Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`I, Geoffrey O. Thompson, hereby declare as follows:
`
`1.
`
`2.
`
`INTRODUCTION
`
`I am presently a Member Emeritus of the IEEE 802 LAN/MAN
`
`Standards Executive Committee and the Principal at GraCaSI Standards Advisors,
`
`which has its principal place of business at 158 Paseo Court, Mountain View, CA
`
`94043-5286.
`
`3.
`
`I have prepared this Declaration on behalf of Sony Corporation of
`
`America in connection with the Petition for Post-Grant Review of U.S. Patent No.
`
`6,218,930 (the “’930 patent”), which is to be filed concurrently with this
`
`Declaration.
`
`4.
`
`A.
`
`5.
`
`BACKGROUND AND QUALIFICATIONS
`
`Educational Background and Employment
`
`I was awarded a bachelor’s degree in electrical engineering from
`
`Purdue University in 1964.
`
`6.
`
`From 1964 to 1965, I worked at the Walbridge Test Center of Ohio
`
`Bell Telephone as a Manager. My responsibilities included managing and
`
`supervising operation of a local telephone test and repair center for 1/3 of a
`
`metropolitan area comprising approximately 300,000 people.
`
`7.
`
`I became employed by Xerox Corporation beginning in 1965. My first
`
`position at Xerox was Associate Engineer. Between 1965 and 1973, I was
`
`SONY EXHIBIT 1004
`
`Page 1 of 44
`
`
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`I, Geoffrey O. Thompson, hereby declare as follows:
`
`1.
`
`2.
`
`INTRODUCTION
`
`I am presently a Member Emeritus of the IEEE 802 LAN/MAN
`
`Standards Executive Committee and the Principal at GraCaSI Standards Advisors,
`
`which has its principal place of business at 158 Paseo Court, Mountain View, CA
`
`94043-5286.
`
`3.
`
`I have prepared this Declaration on behalf of Sony Corporation of
`
`America in connection with the Petition for Post-Grant Review of U.S. Patent No.
`
`6,218,930 (the “’930 patent”), which is to be filed concurrently with this
`
`Declaration.
`
`4.
`
`A.
`
`5.
`
`BACKGROUND AND QUALIFICATIONS
`
`Educational Background and Employment
`
`I was awarded a bachelor’s degree in electrical engineering from
`
`Purdue University in 1964.
`
`6.
`
`From 1964 to 1965, I worked at the Walbridge Test Center of Ohio
`
`Bell Telephone as a Manager. My responsibilities included managing and
`
`supervising operation of a local telephone test and repair center for 1/3 of a
`
`metropolitan area comprising approximately 300,000 people.
`
`7.
`
`I became employed by Xerox Corporation beginning in 1965. My first
`
`position at Xerox was Associate Engineer. Between 1965 and 1973, I was
`
`SONY EXHIBIT 1004
`
`Page 1 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`promoted to Engineer and to Senior Engineer. In 1973, I became a Senior Member
`
`of the Research Staff at Xerox PARC and held that title until 1981, when I became
`
`a Consulting Member of the Engineering Staff for Systems Development at Xerox.
`
`8.
`
`Beginning in 1998, I held various staff positions at SynOptics
`
`Communications, Bay Networks, and Nortel Networks. In these positions I was
`
`responsible for working with the IEEE 802.3 standards and providing technical
`
`analyses relating to the standards. I became a Distinguished Member of the
`
`Technical Staff at Nortel Networks in 2008.
`
`9.
`
`In 2009, I left Nortel Networks to begin work at GraCaSI Standards
`
`Advisors as the Principal.
`
`A.
`
`Standards Work
`
`10.
`
`I have worked with the IEEE 802.3 standards Working Group since
`
`1983. My early work included promoting the Ethernet standard as a U.S. delegate
`
`in international standards forums. Beginning in 1983, I also served as a technical
`
`contributor and chairperson of various task forces for IEEE 802.3 standards
`
`projects, including the Chair of the Maintenance Task Force.
`
`11.
`
`From 1991 to 1993, I served as Vice Chairman of the IEEE 802.3
`
`Working Group and was responsible for procedures, membership, technical
`
`maintenance, and working group management assistance, in addition to technical
`
`contributions.
`
`Page 2 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`From 1993 to 2002 I was the Chair of the IEEE Working Group
`
`12.
`
`responsible for Ethernet standards in Layer 1 and the Media Access Controller
`
`portion of Layer 2 (per the ISO 7 layer reference model). In this position, I
`
`supervised 14 standards projects covering the development of Ethernet using
`
`speeds from 100 Mb/s, 1 Gb/s, and 10 Gb/s, as well as various other projects such
`
`as switching/full duplex, auto-negotiation, management, virtual local area
`
`networks, Power over Ethernet, and link aggregation.
`
`13.
`
`In 2002, I became the 1st Vice Chairman of the IEEE 802 LAN/MAN
`
`Standards Executive Committee. In this role, I supported the Chair of the
`
`Committee and assisted in governance of the Committee. I also advocated IEEE
`
`802.3 standards in interactions with IEEE Standards Association staff and higher
`
`level governance.
`
`14.
`
`From 2010 to 2011, I was the Chair of the 802.23 Emergency Services
`
`Working Group.
`
`15.
`
`I became a Member Emeritus of the IEEE 802 LAN/MAN Standards
`
`Executive Committee in 2002. I returned to that position in 2011 and continue to
`
`hold this title today. I also remain a voter and active participant in the IEEE 802.3
`
`Working Group.
`
`Page 3 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`
`A.
`
`Patents Awarded
`
`16.
`
`Through my years of work in the communications and networking
`
`industry, I have been awarded at least 12 U.S. patents.
`
`17.
`
`Several of these patents deal with local area networks, Ethernet
`
`implementations, indicating power over Ethernet connections, data switching in
`
`network environments and techniques for virtual LAN identification.
`
`A.
`
`Other Awards
`
`18. At Nortel, I received the title of Distinguished Member Technical
`
`Staff in 2008. Also at Nortel, I received the Significant Patent Award in September
`
`2000.
`
`19.
`
`Through my work with the IEEE, I received the IEEE-SA Standards
`
`Board Distinguished Service Award in 2006. I also received the IEEE Standards
`
`Medallion in 1996.
`
`A.
`
`Qualifications
`
`20.
`
`Based on my industry experience and key roles in various IEEE 802.3
`
`standards projects as described above, including the project that standardized
`
`Power over Ethernet as IEEE 802.3af (2003), I consider myself to be an expert in
`
`the field of networking systems and equipment.
`
`21.
`
`I believe that I am qualified to provide an opinion as to what a person
`
`having ordinary skill in the art would have understood, known, or concluded
`
`Page 4 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`during the timeframe of 1998-2000 (hereinafter, a “PHOSITA”). Such a person
`
`would have (i) a bachelors degree in electrical or electronics engineering, including
`
`studies related to the field of communications or (ii) 3-5 years of comparable work
`
`experience.
`
`22. MATERIALS CONSIDERED
`
`23.
`
`In the course of preparing this Declaration, I have reviewed the ’930
`
`patent and its file history, the previous ex parte reexamination proceeding (control
`
`no. 90/012,401), as well as the prior art references and related documents discussed
`
`below.
`
`24.
`
`I have also reviewed the Petition for Post-Grant Review of the ’930
`
`Patent (“the Petition”) and claim charts that are being submitted concurrently with
`
`this Declaration.
`
`25.
`
`In addition, I have reviewed the Decision on Institution of Inter
`
`Partes Review in Case IPR2013-00092 dated May 24, 2013 (“the Sony-Axis IPR
`
`Decision”), Decision on Institution of Inter Partes Review in Case IPR2013-00386
`
`dated July 29, 2013 (“the Sony-Axis-Hewlett-Packard IPR Decision”), the
`
`Decision on Institution of Inter Partes Review in Case IPR2013-00071 dated May
`
`24, 2013 (“the Avaya IPR Decision”), the Final Written Decision of Inter Partes
`
`Review in Case IPR2013-00071 dated May 22, 2014 (“the Avaya Final Written
`
`Decision”).
`
`Page 5 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`26. OVERVIEW OF THE ’930 PATENT
`
`27.
`
` The ’930 patent purports to have a filing date of March 7, 2000, and
`
`claims priority to U.S. Provisional Application No. 60/123,688, filed on March 10,
`
`1999. Because the prior art references I discuss below predate the asserted March
`
`10, 1999 date, I have not assessed whether the ’930 patent is in fact entitled to such
`
`a priority date.
`
`28.
`
`The ’930 patent generally relates to delivering power and data to an
`
`access device over a data signaling pair. According to the “Field of the Invention”
`
`section of the ’930 patent, “[t]he invention more particularly relates to apparatus
`
`and methods for automatically determining if remote equipment is capable of
`
`remote power feed[,] and if it is determined that the remote equipment is able to
`
`accept power remotely[,] then to provide power in a reliable non-intrusive way.”
`
`Ex. 1001, ’930 patent, 1:14-19.
`
`29.
`
`The “Background of the Invention” section of the patent indicates
`
`several objectives. One stated objective is “to add remotely powered devices to a
`
`data network.” Id. at 1:33-35. Another objective is to “have a centrally powered
`
`system that can be protected during a power outage.” Id. at 1:39-40. A further
`
`objective is “to provide methods and apparatus for reliably determining if a remote
`
`piece of equipment is capable of accepting remote power.” Id. at 1:41-43. A final
`
`stated objective is “to provide methods and apparatus for delivering remote power
`
`Page 6 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`to remote equipment over 10/100 switched Ethernet segments and maintain
`
`compliance with IEEE 802.3 standards.” Id. at 1:44-47. Although this objective
`
`refers to 10/100 switched Ethernet segments, claims 6, 8, 9, 12-19, and 22 of the
`
`’930 patent do not require any particular communications protocol. Only claims 4,
`
`10-11, 20, 21, and 23 contain recitation of “Ethernet.”
`
`30.
`
`The ’930 patent describes a remote access device 10, which “requires
`
`power to carry out its operation and includes an internal dc-dc switching supply.”
`
`Id. at 2:36-44. The remote access device may be a telephone 62, as shown in
`
`Figure 1. Id. at 3:60-66. Cable 12, which can be Category 5 wire, connects the
`
`remote access device 10 to a network data node 14. Id. at 2:44-51. While the
`
`example of cable 12 given in the specification is Category 5 wire, claims 6, 9, 13,
`
`and 19-23 of the ’930 patent require only a “data signaling pair.” Only claim 18
`
`requires at least “two data signaling pairs.”
`
`31. A power source 16, which “may be the same as the conventional main
`
`power supply used to power the node 14,” is connected to cable 12 to supply a
`
`“power level sensing potential to the remote access equipment 10 over one of the
`
`cable conductors.” Id. at 2:52-57. A remote power detector 22 operates a detection
`
`circuit consisting of a resistor 26 with shunting switch 28 connected in parallel to a
`
`resistor 30, which provides a path to ground. Id. at 2:59-65.
`
`Page 7 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`32. Detection of remote equipment is performed by delivering a “low
`
`level current (approx. 20 ma) to the network interface and measuring a voltage
`
`drop in the return path.” Id. at 2:66-3:2. According to the ’930 patent, “[t]here are
`
`three states which can be determined: no voltage drop, a fixed level voltage drop or
`
`a varying level voltage drop.” Id. at 3:2-4. The first two states indicate that the
`
`access device is unable to accept remote power. Id. at 3:4-11. The third state, a
`
`varying voltage level, indicates that the access equipment is capable of accepting
`
`remote power. Id. at 3:12-27.
`
`33.
`
`“Once the remote equipment is operating and confirmed as a known
`
`remote power enabled device,” the removal of the device or a fault condition may
`
`be detected. Id. at 3:49-52. If the voltage level drops, this indicates removal of the
`
`remote equipment. Id. at 3:52-55.
`
`34.
`DEVICES
`
`BRIEF BACKGROUND ON REMOTE POWERING OF
`
`35.
`
`The ’930 patent correctly acknowledges that “[a] variety of
`
`telecommunications equipment is remotely powered today,” i.e., prior to the
`
`alleged invention of the ’930 patent. Id. at 1:22-24. Nevertheless, the patent is
`
`incorrect in stating that remote powering techniques had “not migrated to data
`
`communications equipment.” Id. at 1:24-27. Below, I provide some brief
`
`Page 8 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`background on remote powering of devices, in both telecommunications and data
`
`communications environments, which would have been available to a PHOSITA.
`
`36.
`
`Telecommunications equipment has been remotely powered since the
`
`earliest telegraphs. Early dial telephones received power from a central office
`
`battery as the means to power the customer premises telephone instrument. An
`
`example of such a system is shown in U.S. Patent No. 447,918, to Strowger, dated
`
`1891. The Strowger system also used a remote detection technique. In particular,
`
`picking up the receiver placed a low impedance resistor across the wire pair which
`
`in turn activated a relay in the central office and connected the phone to dial
`
`activated call routing equipment.
`
`37. When AT&T started using digital transmission equipment for
`
`telephone systems in the 1960s, the first system to be deployed was the T-1 Carrier
`
`System (Bell Laboratories Record, November, 1962), which was used to increase
`
`the capacity of voice trunk circuits between telephone central offices. Such a T-1
`
`system used two voice wire pairs and required a repeater approximately every
`
`6,000 feet. The repeaters were mounted on telephone poles or placed in manholes
`
`and were remotely powered from a central office. The power was provided over
`
`the twisted pairs via a phantom circuit.
`
`Page 9 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`38. Years later, customer demand for high speed digital service directly
`
`from customers’ premises led to T-1 service actually being terminated at a user
`
`interface in the customers’ premises, where it continues to this day in many areas.
`
`39.
`
`In the mid-1980s, there was a major move to migrate analog telephone
`
`services to a digitally based service that would include provision for data
`
`connectivity as well as digital voice. This was the Integrated Services Digital
`
`Network (ISDN), which was ultimately standardized by ITU-T in the I (Eye) series
`
`of recommendations. There were several means proposed to power user terminals
`
`(e.g., ISDN telephones) via the cable and the eight-pin modular jack commonly
`
`known as an RJ-45. ISDN was not a big success, especially in the United States,
`
`but the cabling and connectors for it were adapted for local area network (LAN)
`
`use in general, and Ethernet (10BASE-T) use in particular. The ISDN specification
`
`options for providing power over the data cabling are called out in ITU-T I.430-
`
`1988 and its ISO equivalent ISO 8877 as referenced in IEEE Std 802.3e-1987.
`
`40.
`
`LANs were invented in the 1970s (see, e.g., U.S. Patent No.
`
`4,063,220, to Metcalfe, dated 1977) and moved into the product and standards
`
`arena in the 1980s. Many LAN implementations had portions of their equipment
`
`that were remotely powered over the data cabling. In Ethernet, the transceiver or
`
`Media Access Unit (MAU) clamped to the coaxial cable linear bus that was the
`
`core medium of the LAN. The transceiver was connected to its computer by up to
`
`Page 10 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`50 meters of twisted-pair cable. That cable provided power from the computer to
`
`the transceiver, albeit on a separate pair of the “AUI Cable.” U.S. Patent No.
`
`4,733,389, to Puvogel, dated 1988, described how to reduce the number of pairs
`
`needed in an AUI cable from four to two by putting both power and the collision
`
`signal onto a phantom circuit formed by the transmit and receive pairs.
`
`41.
`
`In other LAN technology, Token Ring (IBM, IEEE Std 802.5 1985)
`
`computers provided a power signal over a phantom circuit on the twisted pairs of
`
`the cable called out by the IBM Cabling System. The power was used by the
`
`Token Ring Hub to detect that a station was plugged in and powered up. The low
`
`power was used to switch a relay which rerouted the wiring of the ring from bypass
`
`to pass through the attached station. The same power arrangement was later used in
`
`the CDDI standard and in Ethernet over IBM cabling (e.g., in LattisNet STP by
`
`SynOptics Communications). The same scheme was also used as a link integrity
`
`signal by SynOptics in its broadly deployed precursor to 10BASE-T, marketed as
`
`LattisNet UTP.
`
`42.
`
`Thus remote powering was well known by PHOSITAs in both the
`
`telephony and data networking fields by the time LAN speeds were high enough,
`
`and silicon integration was advanced enough, to enable Ethernet-based voice over
`
`Internet Protocols (VoIP) telephones, well before the claimed priority date of the
`
`’930 patent. The introduction of telephones as Ethernet-based instruments called
`
`Page 11 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`for power over the signal cord to match customer expectations associated with
`
`legacy (POTS) and ISDN telephones.
`
`43. VALIDITY ANALYSIS
`
`44.
`
`I have been asked to provide opinions addressing whether claims 6
`
`and 8-23 of the ’930 patent are valid based on the prior art references discussed
`
`below. Specifically, those references include: U.S. Patent No. 5,345,592 to
`
`Woodmas (Ex. 1024) (“Woodmas”); International Application Publication No. WO
`
`96/23377 to Hunter et al. (Ex. 1025) (“Hunter”); TELEVISION PRODUCTION, by Ron
`
`Whittaker (1993) (Ex. 1026) (“TELEVISION PRODUCTION”); Japanese Unexamined
`
`Patent Application No. H10-13576 to Matsuno (Ex. 1028) (“Matsuno”) (English).
`
`45.
`
`In my analysis, I have relied on certain claim constructions that were
`
`provided in the Avaya IPR Decision (Ex. 1003) issued by the Patent Office. I have
`
`formed no independent opinion as to the correctness of the claim constructions. In
`
`particular, I have relied on the following claim constructions in my analysis:
`
`a.
`
`“low level current”: a current (e.g., approximately 20 mA) that
`
`is sufficiently low that, by itself, it will not operate the access
`
`device.
`
`b.
`
`“data node adapted for data switching”: a data switch or hub
`
`configured to communicate data using temporary rather than
`
`Page 12 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`permanent connections with other devices or to route data
`
`between devices.
`
`c.
`
`d.
`
`“data signaling pair”: a pair of wires used to transmit data.
`
`“main power source” and “secondary power source”: not
`
`necessarily physically separate devices.
`
`46.
`
`In my opinion, each and every element of claims 6 and 8-23 of the
`
`’930 patent is disclosed in the prior art references discussed below. Specifically,
`
`the prior art discloses the subject matter of claims 6 and 8-23 as arranged in those
`
`claims. The prior art references also explain and present the subject matter of
`
`claims 6 and 8-23 so as to enable a PHOSITA to make and use the claimed
`
`methods.
`
`A. Woodmas
`
`47.
`
`Based on my review of Woodmas, it is my opinion that a PHOSITA
`
`would have regarded claims 6, 8, 9, 12-17, 19, and 22 of the ’930 patent as
`
`anticipated based on the teachings of Woodmas in view of the ordinary knowledge
`
`possessed by a PHOSITA. It is also my opinion that the teachings of Woodmas
`
`would have been sufficient to enable a PHOSITA to make and use the methods of
`
`claims 6, 8, 9, 12-17, 19, and 22.
`
`48.
`
`I have reviewed the Petition and accompanying claim chart which
`
`explain in detail how Woodmas teaches each and every element of claims 6, 8, 9,
`
`Page 13 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`12-17, 19, and 22 as arranged in those claims. In my opinion, the Petition and
`
`claim chart demonstrate that these references disclose every element of claims 6, 8,
`
`9, 12-17, 19, and 22 as arranged in those claims and render those claims obvious.
`
`49. Woodmas is directed to remotely powering equipment over a two
`
`conductor cable, such as a coaxial cable. Ex. 1024, Woodmas, Abstract. According
`
`to Woodmas, a control station module includes a power delivery unit for delivering
`
`power to the conductors, and a remote station module includes a power reception
`
`unit for receiving power from the conductors. Id. at 2:3-17. The control station
`
`module 26 includes a control station signal unit 32 and power deliver unit 34. Id. at
`
`2:62-63; Fig. 1. The control module 26 is operable of bi-directional communication
`
`with the control station 14. The signal unit 32 within the control station module 26
`
`is preferably a conventional signal multiplexing unit, which allows the control
`
`station module 26 to receive a plurality of signals from the control station 14,
`
`which further combines and multiplexes those signals onto a coaxial cable portion
`
`36 for transmission by the power delivery unit 34. Id. at 2:64-3:2. Similarly, the
`
`signal unit 32 receives multiplexed signals over cable portion 36 and separates the
`
`signals for presentation to control station 14. Id. at 3:3-6. Therefore, the control
`
`station module 26 with the signal unit 32 described in Woodmas discloses the “data
`
`node adapted to data switching” recited in claim 6 of the ’930 patent. This is also
`
`consistent with the claim constructions provided for “data node adapted for data
`
`Page 14 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`switching” in the Sony-Axis IPR Decision and the Avaya IPR Decision, which
`
`communicate data using temporary rather than permanent connections with other
`
`devices or to route data between devices.
`
`50.
`
`The camera station module 28 described in Woodmas is coupled with
`
`components 18-24, which include a DC-powered video camera 18, talent earpiece
`
`20, camera operator intercom headset 22, and talent microphone. Id. at 2:50-53;
`
`2:56-61. Camera station module 28, camera station 16, and components 18-24,
`
`when considered alone or in combination, disclose an “access device adapted for
`
`data transmission” as recited in claim 6 of the ’930 patent, because each is able to
`
`send and receive data (e.g., audio-video data or control signals) and receive power
`
`by means of a data signaling pair, cable 30, as further discussed below.
`
`51. Woodmas discloses a two-conductor cable, which may be a coaxial
`
`cable that is used to connect control station 26 to camera station module 28. Id. at
`
`5:3-10. As Woodmas explains, cable 30 is capable of handling both bi-directional
`
`signaling and power delivery. Id.; see also id. at 2:54-61; 5:3-6. Both the coaxial
`
`embodiment described in Woodmas and the “two wire pair” embodiment involve a
`
`pair of conductors. Id. at 9:47-49. Accordingly, cable 30 in Woodmas satisfies the
`
`construction of “data signaling pair,” because it comprises a pair of wires used to
`
`transmit data.
`
`Page 15 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`52. Various types of power sources are disclosed in Woodmas. For
`
`example, Woodmas teaches a power supply 38, which draws power from a
`
`conventional 120 volt AC power source, which would be a wall outlet or generator.
`
`Id. at 3:26-33. This conventional AC power source is illustrated in Figure 2.
`
`Woodmas also discloses a power delivery unit 34, which includes the power supply
`
`38. Id. at 3:17-25. A PHOSITA would understand that the power that operates
`
`control station 14, control station module 26, and power delivery unit 34 is a
`
`conventional AC power source. Power from this source is in turn used by power
`
`delivery unit 34 and power supply 38 to supply a current to cable 30, which is
`
`transmitted to camera station module 28. Id. at 3:12-17. Camera station module 28
`
`is able to separate the power and deliver it to the components at camera station 16
`
`that require power, such as camera 18, earpiece 20, intercom headset 22, and
`
`microphone 24. Id.; see also id. at 2:50-53; 5:32-35. Therefore, the conventional
`
`AC power source described in Woodmas, as well as the power delivery unit 34 or
`
`DC power supply 38, disclose the “main power source” and “secondary power
`
`source” recited in claim 6 of the ’930 patent. This is also consistent with the claim
`
`constructions provided for “main power source” and “secondary power source” in
`
`the Sony-Axis IPR Decision and the Avaya IPR Decision, which do not require the
`
`two power sources to be physically separate.
`
`Page 16 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`53. According to Woodmas, before full power is provided to connected
`
`devices, a low level voltage, with a current limited to 15 mA, is delivered. Id. at
`
`6:45-47; 7:24-26. Woodmas explains that this 15 mA current is applied “when
`
`power delivery unit 34 is initially energized.” Id. at 3:50-52. This current of 15 mA
`
`discloses the limitation of a “low level current” recited in claim 6. In fact, this
`
`current level is lower than the example of 20 mA given in the ’930 patent. See Ex.
`
`1001, ’930 patent, 2:66-3:2. This current level in Woodmas is also consistent with
`
`the claim constructions given in the Sony-Axis Decision and the Avaya Decision,
`
`which require the current to be sufficiently low that, by itself, it will not operate the
`
`access device. Woodmas teaches exactly this concept, because it explains that the
`
`15 mA current is applied to cable 30 “before full operating power is imposed.” Ex.
`
`1024, Woodmas, 7:24-26 (emphasis added).
`
`54. Upon receiving voltage from power delivery unit 34, a voltage
`
`controlled oscillator 88 within the power reception unit 76 generates a power status
`
`signal as a frequency modulated signal based on the voltage received. Id. at 6:16-
`
`23. The frequency of the power status signal represents the voltage as delivered by
`
`cable 30 to camera station module 28. Id. at 6:23-26. The power status signal
`
`generated by oscillator 88 is sent via cable 30 back to power delivery unit 34. Id. at
`
`6:32-40; 7:44-52. For example, because the power status signal is an oscillating
`
`voltage, it is similar to the “varying voltage level” described in the ’930 patent,
`
`Page 17 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`which is described as the voltage parameter that identifies a DC-DC switching
`
`supply in the remote equipment. Ex. 1001, ’930 patent, 3:12-17. The power status
`
`signal is thus “representative of the low level voltage” delivered from delivery unit
`
`34. Ex. 1024, Woodmas, 7:44-50. Woodmas then “asks whether the power status
`
`signal is present as detected” and provides the power status signal to
`
`microcontroller 54 if detected. Id. at 7:39-52. By delivering this low level current
`
`of 15 mA before full operating power is supplied and looking for a return voltage
`
`representative of the low level current, “both the presence and functionality of
`
`power delivery unit 76 are checked before full power is imposed on cable 30.” Id.
`
`at 7:50-52. Sensing this power status signal returned to power delivery unit 34
`
`corresponds to the requirement in claim 6 of sensing a voltage level on the data
`
`signaling pair in response to the low level current, because the power status signal
`
`is in response to, and representative of, the 15 mA current delivered by power
`
`delivery unit 34.
`
`55. Woodmas teaches controlling power in response to the power status
`
`signal in three ways. First, Woodmas teaches that if a short circuit is detected
`
`across cable 30 (e.g., due to cable 30 becoming pinched, cut, or incorrectly
`
`connected), the voltage level will drop below 10 volts, indicating a short circuit is
`
`present. Id. at 6:52-60; 7:24-30. If a short circuit is detected, power delivery is
`
`controlled because a decision is made not to deliver full power from delivery unit
`
`Page 18 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`34; instead, an “alarm subroutine” is initiated. Id. at 7:34-35; Fig. 4A. Second,
`
`Woodmas teaches supplying full power if the power status signal is received and a
`
`short circuit is not detected. Id. at 7:39-50; 8:7-17. Third, once power is delivered,
`
`if fluctuations in the power draw at the camera station 16 occur, the power status
`
`signal will change, causing the power delivery unit 34 to supply more or less
`
`power to “compensate.” Id. at 6:26-31; see also id. at Abstract (“The delivery unit
`
`controls the delivered voltage in accordance with the status signal in order to
`
`maintain the received voltage at the camera station at a desired level in order to
`
`compensate for cable voltage drop.”). Each of these techniques for controlling
`
`power supplied from delivery unit 34 correspond to controlling power supplied by
`
`said secondary power source to said access device in response to a preselected
`
`condition of said voltage level, as recited in claim 6.
`
`56. According to Woodmas, the low level current of 15 mA is supplied
`
`from the power delivery unit 34 to confirm that the reception unit 76 is “present
`
`and operational.” Id. at 7:44-52. Both the “presence” and “functionality” of
`
`reception unit 76 are checked in this manner before full power is supplied. Id.
`
`When the corresponding power status signal is received, Woodmas teaches
`
`displaying the message “camera unit present.” Id. at 7:53-54; Fig. 4A. By
`
`providing a low level current of 15 mA and confirming the presence and
`
`functionality of the camera unit in this manner before supplying full operational
`
`Page 19 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`power, Woodmas teaches polling the access device to identify it and confirm that it
`
`is capable of accepting remote power, as recited in claim 8 of the ’930 patent.
`
`Furthermore, using the same technique, Woodmas is able to determine whether the
`
`access device is capable of accepting remote power, as recited in claim 20 of the
`
`’930 patent.
`
`57. As discussed above, Woodmas also teaches supplying power from
`
`power delivery unit 34 to camera station module 28 and its power reception unit 76
`
`based on the power status signal received at power delivery unit 34. Woodmas
`
`teaches that, during operation, the power draw at camera station may vary, which
`
`in turn may affect the power status signal. Id. at 6:26-31. Power delivery unit 34 is
`
`designed to “compensate” in such a situation by delivering more or less power
`
`based on the fluctuations in power draw at the camera station. Id. In addition, as
`
`discussed above, Woodmas teaches detecting short circuits, which may result from
`
`disconnected equipment, when the sensed voltage level drops below 10 volts. Id. at
`
`6:52-60. Therefore, by teaching that the power delivery unit 34 compensates for
`
`changes detected in the power status signal and can detect when a short circuit is
`
`present, Woodmas discloses continuing to sense voltage level and to decrease
`
`power from the secondary power source if voltage level drops on the data signaling
`
`pair, indicating removal of the access device as recited in claim 9 of the ’930
`
`patent.
`
`Page 20 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`
`A.
`
`Hunter in View of Woodmas
`
`58.
`
`Based on my review of Hunter and Woodmas, it is my opinion that a
`
`PHOSITA would have regarded claims 6 and 10-23 of the ’930 patent as obvious
`
`based on the teachings of Hunter and Woodmas in view of the ordinary knowledge
`
`possessed by a PHOSITA. It is also my opinion that the teachings of Hunter in
`
`view of Woodmas would have been sufficient to enable a PHOSITA to make and
`
`use the methods of claims 6 and 10-23.
`
`59.
`
`I have reviewed the Petition and accompanying claim chart which
`
`explain in detail how Hunter in view of Woodmas teaches each and every element
`
`of claims 6, 8, and 9 as arranged in those claims. In my opinion, the Petition and
`
`claim chart demonstrate that these references disclose every element of claims 6
`
`and 10-23 as arranged in those claims and render those claims obvious.
`
`60. Hunter discloses providing power to equipment coupled to an
`
`Ethernet data node. Ex. 1025, Hunter, 34:18-20, 36:25-37:28. To obtain the
`
`objective, Hunter provides “a power subsystem and method for providing phantom
`
`power via a computer network backbone, the bus including first and second
`
`conductors.” Id. at 19:13-17. For example, an interactive multimedia system could
`
`employ the power subsystem. According to Hunter, the system can be remotely
`
`powered by “a phantom powering subsystem” (id. at 20:19-20) or “a bus interface
`
`for a LAN” capable of providing phantom power (id. at 23:25-26).
`
`Page 21 of 44
`
`
`
`Petition for Post-Grant Review
`Covered Business Method Patent Review
`United States Patent No. 6,218,930
`In the illustrated embodiment, the multimedia hub 120 contains the
`
`61.
`
`following functions: 10Base-T hub repeater, B-channel switch, isoEthernet®
`
`interfaces. Id. at 32:16-20. A 10Base-T hub 170 provides 24 SNMP-managed 10
`
`Base-T ports.
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
