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`EXHIBIT E
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`EXHIBIT E
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`DECLARATION OF ZAYDOON JAWADI
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`I, Zaydoon Jawadi, hereby declare as follows:
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`1.
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`I am an independent computer expert and consultant.
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`2. As shown in my CV (attached as Exhibit 1), I have a Bachelor of Science in
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`Electrical Engineering from Mosul University, a Master of Science in Computer
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`Science from Columbia University, and over 35 years of experience in software
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`development, engineering, consulting, and management in the fields of computing
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`systems, Internet, website technologies, data storage, data networking, software
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`applications, telephony, and telecommunication.
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`3.
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`In 2010, I cofounded and am the President of Rate Speeches, Inc., an Internet
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`company providing online communication rating and evaluation services.
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`4. From 2001 to 2006, I was President and cofounder of CoAssure, Inc., a provider of
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`automated web-based telecommunication test services.
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`5. From 1999 to 2001, I was CEO, Chairman, and founder of Can Do, Inc. an Internet
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`eCommerce and community company.
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`6. From 1992 to 1996, I was President and founder of Zadian Technologies, Inc., a
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`supplier of data storage test systems, with over 50,000 units installed worldwide.
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`7.
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`In 1996, Zadian Technologies was acquired by Xyratex International LTD
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`(NASDAQ: XRTX, which was acquired by Seagate, NASDAQ: STX, in 2014).
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`Following Zadian's acquisition by Xyratex, I became a general manager at Xyratex
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`until 1998. At Xyratex, I was responsible for a data networking analysis tools
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`business unit, which designed and built Gigabit Ethernet network protocol analysis
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`and monitoring products, which were sold, under OEM agreement, by the largest
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`network protocol analysis and monitoring products supplier.
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`8. Prior to 1992, I worked as a software consultant, a software engineer, and an
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`electrical engineer.
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`9. My experience specifically relevant to the digital signage includes being general
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`manager of a data networking analysis tools business unit at Xyratex, 1997-1998,
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`being general manager of a manufacturing test systems division at Xyratex, 1996-
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`1996, and being president of a manufacturing test systems supplier, Zadian
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`Technologies, 1992-1996. The Xyratex and Zadian manufacturing test systems
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`comprised multiple individual test units (each with an independent LCD display
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`operated by an embedded system) connected through a network to a central control
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`system; the central control system has the ability to control the displays of the
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`individual test units. My experience (1984-1992) also includes designing and
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`implementing networked individual devices (each with an independent display
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`operated by embedded system or PC) connected through a network to central
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`control systems that control the display of the individual devices, and includes
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`designing and implementing database, applications, and system software as well as
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`drivers and other software for controlling graphics and monitor displays. In addition
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`to my technical work, my background includes being involved with direct marketing
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`and advertising at Zadian Technologies (1992-1996), at Xyratex (1996-1998), at
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`Can Do (1999-2001), at CoAssure (2001-2006), and at Rate Speeches (2010-
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`present).
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`10. I have been retained by Farney Daniels PC, counsel for T-Rex Property AB. I have
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`been informed that T-Rex is a company organized and existing under the laws of
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`Sweden. I have also been informed that T-Rex is the owner of three patents: (1) U.S.
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`Patent Number RE39,470, entitled “Digital Information System” (2) U.S. Patent
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`Number 7,382,334, entitled “Digital Information System” and (3) U.S. Patent
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`Number 6,430,603, entitled “System for Direct Placement of Commercial
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`Advertising, Public Service Announcements and Other Content on Electronic
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`Billboard Displays.”
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`11. I have been asked to assess claims 25 and 26 of the '470 Patent, claims 22 and 32 of
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`the '334 Patent, and claims 42 and 43 of the '603 Patent, and in particular to
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`individually assess the specific technologies addressed by each of these claims.
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`12. My compensation does not depend in any way on a particular litigation outcome.
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`13. I am over the age of eighteen and am competent to make this declaration. I make
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`this declaration from my personal knowledge, experience, and education and, if
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`called to do so, could and would testify competently thereto.
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`14. In preparing this Declaration, I reviewed the '470 Patent and its file history, the '334
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`Patent and its file history, and the '603 Patent and its file history. I also spoke with
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`one of the inventors of the patent and one of the engineers who implemented the
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`technology.
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`Digital Signage
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`15. Traditional out-of-home advertising (AKA outdoor advertising), such as billboards,
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`bulletins, notice boards, posters, banners, brochures, is being replaced with
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`electronic signage, and, more recently, digital signage. Digital signage utilizes
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`various digital display technologies, such as LCD, LED, computer monitors, flat
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`screen monitors, projectors, digital television sets, overhead screens, wall-mounted
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`screens, and other display devices. Digital signage may be used to display images,
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`video, text, and other content to convey information, such as transportation
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`schedules and timetables, passenger information, updates, news, weather, traffic,
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`corporate and informational messages, warnings, etc. or for advertising. Digital
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`signage may be deployed in airports, train stations, railway station platforms,
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`subway stations, subway platforms, ship harbors, bus stations, hospitals, sports
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`arenas, theaters, movie theaters, concert halls, hotels, stadiums, museums,
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`conferences, exhibitions, assembly halls, lecture halls, conference rooms, shopping
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`malls, retail stores, restaurants, corporate buildings, etc. Digital signage allows both
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`digital information and digital advertising to be displayed in public infrastructures
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`and places that are accessible to and frequented by a general public. Digital signage
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`technology involves digital display devices, possibly with local computers or
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`processing devices, connected through communications medium, such as dedicated
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`cables, local area network (LAN), wide area network (WAN), or wireless. The
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`devices may be managed remotely. Digital signage technology involves hardware
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`and software.
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`Patents Inventors and Technology Implementation
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`16. DHJ Media AB was founded in 1996 to transform outdoor advertising, by solving
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`four problems that were inherent in that industry: inefficient distribution, limited
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`inventory, long lead times, and inflexible medium. By 2001, the company had
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`raised 180 million Swedish Krona (over $20 million), developed its digital signage
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`technology, launched multiple installations of its technology, and filed for an initial
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`public offering (IPO) in Sweden. An additional investment of about 100 Swedish
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`Krona was later raised, for a total of about $30 million combined investment.
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`17. The following images demonstrate four of DHJ Media's technology installations.
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`Arlanda Express Subway
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`London City Airport
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`Stockholm Underground Karlaplan
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`London Underground Test Site
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`Patents
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`18. The '470 Patent, the '334 Patent, and the '603 Patent are directed to digital signage
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`and address issues specific to digital signage technologies.
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`19. I understand that the '470 Patent is entitled to a filing date of April 26, 1996.
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`'470 Patent Claim 25
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`20. Independent claim 25 of the '470 Patent is directed to digital signage.
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`21. Claim 25 of the '470 Patent generally discloses a method of selectively displaying
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`digital information at one or multiple locations under the control instructions of
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`external information mediator(s) through a dynamically-updated exposure list
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`conveyed through control instructions. Method claim 25 is reproduced below:
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`25. A method of selectively displaying digital information at one or more of a
`plurality of locations, said method comprising:
`receiving control instructions from at least one external information mediator;
`using said control instructions to generate an exposure list, said exposure list
`specifying three or more of the following items:
`i) what information content is to be displayed;
`ii) at which of said plurality of locations said information content is to be
`displayed;
`iii) when said information content is to be displayed for each location at
`which content is to be displayed; and
`iv) how long said information content is to be displayed for each location at
`which content is to be displayed;
`displaying images at one or more of said locations in accordance with said
`exposure list; and
`permitting said exposure list to be dynamically updated.
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`Claim 25: Problems Solved and Prior Art
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`22. It is my opinion that claim 25 of the '470 Patent solves specific needs and problems
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`over other technologies that existed in 1996. The specific needs and problems
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`include, among other things, controlling and coordinating digital signage displays in
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`concrete, specific ways beyond merely scheduling content to be displayed on remote
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`screens. The inventors came up with a specific solution to resolve these and other
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`particular problems.
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`23. Prior to the inventions disclosed in claim 25 of the '470 Patent, for example, there
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`was no flexible way for external information mediators/suppliers (such as
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`advertising agencies, broadcasters, movie producers, companies, and individuals
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`who wish to utilize digital signage for commercial reasons or for the display of
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`information that concerns the general public) to dynamically control and coordinate,
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`display devices located in different places. Content from external information
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`mediators could not be directly displayed; instead, displaying such content required
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`administrative processing and manual intervention to update the display systems.
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`Even when the administration of information was processed with the aid of modern
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`computer technology, the available display time would nevertheless contain dead
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`time due to, among other things, back-logging caused by the manual process.
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`24. Furthermore, prior to the inventions disclosed in claim 25 of the '470 Patent, for
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`example, there was no flexible way to dynamically control and coordinate what,
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`where, when, and how long to display content (such as images, videos, messages,
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`and announcements) on display devices located in different places. Instead, content
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`display was not coordinated, and individual items were controlled and updated
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`separately, often manually. If any minimal control and coordination capability even
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`existed, it was only the administrator, but not the external information mediators,
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`who had access to such control and coordination.
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`25. Moreover, prior to the inventions disclosed in claim 25 of the '470 Patent, for
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`example, the computer controls of prior art systems were complicated. As a result,
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`control and coordination of content display often had to be carried out by experts;
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`content display had to be planned and coordinated carefully beforehand; mediators
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`had very little chance of influencing the display. Despite the need for doing so,
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`updating and changing content display quickly was not feasible.
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`26. Claim 25 of the '470 Patent solves these problems, and, in doing so, claim 25
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`embodies and improved the operation of digital signage that existed in 1996.
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`Elements of claim 25 were not previously employed in the prior art. In fact,
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`elements of claim 25, individually and in combination, have practical significance,
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`and these elements represented new and useful innovation and improvement to
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`digital signage over the prior art.
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`27. The combination of the elements of claim 25 of the '470 Patent imposes meaningful
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`limitations to improve existing digital signage technology by, for example, allowing
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`external information mediator(s) to dynamically control and coordinate display
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`devices located in different places, extending the usefulness of the digital signage
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`technology. The combination of the elements of claim 25 together is distinct and
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`different from other technologies.
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`28. To solve the above and other problems and to achieve this technological innovation,
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`claim 25 of the '470 Patent incorporates unique, innovative, non-conventional, non-
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`generic elements, including, for instance: receiving control instructions from
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`external information mediator(s); generating an exposure list based on the control
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`instructions; specifying through the exposure list what, where, when, and how long
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`to display; displaying images at location(s) in accordance with the exposure list; and
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`permitting the exposure list to be dynamically updated.
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`29. The functions, application, and implementations of these elements inherently and
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`necessarily are rooted in and require computer technology, communication
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`technology, and digital display technology in order to overcome specific problems
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`arising in the realm of digital signage in 1996. Claim 25 discloses inventive,
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`concrete, and tangible acts requiring intricate computer programming—acts that
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`must be performed through computers. But, the claim goes beyond the mere
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`concept of simply using a computer to perform distributed signage. This is because
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`computers, communication interfaces, and digital display devices are not ancillary
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`or incidental additions but germane and integral parts of the inventions disclosed by
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`claim 25 of the '470 Patent.
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`30. In particular, the claimed inventions of claim 25 of the '470 Patent relate to the
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`functioning of hardware and software technology for digital signage. The claim
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`addresses a technical challenge (controlling and coordinating displays) that is
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`particular to digital signage. In particular, the claimed inventions are directed
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`towards dynamically controlling and coordinating display devices located in
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`different places through control instructions and exposure lists by external
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`information mediators. The claim discloses receiving control instructions from
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`external information mediator(s); generating an exposure list based on the control
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`instructions; specifying through the exposure list what, where, when, and how long
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`to display; displaying images at location(s) in accordance with the exposure list; and
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`permitting the exposure list to be dynamically updated. The claimed actions are
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`inextricably tied to digital signage computer technology, communication
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`technology, and digital display technology.
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`31. For example, the '470 Patent excerpts below exemplify some of the specific
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`problems that claim 25 solves over other 1996 era technologies.
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`"Thus, present-day systems [prior art] do not enable information to be updated
`dynamically for display in real time. Neither do present-day systems enable
`external mediators to update information for display in a central control system,
`nor yet the administrator who makes the display of information available, but that
`it is the administrator who determines when, where and how the information shall
`be displayed." (The '470 Patent at 1:53-60.)
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`"An object of the present invention is to provide a flexible system in which
`external information mediators are able to dynamically control in real time the
`transmission of display instructions to a larger public in different places situated at
`any chosen distance apart through projectors which project information onto
`displays intended therefor." (Id. at 2:39-45.)
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`"Another object of the invention is to enable pictures, images, messages and
`announcements to be configured in accordance with modern digital technology,
`therewith providing rapid communication." (Id. at 2:46-49.)
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`"A further object of the invention is to enable a picture, image or other information
`to be changed in practice as often as is desired, in real time, therewith providing
`direct and immediate communication, and to enable similar or specific information
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`to be displayed in places that are mutually far apart and to enable message
`information to be alternated with advertising spots, for instance." (Id. at 2:50-56.)
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`"Information display subscribers are connected to a computerized control centre
`via computer and telecommunication interfaces for all-day-round transmission of
`information, wherein the control centre has a communication interface against
`with computerized devices situated in connection with said places for projector
`coordination and control." (Id. at 2:64-3:3.)
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`"The display list, which includes control instructions, coordinates and controls the
`projectors concerned with regard to what shall be displayed, when it shall be
`displayed, where it shall be displayed and for how long it shall be displayed, and
`causes each projector, independently of other projectors, to receive the same or
`different information for display through respective projectors and through the
`computerized devices, in accordance with the display list." (Id. at 3:11-18.)
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`"The administrator of the digital information system is able to update the display
`list with desired information at any time whatsoever, wherein the dynamic
`booking can be changed or delayed." (Id. at 3:19-23.)
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`"The administrator controls internally how, what, when or where the information
`shall be displayed by the projectors 22. An important feature in this context,
`however, is that external information mediators 24 are able to give control
`instructions to the projectors 22 with regard to the information that the external
`mediators 24 desire the system 10 to display via the projectors 22, each on its own
`initiative and communication-wise transparent via modems 26." (Id. at 5:6-13.)
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`"At present a mediator which wishes to display information in public places is
`normally forced to wait about two weeks, perhaps longer, before his order can be
`implemented and the information publicly displayed." (Id. at 5:23-27.)
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`"This constitutes an alternative to the insertion of the entire information bit from
`an external mediator 24 in a specific time interval in the exposure list, and enables
`the provision of an exposure list that contains much less information and which is
`thus easier to handle, and to accelerate transmission of the list between computers
`and databases included in the system." (Id. at 7:44-51.)
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`"When the information mediator 24 is an advertising agency and the
`advertisements are to be displayed are in picture form, the advertising subscriber is
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`able to buy a number of spots which are shown in the exposure list." (Id. at 9:14-
`18.)
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`"The control centre 12 sends picture packets/information to the station computer
`34 together with an exposure list. The exposure list includes a series of
`instructions as to what shall be shown, where it shall be shown, when it shall be
`shown and for how long, etc. The station computer 34 then provides each
`projector computer 38 with the material to be exposed. Thus, one and the same
`information material can be shown on all screens, or certain screens can be chosen
`for specific information display. This facility is controlled via the exposure list or,
`when the need is acute, directly from the control centre 12." (Id. at 9:56-67.)
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`32. Furthermore, the prosecution history of the '470 Patent, excerpts below, exemplify
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`some of the specific problems that claim 25 solves over other technologies and the
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`prior art.
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`a. On March 29, 2002, applicant clarified the differences between claim 25 and
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`U.S. Patent 6,122,642 (Mehovic), one of the prior art references cited during
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`prosecution:
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`"Mehovic does not teach or suggest a system or method for selectively
`displaying digital information at one or more of a plurality of locations as
`recited by independent claims 25 and 26. Mehovic pertains to propagating
`airline reservation data to a relational database management system so that
`the data can be retrieved by an end user and is not concerned with
`displaying information in publicly assessable places. The end user in
`Mehovic requests information from the reservation system , 12 through a
`VAX front-end 106 (see column 5, lines 27-30). In contradiction, the end
`users in the present invention (i.e., the public) are passive viewers of
`displayed images.
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`Mehovic fails to disclose the claimed exposure list that specifies display
`content, display location, display timing and display duration. The
`Examiner argues that the Passenger Name Record ("PNR") of Mehovic is
`equivalent to the exposure list. However, the PNR is a mix of textual and
`parametric data related to airline reservations such as airlines, departure
`cities, arrival cities, passenger data and the like. There is no information
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`relating to display content, display location, display timing and display
`duration as required by claims 25 and 26.
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`In addition, there is no teaching that the PNR is generated from control
`instructions received from an information mediator, as is required for the
`exposure list of claims 25 and 26.
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`Furthermore, Mehovic fails to show the claimed element of displaying
`images at one or more locations. Even if one argues that Mehovic displays
`data on the PC client 26 or output means 100, there is no suggestion that the
`system displays images in accordance with an exposure list, as required by
`claims 25 and 26. Instead, each PC client 26 presumably operates
`independently, displaying particular data as requested by the individual end
`users." (The File History of the '470 Patent, Amendment of March 29, 2002
`at 3-4.)
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`b. On May 14, 2003, applicant clarified the differences between claim 25 and
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`U.S. Patent 6,006,159 (Schmier), one of the prior art references cited during
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`prosecution:
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`"Schmier et al fails to anticipate either one of independent claims 25 and
`26. While Schmier et al generally relates to a method and system for
`displaying digital information, this reference does not disclose all of the
`recitations of claims 25 and 26. In particular, claim 25 recites the step of
`generating an exposure list that specifies display content, display location,
`display timing and display duration. The Examiner alleges that the transit
`data table computed by the central processor 22 of Schmier et al
`corresponds to the claimed exposure list. However, the transit data table
`contains predicted vehicle time intervals, arrival times and passenger load
`levels. This information is broadcast by the central processor 22 to the
`display modules 30 for display thereon. As such, the transit data table
`merely specifies display content and does not specify display location,
`display timing and display duration as required by claim 25. For example,
`Schmier at al contemplates displaying all or some of the information in the
`data transfer table (see column 5, lines 12-15). Schmier at al also describes
`continually updating the information in near real time (column 10, lines 3-
`6). Because the information is updated, and thus changed, as soon as it is
`received by the central processor 22, the duration of a given display is
`controlled by the frequency of the updates, not by anything in the transit
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`data table. Also. while Schmier et al mentions displaying other types of
`information (such as news and advertising) at selective displays, there is no
`indication in Schmier at al that the specific location and timing of such
`displays would be controlled by the transit data table.
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`Accordingly, applicant respectfully submits that Schmier at al does not
`disclose an exposure list specifying display location, display timing and
`display duration and thus fails to anticipate claim 25." ('470 File History,
`Amendment of May 14, 2003 at 3-4.)
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`c. On February 2, 2004, applicant amended claim 25 and further clarified the
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`differences between claim 25 and the prior art of record:
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`"Schmier et al fails to teach or suggest the step of receiving control
`instructions from at least one external information mediator." ('470 File
`History, Amendment of February 2, 2004 at 7.)
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`"Claim 25 also recites the step of using the control instructions to generate
`an exposure list. The claim has been amended to recite that the exposure list
`specifies three or more of the following items:" (Id..)
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`"While the [Schmier] transit data table contains information relating to
`predicted time intervals between adjacent transit stops and predicted times
`of arrival, the transit data table does not specify where a piece of
`information is to be displayed, when the information is to be displayed, and
`how long the information is to be displayed. These aspects are dictated by
`other factors. For example, Schmier et al describes continually updating the
`information in near real time (column 10, lines 3-6). Because the
`information is updated, and thus changed, as soon as it is received by the
`central processor 22, how long a piece of information is displayed is
`controlled by the frequency of the updates, not by anything in the transit
`data table. Also, while Schmier et al mentions displaying other types of
`information (such as news and advertising) at selective displays, there is no
`indication in Schmier et al that the specific location and timing of such
`displays would be controlled by the transit data table." (Id. at 8.)
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`Claim 25: Terms and Limitations
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`33. External Information Mediator
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`Claim 25 references "external information mediator" in the first claim element
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`(emphasis added):
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`"receiving control instructions from at least one external information
`mediator;"
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`The following excerpts from the '470 Patent specification provide context for the
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`term "external information mediator."
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`"The information channel cannot be subscribed to directly for the display of
`external information suppliers, such as advertising bureaux, the authorities,
`newspapers, etc., but is processed administratively and fed manually into
`the information display systems." (The '470 Patent at 1:42-48.)
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`"The control centre is able to create and update a display list in real time
`with control instruction fields via booking information for display
`dynamically in time from mediators having drive routine means which are
`connected to the subscription and which are transparent for the transmission
`of information to the drive routine means of the control centre for
`transmission of information in the system." (Id. at 3:4-10.)
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`"The administrator controls internally how, what, when or where the
`information shall be displayed by the projectors 22. An important feature in
`this context, however, is that external information mediators 24 are able to
`give control instructions to the projectors 22 with regard to the information
`that the external mediators 24 desire the system 10 to display via the
`projectors 22, each on its own initiative and communication-wise
`transparent via modems 26." (Id. at 5:6-13.)
`
`"The term information mediator (24) used in the following shall be
`interpreted in its widest meaning, i.e. as not only referring to advertising
`agencies but to all companies and private persons who wish to utilize the
`system 10 for commercial reasons or for the display of information that
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`concerns a general public. At present a mediator which wishes to display
`information in public places is normally forced to wait about two weeks,
`perhaps longer, before his order can be implemented and the information
`publicly displayed. With the inventive digital information system 10, the
`information can be displayed principly in real time, i.e. at the time of
`making the order, possibly with a short delay due to processing, fully-
`booked exposure lists and other quickly passing causes. Furthermore, an
`external information mediator 24 is able to put through information to the
`system 12 twenty-four hours a day, whereupon the information can be
`included instantaneously in an exposure list, as illustrated in more detail
`below. (Id. at 5:18-35.)
`
`"Those external information mediators which connect to the control centre
`12 via modems are, in one embodiment of the invention, connected to the
`control centre via specially designed interfaces (drive routine means) for
`data and telecommunication. In this way, only external mediators 24 having
`the correct interface are able to connect transparently to the control centre
`12 for delivering control instructions in the projectors 22," " (Id. at 5:36-
`43.)
`
`"The exposure handler 3 carries out the important object of the invention
`with regard to the possibility of an external mediator 24 to organize the
`information delivered to the station 16, 18, 20 via an exposure list," (Id. at
`7:10-15.)
`
`"A data message of this kind connected to each individual information
`exposure enables known HASH or switching methods to find information
`included in the exposure time intervals in the exposure list both effectively
`and quickly. A First Class® server can be used conveniently for
`communications transmission between external information mediators 24
`and the control centre 12. Each external information mediator is then able
`to send an e-mail with included information material in any chosen format,
`which provides the advantage of not needing to write in any new software
`for the communication transmission function. As before mentioned, the
`system also incorporates a safety aspect, whereby each external information
`mediator that has an office or when subscribes to the system must possess a
`coded drive means or a coded drive routine in order to connect to the
`control centre 12." (Id. at 7:55-8:3.)
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`"In order for external information mediators 24 to be able to deliver
`complete pictures/films, the mediator will preferably have its own versions
`of the software that the exposure handler 3 uses for enabling pictures/films
`to be introduced transparently into the exposure list without processing via
`the working stations 32 in the control centre 12." (Id. at 8:4-9.)
`
`"In accordance with the aforegoing, external information mediators 24 that
`have access to the exposure program are able to deliver complete picture
`series/films which can be processed automatically and inserted into the
`exposure list, or optionally personnel administering the working stations 32
`are able to pick external mediator information from the queues, or lines,
`and process this information so that it can be inserted into the exposure list
`via the exposure handler 3. In order to be able to distinguish information
`that must be processed via the working stations, external