| Series 17 | Integrated Circuit Engineering Collection | LITIGATION |
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Description:
Motorola vs Fairchild case files: The Trade Secret, 1968 In 1968, Motorola sued Fairchild for hiring away Motorola’s
top scientist, C. Lester Hogan, and eight key executives. Fairchild
won the case. This collection is made-up of documents (primary correspondence)
from ICE, a company that acted as an independent research firm and provided
expert witness for Fairchild’s defense. |
Box 1, File Name A-1, Folder Number
1, 11/21/1968 |
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Letter To:
Glen Madland From: Jack Brown
Contents: Acknowledgment and statement concerning order imposing plaintiff’s interrogatory; blank copy of order imposing confidentiality
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Box 1, File Name A-1, Folder Number
1, No Date |
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Acknowledgment
and statement concerning order imposing confidentiality; signed by Glen
Madland
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Box 1, File Name A-1, Folder Number
1, 10/21/1968 |
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Memo To: Eugene
Blanchette From: William Farrow
Contents: Proposal for an advanced wafer fabrication training program
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Box 1, File Name A-1, Folder Number
1, 10/24/1968 |
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Memo To: Frank
Bower From: Glen Madland
Contents: Technical information for Fairchild
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Box 1, File Name A-1, Folder Number
1, 10/24/1968 |
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Memo To: Eugene
Blanchette From: Glen Madland
Contents: Contains a summary of tasks that have been assigned to ICE as a result of a meeting in Phoenix (October 8&9, 1968)
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Box 1, File Name A-1, Folder Number
1, 10/23/1968 |
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Memo To: Glen
Madland From: Harold Bell
Contents: Fairchild Project - work statement for updating and expanding the plastic packaging portion of integrated circuit assembly process compendium
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Box 1, File Name A-1, Folder Number
1, 10/15/1968 |
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Memo for file
By: Glen Madland
Contents: Telephone call from Jack Brown - sending trade secret stipulations from Motorola, concerning expert witnesses
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Box 1, File Name A-1, Folder Number
1, 10/11/1968 |
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Cover Letter
To: Jack Brown From: Glen Madland
Contents: Informing Mr. Brown about ICE expertise with integrated circuit work
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Box 1, File Name A-1, Folder Number
1, 10/10/1968 |
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Memo For File:
Fairchild Project #371 By: Glen Madland and Harold Bell
Contents: A tour by Dr. Dan Rose and John Carey (both of Fairchild)
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Box 1, File Name A-1, Folder Number
1, 10/15/1968 |
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Letter To:
Gene Blanchette From: William Farrow
Contents: Apology for materials arriving late
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Box 1, File Name A-1, Folder Number
1, 10/03/1968 |
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Memo For File:
Fairchild vs. Motorola By: Glen Madland
Contents: Conversation with Forman Mueller, Motorola Patent Attorney
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Box 1, File Name A-1, Folder Number
1, No Date |
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Page titled
"Fairchild" containing one sentence about an upcoming meeting
between Bower, Hume and Setos (Fairchild Representatives)
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Box 1, File Name A-1, Folder Number
1, 09/29/1968 |
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Contact record
between Glen Madland and Roger Borovoy (Project #371)
Contents: Handwritten notes
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Box 1, File Name A-1, Folder Number
1, 09/23/1968 |
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Call contact
report By: Glen Madland
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Box 1, File Name A-1, Folder Number
1, 09/20/1968 |
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Confirmation
of telephone conversation To: Roger Borovoy From: Glen Madland
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Box 1, File Name A-1, Folder Number
1, 09/19/1968 |
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Cover letter
To: William Drummond From: Glen Madland
Contents: Enclosed records pertaining to several phone conversations and letters
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Box 1, File Name A-1, Folder Number
1, 09/16/1968 |
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Letter To:
Lester Hogan From: Frank Bower
Contents: Motorola vs. Fairchild lawsuit; request to be hired as an outside consultant
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Box 1, File Name A-1, Folder Number
1, 09/11/1968 |
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Letter To:
Forman Mueller From: Glen Madland
Contents: ICE offering to help in the Motorola vs. Fairchild case
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Box 1, File Name A-1, Folder Number
1, 09/19/1968 |
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Memo To: Glen
Madland From: H.K. Dicken
Contents: Legal consulting matters
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Box 1, File Name A-1, Folder Number
1, 09/18/1968 |
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Memo for file:
Fairchild By: Glen Madland
Contents: Conference with Les Hogan
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Box 1, File Name A-2, Folder Number
2, No Date |
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Memo To: Glen
Madland From: Howard Dicken
Contents: Re: Fairchild Report
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Box 1, File Name A-2, Folder Number
3, 10/22/1968 |
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List of AD#
ordered under project #371 for Fairchild
Contents: Also included: Terms for engineering services and a Forbes Magazine Article
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Box 1, File Name A-2, Folder Number
4, 05/21/1969 |
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Memo for all
council
Contents: Re: Agenda
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Box 1, File Name A-2, Folder Number
5, 04/21/1969 |
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Letter To:
Mark Wilmer From: Jack Brown
Contents: Glen Madland wants to extend confidentiality of Fairchild case to VP Howard Dicken and engineer David Krent
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Box 1, File Name A-2, Folder Number
6, 10-03-1968 |
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Memo for file
By: Glen Madland
Contents: Re: Conversation with Forman Mueller
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Box 1, File Name A-2, Folder Number
7, No Date |
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Letter To:
William Drummond From: Glen Madland
Contents: Re: Letter to Forman Mueller
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Box 1, File Name A-2, Folder Number
8, 03/14/1968 |
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Letter To:
Jack Brown From: Glen Madland
Contents: Re: Case fabrication sequence
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Box 1, File Name A-2, Folder Number
9, 03/03/1969 |
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Letter To:
Gene Blanchette From: Jack Brown
Contents: Discussing a letter from Glen Madland and if it should be openly distributed
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Box 1, File Name A-2, Folder Number
10, 02/27/1969 |
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Letter To:
Jack Brown From: Glen Madland
Contents: Letter questioning if an ICE report should be restricted
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Box 1, File Name A-2, Folder Number
11, 02/20/1969 |
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Minutes
Contents: Re: Meeting on 02/18/1969 about the next Fairchild proposal
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Box 1, File Name A-2, Folder Number
12, No Date |
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Memo To: Glen
Madland From: Howard Dicken
Contents: Recommending high price and marketing approach for a report that exposes Fairchild’s weak spots to discourage buyers
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Box 1, File Name A-2, Folder Number
13, 01/30/1969 |
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Letter To:
Glen Madland From: Jack Brown
Contents: Questions about a task report and seeking clarification
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Box 1, File Name A-2, Folder Number
14, 01/02/1969 |
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Note To: Glen
Madland From: Paul Eckstien
Contents: Re: cover Letter for Tarzian option
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Box 1, File Name A-2, Folder Number
15, 12/31/1968 |
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Call report
to Fairchild
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Box 1, File Name A-2, Folder Number
16, 10/10/1968 |
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Memo for file
By: Glen Madland
Contents: Questions and clarifications about a task report
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Box 1, File Name A-2, Folder Number
17, 10/10/1968 |
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Memo for file
By: Glen Madland
Contents: Meeting with Gene Blanchette of Fairchild on 10/09/1968 for project #371
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Box 1, File Name A-2, Folder Number
18, No Date |
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Quotes for
Gene Blanchette By: Glen Madland
Contents: Reference to proposal #104, 1075, 1076, 1077, 1078
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Box 1, File Name A-2, Folder Number
19, No Date |
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Memo for file:
Fairchild By: Glen Madland
Contents: Meeting with gene Blanchette 10/08/1968 for Project #371
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Box 1, File Name A-2, Folder Number
20, 10/24/1968 |
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Letter To:
Gene Blanchette From: Glen Madland
Contents: Summary of tasks assigned to ICE - includes lists, work statements and estimated man hours
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Box 1, File Name A-2, Folder Number
21, 09/20/1968 |
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Letter To:
Roger Borovoy From: Glen Madland
Contents: Contract making ICE a Fairchild consultant - signed by Nelson Stone
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Box 1, File Name A-2, Folder Number
22, No Date (~10/08/1968) |
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7 sheets of
graph paper that appear to be the rough draft of the last memo (10/24/1968)
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Box 1, File Name A-2, Folder Number
23, 09/19/1968 |
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Memo To: Glen
Madland From H.K. Dicken
Contents: Legal consulting
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Box 1, File Name A-2, Folder Number
24, 09/19/1968 |
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Letter To::
William Drummond From: Glen Madland
Contents: ICE acting as a witness for Fairchild
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Box 1, File Name A-2, Folder Number
25, 09/11/1968 |
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Letter To:
Forman Mueller From: Glen Madland
Contents: Offering ICE reference library to Motorola
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Box 1, File Name A-2, Folder Number
26, 09/16/1968 |
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Memo To: Les
Hogan From Frank Bower
Contents: ICE Assisting Fairchild
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Box 1, File Name A-2, Folder Number
27, 09/18/1968 |
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Memo for file:
Fairchild By: Glen Madland
Contents: Story of Les Hogan’s transition to Fairchild from Motorola; also expressing concerns about a conflict of interest if both companies try to use ICE
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Box 1, File Name A-2, Folder Number
28, 08/30/1968 |
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Letter To:
Leo Dwork From: Glen Madland
Contents: Offering services to Fairchild and introducing ICE
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Box 1, File Name A-2, Folder Number
29, 09/18/1968 |
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Letter To:
Dr. Lester Hogan From: Frank Bower
Contents: Personal letter to welcome Hogan to the Bay Area and to offer ICE services
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Box 1, File Name A-2, Folder Number
30, No Date |
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Packet of
Papers
Contents: 4:1 ETCH solution; Emitter diffusion; P base diffusion; Isolation diffusion; EPO growth; Buried layer diffusion; SiO2; Initial oxidation procedure; Pattern wafer cleaning before diffusion - method E; Pattern wafer cleaning before diffusion - method D
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Box 1, File Name A-2, Folder Number
31, 10/21/1968 |
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Proposal #1077
To: Fairchild (Eugene Blanchette) From: William G. Farrow
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Box 1, File Name A-2, Folder Number
32, 09/20/1968 |
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Letter To:
Roger Borovoy From: Glen Madland
Contents: Expressing concerns about Motorola making claims against ICE because they are helping Fairchild
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Box 1, File Name A-2, Folder Number
33, 09/19/1968 |
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Memo To: William
Drummond From: Glen Madland
Contents: Re: Misc. enclosed letters
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Box 1, File Name A-2, Folder Number
34, 10/15/1968 |
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Letter To:
Gene Blanchette From: William Farrow
Contents: Apology for late delivery
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Box 1, File Name A-2, Folder Number
35, 10/03/1968 |
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Memo for file:
Fairchild, Motorola By: Glen Madland
Contents: Conversation with Forman Mueller - Potential trade secret material existed in ICE books didn’t help in Motorola’s claims
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Box 1, File Name A-2, Folder Number
36, 10/23/1968 |
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Memo To: Glen
Madland From: Harold Bell
Contents: Fairchild: work statement for updating and expanding the plastic packaging portion of integrated circuit assembly process compendium
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Box 1, File Name A-2, Folder Number
37, 10/15/1968 |
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Memo for file
By: Glen Madland
Contents: Call from Jack Brown - Sending draft of trade secret stipulations
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Box 1, File Name A-2, Folder Number
38, 10/10/1968 |
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Memo for file
By: Glen Madland
Contents: Visit by Fairchild representatives Dr. Dan Rose, John Carey
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Box 1, File Name A-2, Folder Number
39, 10/24/1968 |
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Task assignments
To: Howard Dicken From: Frank Bower
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Box 1, File Name A-2, Folder Number
40, 10/1968 |
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Proposal #1074
Contents: Advanced fabrications training program for Fairchild Corp.
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Box 1, File Name A-2, Folder Number
41, No Date |
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Rough draft
of a letter to Roger Borovoy By: Glen Madland
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Box 1, File Name A-2, Folder Number
42, No Date |
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Memo for file:
Fairchild By: Glen Madland
Contents: Conference with Les Hogan and his staff on 09/22/1968 and Jack Brown & John Ross (Fairchild attorneys 09/24/1968)
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Box 1, File Name A-2, Folder Number
43, No Date |
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Rough statement
of work objectives
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Box 2, File Name A-2, Folder Number
1, 09/20/1968 |
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Letter To:
Roger Borovoy From: Glen Madland
Contents: Offer services to Fairchild
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Box 2, File Name A-2, Folder Number
2, 09/19/1968 |
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Letter To:
Roger Borovoy From: William Drummond
Contents: Same memo as one listed on 09/20/1968 from Glen Madland to Roger Borovoy
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Box 2, File Name A-2, Folder Number
3, 09/26/1968 |
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Call report:
Fairchild To: Roger Borovoy From: Glen Madland
Contents: Set-up tool communications with two people
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Box 2, File Name A-2, Folder Number
4, 09/19/1968 |
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Memo To: Glen
Madland From: H.K. Dicken
Contents: Re: Legal Consulting (incomplete document)
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Box 2, File Name A-2, Folder Number
5, 09/16/1968 |
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Letter To:
Les Hogan From: Frank Bower
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Box 2, File Name A-3, Folder Number
6, 03/31/1969 |
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Fairchild
File #380
Contents: TAC-Transistor automation system for handling semiconductor die while maintaining orientation
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Box 2, File Name A-3, Folder Number
7, 01/22/1971 |
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Letter To:
Glen Madland From: Roger Borovoy
Contents: Re: Payment for consulting
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Box 2, File Name A-3, Folder Number
8, 11/03/1970 |
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Packet of
papers To: Jack Brown From: Glen Madland
Contents: Enclosed information on public knowledge of trade secrets concerning aluminum epitaxial transistors (2 copies)
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Box 2, File Name A-3, Folder Number
9, 10/19/1970 |
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Letter To:
Glen Madland From: Roger Borovoy
Contents: Payment to ICE
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Box 2, File Name A-3, Folder Number
10, No Date |
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Photocopy
of double epitaxial isolation method for integrated circuit transistors
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Box 2, File Name A-3, Folder Number
11, No Date |
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Handwritten
notes
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Box 2, File Name A-3, Folder Number
12, 09/17/1970 |
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Memo for file:
Project #380 By: Glen Madland
Contents: Review of additional trade secrets filled 06/26/1970
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Box 2, File Name A-3, Folder Number
13, 01/31/1969 |
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Copy of Power
Transistor Bulletin
Contents: Re: Aluminum headers
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Box 2, File Name A-3, Folder Number
14, No Date |
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Photocopied
article from Electronics
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Box 2, File Name A-3, Folder Number
15, 11/18/1970 |
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Letter To:
Glen Madland From: Roger Borovoy
Contents: Request details of consulting provided (Jack Brown sent invoice 04323)
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Box 2, File Name A-3, Folder Number
16, 07/31/1970 |
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Packet of
papers To: Glen Madland From: Roger Borovoy
Contents: Review three trade secret items
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Box 2, File Name A-3, Folder Number
17, No Date |
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Single page
from an ICE manual
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Box 2, File Name A-4, Folder Number
18, No Date |
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Bound ICE
report
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Box 3, File Name B-1, Folder Number
1, No Date |
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Packet of
papers To: Jack Brown From: Glen Madland
Contents: Information for alleged trade secrets 1,2,33,40 & 41; Wafer orientation system from transistor automation; #33 Bonding needle to cut bonding wire; #40,41 NAVAN/HAMCO automatic tensioner (used with annular saw blades)
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Box 3, File Name B-1, Folder Number
2, 03/04/1969 |
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Affidavit
of Charles S. Granieri in support of plaintiff’s response to defendant’s
motion for production of documents
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Box 3, File Name B-1, Folder Number
3, 03/27/1969 |
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Letter To:
Roger Borovoy From: Jack Brown
Contents: Sending affidavit for Mr. Borovoy to sign
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Box 3, File Name B-1, Folder Number
4, 02/02/1970 |
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Packet and
cover letter To: Jack Brown From: Glen Madland
Contents: Information on alleged trade secrets (categorization and brief description)
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Box 3, File Name B-1, Folder Number
5, 12/05/1969 |
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Packet and
cover letter To: Glen Madland From: Jack Brown
Contents: Draft copy of categorization and brief description of alleged trade secrets
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Box 3, File Name B-1, Folder Number
6, 03/04/1969 |
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Affidavit
of Harold Mumma in support of plaintiff’s response to defendant’s
motion for production of documents
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Box 3, File Name B-1, Folder Number
7, 03/04/1969 |
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Affidavit
of Eugene E. Segerson in support of plaintiff’s response to defendant’s’
motion for production of documents
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Box 3, File Name B-1, Folder Number
8, No Date |
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Affidavit
No Civ. 6080 Phx. – Roger Borovoy
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Box 3, File Name C-1, Folder Number
9, No Date |
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Plaintiff’s
Interrogatory #1
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Box 3, File Name C-1, Folder Number
10, 02/21/1969 |
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Packet of
papers To: Glen Madland From: Jack Brown
Contents: 1. Plaintiff’s answers to Fairchild interrogatories listing their trade secrets 2. Memo concerning investigation (Fairchild trade secrets) 3. Roger Borovoy's draft answers to some of plaintiff’s interrogatories
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Box 3, File Name C-1, Folder Number
11, 03/1969 |
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Sworn statement
of Roger Borovoy
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Box 4, File Name D-1, Folder Number
1, 05/15/1970 |
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Memo for file:
Motorola v. Fairchild
Contents: 1. Trade secret #6 (Semiconductor wafer dicing) 2. Trade Secret #71 (Assembly line and procedure – review of Ikeda patent)
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Box 4, File Name D-1, Folder Number
2, 04/17/1969 |
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Packet of
papers
Contents: 1. Rule 34 motion to produce 2. Motorola’s response and 3 affidavits 3. Fairchild’s response to above #2 objections; affidavits of Roger Borovoy and Dr. Gordon Moore 4. Motorola’s final response; 2nd affidavit from Mr. Granieri 5. Motorola’s Rule 34 motion 6. Trial book summary – Trade secrets
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Box 4, File Name D-1, Folder Number
3, 03/31/1969 |
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Affidavit
of Kenneth G. Dieker
Contents: Manager of Administrative Services of Fairchild Semiconductor Division
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Box 4, File Name D-1, Folder Number
4, 03/26/1969 |
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Motion for
order pursuant to Rule 34
Contents: Requiring Fairchild to produce and permit entry by Motorola
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Box 4, File Name D-1, Folder Number
5, 03/26/1969 |
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Affidavit
of Charles Granieri in support of plaintiff’s response to defendant’s
motion for production of documents served 03/04/1969
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Box 4, File Name D-1, Folder Number
6, 03/26/1969 |
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Affidavit
of Harold R. Mumma in support of plaintiff’s response to defendant’s
motion for production of documents served 03/04/1969
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Box 4, File Name D-1, Folder Number
7, 03/26/1969 |
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Affidavit
of Eugene G. Sergson in support of plaintiff’s response to defendant’s
motion for production of documents served 03/04/1969
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Box 4, File Name D-1, Folder Number
8, 04/09/1969 |
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Response to
defendant’s memorandum dated 04/03/1969
Contents: Defendant’s Rule 34 motion
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Box 4, File Name D-1, Folder Number
9, 03/17/1969 |
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Response to
motion for production of documents served 03/04/1969
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Box 4, File Name D-1, Folder Number
10, 03/31/1969 |
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Memorandum
in reply to plaintiff’s response to defendant’s motion to
produce
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Box 4, File Name D-1, Folder Number
11, 03/31/1969 |
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Affidavit
of Gordon E. Moore
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Box 4, File Name D-1, Folder Number
12, No Date |
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Technical
Film Theatre – Program
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Box 4, File Name D-1, Folder Number
13, No Date |
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Two pieces
of paper taped together to make a planning chart
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Box 4, File Name E-1, Folder Number
14, No Date |
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Large packet
of documents; Cover letter To: Nelson Stone From: Jack Brown
Contents: 132 page document from Motorola attorneys answering interrogatory 4 in 2nd set inquiring about trade secrets; and an answer to interrogatory 11; and verifications
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Box 4, File Name F-1, Folder Number
15, No Date |
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An ICE report
Contents: Review of semiconductor fabrication technology - Prepared for Fairchild Semiconductor Division
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Box 5, File Name G-1, Folder Number
1, No Date |
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Complaint
(Approx. 40 pages) Civ. No. 6808 Phx.
Contents: Unfair competition; interference with advantageous personal relationships; anti-trust violations; unjust enrichment; constructive trust upon benefits wrongfully obtained; damages – punitive and compensatory; breach of judiciary duty by officer and director
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Box 5, File Name G-1, Folder Number
2, No Date |
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Plaintiff’s
answers to the first set of defendant’s interrogatories; plaintiff’s
interrogatories to all defendant’s directed to Fairchild’s
knowledge of or use of any of the trade secrets or any techniques included
for trade secrets described in plaintiff’s answers
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Box 5, File Name H-1, Folder Number
3, No Date |
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Loose papers
that are divided and appear to have been in a three-ring binder
Contents: Re: Technical procedures
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Box 5, File Name I-1, Folder Number
4, 03/12/1971 |
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Call report
By: Glen Madland - Conversation with Jack Brown
Contents: Re: ICE consulting program – concern over Motorola changing and strengthening their case (2 copies)
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Box 5, File Name I-1, Folder Number
5, 03/12/1971 |
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Letter To:
Roger Borovoy From: Glen Madland
Contents: Concern is expressed over Motorola’s expert witnesses and the positive effect they could have on a jury – suggests that Fairchild add an additional witness to their case (3 copies)
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Box 5, File Name I-1, Folder Number
6, 03/15/1971 |
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Letter To:
Glen Madland From: Roger Borovoy
Contents: Mr. Borovoy informs Mr. Madland that he isn’t using ICE as much as Madland thinks he should because it doesn’t make sense to research secrets that Motorola may not argue in court.
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Box 5, File Name I-1, Folder Number
7, 02/26/1971 |
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Call report
By: Glen Madland – Conversation with Les Hogan
Contents: Re: Consulting – New Fairchild internal organization char included (handwritten)
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Box 5, File Name I-1, Folder Number
8, 02/17/1971 |
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Call report
By: Glen Madland – Conversation with Roger Borovoy
Contents: Re: Mr. Borovoy received the wrong invoice from ICE
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Box 5, File Name I-1, Folder Number
9, 04/26/1971 |
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Letter To:
Glen Madland From: Roger Borovoy
Contents: Acknowledgment that Fairchild owed ICE $1100.00 and authorization of payment
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Box 5, File Name I-1, Folder Number
10, 11/03/1970 |
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Stapled packet
of papers To: Jack Brown From: Glen Madland
Contents: Information regarding public knowledge of trade secrets S-1, S-2 & S-3 concerning aluminum power transistor packages and double epitaxial transistors
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Box 5, File Name I-1, Folder Number
11, 07/28/1970 |
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Letter and
contract To: Roger Borovoy From: Glen Madland
Contents: Consulting terms and conditions
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Box 5, File Name I-1, Folder Number
12, 11/26/1969 |
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Letter To:
Roger Borovoy From: Glen Madland
Contents: Re: ICE located ½ billion government reports – a fraction related to integrated circuit processing
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Box 5, File Name I-1, Folder Number
13, 10/27/1969 |
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Letter To:
Roger Borovoy From: Glen Madland
Contents: Preparing a bibliography of source material for litigation case
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Box 5, File Name I-1, Folder Number
14, 11/03/1969 |
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Letter To:
Glen Madland From: Roger Borovoy
Contents: Response to #13 letter (2 copies)
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Box 5, File Name I-1, Folder Number
15, 11/03/1970 |
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Letter To:
Jack Brown From: Glen Madland
Contents: Information regarding public knowledge of trade secrets S-1, S-2 & S-3 concerning aluminum power transistor packages and double epitaxial transistors (Same as #10)
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Box 6, File Name I-2, Folder Number
1, No Date |
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Copies of
previously cataloged correspondence that has been bound together
Contents: Includes exhibits: 57 (Material for the defendant); 56-1 (Labor analysis); 53 (Literature from Lea-Ronal, Inc.); Technical Bulletin, Aurall 292 process, Aurall 177 gold process; Lea-Ronal Auro Glo PC 171 gold process; Lea-Ronal Auro Vel HV gold process; Lea-Ronal Kovar Activator; Lea-Ronal bright silver process "3K"
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Box 6, File Name I-2, Folder Number
1 (cont.), Exhibit #52 |
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Memo To: Howard
Dicken, Gary Orman, Bill Farrow, Bob McLellan From: Glen Madland
Contents: Re: Publication of "A Review of semiconductor Fabrication Technology"
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Box 6, File Name I-2, Folder Number
1 (cont.), Exhibit #51 03/14/1969 |
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Confidential
letter To: Jack Brown
Contents: Re: Copy of Motorola vs. Fairchild Cross-Index
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Box 6, File Name I-2, Folder Number
1 (cont.), Exhibit #50 |
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Letter To:
Roger Borovoy From: Jack Brown
Contents: Re: Information on government publications
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Box 6, File Name I-2, Folder Number
1 (cont.), Exhibit #49 |
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Memo To :
Glen Madland
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Box 7, File Name J-1, Folder Number
1, No Date |
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Motorola vs.
Fairchild - Civil Action 36808 – Phx.
Contents: Defendant's answers to Plaintiff's interrogatories served 11/19/1968
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Your contacts for requesting information and/or appointments
to research the Chip Collection are: |
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