3. Goddard Controller Model 2
Mr. Goddard is said to have begun construction of controller model, Model 2, on about
January 24, 1989.3 (Goddard=s Brief, p. 6, Goddard Declaration, & 12; Champion Declaration,
& 9, emphasis added). The overall design for controller Model 2 is presented in Goddard
notebook pages 30 and 31 which are marked as Goddard Exhibits J14 and J15. Exhibit J15
depicts controller Model 2 as possessing a thumb-pad having a keypad.
4. Goddard Controller Model 3
On about February 13, 1989, Mr. Goddard is said to have begun making controller
Model 3, which possessed a thumb pad concavity just to the left of the grip portion. (Goddard=s
Brief, p. 6, Goddard Declaration, & 14; Champion Declaration, & 10, emphasis added). A
photograph of controller Model 3 is provided as Goddard Exhibit J4.4 According to the brief,
Aone can clearly see the metallic key positions located in the concavity where they are thumb
actuated.@ (Goddard=s Brief, p. 7, Goddard Declaration, & 14; Champion Declaration, & 10). As
depicted in Exhibit J4, there does appear to be a metallic device, i.e., thumb tacks, in a thumb
pad. Interestingly, in response to an interrogatory regarding fabrication of a device with actual
switches, Goddard stated that:
The metallic devices inserted in Model 3 were capable of carrying
current, and thus functioning as a device for making, breaking, or
changing the connections in an electrical circuit. The date of
Model 3 was on or about February 13, 1989.
(Goddard Record, p. 21, Goddard Answers to Written Interrogatories, Interrogatory No. 8).
5. Goddard Controller Model 4
Continuing to work on the controller device design, Goddard is said to have begun
making controller Model 4 on about February 23, 1989.5 (Goddard=s Brief, p. 7, Goddard
3 Goddard does not appear to have mentioned an exact date of completion for the
construction of the Model 2 controller.
4 Goddard=s brief does not appear to have provided a exact date of completion for the
construction of his Model 3 controller. In the photograph of Model 3, Exhibit J4, there is a piece
of paper with a date of February 13, 1989. Furthermore, the declaration of Mr. Jeffrey S.
Caldwell verifies that the photograph depicted in Goddard Exhibit J4 was taken in early 1989.
(Caldwell Declaration, &4).
5 Goddard=s brief does not appear to have provided a exact date of completion for the
construction of his Model 4 controller. In the photograph of Model 4, Exhibit J5, there is a piece
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