throbber
Declaration of Tal Lavian in Support of Petition for inter partes
`review of U.S. Patent No. 6,970,183
`
`Mail Stop Inter Parties Review
`
`Attn:Patent Trial and Appeal Board
`Commissioner for Patents
`PO Box 1450
`Alexandria, VA 22313-1450
`
`Commissioner:
`
`I, Tal Lavian, declare as follows:
`
`1.
`
`I have been retained on behalf of Mobotix Corp. for the above-captioned
`
`inter partes review proceeding, involving U.S. Patent No. 6,970,183
`
`(hereinafter “the ‘183 Patent”).
`
`2.
`
`I have reviewed and am familiar with the specification of the ‘183
`
`Patent, which was filed on June 14, 2000 and issued on November 29,
`
`2005.
`
`3.
`
`I have reviewed and am familiar with Imaide et al., An MPEG Camera
`
`with Tapeless Video Recording, Digest of Technical Paper, International
`
`Conference on Consumer Electronics. Appl. Phys. 1322 (11-13 June
`
`1997) (hereinafter “Imaide”), Barzdins et al., Wireless Internet Access in
`
`Latvia, (hereinafter “Barzdins”), Japan Patent Publication No. 11-
`
`284987 to Bonshihara et al., (hereinafter “Bonshihara”), Canadian
`
`Patent Publication No. 2,228,679 to Heggie et. al. (hereinafter
`
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`“Heggie”), International Patent Application Publication No. WO
`
`97/40624 to Ely et al. (hereinafter “Ely”), U.S Patent No. 6,323,897 to
`
`Kogane et al. (hereinafter “Kogane”) and U.S. Patent No. 6,697,103 to
`
`Fernandez (hereinafter “Fernandez”).
`
`4.
`
`I have been asked to provide my technical review, analysis, insights, and
`
`opinions regarding the above-noted references that form the basis for the
`
`grounds for rejection set forth in the Petition for inter partes review of
`
`the ‘183 Patent.
`
`I. Qualifications
`I possess the knowledge, skills, experience, training and the education to
`5.
`
`form an expert opinion and testimony in this case. My Curriculum
`
`Vitae, including a listing of academic/professional publications and
`
`patents, is set forth in MOB1003a.
`
`6. My academic background includes a Ph.D. in Computer Science,
`
`received from the University of California at Berkeley, a Master of
`
`Science (“M.Sc.”) degree in Electrical Engineering, and a Bachelor of
`
`Science, (“B.Sc.”) degree in Mathematics and Computer Science from
`
`Tel Aviv University. My Ph.D. Dissertation was entitled: “Lambda
`
`Data Grid: Communications Architecture
`
`in Support of Grid
`
`Computing.”
`
`
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`7.
`
`I currently serve as a Center for Entrepreneurship and Technology
`
`(CET) Industry Fellow and Lecturer at University of California
`
`Berkeley’s College of Engineering. At U.C. Berkeley, I have studied
`
`network
`
`services,
`
`telecommunications
`
`systems
`
`and
`
`software,
`
`communications infrastructure and data centers. I have also served as
`
`the scientific liaison between U.C. Berkeley and Nortel Research Lab.
`
`8.
`
`Since 2006, I have also served as the Principal Scientist at Innovations
`
`IP, based in Sunnyvale, CA, providing consulting and research services
`
`in the areas including network communications, telecommunications
`
`and internet software technologies.
`
`9.
`
`From 1996-2007, I worked at Nortel Research Lab, holding the
`
`positions of Principal Scientist, Principal Architect, Principal Engineer,
`
`and Senior Software Engineer. At Nortel, I also served as Principal
`
`Investigator for several US Department of Defense (DARPA) projects
`
`concerning network communications. In addition, I led a project on
`
`networking computation for the United States Air Force Research Lab
`
`(AFRL). I also led a network communications research project for an
`
`undisclosed US Federal Agency, as well as several other research
`
`projects concerning communications networks.
`
`
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`10. While at Nortel, I received the Top Talent Award and the Top Inventors
`
`Award.
`
`11. Prior to my work at Nortel, I worked at Bay Networks; Bay Networks
`
`was later acquired by Nortel Networks. At Bay Networks, I held
`
`various scientific and research roles including working in the CTO
`
`Office in the fields of computer networking and Internet technologies.
`
`Prior to my work at Bay Networks, I worked as a software engineer for
`
`Aptel Communications, a start-up company developing wireless spread
`
`spectrum Personal-Communication-Network (PCN) and Personal-
`
`Communication-System (PCS) technologies.
`
`12.
`
`I am named as a co-inventor on over 80 issued patents and patent
`
`applications. I have co-authored over 25 scientific publications, journal
`
`articles, and peer-reviewed papers. I am also a Senior Member of the
`
`Institute of Electrical and Electronics Engineers (“IEEE”).
`
`II. Understanding the Law
`I have been instructed that the words of patent claims themselves define
`13.
`
`the scope of the patented invention.
`
`14.
`
`I have been instructed that the claims should be interpreted based upon
`
`their meaning as would have been understood by a person of ordinary
`
`
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`skill in the art (POSITA) at the time of the invention in light of the
`
`specification.
`
`15.
`
`I have been instructed that, during infringement litigation, the history of
`
`an application’s prosecution before the Patent and Trademark Office can
`
`affect the meaning of claims in that application. However, I was also
`
`informed that, in the Patent and Trademark Office claims are given their
`
`broadest reasonable interpretation in light of the specification.
`
`16.
`
`I have been instructed that the doctrine of claim differentiation implies
`
`that the presence of a dependent claim that adds a particular limitation
`
`gives rise to a presumption that the limitation in question is not present
`
`in the independent claim. While I am, as I previously stated, no expert
`
`in patent law, I believe that I understand what is meant by the term
`
`“presumption.”
`
`17.
`
`I have been instructed that, to anticipate a patent claim, a single piece of
`
`prior art must disclose every element of the claim, either expressly or
`
`inherently, as that claim and that prior art would have been understood
`
`by a POSITA as of the effective filing date of that claim.
`
`18.
`
`I have been instructed that prior art is information that is defined in the
`
`patent statute. In my opinions below that involve prior art, I have relied
`
`upon the prior art that I have received .
`
`
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`a. My understanding of obviousness
`It is my understanding that a claimed invention is unpatentable if the
`
`19.
`
`differences between the invention and the prior art are such that the
`
`subject matter as a whole would have been obvious at the time the
`
`invention was made to a person having ordinary skill in the art to which
`
`the subject matter pertains.
`
`20.
`
`It is my understanding that “obviousness” is a question of law based on
`
`underlying factual issues including the content of the prior art and the
`
`level of skill in the art. I understand that for a single reference or a
`
`combination of references to make the claimed invention obvious, a
`
`person of ordinary skill in the art must have been able to arrive at the
`
`claimed invention by modifying, altering or combining the applied
`
`references.
`
`21.
`
`I also understand that when considering the obviousness of a patent
`
`claim, one should consider whether a
`
`teaching, suggestion, or
`
`motivation to combine the references exists so as to avoid impermissibly
`
`applying hindsight when considering the prior art. I understand this test
`
`should not be rigidly applied, but that the test can be important to avoid
`
`such hindsight.
`
`22.
`
`I am not a lawyer but I believe that I understand these legal definitions.
`
`
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`III. Background of the ‘183 Patent
`23. The ‘183 Patent purports to a surveillance and monitoring system
`
`including a combination of digital cameras with full motion video
`
`surveillance capability and a network, the network including network
`
`components and appliances such as wiring, workstations, and servers.
`
`The ‘183 Patent, Abstract.
`
`24. The ‘183 Patent further describes that the surveillance system is capable
`
`of a wide range of monitoring techniques utilizing digital network
`
`architecture and is adapted for transmitting event data, video and/or
`
`image monitoring information, audio signals and other sensor and
`
`detector data over significant distances using digital data transmission
`
`over a LAN, wireless LAN, Intranet or Internet for automatic
`
`assessment and response including dispatch of response personnel. The
`
`‘183 Patent, Abstract.
`
`25. Centralized monitoring stations have access to all of the surveillance
`
`data from various remote locations via the Internet or the WAN. A
`
`server provides a centralized location for data collection, alarm detection
`
`and processing, access control, dispatch processing, logging functions
`
`and other specialized functions. The ‘183 Patent, Abstract.
`
`
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`IV. Application of Ely
`26. U.S. Patent No. 5,982,418 to Ely (hereinafter “Ely”) describes a video
`
`surveillance system including a central control station and a plurality of
`
`cameras. A video buffer memory storing compressed video data
`
`generated by the camera is mounted with each camera. Data buffered at
`
`the cameras may be selectively protected from overwriting in response
`
`to alarm signals and then retrieved for display or tape by the central
`
`control station (host computer). Both live and buffered video signals are
`
`transmitted in compressed form over a data network that is also used for
`
`command, alarm and status messaging. Ely, Abstract.
`
`27. Ely teaches a local area network (LAN) 112. Ely p.9, lines 11-12; FIG
`
`2. A LAN is defined by the IEEE as ”a computer network located on a
`
`user’s premise within a limited geographical area” and is designed to
`
`handle digital data including IP.
`
`28. Ely inherently teaches that an alarm condition signal from the sensor
`
`device 120 is converted from a conventional sensor signal into a
`
`network compatible signal in order to send it to the central station 102
`
`over the LAN 112 because an empirical (analog) signal or status to be
`
`sensed such as heat must be converted to a digital electrical signal to be
`
`sent over the LAN. Ely, p.9, lines 18-23.
`
`
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`29. Ely inherently teaches a server receiving and logging conventional
`
`sensor data and video data. Ely teaches a host computer 104 comprising
`
`hardware and software. Ely, p.9, lines 5-12; FIG. 2. The main
`
`operational function of a computer in a security application environment
`
`is to receive and log alarm data, sensor data, video data and other
`
`relevant security data.
`
`30. Ely also teaches a camera unit comprising a video codec 136 configured
`
`to compress image data according to the H.261 standard. Ely p.11, line
`
`19 and 33; Figure 3. The ITU-T standard H.261 includes full motion
`
`video and the option of capturing still frame images because in H.261
`
`digital video is composed of multiple still frames and the ability to
`
`collect a signal frame is included as part of the standard. Attachment,
`
`Annex D.
`
`31. Ely further teaches that a suitable data recorder can be connected to the
`
`LAN 112 to record compressed video data directly from that LAN 112.
`
`Moreover, the data recorder could be operated continuously to record all
`
`traffic on the LAN, including both live and buffered video data. Ely, p.
`
`16, line 32-p. 17, line 2. Ely does not expressly shows that the data
`
`recorder is adapted for managing data transmitted by the plurality of
`
`sensor appliances.
`
`
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`32.
`
`It would have been obvious to a person having ordinary skill in the art at
`
`the time of the invention to modify the data recorder as taught by Ely
`
`such that the data recorder itself manages the transmitted data because
`
`this is a known technique to improve similar devices in the same way
`
`since
`
`it
`
`is based on common sense or
`
`the result of routine
`
`experimentation.
`
`V. Application of Ely and Fernandez
`33. Ely teaches the features as described in ¶¶ [26]-[32].
`
`34. U.S. Patent No. 6,697,103 to Fernandez et al. (hereinafter “Fernandez”)
`
`is directed to a surveillance system including an integrated fixed and/or
`
`wireless network for monitoring and processing remote and/or local
`
`moveable objects. Fernandez, 1:33-36. Fernandez teaches that the
`
`TCP/IP or LAN/WAN network 8 is connected to a server 5 (and a
`
`detector 3) and a wired or wireless communicator 7 for communicating
`
`to one or more target units 4. E.g., Fernandez, 3:17-22 and 3:49; Figure
`
`1.
`
`35. Fernandez teaches an integrated camera such as target unit 4 which may
`
`include one or more video cameras, active sensor, microphone or
`
`physical monitoring or observation device to provide real time object
`
`data, such as audio and/or video signals (sensor unit 44). Fernandez
`
`
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`6:16-23. The sensor unit 44 may comprise a temperature detector, a
`
`smoke detector, a thermostat, etc. because the sensor unit 44 may be the
`
`same devices as detector 3. Fernandez, 4:43-47.
`
`36. Claim 16 of the ‘183 Patent recites a fire detector. Fernandez teaches a
`
`smoke detector. It is well known that a smoke detector is a form of a
`
`fire detector because the smoke detector typically detects smoke as
`
`indicator of fire.
`
`37. Claim 17 of the ‘183 Patent recites a chemical detector. Fernandez
`
`teaches a smoke detector. It is well known that a smoke detector is a
`
`form of a chemical detector. For example, an ionization smoke detector
`
`ionizes air and the ionized air reacts with smoke altering a current in a
`
`circuit of the detector. This is a form of a chemical detection.
`
`38. Fernandez teaches a surveillance system comprising a controller 6
`
`having a software tool 166 adaptively providing positional or directional
`
`functionality to alert authorities or other interested parties when
`
`undesirable object or movement is monitored. Fernandez, 15:42-44;
`
`Figure 3.
`
`39. Both Ely and Fernandez relate a surveillance system for monitoring an
`
`area by using cameras and sensors.
`
`40.
`
`It would be obvious to a person having ordinary skill in the art at the
`
`
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`time of invention to substitute the camera of Ely with the integrated
`
`camera of Fernandez because both references teach using known
`
`components (cameras and sensors) in the same way yielding predictable
`
`results. Such a substitution is well known, based on common sense, or
`
`the result of routine experimentation.
`
`41.
`
`It would be obvious to a person having ordinary skill in the art at the
`
`time of invention to substitute the (LAN) network of Ely with the
`
`LAN/WAN or TCP/IP network of Fernandez because both references
`
`teach using known networks in the same way yielding predictable
`
`results. Such a substitution is well known, based on common sense, or
`
`the result of routine experimentation.
`
`42.
`
`It would be obvious to a person having ordinary skill in the art at the
`
`time of invention to improve the surveillance system of Ely with a
`
`software tool providing positional or directional functionality for
`
`interested parties as taught by Fernandez because this is a known
`
`technique to improve similar devices in the same way since it is based
`
`on common sense or the result of routine experimentation.
`
`VI. Application of Ely, Fernandez and Barzdins
`43. Ely teaches the features as described in ¶¶ [26]-[32].
`
`44. Fernandez teaches a surveillance system comprising a network 8
`
`
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`coupled to a communicator 7, wherein the communicator 7 provides a
`
`conventional or proprietary wireless connection to a target unit 4.
`
`Fernandez, 3:17-22; Figure 1. The target unit 4 may couple wirelessly
`
`to a controller 6 through the network 8, as the communicator 7 provides
`
`wireless connectivity between the network 8 and the target unit 4.
`
`Fernandez, 5:42-45. The target unit 4 may include a sensor unit 44 such
`
`as camera(s), a communicator unit 46, a power source and a non-volatile
`
`memory. Fernandez, 6:11-16.
`
`45. Barzdins teaches that spread spectrum wireless data transmission
`
`(wireless LAN) has been available since the early 1990s. Wireless
`
`LANs can be used to interconnect distant buildings, for example. The
`
`wireless Local Area Network (wireless LAN) has made building private
`
`wireless data links as simple as plugging a radio adapter card into PC
`
`and connecting this card to an antenna. Barzdins, Introduction, p.1.
`
`46. Barzdins shows in great detail off-the-shelf products, including technical
`
`specification and prices. Barzdins specifically shows several Wireless
`
`LAN products commercially available from vendors such as 1) “Free
`
`Wave Technologies, Inc.” 2) “AT&T”, or 3) “Aironet Communications,
`
`Inc.”, including prices and web link to buy them. Barzdins, pp. 5-8
`
`47. Barzdins finally teaches that these commercially available products
`
`
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`conform to the several ETSI standards and FCC regulations. Barzdins,
`
`pp. 5-8
`
`48.
`
`It would be obvious to a person having ordinary skill in the art at the
`
`time of the invention to substitute a wireline connection of the camera
`
`unit of Ely with a wireless connection of the target unit of Fernandez.
`
`Both are interchangeable by just picking a wireless or a wireline camera
`
`and yield predictable results..
`
`49.
`
`It would be obvious to a person having ordinary skill in the art at the
`
`time of the invention to substitute a wireline connection of the central
`
`station (host computer) of Ely with a wireless connection of the
`
`computer of Barzdins because both connections are well known,
`
`commercially available, part of several ETSI standards and FCC
`
`regulations, interchangeable and yield predictable results.
`
`VII. Application of Ely and Imaide
`50. Ely teaches the features described in ¶¶ [26]-[32].
`
`51.
`
`Imaide shows a camera configured to generate multiple files: 1) MPEG
`
`video; 2) MPEG audio; 3) JPEG still pictures and 4) their combinations.
`
`52.
`
`It would be obvious to a person having ordinary skill in the art at the
`
`time of invention to substitute the camera of Ely with the camera of
`
`Imaide because this is a simple well known substitution of one camera
`
`
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`for another camera in order to obtain predictable results.
`
`VIII. Application of Bonshihara
`Japanese Patent Publication No. 1999-284987
`53.
`
`is directed
`
`to a
`
`surveillance system. The surveillance (image monitoring) system
`
`includes one or more cameras (image capture and recording devices)
`
`100 and a monitoring device 200 connected via computer network 1a.
`
`Bonshihara, Means of Resolution; Figures 1-3. The image capture and
`
`recording device 100 and the monitoring device 200 are respectively
`
`connected to external sensor 130, 240, and have a function which
`
`receives monitoring signals from the sensors. Bonshihara, ¶ [0048].
`
`Bonshihara teaches that the monitoring device 200 comprises a
`
`microcomputer. Bonshihara, ¶ [0034].
`
`54.
`
`JPEG compression typically generates still frame pictures.
`
`IX. Application of Bonshihara and Fernandez
`55. Bonshihara teaches the features described in ¶¶ [53]-[54].
`
`56. Fernandez teaches the features described in ¶¶ [34]-[38].
`
`57. Both Bonshihara and Fernandez relate a surveillance system for
`
`monitoring an area by using cameras and sensors.
`
`58.
`
`It would be obvious to a person having ordinary skill in the art at the
`
`time of invention to substitute the image capture and recording device of
`
`
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`Bonshihara with the integrated camera of Fernandez. This is a simple
`
`replacement. Both references teach using known components (cameras
`
`and sensors) in the same way yielding predictable results.
`
`X. Application of Bonshihara, Fernandez and Barzdins
`59. Bonshihara teaches the features described in ¶¶ [53]-[54].
`
`60. Fernandez teaches the features described in ¶ [44].
`
`61. Barzdins teaches the features described in ¶¶ [45]-[47].
`
`62.
`
`It would be obvious to a person having ordinary skill in the art at the
`
`time of the invention to substitute a wireline connection of the image
`
`capture and recording device of Bonshihara with a wireless connection
`
`of the target unit of Fernandez. Both are interchangeable by just picking
`
`a wireless or a wireline camera and yield predictable results.
`
`63.
`
`It would be obvious to a person having ordinary skill in the art at the
`
`time of the invention to substitute a wireline connection of the
`
`monitoring device of Bonshihara with a wireless connection of the
`
`computer of Barzdins because both connections are well known,
`
`commercially available, part of several ETSI standards and FCC
`
`regulations, interchangeable and yield predictable results.
`
`XI. Application of Bonshiara and Imaide
`64. Bonshihara teaches the features described in ¶¶ [53]-[54].
`
`
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`65.
`
`Imaide teaches the features described in ¶ [51].
`
`66.
`
`It would be obvious to a person having ordinary skill in the art at the
`
`time of invention to substitute the camera of Bonshihara with the camera
`
`of Imaide because this is a simple substitution of one camera for another
`
`camera in order to obtain predictable results.
`
`XII. Application of Heggie and Fernandez
`67. Canadian Patent Publication 2,228,679 A1 to Heggie et al. (hereinafter
`
`“Heggie”) is directed to a surveillance system for monitoring and
`
`recording activity at a remote location. Heggie further teaches that the
`
`monitoring devices such as cameras are capable of continually surveying
`
`zones at remote locations, detecting activity such as motion, and
`
`providing an alarm to a monitoring station when motion is detected.
`
`Heggie, Abstract; Figure. The surveillance system includes cameras
`
`connected to capture stations (remote stations), a surveillance station
`
`(client station, operator and/or management station) and a database
`
`server (video database) connected to a network. Heggie, Figure. When
`
`an alarm occurs the client station will supply information about whom to
`
`inform of the alarm. Heggie, p.17, lines 4 and 5.
`
`68. Fernandez teaches the features described in ¶¶ [34]-[38].
`
`69.
`
`It would be obvious to a person having ordinary skill in the art at the
`
`
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`time of invention to improve the surveillance system of Heggie with a
`
`software tool providing positional or directional functionality for
`
`interested parties as taught by Fernandez because this is a known
`
`technique to improve similar devices in the same way since it is based
`
`on common sense or the result of routine experimentation.
`
`XIII. Application of Kogane and Fernandez
`70. U.S. Patent No. 6,323,897 to Kogane et al. (hereinafter “Kogane”) is
`
`directed to a surveillance system including camera units 1, a data storing
`
`unit 3, a control server 5, a monitor display 4 and a TCP/IP capable
`
`network 2. Kogane, Abstract; Figure 2. The camera units 1 may
`
`include a motion detector 30 for detecting motion in video data, a
`
`memory for storing the video data 31, a microphone 54, a traffic monitor
`
`41, and a sensor input circuit 34. Kogane, Abstract; Figure 3. The
`
`display terminal 4 may further include a speaker for reproducing the
`
`sound data. Kogane, 2:66-67 and 3:1-3.
`
`71. Fernandez teaches the features as described in ¶¶ [34]-[38].
`
`72. Moreover, Fernandez teaches a controller 6 having a software
`
`communication module 161 functions adaptively to initiate, establish,
`
`modify, and coordinate user communication between controller 6 and
`
`mobile target unit 4, as well as any other processor or peripherals
`
`
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`coupled to network 8. Fernandez, 10:51-56. Software communication
`
`module 161 communicates, upon detection of an emergency or another
`
`urgent message (e.g., 911 phone calls from target unit cell phones),
`
`relevant object location, movement, or other conditions and immediately
`
`forwards this information to appropriate authorities located proximately
`
`to monitored object in distress. Fernandez, 10:67-11:6.
`
`73.
`
`It would be obvious to a person having ordinary skill in the art at the
`
`time of invention to improve the surveillance system of Kogane with a
`
`software tool providing positional or directional functionality for
`
`interested parties as taught by Fernandez because this is a known
`
`technique to improve similar devices in the same way since it is based
`
`on common sense or the result of routine experimentation.
`
`74.
`
`It would be obvious to a person having ordinary skill in the art at the
`
`time of invention to improve the surveillance system of Kogane with a
`
`software tool providing relevant object location, movement, or other
`
`conditions to appropriate authorities located proximately to monitored
`
`object in distress as taught by Fernandez because this is a well-known
`
`technique to improve similar devices in the same way since it is based
`
`on common sense or the result of routine experimentation.
`
`
`
`
`
`Page 19 of 20
`
`MOB1003
`IPR of U.S. Patent No. 6,970,183
`
`

`

`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 further that these statements were made with the knowledge that willful false
`
`statements and the like so made are punishable by fine or imprisonment, or both,
`
`under Section 1001 of Title 18 of the United States Code.
`
`this }f duv or fr f r' |
`Executed
`
`,2013 in {u^ 4y v.l- L/l-
`
`Date: vl />( /tat3
`
`Page20 of20
`
`MOB1003
`IPR of U.S. Patent No. 6,970,183
`
`

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