Technology.  As part of reducing to practice the                              
                     invention of the ‘952 Patent, my work was directed to combining an                                    
                     interactive graphical user interface with power network analysis tools then                           
                     being developed primarily by my co-inventor.  Moreover as part of this                                
                     reduction to practice, Epic Design Technology, in collaboration with Archer                           
                     Systems, integrated Epic’s RailMill product with the graphical user                                   
                     interface known as ChipViewer.  The RailMill product with the graphical                               
                     user interface referred to as ChipViewer was then released as the Arcadia                             
                     product.  The RailMill and ChipViewer parts of Arcadia are therefore our                              
                     own reduction to practice of the invention conceived by my co-inventor                                
                     and I as claimed in the ‘952 Patent.                                                                  


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