UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________________________
`
`APPLE INC.,
`Petitioner
`
`v.
`
`OpenTV, Inc.,
`Patent Owner.
`
`Case No. ______
`
`
`
`DECLARATION OF STEPHEN MELVIN, Ph.D.
`IN SUPPORT OF APPLE INC.’S PETITION FOR COVERED BUSINESS
`METHOD PATENT REVIEW OF U.S. PATENT NO. 7,055,169
`
`
`
`Apple Ex. 1004
`
`
`______________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________________________
`
`APPLE INC.,
`Petitioner
`
`v.
`
`OpenTV, Inc.,
`Patent Owner.
`
`Case No. ______
`
`
`
`DECLARATION OF STEPHEN MELVIN, Ph.D.
`IN SUPPORT OF APPLE INC.’S PETITION FOR COVERED BUSINESS
`METHOD PATENT REVIEW OF U.S. PATENT NO. 7,055,169
`
`
`
`Apple Ex. 1004
`
`
`
`I, Stephen Melvin, hereby declare as follows:
`
`U.S. Patent No. 7,055,169
`Petition for Covered Business Method Patent Review
`Declaration of Stephen Melvin, Ph.D.
`
`
`I.
`1.
`
`INTRODUCTION
`I have prepared this Declaration in connection with Apple Inc.’s Petition for
`
`Covered Business Method Patent Review of U.S. Patent No. 7,055,169 (“the ’169
`
`patent”) (Ex. 1001), which is to be filed concurrently with this Declaration.
`
`2.
`
`In the course of preparing this Declaration, I reviewed the ’169 Patent, its
`
`prosecution file history, as well as the documents discussed in this Declaration.
`
`3.
`
`I have been retained by Apple Inc. (“Apple” or “Petitioner”) as an expert in
`
`the fields of computer science, computer communications, and related
`
`technologies. I am being compensated at my normal consulting rate of $445 per
`
`hour for my time. My compensation is not dependent on and in no way affects the
`
`substance of my statements in this Declaration.
`
`4.
`
`I have no financial interest in Apple. I similarly have no financial interest in
`
`the ’169 Patent or the owner of the ’169 Patent, and I have had no contact with the
`
`named inventors of the ’169 Patent.
`
`II. QUALIFICATIONS
`5.
`I received a Ph.D. in Computer Science from the University of California at
`
`Berkeley in 1991 and a B.S. in Electrical Engineering and Computer Science from
`
`the University of California at Berkeley in 1982. I have more than 30 years of
`
`Apple Ex. 1004 – Page 1
`
`
`
`U.S. Patent No. 7,055,169
`Petition for Covered Business Method Patent Review
`Declaration of Stephen Melvin, Ph.D.
`
`experience in computer science and computer engineering. I am an inventor on
`
`over 45 patents, and I am a registered patent agent before the USPTO.
`
`6. My Ph.D. research areas included high-performance computer architecture
`
`and microarchitecture and microcode-based system performance analysis tools.
`
`From September 2001 through April 2002, I was a Visiting Scholar at the
`
`University of Texas, Austin, where I directed graduate students in research in the
`
`area of high-performance computer architecture.
`
`7.
`
`In May 2001, I co-founded and was the Chief Architect of Flowstorm, Inc., a
`
`start-up company based in Silicon Valley, where I defined and guided the overall
`
`chip architecture for a multithreaded packet processor. From March 2000 through
`
`May 2001, I worked as the Senior CPU Architect at Clearwater Networks, where I
`
`was involved in defining the architecture and microarchitecture of Clearwater’s
`
`CNP810S multithreaded network processor.
`
`8.
`
`From August 1983 to the present, I have been the President of Zytek
`
`Communications Corporation (“Zytek”). Zytek is an engineering, consulting, and
`
`small-scale manufacturing company that currently provides intellectual property
`
`consulting services as well as services related to the design, implementation, and
`
`testing of embedded systems. Zytek’s general areas of activity have included
`
`industrial control and measurement, Internet-related services, hard disk analysis
`
`and file recovery, and computer engineering research services. Through my work
`
`Apple Ex. 1004 – Page 2
`
`
`
`U.S. Patent No. 7,055,169
`Petition for Covered Business Method Patent Review
`Declaration of Stephen Melvin, Ph.D.
`
`at Zytek, I have designed numerous microprocessor-based embedded systems,
`
`including analog and digital circuit design, firmware development for embedded
`
`microcontrollers, and software development for host interfacing, product
`
`development, and debugging.
`
`9.
`
`I am a member of the following professional organizations: The Institute of
`
`Electrical and Electronics Engineers (IEEE); The Association for Computing
`
`Machinery (ACM); The American Intellectual Property Law Association (AIPLA);
`
`The Intellectual Property Owners Association (IPO); and The National Association
`
`of Patent Practitioners (NAPP).
`
`10.
`
`I served as General Chair of the 45th Annual International Symposium on
`
`Microarchitecture (Micro-45), held in Vancouver in December of 2012. I also
`
`served as co-chair of the 29th Annual International Symposium on
`
`Microarchitecture (Micro-29), held in Paris in December of 1996.
`
`11. For further details regarding my employment and academic history, please
`
`refer to my curriculum vitae, attached as Ex. 1005.
`
`III. RELEVANT LAW
`12.
`I am not an attorney. For the purposes of this Declaration, I have been
`
`informed about certain aspects of the law that are relevant to my opinions. My
`
`understanding of the law is summarized below.
`
`Apple Ex. 1004 – Page 3
`
`
`
`U.S. Patent No. 7,055,169
`Petition for Covered Business Method Patent Review
`Declaration of Stephen Melvin, Ph.D.
`
`I have been informed and understand that claim construction is a matter of
`
`13.
`
`law and that the final claim constructions for this proceeding will be determined by
`
`the Patent Trial and Appeal Board.
`
`14.
`
`I have been informed and understand that in the context of a covered
`
`business method patent review, a claim of an unexpired patent must be construed
`
`according to its broadest reasonable construction in light of the specification.
`
`15.
`
`I have been informed and understand that a “technological invention” in the
`
`context of a CBM review refers to “whether the claimed subject matter as a whole
`
`recites a technological feature that is novel and unobvious over the prior art; and
`
`solves a technical problem using a technical solution.” 37 C.F.R. § 42.301(b).
`
`16.
`
`I have been informed and understand that patent-eligibility under 35 U.S.C.
`
`§ 101 is determined by a two-step analysis set forth by the United States Supreme
`
`Court in Alice Corp. Pty. Ltd. v. CLS Bank Int’l, 134 S. Ct. 2347 (2014) (the “Alice
`
`test”): (1) it is determined whether the claims at issue are directed to an abstract
`
`idea, and (2) if so, it is determined whether the claim’s elements “transform the
`
`nature of the claim” into a patent-eligible application.
`
`IV. LEVEL OF ORDINARY SKILL IN THE ART
`17. Based on my review of the ’169 Patent and my background and experience
`
`in the field of computer science, it is my opinion that one of ordinary skill in the art
`
`as of the priority date would be someone with a bachelor’s degree in computer
`
`Apple Ex. 1004 – Page 4
`
`
`
`U.S. Patent No. 7,055,169
`Petition for Covered Business Method Patent Review
`Declaration of Stephen Melvin, Ph.D.
`
`science, computer engineering, or the equivalent, plus approximately two years of
`
`experience in the field of computer engineering or software development, or an
`
`equivalent amount of relevant work and/or research experience.
`
`18.
`
`I have been informed and understand that claim construction is viewed from
`
`the perspective of a person of ordinary skill in the art in question at the time of the
`
`invention. I have been informed that the owner of the ’169 Patent claims an
`
`invention date of June 2001. I have been asked to assume that this is the proper
`
`priority date for the ’169 Patent. However, the opinions I expressed in this report
`
`would be the same if I applied a priority date of April 2002 (the provisional filing
`
`date of the ’169 Patent) or April 2003 (the actual filing date of the ’169 Patent).
`
`19. The ’169 Patent generally relates to computer content control and interactive
`
`television systems.
`
`20. Based on my education and experience, I am familiar with the level of
`
`knowledge that one of ordinary skill would have possessed during the relevant
`
`period of time.
`
`21.
`
`In reaching this opinion as to the qualifications of the hypothetical person of
`
`ordinary skill in the art, I have considered the types of problems encountered in the
`
`art, the prior art solutions to those problems, the rapidity with which innovations
`
`are made, the sophistication of the technology, and the educational level of active
`
`workers in the field.
`
`Apple Ex. 1004 – Page 5
`
`
`
`U.S. Patent No. 7,055,169
`Petition for Covered Business Method Patent Review
`Declaration of Stephen Melvin, Ph.D.
`
`22. By the priority date of the ’169 Patent, I was a person who had more than
`
`ordinary skill in the art.
`
`V. OVERVIEW OF THE ’169 PATENT
`23. The ’169 Patent, entitled “Supporting Common Interactive Television
`
`Functionality Through Presentation Engine Syntax,” was filed on April 21, 2003,
`
`and issued on May 30, 2006. See Ex. 1001 at Cover.
`
`24. The ’169 Patent discloses methods and systems for handling the presentation
`
`of audio, video, or graphic presentations that require a set of resources. See Ex.
`
`1001 at Abstract, 2:33-57, 46:54-47:10, claims 1, 22, and 23.
`
`25. Specifically, the ’169 Patent discloses systems and methods that receive
`
`“directives” indicating an audio, video, or graphic presentation that requires a set
`
`of resources. Id.
`
`26.
`
` The method or system claimed by the ’169 Patent determines whether any
`
`of the received directives are a “prerequisite directive.” Id. at claims 1, 22, and 23.
`
`27.
`
`If the directives include a “prerequisite directive,” then the method or system
`
`prohibits the presenting or initiation of the presentation until the “prerequisite”
`
`resources are acquired. Id. If the directives do not include a “prerequisite
`
`directive” indicating that there are resources that must be acquired before
`
`initiation, then the presentation is initiated. Id.
`
`Apple Ex. 1004 – Page 6
`
`
`
`U.S. Patent No. 7,055,169
`Petition for Covered Business Method Patent Review
`Declaration of Stephen Melvin, Ph.D.
`
`In one embodiment, the directives can be comprised of a markup language, a
`
`28.
`
`scripting language, and/or a style sheet. Id. at 46:54-47:10, claim 2.
`
`29.
`
`In one embodiment, the prohibiting step is in further response to detecting a
`
`corresponding time for expiration has not yet expired and the method for handling
`
`the presentation further comprises allowing the presenting of the presentation in
`
`response to detecting the time for expiration has expired. Id. at 21:53-22:10, claim
`
`12.
`
`30. The concept behind the system and method disclosed by the ’169 Patent—
`
`ensuring that resources deemed to be necessary are available before commencing a
`
`presentation—is well-known and has been used in many other contexts.
`
`31. The idea of ensuring that resources deemed to be necessary are available
`
`before commencing a presentation is not technology-specific, but applies to
`
`situations where a person wants to ensure that he or she has resources deemed to be
`
`necessary before starting a presentation.
`
`32.
`
`It is my opinion that the claimed subject matter as a whole does not recite a
`
`technological feature that is novel and unobvious over the prior art, and does not
`
`solve a technical problem using a technical solution.
`
`33. The ’169 Patent specification acknowledges that various interactive
`
`television standards—including the “DVB MPH 1.1 specification” (Digital Video
`
`Broadcasting - Multimedia Home Platform) and the “DAVIC 1.4.1” (Digital Audio
`
`Apple Ex. 1004 – Page 7
`
`
`
`U.S. Patent No. 7,055,169
`Petition for Covered Business Method Patent Review
`Declaration of Stephen Melvin, Ph.D.
`
`Video Council)—already existed by the priority date of the ’169 Patent. Id. at
`
`2:16-25. These specifications provided “mechanisms to handle … resources,”
`
`including mechanisms to ensure that resources are available for presentations. See
`
`id.
`
`34. The ’169 Patent includes 23 claims. I have been asked to analyze claims 1,
`
`2, 12, 22, and 23.
`
`35.
`
`Independent claim 1 recites:
`
`1. A method comprising:
`[a] receiving one or more directives, wherein said directives are
`indicative of an audio, video and/or graphic presentation which
`requires a set of resources;
`[b] determining whether said one or more directives includes a
`prerequisite directive which indicates that acciuisition [sic] of a
`subset of said set of resources is a prerequisite for initiating the
`presentation;
`[c] initiating said presentation, in response to determining the
`one or more directives do not include said prerequisite directive;
`and
`[d] prohibiting initiation of said presentation until said subset of
`resources are acquired, in response to determining the one or
`more directives include said prerequisite directive.
`
`36. Claim 1 is a method claim that recites a method for handling a presentation.
`
`The claimed method is not tied to any hardware elements or specific application.
`
`Apple Ex. 1004 – Page 8
`
`
`
`U.S. Patent No. 7,055,169
`Petition for Covered Business Method Patent Review
`Declaration of Stephen Melvin, Ph.D.
`
`37. Claims 2 and 12 depend from independent claim 1.
`
`38. Claim 22 recites “a client device in an interactive television system”
`
`comprising “a receiver configured to receive signals …” and a “processing unit
`
`coupled to said receiver.” These components are “configured to” perform a
`
`process similar to the method recited by claim 1.
`
`39. Claim 23 recites a “computer readable medium comprising program
`
`instructions executable by a computer” that performs a method for controlling a
`
`presentation.
`
`VI. CLAIM CONSTRUCTION ANALYSIS
`40.
`I have been asked to opine on the following claim limitations: “directive”
`
`(claims 1, 2, 22, and 23).
`
`41. The ’169 Patent describes “directives,” stating: “[T]he declarations or other
`
`statements used in the creation and/or manipulation of resources and content in this
`
`document may be generally referred to as ‘directives.’” Ex. 1001 at 47:7-10.
`
`42. The ’169 Patent also explains: “In one embodiment, a device in an
`
`interactive television system is configured to receive one or more directives
`
`provided by a content author which describe or otherwise indicate an audio and/or
`
`video presentation.” Id. at 2:39-42.
`
`43. Further, The American Heritage College Dictionary defines “directive” as:
`
`“An order or instruction, esp. one from a central authority.” Ex. 1007 at 393. The
`
`Apple Ex. 1004 – Page 9
`
`
`
`U.S. Patent No. 7,055,169
`Petition for Covered Business Method Patent Review
`Declaration of Stephen Melvin, Ph.D.
`
`New Shorter Oxford English Dictionary defines “directive” as: “Something that
`
`directs; spec. a general instruction for procedure or action given to a subordinate.”
`
`Ex. 1008 at 680.
`
`44. Accordingly, it is my opinion that, in the context of the ’169 Patent, a person
`
`of ordinary skill in the art would have understood “directive” to mean “declaration
`
`or instruction.”
`
`VII. CLAIMS 1, 2, 12, 22, AND 23 ARE DIRECTED TO AN ABSTRACT
`IDEA
`45. Claims 1, 2, 12, 22, and 23 attempt to patent the idea of ensuring that
`
`resources deemed to be necessary are available before commencing a presentation.
`
`See, e.g., Ex. 1001 at claims 1, 22, and 23; 47:57-48:3 (“If the client does not have
`
`these resources, the client may then take any actions necessary to prefetch the
`
`prerequisite resources …. Once the client has obtained the prerequisite resources
`
`(decision block 514), presentation of the content corresponding to the prerequisite
`
`resources is permitted.”).
`
`46.
`
`Independent claims 1, 22, and 23 recite a method, a device, and a computer
`
`readable medium that perform the process of receiving “directives” indicative of a
`
`presentation, determining whether these “directives” include “a prerequisite
`
`directive” indicating that certain resources are required either “for initiating the
`
`presentation” or “for the presentation,” and “initiating said presentation” and
`
`Apple Ex. 1004 – Page 10
`
`
`
`U.S. Patent No. 7,055,169
`Petition for Covered Business Method Patent Review
`Declaration of Stephen Melvin, Ph.D.
`
`“prohibiting said presentation” based on the “prerequisite directive” and
`
`availability of its indicated resources. Id. at claims 1, 22, and 23.
`
`47. The concept behind the system and method disclosed by claims 1, 22, and
`
`23—ensuring that resources deemed to be necessary are available before
`
`commencing a presentation—is an idea that is well-known and has been used in
`
`many other contexts. For example, these claims are based on the same concept as
`
`ensuring that a presidential candidate has a written script in hand before
`
`commencing a stump speech or that lawyers have a PowerPoint presentation
`
`available before starting an examination. The concept is merely that certain
`
`resources are deemed to be necessary, and a presentation does not commence until
`
`those resources are available.
`
`48. Each of the claimed steps—“receiving,” “determining,” “initiating,” and
`
`“prohibiting”—can be manually performed by a person. For example, the
`
`“receiving,” “initiating,” and “prohibiting” steps can all be performed by verbal
`
`and/or non-verbal communication, and a person can perform the “determining”
`
`step in his or her mind.
`
`49. Thus, independent claims 1, 22, and 23 are directed to the abstract idea of
`
`ensuring that resources deemed to be necessary are available before commencing a
`
`presentation.
`
`Apple Ex. 1004 – Page 11
`
`
`
`U.S. Patent No. 7,055,169
`Petition for Covered Business Method Patent Review
`Declaration of Stephen Melvin, Ph.D.
`
`50. Dependent claims 2 and 12 do not add any limitations that affect this
`
`determination.
`
`51. Claim 2, which depends from claim 1, limits the “prerequisite directive” to
`
`one of “a markup language, a scripting language, and a style sheet.” Id. at claim 2.
`
`This limitation does not alter the underlying abstract idea of claim 1. Instead, it
`
`only serves to specify the format of the “prerequisite directive.”
`
`52. Claim 12 depends from claim 1 and adds a step of “detecting a
`
`corresponding time for expiration has not yet expired.” Id. at claim 12. This
`
`limitation does not alter the underlying abstract idea of claim 1 because the step of
`
`“detecting a corresponding time for expiration has not yet expired” can be
`
`manually performed by a person. Using an expiration time to trigger an event is an
`
`abstract idea that has long existed before the invention of computers.
`
`53. The problem addressed by claims 1, 2, 12, 22, and 23—ensuring that
`
`resources deemed to be necessary are available before commencing a
`
`presentation—exists in virtually all domains. It is not a technological problem;
`
`ensuring that resources deemed to be necessary are available before commencing a
`
`presentation is not a problem necessarily rooted in technology. Further, there is
`
`nothing unique about this problem in the context of interactive television systems.
`
`54. Even if claims 1, 2, 12, 22, and 23 are construed to be limited to computer
`
`technology (or interactive television systems), they are still abstract. In the context
`
`Apple Ex. 1004 – Page 12
`
`
`
`U.S. Patent No. 7,055,169
`Petition for Covered Business Method Patent Review
`Declaration of Stephen Melvin, Ph.D.
`
`of computer systems, setting a threshold requiring the receipt of a certain amount
`
`of data—e.g., all, some, or none of the resources for a website or interactive
`
`television application—is still based on the abstract idea of ensuring that resources
`
`deemed to be necessary are available before beginning a presentation.
`
`55.
`
`In addition, the ’169 Patent’s proffered solution to the problem—using
`
`“directives” to ensure that resources deemed to be necessary are available before
`
`commencing a presentation—is not a technical solution.
`
`VIII. CLAIMS 1, 2, 12, 22, AND 23 USE ONLY CONVENTIONAL
`TECHNOLOGY
`56. Claims 1, 2, and 12 are directed to an abstract idea and are not tied to any
`
`technology. Claims 22 and 23 offer no meaningful limitation beyond generally
`
`linking an abstract idea to conventional technology.
`
`57. The limitations of claims 1, 2, and 12 are not tied to a particular machine or
`
`apparatus, but instead generally recite method steps that can be performed
`
`manually by a person or on a generic computer.
`
`58. The limitations of claims 1, 2, and 12 also do not transform an article into a
`
`different state or thing.
`
`59. Claim 22 recites a “client device in an interactive television system”
`
`comprising a “receiver” and a “processing unit.” Both receivers and processing
`
`Apple Ex. 1004 – Page 13
`
`
`
`U.S. Patent No. 7,055,169
`Petition for Covered Business Method Patent Review
`Declaration of Stephen Melvin, Ph.D.
`
`units are conventional, generic computer components that existed long before the
`
`priority date of the ’169 Patent.
`
`60.
`
`Indeed, the ’169 Patent describes the “client” device as a standard “set top
`
`box.” Id. at 5:15-22. It further describes the “client” device as using “ordinary
`
`general purpose” computer components such as microprocessor and RAM
`
`memory. Id. at 5:25-35 (“Client 1012 includes a control unit 1030, front end 1026,
`
`return channel 1038, transport stage 1028, and AV stage 1034. Also represented in
`
`FIG. 3 is a memory 1080 which includes OS and/or middleware 1044, message
`
`processing engine 1036, and applications 1042. Also shown is an I/O interface
`
`1040 and conditional access (CA) module(s) 1032. I/O interface 1040 may be
`
`configured to detect user interaction via a remote control, keyboard, or other
`
`device. Control unit 1030 may comprise a microprocessor, memory (e.g., RAM),
`
`and other components which are necessary to perform ordinary general purpose
`
`computing.”).
`
`61. The ’169 Patent does not disclose a new hardware design. As acknowledged
`
`by the ’169 Patent specification, microprocessors, RAM memory, I/O interfaces,
`
`OS and/or middleware, and other components described by the ’169 Patent were
`
`conventional and well-known long before the priority date of the ’169 Patent. See
`
`id. at 5:15-35. I designed, built, and used these software and hardware components
`
`Apple Ex. 1004 – Page 14
`
`
`
`U.S. Patent No. 7,055,169
`Petition for Covered Business Method Patent Review
`Declaration of Stephen Melvin, Ph.D.
`
`during my graduate studies in the late 1980s, more than 10 years before the priority
`
`date of the ’169 Patent.
`
`62. Claim 23 recites a “computer readable medium comprising program
`
`instructions executable by a computer” that performs steps similar to those recited
`
`in claim 1. A computer readable medium comprising program instructions
`
`executable by a computer is conventional, generic computer technology.
`
`63. The use of “directives” to indicate that certain resources are necessary was
`
`well-known long before the priority date of the ’169 Patent, and is not specific to
`
`the computer industry. As explained above, the term “directive” refers to
`
`“declaration or instruction.” People have long used declarations or instructions to
`
`communicate that certain resources are required.
`
`64.
`
`I understand that in the related district court litigation between Petitioner and
`
`Patent Owner, Patent Owner argues that “directive” should be narrowly construed
`
`as “a declaration or other statement that is formed using a computer language (e.g.,
`
`HTML, Javascript, CSS, etc.) used in the creation and/or manipulation of resources
`
`and content.” Ex. 1011 at 7.
`
`65. The ’169 Patent, along with Patent Owner’s narrow construction of
`
`“directive,” do not purport to have invented a new computer language. Instead, the
`
`’169 Patent explains that it aims to apply its solution using conventional,
`
`“commonly used” computer programming techniques. Ex. 1001 at 47:5-7 (“In one
`
`Apple Ex. 1004 – Page 15
`
`
`
`U.S. Patent No. 7,055,169
`Petition for Covered Business Method Patent Review
`Declaration of Stephen Melvin, Ph.D.
`
`embodiment, languages and constructs which are commonly used in creating and
`
`manipulating Web content are contemplated.”) (emphasis added).
`
`66.
`
`Indeed, the programming languages identified in Patent Owner’s
`
`construction—HTML, Javascript, and CSS—were conventional and commonly
`
`used to manipulate interactive content, such as web pages, long before the priority
`
`date of the ’169 Patent. HTML, or Hypertext Markup Language, was first used
`
`around 1990, and, as it has evolved through multiple generations, has served as the
`
`standard language for web pages since then. Javascript was developed around
`
`1995 and has become widely used in Web applications, starting at least as early as
`
`the late-1990s. CSS, or Cascading Style Sheets, was first introduced around 1996
`
`and also has become a common technique for setting the visual style of web pages,
`
`starting at least as early as the late-1990s. I was familiar with these languages and
`
`techniques long before the priority date of the ’169 Patent.
`
`IX. CONCLUSION
`67.
`In signing this Declaration, I recognize that the Declaration will be filed as
`
`evidence in a contested case before the Patent Trial and Appeal Board of the
`
`United States Patent and Trademark Office. I also recognize that I may be called
`
`upon to testify in deposition or before the Patent Trial and Appeal Board. If called
`
`upon to testify, I would testify truthfully and competently to all matters stated in
`
`this Declaration.
`
`Apple Ex. 1004 – Page 16
`
`
`
`U.S. Patent No. 7,055,169
`Petition for Covered Business Method Patent Review .
`
`Declaration of Stephen Melvin, Ph.D.
`
`68.
`
`I reserve the right to supplement my opinions in the future to respond to any
`
`arguments that Patent Owner raises and to take into account new information as it
`
`becomes available to me.
`
`69.
`
`I hereby declare that all statements made herein of my own knowledge are
`
`true, and that all statements made on information and belief are believed to be true
`
`and that such statements are made with the knowledge that willful false statements
`
`and the like are punishable by fine or imprisonment, or both, under Section 1001 of
`
`Title 18 of the United States Code.
`
`Date: April 26, 2016
`
`
`
`Stephen Melvin, Ph.D.
`
`Apple Ex. 1004 — Page 17
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
