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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`K—40 ELECTRONICS, LLC
`Petitioner
`
`V.
`
`ESCORT, INC.
`Patent Owner
`
`Case IPR 2013-00240
`
`US Patent No. 6,670,905
`
`DECLARATION OF BETH ANDREWS
`
`Mail Stop "PA TENT BOARD”
`Patent Trial and Appeal Board
`US. Patent and Trademark Office
`
`PO. Box 1450
`
`Alexandria, VA 22313- 1450
`
`Escort Ex. 2053, pg. 1
`
`Escort Ex. 2053, pg. 1
`
`

`

`1.
`
`I was employed at Cincinnati Microwave Inc. (“CMI”) from or about
`
`1983 to or about December 1996. From or about 1993 to or about December 1996
`
`I was a Product Manager at CMI.
`
`2.
`
`In or about 1996, I was involved with product planning at CMI. At
`
`that time, it was important to marketing to have the CM] technical staff develop a
`
`product to deal with the “falsing” issue, i.e., that solved the false alarm door opener
`
`problem wherein a radar detector would render an alert from a non-police radar
`
`emission. In other words, in 1996 CMI wanted to have a product that had less
`
`“falsing” than other brands so we had a real need to figure out a way to deal with
`
`“falsing.”
`
`3.
`
`Attached hereto as Exhibit 2050 is a true and correct copy of pages
`
`from my 1996 “QUAD” calendar. More specifically, as shown therein and in a
`
`true and correct excerpt therefrom that is reproduced herein, at or about 1 pm.
`
`GEDT), Tuesday,
`
` April 2, 1996, a
`
`“Brainstorming”
`
`‘ -' '-* L
`
`meeting with
`
`Greg Blair, Steve Orr, Tom Perszyk, and myself was held in Conference Room D
`
`at CMI. During that meeting, I recorded notes on a whiteboard which had the
`
`option to send those notes to a printer. Attached hereto as Exhibit 2051 is a true
`
`Page 2 of 4
`
`Escort Ex. 2053, pg. 2
`
`Escort Ex. 2053, pg. 2
`
`

`

`and correct copy of the printout from the whiteboard from that brainstorming
`
`session. The printout includes my following handwritten notes:
`
`(wringing? __._ wwww
`
`ix. gag.
`
`Thus, during this brainstorming session, I recorded that the “Next Product” would
`
`include “GPS” and that it would have a “trainable auto-X source.” Exhibit 2051.
`
`In other words, the goal was to have a device which one could train, by using
`
`Global Positioning System (“GPS”) data, to automatically cancel (“X”) false radar
`
`sources, i.e., sources of radar from other than actual police activities. Id.
`
`4.
`
`In the weeks thereafter, as further Shown in my 1996 “QUAD”
`
`
`calendar (Ex. 2050)
`
`and in the true and
`
`correct excerpts
`
`Page 3 of 4
`
`Escort Ex. 2053, pg. 3
`
`Escort Ex. 2053, pg. 3
`
`

`

`therefrom that are reproduced herein,
`
`there was “Follow up on [the]
`
`brainstorming” session and attention to
`
`5. I recall that Steve Orr actively
`
`the required “Accessory items —
`
`Significant —— GPS” for “Velocity”
`
`monitoring, determining the locations
`
`of “Speed traps,” and for the “trainable
`
`auto-X source” “Program” feature.
`
`pursued developing a prototype of this
`
`“Next Product” and would periodically and generally informally provide updates
`
`on his progress. At one point, he provided a demonstration of a prototype system
`
`he had developed on a picnic table in the CMI outdoor lounge area, a true and
`
`correct picture of which is shown herein. His demonstration used a laptop
`
`computer and showed the desired GPS functionality.
`
`5. While it was not clear whether Steve Orr’s GPS solution would be
`
`affordable at the time, that question was not resolved prior to my departure.
`
`6.
`
`I declare under penalty of perjury that the foregoing is true and
`
`correct.
`
`Z 7 /47
`
`Date:
`
`@452? '
`
`Beth Andrews
`
`Page 4 of 4
`
`Escort Ex. 2053, pg. 4
`
`Escort Ex. 2053, pg. 4
`
`

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