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`EXHIBIT 1005
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`EXHIBIT 1005
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________________________________
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`SONY CORPORATION OF AMERICA; AXIS COMMUNICATIONS AB; AXIS
`COMMUNICATIONS, INC.; and HEWLETT-PACKARD CO.
`Petitioners
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`v.
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`NETWORK-1 SECURITY SOLUTIONS, INC.
`Patent Owner
`____________________________________________
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`INTER PARTES REVIEW OF U.S. PATENT NO. 6,218,930
`Case IPR: Unassigned
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`DECLARATION OF GEOFFREY O. THOMPSON
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`
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`Mail Stop: Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`1
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`I, Geoffrey O. Thompson, hereby declare as follows:
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`I.
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`INTRODUCTION
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`1.
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`I am presently a Member Emeritus of the IEEE 802 LAN/MAN
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`Standards Executive Committee and the Principal at GraCaSI Standards Advisors,
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`which has its principal place of business at 158 Paseo Court, Mountain View, CA
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`94043-5286.
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`2.
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`I have prepared this Declaration on behalf of Sony Corporation of
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`America, Axis Communications AB, Axis Communications, Inc., and Hewlett-
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`Packard Co. in connection with the Petition for Inter Partes Review of U.S. Patent
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`No. 6,218,930 (the “’930 patent”), which is to be filed concurrently with this
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`Declaration.
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`II. BACKGROUND AND QUALIFICATIONS
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`A.
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`3.
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`Educational Background and Employment
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`I was awarded a bachelors degree in electrical engineering from
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`Purdue University in 1964.
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`4.
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`From 1964 to 1965 I worked at the Walbridge Test Center of Ohio
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`Bell Telephone as a Manager. My responsibilities included managing and
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`supervising operation of a local telephone test and repair center for 1/3 of a
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`metropolitan area comprising approximately 300,000 people.
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`2
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`5.
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`I became employed by Xerox Corporation beginning in 1965. My
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`first position at Xerox was Associate Engineer. Between 1965 and 1973 I was
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`promoted to Engineer and to Senior Engineer. In 1973 I became a Senior Member
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`of the Research Staff at Xerox PARC and held that title until 1981, when I became
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`a Consulting Member of the Engineering Staff for Systems Development at Xerox.
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`6.
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`Beginning in 1998 I held various staff positions at SynOptics
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`Communications, Bay Networks, and Nortel Networks. In these positions I was
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`responsible for working with the IEEE 802.3 standards and providing technical
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`analyses relating to the standards. I became a Distinguished Member of the
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`Technical Staff at Nortel Networks in 2008.
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`7.
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`In 2009 I left Nortel Networks to begin work at GraCaSI Standards
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`Advisors as the Principal.
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`B.
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`8.
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`Standards Work
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`I have worked with the IEEE 802.3 standards Working Group since
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`1983. My early work included promoting the Ethernet standard as a U.S. delegate
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`in international standards forums. Beginning in 1983, I also served as a technical
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`contributor and chairperson of various task forces for IEEE 802.3 standards
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`projects, including the Chair of the Maintenance Task Force.
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`9.
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`From 1991 to 1993 I served as Vice Chairman of the IEEE 802.3
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`
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`Working Group and was responsible for procedures, membership, technical
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`maintenance, and working group management assistance, in addition to technical
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`contributions.
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`10. From 1993 to 2002 I was the Chair of the IEEE Working Group
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`responsible for Ethernet standards in Layer 1 and the Media Access Controller
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`portion of Layer 2 (per the ISO 7 layer reference model). In this position, I
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`supervised 14 standards projects covering the development of Ethernet using
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`speeds from 100 Mb/s, 1 Gb/s, and 10 Gb/s, as well as various other projects such
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`as switching/full duplex, auto-negotiation, management, virtual local area
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`networks, Power over Ethernet, and link aggregation.
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`11.
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`In 2002 I became the 1st Vice Chairman of the IEEE 802 LAN/MAN
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`Standards Executive Committee. In this role, I supported the Chair of the
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`Committee and assisted in governance of the Committee. I also advocated IEEE
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`802.3 standards in interactions with IEEE Standards Association staff and higher
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`level governance.
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`12. From 2010 to 2011, I was the Chair of the 802.23 Emergency Services
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`Working Group.
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`4
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`13.
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`I became a Member Emeritus of the IEEE 802 LAN/MAN Standards
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`
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`Executive Committee in 2002. I returned to that position in 2011 and continue to
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`hold this title today. I also remain a voter and active participant in the IEEE 802.3
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`Working Group.
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`C.
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`Patents Awarded
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`14. Through my years of work in the communications and networking
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`industry, I have been awarded at least 12 U.S. patents.
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`15. Several of these patents deal with local area networks, Ethernet
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`implementations, indicating power over Ethernet connections, data switching in
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`network environments and techniques for virtual LAN identification.
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`D. Other Awards
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`16. At Nortel, I received the title of Distinguished Member Technical
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`Staff in 2008. Also at Nortel, I received the Significant Patent Award in September
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`2000.
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`17. Through my work with the IEEE, I received the IEEE-SA Standards
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`Board Distinguished Service Award in 2006. I also received the IEEE Standards
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`Medallion in 1996.
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`E. Qualifications
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`5
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`18. Based on my industry experience and key role in various IEEE 802.3
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`
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`standards projects as described above, including the project that standardized
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`Power over Ethernet as IEEE 802.3af (2003), I consider myself to be an expert in
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`the field of networking systems and equipment.
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`19.
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`I believe that I am qualified to provide an opinion as to what a person
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`having ordinary skill in the art would have understood, known, or concluded
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`during the timeframe of 1998-2000 (hereinafter, a “PHOSITA”). Such a person
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`would have (i) a bachelors degree in electrical or electronics engineering, including
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`studies related to the field of communications or (ii) 3-5 years of comparable work
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`experience.
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`III. MATERIALS CONSIDERED
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`20.
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`In the course of preparing this Declaration, I have reviewed the ’930
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`patent and its file history, as well as the prior art references and related documents
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`discussed below.
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`21.
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`I have also reviewed the Petition for Inter Partes Review of the ’930
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`Patent (“the Petition”) and claim charts that are being submitted concurrently with
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`this Declaration.
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`22.
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`In addition, I have reviewed the Decision on Institution of Inter Partes
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`Review in Case IPR2013-00092 dated May 24, 2013 (“the Sony-Axis IPR
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`6
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`Decision”) (Ex. 1020) and the Decision on Institution of Inter Partes Review in
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`Case IPR2013-00071 dated May 24, 2013 (“the Avaya IPR Decision”) (Ex. 1019).
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`IV. OVERVIEW OF THE ’930 PATENT
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`23. The ’930 patent purports to have a filing date of March 7, 2000, and
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`claims priority to U.S. Provisional Application No. 60/123,688, filed on March 10,
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`1999. Because the prior art references I discuss below predate the asserted March
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`10, 1999 date, I have not assessed whether the ’930 patent is in fact entitled to such
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`a priority date.
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`24. The ’930 patent generally relates to delivering power and data to an
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`access device over a data signaling pair. According to the “Field of the Invention”
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`section of the ’930 patent, “[t]he invention more particularly relates to apparatus
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`and methods for automatically determining if remote equipment is capable of
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`remote power feed and if it is determined that the remote equipment is able to
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`accept power remotely then to provide power in a reliable non-intrusive way.” Ex.
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`1001, ’930 patent, 1:14-19.
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`25. The “Background of the Invention” section of the patent indicates
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`several objectives. One stated objective is “to add remotely powered devices to a
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`data network.” Id. at 1:33-35. Another objective is to “have a centrally powered
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`system that can be protected during a power outage.” Id. at 1:39-40. A further
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`objective is “to provide methods and apparatus for reliably determining if a remote
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`piece of equipment is capable of accepting remote power.” Id. at 1:41-43. A final
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`stated objective is “to provide methods and apparatus for delivering remote power
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`to remote equipment over 10/100 switched Ethernet segments and maintain
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`compliance with IEEE 802.3 standards.” Id. at 1:44-47. Although this objective
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`refers to 10/100 switched Ethernet segments, claims 6, 8, and 9 of the ’930 patent
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`do not require any particular communications protocol. Indeed, the only recitation
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`of “Ethernet” in the claims is found in claim 4, which depends from claim 1.
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`26. The ’930 patent describes a remote access device 10, which “requires
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`power to carry out its operation and includes an internal dc-dc switching supply.”
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`Id. at 2:36-44. The remote access device may be a telephone 62, as shown in
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`Figure 1. Id. at 3:60-66. Cable 12, which can be Category 5 wire, connects the
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`remote access device 10 to a network data node 14. Id. at 2:44-51. While the
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`example of cable 12 given in the specification is Category 5 wire, claims 6, 8, and
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`9 of the ’930 patent require only a “data signaling pair.”
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`27. A power source 16, which “may be the same as the conventional main
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`power supply used to power the node 14,” is connected to cable 12 to supply a
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`“power level sensing potential to the remote access equipment 10 over one of the
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`cable conductors.” Id. at 2:52-57. A remote power detector 22 operates a detection
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`8
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`circuit consisting of a resistor 26 with shunting switch 28 connected in parallel to a
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`resistor 30, which provides a path to ground. Id. at 2:59-65.
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`28. Detection of remote equipment is performed by delivering a “low
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`level current (approx. 20 ma) to the network interface and measuring a voltage
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`drop in the return path.” Id. at 2:66-3:2. According to the ’930 patent, “[t]here are
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`three states which can be determined: no voltage drop, a fixed level voltage drop or
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`a varying level voltage drop.” Id. at 3:2-4. The first two states indicate that the
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`access devices is unable to accept remote power. Id. at 3:4-11. The third state, a
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`varying voltage level, indicates that the access equipment is capable of accepting
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`remote power. Id. at 3:12-27.
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`29.
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`“Once the remote equipment is operating and confirmed as a known
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`remote power enabled device,” the removal of the device or a fault condition may
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`be detected. Id. at 3:49-52. If the voltage level drops, this indicates removal of the
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`remote equipment. Id. at 3:52-55.
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`V.
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`BRIEF BACKGROUND ON REMOTE POWERING OF DEVICES
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`30. The ’930 patent correctly acknowledges that “[a] variety of
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`telecommunications equipment is remotely powered today,” i.e., prior to the
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`alleged invention of the ’930 patent. Id. at 1:22-24. Nevertheless, the patent is
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`incorrect in stating that remote powering techniques had “not migrated to data
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`9
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`communications equipment.” Id. at 1:24-27. Below, I provide some brief
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`background on remote powering of devices, in both telecommunications and data
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`communications environments, which would have been available to a PHOSITA.
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`31. Telecommunications equipment has been remotely powered since the
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`earliest telegraphs. Early dial telephones received power from a central office
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`battery as the means to power the customer premises telephone instrument. An
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`example of such a system is shown in U.S. Patent No. 447,918, to Strowger, dated
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`1891 (Ex. 1023). The Strowger system also used a remote detection technique. In
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`particular, picking up the receiver placed a low impedance resistor across the wire
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`pair which in turn activated a relay in the central office and connected the phone to
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`dial activated call routing equipment.
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`32. When AT&T started using digital transmission equipment for
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`telephone systems in the 1960s, the first system to be deployed was the T-1 Carrier
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`System (Bell Laboratories Record, November, 1962), which was used to increase
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`the capacity of voice trunk circuits between telephone central offices. Such a T-1
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`system used two voice wire pairs and required a repeater approximately every
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`6,000 feet. The repeaters were mounted on telephone poles or placed in manholes
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`and were remotely powered from a central office. The power was provided over
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`the twisted pairs via a phantom circuit.
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`10
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`33. Years later, customer demand for high speed digital service directly
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`from customers’ premises led to T-1 service actually being terminated at a user
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`interface in the customers’ premises, where it continues to this day in many areas.
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`34.
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`In the mid 1980s, there was a major move to migrate analog telephone
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`services to a digitally based service that would include provision for data
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`connectivity and well as digital voice. This was the Integrated Services Digital
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`Network (ISDN), which was ultimately standardized by ITU-T in the I (Eye) series
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`of recommendations. There were several means proposed to power user terminals
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`(e.g., ISDN telephones) via the cable and the eight-pin modular jack commonly
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`known as an RJ-45. ISDN was not a big success, especially in the United States,
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`but the cabling and connectors for it were adapted for local area network (LAN)
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`use in general, and Ethernet (10BASE-T) use in particular. The ISDN specification
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`options for providing power over the data cabling are called out in ITU-T I.430-
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`1988.
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`35. LANs were invented in the 1970s (see, e.g., U.S. Patent No.
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`4,063,220, to Metcalfe, dated 1977) and moved into the product and standards
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`arena in the 1980s. Many LAN implementations had portions of their equipment
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`that were remotely powered over the data cabling. In Ethernet, the transceiver or
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`Media Access Unit (MAU) clamped to the coaxial cable linear bus that was the
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`core medium of the LAN. The transceiver was connected to its computer by up to
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`50 meters of twisted-pair cable. That cable provided power from the computer to
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`the transceiver albeit on a separate pair of the “AUI Cable.” U.S. Patent No.
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`4,733,389, to Puvogel, dated 1988 (Ex. 1024), described how to reduce the number
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`of pairs needed in an AUI cable from four to two by putting both power and the
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`collision signal onto a phantom circuit formed by the transmit and receive pairs.
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`36.
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`In other LAN technology, Token Ring (IBM, IEEE Std., 1985)
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`computers provided a power signal over a phantom circuit on the twisted pairs of
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`the cable called out by the IBM Cabling System. The power was used by the
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`Token Ring Hub to detect that a station was plugged in and powered up. The low
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`power was used to switch a relay which rerouted the wiring of the ring from bypass
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`to pass through the attached station. The same power arrangement was later used
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`in the CDDI standard and in Ethernet over IBM cabling (e.g., in LattisNet STP by
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`SynOptics Communications). The same scheme was also used as a link integrity
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`signal by SynOptics in its broadly deployed precursor to 10BASE-T, marketed as
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`LattisNet UTP.
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`37. Thus remote powering was well known by PHOSITAs in both the
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`telephony and data networking fields by the time LAN speeds were high enough,
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`and silicon integration was advanced enough, to enable Ethernet-based voice over
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`12
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`Internet Protocols (VoIP) telephones, well before the claimed priority date of the
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`’930 patent. The introduction of telephones as Ethernet-based instruments called
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`for power over the signal cord to match customer expectations associated with
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`legacy (POTS) and ISDN telephones.
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`VI. VALIDITY ANALYSIS
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`38.
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`I have been asked to provide opinions addressing whether claims 6, 8,
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`and 9 of the ’930 patent are valid based on the prior art references discussed below.
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`Specifically, those references include: U.S. Patent No. 5,345,592 to Woodmas (Ex.
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`1011) (“Woodmas”); U.S. Patent No. 5,982,456 to Smith et al. (Ex. 1012)
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`(“Smith”); Television Production, by Ron Whittaker (1993) (Ex. 1013) (“Television
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`Production”); U.S. Patent No. 6,473,608 to Lehr et al. (Ex. 1014) (“Lehr”), as well
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`as the provisional application (U.S. Provisional Application No. 60/115,628) to
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`which Lehr claims priority (Ex. 1018) (“Lehr Provisional”); Japanese Unexamined
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`Patent Application No. H10-13576 to Matsuno (Ex. 1015, 1016) (“Matsuno”); and
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`U.S. Patent No. 6,449,348 to Lamb et al. (Ex. 1017) (“Lamb”).
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`39.
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`In my analysis, I have relied on certain claim constructions that were
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`provided in the Sony-Axis IPR Decision (Ex. 1020) and the Avaya IPR Decision
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`(Ex. 1019) issued by the Patent Office. I have formed no independent opinion as
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`13
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`to the correctness of the claim constructions. In particular, I have relied on the
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`following claim constructions in my analysis:
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`a.
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`“low level current”: a current (e.g., approximately 20 mA) that
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`is sufficiently low that, by itself, it will not operate the access device.
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`b.
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`“data node adapted for data switching”: a data switch or hub
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`configured to communicate data using temporary rather than permanent
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`connections with other devices or to route data between devices.
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`c.
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`d.
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`“data signaling pair”: a pair of wires used to transmit data.
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`“main power source” and “secondary power source”: not
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`necessarily physically separate devices.
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`40.
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`In my opinion, each and every element of claims 6, 8, and 9 of the
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`’930 patent is disclosed in the prior art references discussed below. Specifically,
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`the prior art discloses the subject matter of claims 6, 8, and 9 as arranged in those
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`claims. The prior art references also explain and present the subject matter of
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`claims 6, 8, and 9 so as to enable a PHOSITA to make and use the claimed
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`methods.
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`A. Woodmas in View of Smith and/or Television Production
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`41. Based on my review of Woodmas, Smith, and Television Production, it
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`is my opinion that a PHOSITA would have regarded claims 6, 8, and 9 of the ’930
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`14
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`patent as obvious based on the teachings of Woodmas combined with the teachings
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`of Smith and/or Television Production in view of the ordinary knowledge possessed
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`by a PHOSITA. It is also my opinion that the teachings of Woodmas in view of
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`Smith and/or Television Production would have been sufficient to enable a
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`PHOSITA to make and use the methods of claims 6, 8, and 9.
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`42.
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` I have reviewed the Petition and accompanying claim chart which
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`explain in detail how Woodmas as combined with Smith and/or Television
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`Production teaches each and every element of claims 6, 8, and 9 as arranged in
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`those claims. In my opinion, the Petition and claim chart demonstrate that these
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`references disclose every element of claims 6, 8, and 9 as arranged in those claims
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`and render those claims obvious.
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`43. Woodmas is directed to remotely powering equipment over a two-
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`conductor cable, such as a coaxial cable. Ex. 1011, Woodmas, Abstract. According
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`to Woodmas, a control station module includes a power delivery unit for delivering
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`power to the conductors, and a remote station module includes a power reception
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`unit for receiving power from the conductors. Id. at 2:3-17. The camera station
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`module 28 described in Woodmas is coupled with components 18-24, which
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`include a DC-powered video camera 18, talent earpiece 20, camera operator
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`intercom headset 22, and talent microphone. Id. at 2:50-53; 2:56-61. Camera
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`15
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`station module 28, camera station 16, and components 18-24, when considered
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`alone or in combination, disclose an “access device adapted for data transmission”
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`as recited in claim 6 of the ’930 patent, because each is able to send and receive
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`data (e.g., audio-video data or control signals) and receive power by means of a
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`data signaling pair, cable 30, as further discussed below.
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`44. Woodmas discloses a two-conductor cable, which may be a coaxial
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`cable, that is used to connect control station 26 to camera station module 28. Id. at
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`5:3-10. As Woodmas explains, cable 30 is capable of handling both bi-directional
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`signaling and power delivery. Id.; see also id. at 2:54-61; 5:3-6. Both the coaxial
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`embodiment described in Woodmas and the “two wire pair” embodiment involve a
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`pair of conductors. Id. at 9:47-49. Accordingly, cable 30 in Woodmas satisfies the
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`construction of “data signaling pair,” because it comprises a pair of wires used to
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`transmit data.
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`45. Various types of power sources are disclosed in Woodmas. For
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`example, Woodmas teaches a power supply 38, which draws power from a
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`conventional 120 volt AC power source, which would be a wall outlet or generator.
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`Id. at 3:26-33. This conventional AC power source is illustrated in Figure 2.
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`Woodmas also discloses a power delivery unit 34, which includes the power supply
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`38. Id. at 3:17-25. A PHOSITA would understand that the power that operates
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`16
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`control station 14, control station module 26, and power delivery unit 34 is a
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`conventional AC power source. Power from this source is in turn used by power
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`delivery unit 34 and power supply 38 to supply a current to cable 30, which is
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`transmitted to camera station module 28. Id. at 3:12-17. Camera station module
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`28 is able to separate the power and deliver it to the components at camera station
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`16 that require power, such as camera 18, earpiece 20, intercom headset 22, and
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`microphone 24. Id.; see also id. at 2:50-53; 5:32-35. Therefore, the conventional
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`AC power source described in Woodmas, as well as the power delivery unit 34 or
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`DC power supply 38, disclose the “main power source” and “secondary power
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`source” recited in claim 6 of the ’930 patent. This is also consistent with the claim
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`constructions provided for “main power source” and “secondary power source” in
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`the Sony-Axis IPR Decision and the Avaya IPR Decision, which do not require the
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`two power sources to be physically separate.
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`46. According to Woodmas, before full power is provided to connected
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`devices, a low level voltage, with a current limited to 15 mA, is delivered. Id. at
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`6:45-47; 7:24-26. Woodmas explains that this 15 mA current is applied “when
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`power delivery unit 34 is initially energized.” Id. at 3:50-52. This current of 15
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`mA discloses the limitation of a “low level current” recited in claim 6. In fact, this
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`current level is lower than the example of 20 mA given in the ’930 patent. See Ex.
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`17
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`1001, ’930 patent, 2:66-3:2. This current level in Woodmas is also consistent with
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`the claim constructions given in the Sony-Axis Decision and the Avaya Decision,
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`which require the current to be sufficiently low that, by itself, it will not operate the
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`access device. Woodmas teaches exactly this concept, because it explains that the
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`15 mA current is applied to cable 30 “before full operating power is imposed.” Ex.
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`1011, Woodmas, 7:24-26 (emphasis added).
`
`47. Upon receiving voltage from power delivery unit 34, a voltage
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`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,
`
`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
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`signal is thus “representative of the low level voltage” delivered from delivery unit
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`34. Ex. 1011, Woodmas, 7:44-50. Woodmas then “asks whether the power status
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`signal is present as detected” and provides the power status signal to
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`
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`18
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`
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`microcontroller 54 if detected. Id. at 7:39-52. By delivering this low level current
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
`
`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.
`
`48. 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
`
`34; instead, an “alarm subroutine” is initiated. Id. at 7:34-35; Fig. 4A. Second,
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`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
`
`
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`19
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`
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`signal will change, causing the power delivery unit 34 to supply more or less
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`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
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`compensate for cable voltage drop.”). Each of these techniques for controlling
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`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.
`
`49. According to Woodmas, the low level current of 15 mA is supplied
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`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.
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`When the corresponding power status signal is received, Woodmas teaches
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`displaying the message “camera unit present.” Id. at 7:53-54; Fig. 4A. By
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`providing a low level current of 15 mA and confirming the presence and
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`functionality of the camera unit in this manner before supplying full operational
`
`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.
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`20
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`50. As discussed above, Woodmas also teaches supplying power from
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`
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`power delivery unit 34 to camera station module 28 and its power reception unit 76
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`based on the power status signal received at power delivery unit 34. Woodmas
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`teaches that, during operation, the power draw at camera station may vary, which
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`in turn may affect the power status signal. Id. at 6:26-31. Power delivery unit 34
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`is designed to “compensate” in such a situation by delivering more or less power
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`based on the fluctuations in power draw at the camera station. Id. In addition, as
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`discussed above, Woodmas teaches detecting short circuits, which may result from
`
`disconnected equipment, when the sensed voltage level drops below 10 volts. Id.
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`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
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`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
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`patent.
`
`51.
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`In my opinion, it would have been obvious to a PHOSITA to combine
`
`the capability of supplying remote power via a phantom circuit and power
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`control/qualification via a low level current, as described in Woodmas, with the
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`
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`21
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`
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`“digital video production switcher 10” disclosed by Smith and/or the “production
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
`
`switcher” disclosed by Television Production, as discussed below.
`
`52. Woodmas, Smith, and Television Production each expressly teach
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`“production switchers.” According to Woodmas, control station 14 includes
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`“conventional television production equipment well known to those skilled in the
`
`art such as the production switcher. . . .” Id. at 2:44-50. Woodmas teaches that
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`such a conventional “production switcher” is used in conjunction with other
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`production equipment, including “video and audio transmitters, camera monitors,
`
`preview monitors, program monitors, director’s intercom, control signal
`
`generators, and control signal receivers.” Id. Similarly, Smith teaches a “digital
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`video production switcher” used in a “production environment.” Ex. 1012, Smith,
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`Abstract. Also, similar to the “preview monitors” in Woodmas, Smith teaches a
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`“monitor 20,” which is used to display selected video signals. Id. at 3:55-57.
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`Likewise, Television Production includes an entire chapter (Chapter 9) that focuses
`
`on video control and production switchers. Ex. 1013, Television Production, 232-
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`56. Just like the production switchers in Woodmas and Smith, the production
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`switchers in Television Production are used in a production environment
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`comprising multiple video input sources and multiple preview monitors. Id. at
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`234-35.
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`22
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`U.S. Patent No. 6,218,930
`Petition for Inter Partes Review
`Declaration of Geoffrey O. Thompson
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`53. A PHOSITA would have considered it obvious to combine elements
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`
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`from Smith and/or Television Production with Woodmas because each reference
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`relates to the same field of endeavor (audio-video production and signal switching)
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`and each discloses similar components as discussed above, including well-known
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`production switchers. Combining the production switcher functionality of Smith
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`and/or Television Production with the production switcher and remote phantom
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`powering functionality of Woodmas wou
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