YAMADA et al. - Page 15





          establish, by a preponderance of the evidence, its conception.            
          The first of these is that the Invention Disclosure fails to              
          describe the invention with particularity (Paper 27 at 2, Paper           
          28 at 5).                                                                 
               Specifically, Yamada argues that the Invention Disclosure            
          (Ex. 2002):                                                               
               [F]ails to describe every feature recited by the count with          
               particularity because it lacks explanations of the cryptic           
               statements therein regarding the operation of the circuits           
               discussed and depicted[,] the numerous components cited and          
               depicted, how the components in the circuits operate                 
               individually and together, how the experimental measurements         
               were obtained and what they mean, and how the documents of           
               Exhibit 2002 relate to each other. In addition, several              
               contradictions exist between the documents of Exhibit 2002,          
               and no explanation is provided regarding these                       
               contradictions. (Paper 28 at 6).                                     

               Yamada has failed to sufficiently explain why the Invention          
          Disclosure does not, by itself, describe with particularity the           
          elements of the count. Specifically, Yamada has failed to                 
          sufficiently explain why the "first circuit diagrarff'6 of the            
          drawing attached to the Invention Disclosure form fails to show           
          the elements of the count.                                                
               Yamada does not specifically address whether the "first              
          circuit diagrarr(' does or does not illustrate the elements of the        


               6 The "first circuit diagramę' is what Yamada refers to as           
          the portion of the drawing that includes the inverters connected          
          together and connected to the charge pump. The remaining                  
          depictions in the drawing and handwritten notes are not part of           
          what Yamada has labeled the "first circuit diagrarff' (Paper 28 at        
          10).                                                                      
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