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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