throbber
EXHIBIT 2027
`
`EXHIBIT 2027
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
`
`BROADCOM CORPORATION
`Petitioner
`
`v.
`
`WI-FI ONE, LLC
`Patent Owner
`____________________
`
`Case IPR2013-00636
`Patent 6,424,625
`
`____________________
`
`REPLY DECLARATION BY ROBERT AKL, D.Sc.,
`IN SUPPORT OF PATENT OWNER’S MOTION TO AMEND
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`REPLY DECLARATION BY ROBERT AKL, D.Sc.,
`IN SUPPORT OF PATENT OWNER’S MOTION TO AMEND
`
`I, Robert Akl, D.Sc., hereby declare, affirm, and state the following:
`
`INTRODUCTION
`
`1.
`
`The facts set forth below are known to me personally and I have
`
`firsthand knowledge of them. I am a U.S. citizen over eighteen years of age. I am
`
`fully competent to testify as to the matters addressed in this Declaration. I
`
`understand that this Declaration is being submitted along with Patent Owner’s
`
`Reply to Petitioner's Opposition to Motion to Amend US Patent No. No. 6,424,625
`
`(“the ’625 Patent”).
`
`QUALIFICATIONS AND COMPENSATION
`
`2.
`
`I have summarized in this section my educational background, work
`
`experience, and other relevant qualifications. A true and accurate copy of my
`
`curriculum vitae is attached hereto as Attachment A.
`
`3.
`
`I earned my Bachelor of Science degrees in Electrical Engineering
`
`and Computer Science summa cum laude with a ranking of first in my
`
`undergraduate class from Washington University in Saint Louis in 1994. In 1996 I
`
`earned my Master of Science degree in Electrical Engineering from Washington
`
`University in Saint Louis. I earned my Doctorate of Science in Electrical
`
`Engineering from Washington University in Saint Louis in 2000, with my
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`dissertation on “Cell Design to Maximize Capacity in Cellular Code Division
`
`Multiple Access (CDMA) Networks.”
`
`4.
`
`After obtaining my Doctorate of Science degree, I worked as a Senior
`
`Systems Engineer at Comspace Corporation from October of 2000 to December of
`
`2001. In this position, I designed, and developed advanced data coding and
`
`modulation systems for improving the reliability and increasing the available data
`
`rates for cellular communications.
`
`5.
`
`In January of 2002, I joined the faculty of the University of New
`
`Orleans in Louisiana as an Assistant Professor in the Department of Electrical
`
`Engineering. While on this faculty, I designed and taught two new courses called
`
`“Computer Systems Design I and II.” I also developed a Computer Engineering
`
`Curriculum with strong hardware-design emphasis, formed a wireless research
`
`group, and advised graduate and undergraduate students.
`
`6.
`
`In September of 2002, I received an appointment as an Assistant
`
`Professor in the Department of Computer Science and Engineering at the
`
`University of North Texas, in Denton, Texas. In May of 2008, I became a tenured
`
`Associate Professor in the Department of Computer Science and Engineering. As a
`
`faculty member, I have taught courses and directed research in wireless
`
`communications, including 2G, 3G, 4G, CDMA/WCDMA, GSM, UMTS, LTE,
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`wireless sensors, Bluetooth, VoIP, multi-cell network optimization, call admission
`
`control, channel coding, ad-hoc networks, and computer architecture.
`
`7.
`
`I have authored and co-authored approximately 65
`
`journal
`
`publications, conference proceedings, technical articles, technical papers, book
`
`chapters, and technical presentations, in a broad array of communications-related
`
`technology, including networking and wireless communication. I have also
`
`developed and taught over 70 courses related to communications and computer
`
`system designs, including a number of courses on wireless communication,
`
`communications systems, computer systems design, and computer architecture.
`
`These courses have included introductory courses on communication systems and
`
`sensor networks, as well as more advanced courses on wireless communications.
`
`A complete list of my publications and the courses I have developed and/or taught
`
`is also contained in my curriculum vitae.
`
`8.
`
`I am being compensated at the rate of $550 per hour for my work in
`
`connection with this matter. My compensation is not dependent in any way on the
`
`contents of this Declaration, the substance of any further opinions or testimony that
`
`I may provide, or the ultimate outcome of this matter.
`
`9.
`
`A complete list of cases in which I have testified at trial, hearing, or
`
`by deposition within the preceding four years is provided in my curriculum vitae,
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`which is attached hereto as Attachment A . In the listed cases, I have represented
`
`both patent owners as well as accused infringers.
`
`OPINIONS
`
`A.
`
`The Proposed Amendment is Supported by the ‘625 Patent
`
`10. Broadcom’s argument that the ’625 patent allegedly does not support
`
`the proposed amendment is premised on the faulty assumption that the receiver and
`
`transmitter windows must be of identical size W, where W=2k-1. (Paper No. 44 at
`
`4.) The ’625 patent has no such requirement. In a Go-Back-N Scheme, the
`
`receiver window includes “just one position” (’625 pat. at 2:61-63), whereas in the
`
`Selective Reject Scheme, the receiver window “can include up to 2k-1 positions,”
`
`(id. at 2:61-62; Akl Tr. (Ex. 1021) at 114:21-115:2). In either scheme, the
`
`transmitter window is “an arbitrary window size W” in the general case, or “[i]n
`
`the special case, the window size is W=2k-1.” (’625 pat. at 5:58-63.) In an
`
`embodiment of the ’625 patent, “the receiver and the transmitter must both use the
`
`same arbitrary value for W.” (Id. at 7:21-22.) But that does not require identical
`
`transmitter and receiver window size. Because the receiver window size in a Go-
`
`Back-N Scheme is “just one position” (id. at 2:61-63), the size of the receiver
`
`window cannot be limited to 2k-1 as Broadcom erroneously suggests (Paper No.
`
`44 at 4.) W refers to the transmitter, not receiver window size.
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`11.
`
`The receiver and the transmitter must use the same arbitrary value for
`
`W so that the receiver knows which packets to properly receive. “If the difference
`
`between N(S) and ESN . . . is less than 2k-1 and RPEB=TRUE at a packet
`
`reception, then the packet will be accepted and forwarded to higher layer as long as
`
`the data carried in the packet is also correct.” (‘625 pat. at 6:31-35.) Furthermore,
`
`in a Selective Reject Scheme, “A packet shall be accepted, apart from the normal
`
`Go-Back-N function, when N(S)-ESN<2k-W, RPEB=TRUE and the data in the
`
`packet are correct.” (Id. at 7:23-25.) These calculations occur so that the receiver
`
`knows whether the received packet was within the transmitter window – if so, the
`
`packet is accepted, otherwise rejected, including a packet whose sequence number
`
`is outside the receiver window. (Akl Tr. (Ex. 1021) at 116:3-118:19; ’625 pat.
`
`at 6:36-43.)
`
`B. Claim 20 is not anticipated by Vornefeld
`
`12. Vornefeld creates, rather than releases, expectations of cells having a
`
`lower sequence number. (Paper No. 36 at 10-11; Ex. 2022 at ¶ 26.) When packets
`
`are accepted outside a receiver window in Vornefeld, the receiver window is
`
`adjusted so that the last sequence number (not the first sequence number) in the
`
`receiver window is sequence number of the just received packet, and continues to
`
`wait for outstanding packets before releasing the received packets to the higher
`
`layer. (Vornefeld Fig. 5.3, 5.6; Paper No. 36 at 11; Ex. 2022 at ¶ 26.) And as
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`Vornefeld receiver in Fig. 5.3 continues to wait for SN2, expectations for all
`
`outstanding packets are not released. (Paper No. 44 at 9.)
`
`13. Broadcom argues that the “releasing expectation” limitation is met
`
`when the receiver receives SN5 with only SN1 outstanding in Fig. 5.3 of
`
`Vornefeld. (Paper No. 44 at 9.) I disagree. The Vornefeld receiver cannot
`
`distinguish between cells discarded and incorrectly received: “However, the
`
`recipient cannot differentiate between I-Frames discarded and
`
`incorrectly
`
`[received] outside of the reception window so that in the worst cases, there may be
`
`a doubling or exchanging of ATM-cells.” (Vornefeld at 42; Akl Tr. (Ex. 1021) at
`
`147:12-18.) The Vornefeld receiver cannot release expectations for outstanding
`
`cells because the upper layers in the receiver may require those outstanding cells.
`
`Vornefeld creates, rather than releases expectations for these cells, because the
`
`receiver cannot differentiate between old and new cells. For these reasons, it is
`
`my opinion that Vornefeld does not anticipate claim 20.
`
`ACKNOWLEDGEMENT
`
`14.
`
`I further 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
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`and that willful false statements or the like may jeopardize the validity of the
`
`patent or any patent issuing thereon.
`
`Signed in Denton, Texas on November __, 2014
`
`By ________________________________
`Dr. Robert Akl, D.Sc.
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`ATTACHMENT “A”
`
`ATTACHMENT “A”
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`Robert Akl, D.Sc.
`
`
`
`Professional Summary
`
`Dr. Akl has over 20 years of industry and academic experience. He is
`currently a Tenured Associate Professor at the University of North Texas
`and a Senior Member of IEEE. He has designed, implemented, and
`optimized both hardware and software aspects of several wireless communication systems for
`CDMA, Wi-Fi, and sensor networks. He has broad expertise in wireless communication,
`Bluetooth, CDMA/WCDMA network optimization, GSM, LTE, VoIP, computer architecture,
`and computer networks. He is a very active researcher and is well published and cited. He has
`given depositions, trial testimony, and has prepared expert reports on claim construction, claim
`invalidity, infringement, and non-infringement. He has handled both ITC and district court
`cases. Dr. Akl was the 2008 recipient of the IEEE Professionalism Award and winner of the
`2010 Tech Titan of the Future Award.
`
`Areas of Expertise
`
`Wireless Communication, 2G, 3G, 4G, CDMA/WCDMA, GSM, UMTS, LTE, Wireless
`Sensors, Bluetooth, VoIP, Multi-cell Network Optimization, Call Admission Control, Channel
`Coding, Ad-hoc Networks, Computer Architecture.
`
`Employment History
`
`
`From:
`To:
`
`
`
`
`
`
`
`From:
`To:
`
`
`
`From:
`To:
`
`
`
`University of North Texas
`5/2008
`Present Denton, TX
`Position: Associate Professor Department of Computer Science and Engineering
`
`Conducting research on cellular networks and wireless sensor networks.
`Teaching wireless communication courses. Advising graduate and
`undergraduate students.
`
`University of North Texas
`9/2002
`Denton, TX
`5/2008
`Position: Assistant Professor Department of Computer Science and Engineering
`
`Conducting research on WCDMA/UMTS wireless networks. Teaching
`wireless communication and computer architecture courses. Advising
`graduate and undergraduate students.
`
`University of New Orleans
`1/2002
`New Orleans, LA
`8/2002
`Position: Assistant Professor Department of Electrical Engineering
`
`Designed and taught two new courses “Computer Systems Design I and
`II”. Developed a Computer Engineering Curriculum with strong
`hardware-design emphasis. Formed a wireless research group. Advised
`
`CV of Robert Akl, D.Sc.
`Printed: 11/03/14
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Page 1
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`
`
`
`
`
`
`From:
`To:
`
`
`
`From:
`To:
`
`
`
`From:
`To:
`
`
`
`graduate and undergraduate students.
`
`10/2000 Comspace Corporation
`12/2001 Coppell, TX
`Position: Senior Systems Engineer
`
`Designed, coded (in Matlab), and simulated Viterbi decoding, Turbo coding,
`trellis coded modulation (TCM), and Reed-Muller codes. Optimized soft
`decision parameters and interleavers for additive white Gaussian and
`Rayleigh faded channels. Extended the control and trunking of push-to-talk
`Logic Trunked Radio (LTR) to include one-to-one and one-to-many voice
`and data messaging.
`
`8/1996 MinMax Corporation
`8/2000
`Saint Louis, MO
`Position: Research Associate
`
`Designed software packages that provide the tools to flexibly allocate
`capacity in a CDMA network and maximize the number of subscribers.
`Validated, simulated (logical and timing), and developed the hardware
`architecture for an ATM switch capable of channel group switching.
`
`8/1994 Washington University
`8/2000
`Saint Louis, MO
`Position: Research and Teaching Assistant
`
`Taught, consulted, and graded Circuit Analysis at the undergraduate
`level and Network Design at the graduate level.
`
`
`Litigation Support and Expert Witness Experience
`
`
`L1. 2014
`Case:
`
`Matter
`Project:
`
`L2. 2014
`Case:
`
`Matter
`Project:
`
`L3. 2014
`Case:
`
`Matter
`Project:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Bragalone Conroy PC
`Securus Technologies, Inc. v. Global Tel*Link Corporation
`IPR2015-00153, IPR2015-00155, IPR2015-00156
`Inter Partes Review, VoIP call monitoring and recording
`Three declarations to support 3 IPR petitions
`
`Andrews Kurth LLP
`Sony Mobile Communications (USA) v. Adaptix Inc.
`IPR2014-01524, IPR2014-01525
`Inter Partes Review, subcarrier selection in LTE
`Two declarations to support 2 IPR petitions
`
`Steptoe & Johnson LLP, Baker & McKenzie LLP
`VTech Communications, Inc. and Uniden America Corporations v.
`Spherix Incorporated
`IPR2014-01432
`Inter Partes Review, IP telephony
`Declaration to support IPR petition
`
`CV of Robert Akl, D.Sc.
`Printed: 11/03/14
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Page 2
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`L4. 2014
`Case:
`
`Matter
`Project:
`
`L5. 2014
`Case:
`
`Matter
`Project:
`
`L6. 2014
`Case:
`
`Matter
`Project:
`
`L7. 2014
`Case:
`
`Matter
`Project:
`
`L8. 2014
`Case:
`
`Matter
`Project:
`
`L9. 2014
`Case:
`
`Matter
`Project:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Steptoe & Johnson LLP, Baker & McKenzie LLP
`Spherix Inc. v. VTech Telecommunications Ltd., et al.
`Spherix Inc. v. Uniden Corp, et al.
`Northern District of Texas, Dallas Division, Case No. 3:13-cv-3494
`and 3:13-cv-3496
`Patent infringement, IP telephony
`Claim construction, declaration, deposition
`
`McKool Smith
`Good Technology Corp. v. MobileIron, Inc.
`Good Technology Corp. v. AirWatch LLC
`Northern District of California, Case No. 5:12-cv-05826-PSG and
`5:12-cv-05827-EJD
`Patent infringement, software management in wireless devices
`Claim construction, 2 declarations
`
`Lee & Hayes
`Broadcom Corp. v. Ericsson, Inc.
`IPR2013-00601, IPR2013-00602, and IPR2013-00636
`Inter Partes Review, ARQ protocols
`Three declarations to support Patent Owner’s Response, two
`declarations to support Patent Owner’s Motion to Amend, deposition,
`two reply declarations, deposition
`
`Sidley Austin LLP
`Adaptix, Inc. v. Huawei Technologies Co., et al.
`Eastern District of Texas, Case No. 6:13-cv-00438, 439, 440 and 441
`Patent infringement, subcarrier selection in LTE
`Non-infringement consulting, source code review
`
`Finnegan Henderson Farabow Garrett & Dunner LLP
`Cell and Network Selection LLC v. Huawei Technologies Co., et al.
`Eastern District of Texas, Case No. 6:13-cv-00404-LED-JDL
`Patent infringement, base station selection in LTE
`Non-infringement consulting
`
`Lott & Fischer
`Zenith Electronics, LLC, et al. v. Craig Electronics, Inc.
`Southern District of Florida, Case No. 9:13-cv-80567-DMM/DLB
`Patent infringement, HDTV transmission and reception
`Opening expert report regarding nonessentiality
`
`
`CV of Robert Akl, D.Sc.
`Printed: 11/03/14
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Page 3
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`L10. 2013
`Case:
`
`Matter
`Project:
`
`L11. 2013
`Case:
`
`Matter
`Project:
`
`L12. 2013
`Case:
`
`Matter
`Project:
`
`L13. 2013
`Case:
`
`Matter
`Project:
`
`L14. 2013
`Case:
`
`Matter
`Project:
`
`L15. 2013
`Case:
`
`Matter
`Project:
`
`L16. 2013
`Case:
`
`Matter
`Project:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`McKool Smith
`Zenith Electronics, LLC, et al. v. Curtis International Ltd.
`Southern District of Florida, Case No. 9:13-cv-80568-DMM/DLB
`Patent infringement, HDTV transmission and reception
`Claim construction, declaration
`
`Gibson Dunn
`Straight Path IP Group v. Sharp Corp. and Sharp Electronics Corp.
`In the Matter of Certain Point-to-Point Network Communication
`Devices and Products Containing Same, ITC Investigation No. 337-
`TA-892
`Patent infringement, point-to-point network communication
`Non-infringement consulting
`
`Kilpatrick Townsend & Stockton LLP
`Monec Holding AG v. Motorola Mobility LLC, et al.
`District of Delaware, Case No. 1:11-cv-798-LPS-SRF
`Patent infringement, displaying books on tablets
`Non-infringement expert report for Motorola, non-infringement expert
`report for HTC, deposition
`
`Gartman Law Group
`Lone Star WiFi LLC v. Legacy Stonebriar Hotel, Ltd; et al.
`Eastern Dist. Of Texas, Tyler, Case No. 6:12-cv-957
`Patent infringement, levels of access in Wi-Fi networks
`Claim validity consulting
`
`White & Case, LLP
`Nokia Corp and Nokia, Inc. v. HTC Corp and HTC America, Inc.
`In the Matter of Certain Portable Electronic Communication Devices,
`Including Mobile Phones and Components Thereof, ITC Investigation
`No. 337-TA-885
`Patent infringement, App download and installation
`Non-infringement consulting
`
`Heim, Payne & Chorush, LLP
`Rembrandt Wireless v. Samsung; and RIM/Blackberry
`Eastern Dist. of Texas, Marshal, Case No. 2:13-cv-213-JRG-RSP
`Patent infringement, Bluetooth
`Expert report regarding validity
`
`Davis Polk & Wardwell LLP
`Comcast v. Sprint; and Nextel Inc.
`Eastern Dist. of Pennsylvania, Case No. 2:12-cv-00859-JD
`Patent infringement, SMS in Cellular Networks
`Infringement consulting
`
`CV of Robert Akl, D.Sc.
`Printed: 11/03/14
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Page 4
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`L17. 2013
`Case:
`
`Matter
`Project:
`
`L18. 2012
`Case:
`
`Matter
`Project:
`
`L19. 2012
`Case:
`
`Matter
`Project:
`
`L20. 2012
`Case:
`
`Matter
`Project:
`
`L21. 2012
`Case:
`
`Matter
`Project:
`
`L22. 2012
`Case:
`
`Matter
`Project:
`
`L23. 2012
`Case:
`
`Matter
`Project:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`McKool Smith
`Samsung Electronics America v. Ericsson Inc.
`In the Matter of Certain Wireless Communications Equipment and
`Articles Therein, ITC Investigation No. 337-TA-866
`Patent infringement, LTE uplink and downlink
`Prior art research, source code review, claim construction, claim
`invalidity expert report, non-infringement expert report, hearing
`testimony
`
`DLA Piper US LLP
`CSR Technology Inc. v. Freescale Semiconductor, Inc.
`USDC-San Francisco, Case No. 3:12-cv-02619-RS
`Patent infringement, radio transceivers
`Claim construction, declaration
`
`Fish & Richardson PC
`GPNE Corp. v. Apple, Inc.; et al.
`USDC-ND California, Case No. 5:12-cv-02885-LHK
`Patent infringement, resource allocation in wireless networks
`Prior art research consulting
`
`Polsinelli Shughart PC
`Single Touch Interactive, Inc. v. Zoove Corporation
`Northern Dist. of California, Case No. 3:12-cv-00831-JSC
`Patent infringement, abbreviated dialing, information delivery
`Claim construction, Markman hearing tutorial, declaration
`
`K & L Gates
`EON Corp. IP Holdings, LLC v. Novatel Wireless, Inc.; et al.
`DC-Tyler, Texas, Case No. 6:11-cv-00015-LED-JDL
`Patent infringement, wireless modem and 3G services
`Non-infringement expert report, deposition
`
`Simpson Thacher & Bartlett LLP
`CSR Technology, Inc. v. Bandspeed, Inc.
`Western Dist. of Texas, Case No. 1:12-cv-297-LY
`Patent infringement, packet identification in 2.4 GHz and 5 GHz
`Source code review, Markman hearing tutorial, infringement expert
`report
`
`Sheppard Mullin Richter & Hampton LLP
`Wi-LAN v. HTC America, Inc.
`Eastern Dist. of Texas, Case No. 6:10-cv-521-LED
`Patent infringement, CDMA, Orthogonal Codes
`Source code review, non-infringement expert report, deposition, trial
`testimony
`
`CV of Robert Akl, D.Sc.
`Printed: 11/03/14
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Page 5
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`L24. 2012
`Case:
`
`Matter
`Project:
`
`L25. 2012
`Case:
`
`Matter
`Project:
`
`L26. 2012
`Case:
`
`Matter
`Project:
`
`L27. 2011
`Case:
`
`Matter
`Project:
`
`L28. 2011
`Case:
`
`Matter
`Project:
`
`L29. 2011
`Case:
`
`Matter
`Project:
`
`L30. 2011
`Case:
`
`Matter
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Dechert LLP
`Hitachi v. TPV and Vizio, Inc.; and Vizio v. Hitachi, LTD.
`Eastern Dist. of Texas, Case No. 2:10-cv-260
`Patent infringement, HD television transmission and reception
`Prior art research, claim invalidity consulting
`
`Fish & Richardson PC
`InterDigital Commc’n, LLC v. Huawei Tech. Co. LTD; LG
`Electronics, Inc.; Nokia, Inc.; and ZTE (USA) Inc.
`Certain Wireless Devices With 3G Capabilities and Components
`Thereof, ITC Investigation No. 337-TA-800
`Patent infringement, channel coding in UMTS, HSDPA
`Non-infringement consulting
`
`Fish & Richardson PC
`InterDigital Commc’n, LLC v. Huawei Tech. Co. LTD; LG
`Electronics, Inc.; Nokia, Inc.; and ZTE (USA) Inc.
`Dist. of Delaware, Case No. 1:11-cv-00654-UNA
`Patent infringement, channel coding in UMTS, HSDPA
`Non-infringement consulting
`
`O’Melveny & Myers LLP
`MobileMedia Ideas, LLC v. Apple, Inc.
`Dist. of Delaware, Case No. 1:10-cv-00258-SLR-MPT
`Patent infringement, voice control, call rejection in mobile phones
`Source code review, prior art research, declaration, claim invalidity
`expert report, non-infringement expert report, deposition, trial
`testimony
`
`Wilmer Cutler Pickering Hale and Dorr
`Apple, Inc. v. Samsung Electronics Co.
`Northern Dist. of California, Case No. 5:11-cv-01846-LHK
`Patent infringement, channel coding in CDMA, E-AGCH, TFCI
`Prior art research, claim construction consulting
`
`Weil, Gotshal & Manges LLP
`Vizio, Inc. v. Renesas Electronics America, Inc.
`ITC Investigation No. 337-TA-789
`Patent infringement, HD television transmission and reception
`Claim invalidity consulting
`
`Shapiro Cohen
`TenXc Wireless Inc. v. Andrew LLC
`TenXc Wireless Inc. v. Mobi Antenna Technologies Ltd.
`Patent infringement, antenna design, sectorized cellular network
`
`CV of Robert Akl, D.Sc.
`Printed: 11/03/14
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Page 6
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`Project:
`
`Claim validity consulting
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`L31. 2010
`Case:
`
`Matter
`Project:
`
`L32. 2010
`Case:
`
`Matter
`Project:
`
`L33. 2008
`Case:
`
`Matter
`Project:
`
`L34. 2008
`Case:
`
`Matter
`Project:
`
`L35. 2006
`Case:
`
`Matter
`Project:
`
`Fish & Richardson PC
`Vizio, Inc., v. LG Electronics, Inc.
`ITC Investigation No. 337-TA-733
`Patent infringement, HD television transmission and reception
`Claim charts, claim construction expert report, deposition
`
`Fish & Richardson PC
`Vizio, Inc., v. LG Electronics, Inc.
`Dist. of Maryland, Case No. 1:09-cv-1481-BEL
`Patent infringement, HD television transmission and reception
`Claim charts, claim construction expert report, deposition
`
`Kaye Scholer LLP
`eBay Inc. v. IDT.
`Western Dist. of Arkansas, Case No. 4:08-cv-4015-HFB
`Patent infringement, long distance communication using Internet
`Prior art research, claim construction consulting
`
`Simpson Thacher & Bartlett LLP
`Commil USA, LLC v. Cisco Systems, Inc.
`Eastern Dist. of Texas, Case No. 2:07-cv-00341-DF-CE
`Patent infringement, two-level wireless protocol
`Prior art research
`
`Woodfill and Pressler
`Charles Russell v. Interinsurance Exchange of the Auto Club
`Harris County, Texas, Case No. 2005-19706
`House fire and insurance claim
`Determining user location using cellular phone records, expert report,
`deposition, trial testimony
`
`Heim, Payne & Chorush, LLP
`Houston, TX
`Analyze patents on wireless technologies.
`
`Collin County Sheriff’s Office
`McKinney, TX
`Analyzed cellular record data and determined user location in a double-
`homicide investigation.
`
`
`Consulting History
`
`
`From:
`To:
`
`
`1/2013
`3/2013
`Duties:
`
`From:
`To:
`
`
`4/2007
`5/2007
`Duties:
`
`
`
`From:
`To:
`
`4/2004
`5/2004
`
`Allegiant Integrated Solutions
`Fort Worth, TX
`
`CV of Robert Akl, D.Sc.
`Printed: 11/03/14
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Page 7
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`Designed and developed an integrated set of tools for fast deployment
`of wireless networks. The tools optimize the placement of Access
`Points and determine their respective channel allocations to minimize
`interference and maximize capacity.
`
`Input/Output Incorporated
`New Orleans, LA
`Designed and implemented an algorithm in MATLAB for optimizing
`the frequency selection process used by sonar for scanning the bottom
`of the ocean.
`
`Teleware Corporation
`Seoul, South Korea
`Designed and developed a software package for analyzing the capacity
`in a CDMA network to maximize the number of subscribers.
`
`
`
`Duties:
`
`
`
`
`
`From:
`To:
`
`
`3/2002
`4/2002
`Duties:
`
`From:
`To:
`
`
`6/1998
`7/1998
`Duties:
`
`
`Education
`
`
`GPA
`Degree
`Year College/University
`2000 Washington University in Saint Louis D.Sc. in Electrical Engineering 4.0 / 4.0
`4.0 / 4.0
`1996 Washington University in Saint Louis M.S. in Electrical Engineering
`4.0 / 4.0
`1994 Washington University in Saint Louis B.S. in Electrical Engineering
`4.0 / 4.0
`1994 Washington University in Saint Louis B.S. in Computer Science
`
`
`Graduated summa cum laude and ranked first in undergraduate class.
`Dissertation: “Cell Design to Maximize Capacity in Cellular Code Division Multiple Access
`(CDMA) Networks.” Advisors: Dr. Manju Hegde and Dr. Paul Min.
`
`
`Funded Proposals
`
`
`R1. “Robotics, Game and App Programming Summer Camps” under Texas Workforce
`Commission: Summer Merit Program. Requested amount is $63,000. Submitted
`12/14/12. Robert Akl (PI), awarded $63,000.
`
`R2. “Bio-Com Project,” funded by Raytheon under Net-Centric Software and Systems
`I/UCRC 2nd year. Requested amount is $30,000. Submitted 5/12/12. Krishna Kavi
`(PI), Robert Akl (co-PI), awarded $30,000.
`
`R3. “Bio-Com Project,” funded by Raytheon under Net-Centric Software and Systems
`I/UCRC. Requested amount is $30,000. Submitted 5/12/11. Krishna Kavi (PI),
`Robert Akl (co-PI), awarded $30,000.
`
`R4. “Game Programming for Xbox 360 Summer Camp” under Texas Higher
`Education Coordinating Board: Engineering Summer Program. Requested amount
`is $20,000. Submitted 3/21/11. Robert Akl (PI), awarded $20,000.
`
`
`
`
`
`
`
`
`
`CV of Robert Akl, D.Sc.
`Printed: 11/03/14
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Page 8
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`R5. “RoboCamps and Game Programming Summer Camps” under Texas Workforce
`Commission: Summer Merit Program. Requested amount is $63,000. Submitted
`2/17/11. Robert Akl (PI), awarded $63,000.
`
`R6. “Game Programming for Xbox 360 Summer Camp” under Texas Higher
`Education Coordinating Board: Engineering Summer Program. Requested amount
`is $13,000. Submitted 2/22/10. Robert Akl (PI), awarded $18,000.
`
`R7. “Robotics and Game Programming Summer Camps” under Texas Workforce
`Commission: Summer Merit Program. Requested amount is $63,000. Submitted
`10/16/09. Robert Akl (PI), awarded $63,000.
`
`R8. “Micro Air Vehicle Design: A Collaborative Undergraduate Project for Electrical
`Engineering, Computer Engineering, and Computer Science Students,” under
`UNT Undergraduate Research Initiative. Submitted 9/25/2009. Robert Akl (co-
`PI), awarded $8,000.
`
`R9. “Summer Merit Program” under Texas Workforce Commission. Requested
`amount is $42,000. Submitted 3/20/09. Robert Akl (PI), awarded $42,000.
`
`R10. “Robocamp at Stewpot” under Dallas Women's Foundation. Requested amount is
`$20,000. Submitted 2/23/09. Robert Akl (PI), awarded $18,600.
`
`R11. “Robocamp Jump Start” under Motorola Foundation Innovation Generation
`Grant. Requested amount is $29,852. Submitted 2/12/09. Robert Akl (PI),
`awarded $30,700.
`
`R12. “Engineering Summer Program” under Texas Higher Education Coordinating
`Board. Requested amount is $7,944. Submitted 2/13/09. Robert Akl (PI), awarded
`$11,111.
`
`R13. “Texas Youth in Technology” under Texas Workforce Commission. Requested
`amount is $152,393. Submitted 11/10/08. Robert Akl (PI), awarded $152,393.
`
`R14. “IUCRC Center Proposal: Net-Centric Software and Systems,” under NSF-07-
`537: Industry/University Cooperative Research Centers. Requested amount is
`$349,482. Submitted 9/26/08. Krishna Kavi (PI), Robert Akl (co-PI), awarded
`$60,000 per year for 5 years.
`
`R15. “Robocamp and Beyond” under Motorola Foundation Innovation Generation
`Grant. Requested amount is $30,000. Submitted 6/20/08. Robert Akl (PI),
`awarded $30,000.
`
`R16. Texas Youth in Technology” under Texas Workforce Commission. Requested
`amount is $30,000. Submitted 2/27/08. Robert Akl (PI), awarded $31,500.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`CV of Robert Akl, D.Sc.
`Printed: 11/03/14
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Page 9
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`R17. “Robocamp Program for Young Women” under RGK foundation. Requested
`amount is $30,000. Submitted 11/5/07. Robert Akl (PI), awarded $15,000.
`
`R18. “Texas Youth in Technology” under Texas Workforce Commission. Requested
`amount is $102,514. Submitted 10/22/07. Robert Akl (PI), awarded $102,514.
`
`R19. “Women Art Technology” under Hispanic and Global Studies Initiatives Fund.
`Requested amount is $14,125. Submitted 9/30/07. Jennifer Way (PI), Robert Akl
`(co-PI), awarded $12,785.
`
`R20. “Robocamp Mobile Unit” under Motorola Foundation Innovation Generation
`Grant. Requested amount is $35,000. Submitted 6/20/07. Robert Akl (PI),
`awarded $30,000.
`
`R21. “ICER: UNT Engineering Challenge Camps” under NSF 0547299. Requested
`amount is $35,000. Submitted 4/27/07. Oscar Garcia (PI), Robert Akl (senior
`personnel), awarded $32,792.
`
`R22. “IUCRC-Planning Proposal: UNT Research Site Proposal to join Embedded
`Systems I/UCRC,” under NSF-01-116: Industry/University Cooperative Research
`Centers. Requested amount is $10,000. Submitted 3/31/07. Krishna Kavi (PI),
`Robert Akl (co-PI), awarded $10,000.
`
`R23. “High-assurance NCCS: Ultra Dependability
`Integration Engineering,”
`Department of Defense. Requested amount is $20,000. Submitted 3/12/07.
`Krishna Kavi (PI), Robert Akl (co-PI), awarded $20,000.
`
`R24. “Recruiting and Retention Strategies for Computer Science at UNT” under Texas
`Technology Workforce Development Grant Program – 2005. Requested amount
`is $163,322. Submitted 3/17/05. Robert Akl (PI), awarded $125,322.
`
`R25. UNT Faculty Research Grant for Fall 2003, Robert Akl (PI), $5,000, awarded
`$4,000.
`
`R26. UNT Junior Faculty Summer Research Fellowship for Summer 2003, Robert Akl
`(PI), $5,000, awarded $5,000.
`
`
`Publications
`
`Journal Publications
`
`
`J1. M. Haidar, H.M. Al-Rizzo, R. Akl, and Z. Elbazzal, “The Effect of an Enhanced
`Channel Assignment Algorithm in an IEEE 802.11 WLAN,” World Scientific and
`Engineering Academy and Society Transactions on Communications, WSEAS,
`Vol. 8, Issue 12, December 2009.
`
`CV of Robert Akl, D.Sc.
`Printed: 11/03/14
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Page 10
`
`Broadcom v. Wi-Fi
`IPR2013-00636
`Ex. 2027
`
`

`
`J2. R. Akl, P. Kadiyala, and M. Haidar, “Non-Uniform Grid-Based Coordinated
`Routing in Wireless Sensor Networks”, Journal of Sensors, article ID 491349,
`volume 2009, 11 pages.
`
`J3. M. Haidar, M. Al-Rizzo, Y. Chan, R. Akl, “User-Based Channel Assignment
`Algorithm in a Load-Balanced IEEE 802.11 WLAN”, International Journal of
`Interdisciplinary Telecommunications & Networking (IJITN), April-June 2009,
`1(2), pp. 66-81.
`
`J4. R. Akl, D. Keathly, and R. Garlick, “Strategies for Retention and Recruitment of
`Women and Minorities in Computer Science and Engineering,” iNEER Special
`Volume: Innovations 2007- World Innovations in Engineering Education and
`Research, 9 pgs., 2007.
`
`
`J5. R. Garlick and R. Akl, “Motivating and Retaining CS2 Students with a
`Competitive Game Programming Project,” iNEER Special Volume: Innovations
`2007- World Innovations in Engineering Education and Research, 9 pgs., 2007.
`
`
`J6. R. Akl and S. Nguyen, “UMTS Capacity and Throughput Maximization for
`Different Spreading Factors,” Journal of Networks, July 2006, vol. 1, issue 3, pp.
`40-49. ISSN: 1796-2056
`
`
`J7. W. Li, K. Kavi, and R. Akl, “A Non-preemptive Scheduling Algorithm for Soft
`Real-time Systems

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

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.

throbber

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.

Become a Member

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

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket