HILL et al. V. ANDERSON et al. V. SNITZER et al. - Page 9





                35. Dr. white states that her reference to "bold new ideas"                         
          was with the thoughts of the method of the count conceived of by                          
          Drs. Anderson and Mizrahi (AR 296, $ 7).                                                  
                36. The memorandum was prepared for signature by Alastair                           
          M. Glass (Dr. Glass) (Anderson Ex. 1027).                                                 
                37. Dr. Glass states that he too recalls that the "bold new                         
          ideas" referred to in the memorandum involved placing a phase                             
          mask adjacent and parallel to a photosensitive optical fiber and                          
          applying a single beam of light through the phase mask onto the                           
          fiber to make a Bragg grating in the fiber (AR 304, $ 6).                                 
                38. On 2 July 1992, Dr. White made an entry in her                                  
          notebook that states:                                                                     
                                  I'Ti - mask - commercially available                              
                                                  - interested in getting phase                     
                                                     mask that can be                               
                                                     placed next to fiber                           
                                                     have second order, want                        
                                                     first order" (Anderson                         
                                                    Ex.1030).                                       
                39. Anderson relies on the entry as further evidence of                             
          corroboration of the alleged conception (Paper 274 at 59).                                
                40. Dr. White states that she suggested using an ion                                
          implementation method to make a phase mask, and that her notebook                         
          entries indicate this (AR 298, $ 13).                                                     
                                       Acts of diligence                                            
                41. Dr. Anderson left Bell Labs in April 1992 and did not                           
          return until January 1993.                                                                


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