practice (Paper 272 at 31).
57. Specifically, Hill relies on the description in its
manuscript of testing it did to meet the limitations of the
count.
Diligence
58. Hill alternatively argues that it reduced to practice
its invention by 29 October 1992, when Hill's involved
application was filed (Paper 272 at 42).
59. Hill seeks to establish diligence from its 8 September
1992 conception to its constructive reduction to practice (Paper
272 at 42).
60. Hill relies on a letter dated 14 September 1992,
requesting Mr. Ed. Pascal to provide a cost estimate for filing a
patent application (HR 156).
61. Attached to the letter is a description of the Hill
invention (HR 1S8).
Hill's case of derivation
62. Hill argues that Snitzer derived the invention from it
(Paper 311 at 49) .
63. Hill alleges that inventor Elias Snitzer received and
read a copy of the Hill manuscript sometime after 8 September
1992, but prior to 17 October 1992, when the Snitzer inventors
amended their parent '839 application to include use of a phase
mask.
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