20. Anderson alleges a date of actual reduction to practice
of the method of the count on 9 January 1993 (Paper 274 at 63).
21. Anderson alleges acts of diligence toward actually
reducing the method of the count to practice, from prior to
Hill's 8 September 1992 alleged date of conception until
Anderson's alleged date of actual reduction to practice (Paper
274 at 64).
22. Anderson's preliminary statement states that Dana Z.
Anderson (Dr. Anderson) and Victor Mizrahi (Dr. Mizrahi)
conceived of the invention of the count (Paper 101).
Conception
23. Dr. Anderson was a visiting consultant at AT&T Bell
Laboratories in early April 1992 (AR 290, 1 3).
24. There, he became acquainted with Dr. Mizrahi's
procedures for growing Bragg gratings in photosensitive optical
fibers using an interferometer (AR 291, $ 4).
25. On April 6, 1992 Dr. Anderson thought of an idea for
improving upon the stability of the interferometer by using a
fused silica substrate plate with polymer coating to act as a
beamsplitter for recombining the original UV beams (AR 291, t 5).
26. According to Dr. Anderson, he had the idea that the
beamsplitting plate would also serve as a phase grating mask for
growing Bragg gratings, by (i) placing the mask adjacent and
parallel to a photosensitive optical fiber and (ii) applying a
7
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