`
`
`
`
`
`
`
`
`
`
`
`
`Exhibit 2016
`Exhibit 201 6
`
`

`

`IPR2014-00199
`U.S. Patent 6,771,970
`
`
`
`By: Thomas Engellenner
`Pepper Hamilton LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02110
`(617) 204-5100 (telephone)
`(617) 204-5150 (facsimile)
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`WAVEMARKET, INC. D/B/A LOCATION LABS
`Petitioner
`
`v.
`
`LOCATIONET SYSTEMS, LTD.
`Patent Owner
`___________________
`
`Case No. IPR2014-00199
`U.S. Patent 6,771,970
`___________________
`
`
`DECLARATION OF DR. NARAYAN MANDAYAM IN SUPPORT OF
`LOCATIONET SYSTEMS, LTD.’S PATENT OWNER RESPONSE
`
`
`
`
`
`#29351438 v1
`
`
`
`

`

`IPR2014-00199
`U.S. Patent 6,771,970
`
`I, Narayan Mandayam, do hereby declare:
`
`1.
`
`I am making this declaration at the request of Locationet Systems, Ltd. in the
`
`matter of Inter Partes Review of U.S. Patent No. 6,771,970 (the ‘970 patent”)
`
`to Dan Meir.
`
`2.
`
`In the preparation of this declaration, I have studied (1) the ‘970 patent (Ex.
`
`1001), (2) file history of the ‘970 patent (Ex. 1012), (3) U.S. Patent No.
`
`6,243,039 (“Elliot”; Ex. 1003), (4) Provisional Patent Application No.
`
`60/157,643 (Ex. 1002), (5) Petition for Inter Partes Review (Paper 6), (6)
`
`Declaration of Scott Hotes (Ex. 1013); and (7) Institution Decision (Paper 18).
`
`3.
`
`In forming the opinions expressed below, I have considered:
`
`a. The documents listed above;
`
`b. The relevant legal standards, including the standard for anticipation and
`
`any additional authorities as cited in the body of this declaration; and
`
`c. My knowledge and experience based upon my work in this area as
`
`described below.
`
`Qualifications and Professional Experience
`
`4.
`
`I received a bachelor degree (with Honors) in 1989 from the Indian Institute of
`
`Technology, Kharagpur, and M.S. and Ph.D. degrees in 1991 and 1994 from
`
`Rice University, Houston, TX, all in electrical engineering.
`
`
`
`1
`
`

`

`
`
`5.
`
`I was a Research Associate at the Wireless Information Network Laboratory
`
`(“WINLAB”), Department of Electrical & Computer Engineering, Rutgers
`
`University, between 1994 and 1996. In September 1996, I joined the faculty of
`
`Department of Electrical & Computer Engineering at Rutgers where I became
`
`Associate Professor in 2001, Professor in 2003, and Distinguished Professor in
`
`2014. I also served as the Peter D. Cherasia Endowed Faculty Scholar at
`
`Rutgers University from 2010 to 2014. Currently, I also serve as Associate
`
`Director at WINLAB where I conduct research in various aspects of wireless
`
`systems and networks. I teach courses at Rutgers related to Wireless System
`
`Design, Wireless Communication Technologies, Wireless Revolution, and
`
`Detection and Estimation Theory. I was a visiting faculty fellow in the
`
`Department of Electrical Engineering, Princeton University in Fall 2002 and a
`
`visiting faculty at the Indian Institute of Science in Spring 2003.
`
`6. My research focuses on wireless networks and communications, and I have
`
`worked on various aspects of location tracking for wireless devices. Over the
`
`last 25 years, I have published a wide range of articles on various aspects of
`
`wireless systems including techniques for data transmission, resource allocation
`
`strategies, mathematical modeling and performance analysis. Using constructs
`
`from game theory, communications and networking, my work has focused on
`
`#29351438 v1
`
`-2-
`
`

`

`
`
`system modeling and performance, signal processing as well as radio resource
`
`management for enabling wireless technologies to support various applications.
`
`7.
`
`I have also coauthored papers on location tracking systems, including one of the
`
`early and well-cited papers titled “Decision Theoretic Framework for NLOS
`
`Identification” published in the IEEE Vehicular Technology Conference
`
`(“VTC”) in 1998. This paper addresses the problem of identifying whether a
`
`received radio signal at a base station is due to a line-of-sight (“LOS”)
`
`transmission or not (“NLOS”). Such identification is a first step towards
`
`estimating the mobile station’s location and the work in this paper laid the
`
`foundation for a decision theoretic framework where hypotheses tests of the
`
`range measurements are used for NLOS determination.
`
`8.
`
`I have also worked on sensor assisted localization of mobile devices with a
`
`view to satisfying the E-911 requirements stipulated by the U.S. Federal
`
`Communications Commission. Specifically, as published in my paper titled
`
`“Sensor-Assisted Localization in Cellular Systems” published in the IEEE
`
`Transactions on Wireless Communications in 2007, I developed received signal
`
`strength based localization algorithms that use inter-sensor aided measurements
`
`to estimate the location of the mobile while meeting the E-911 requirements in
`
`a wide range of radio transmission environments. Aside from researching
`
`mobile location tracking algorithms in cellular networks, I also have
`
`#29351438 v1
`
`-3-
`
`

`

`
`
`considerable experience in the area of tracking of mobile devices using WiFi-
`
`based infrastructure. Specifically, I have served as a technical consultant to the
`
`company AirTight Networks Inc., a world leader in enterprise network security
`
`that offers the next generation of intelligent edge, secure, and flexible WLAN
`
`solutions.
`
`9.
`
`I have received various awards relating to my research on wireless networks
`
`and communications, including the 2014 IEEE Donald G. Fink Award for my
`
`paper titled “Frontiers of Wireless and Mobile Communications,” the Fred W.
`
`Ellersick Prize from the IEEE Communications Society in 2009 for my work on
`
`dynamic spectrum access models and spectrum policy, the Peter D. Cherasia
`
`Faculty Scholar Award from Rutgers University in 2010, the National Science
`
`Foundation Career Award in 1998, and the Institute Silver Medal from the
`
`Indian Institute of Technology, Kharagpur in 1989.
`
`10.
`
`I am a coauthor of the books “Principles of Cognitive Radio,” Cambridge
`
`(2012) and “Wireless Networks: Multiuser Detection in Cross-Layer Design,”
`
`Springer (2005). I have published over 200 research articles in internationals
`
`journals, conferences and workshops. I have also given numerous invited
`
`presentations at a variety of industry, government and academic forums.
`
`11.
`
`I have served as an Editor for the journals IEEE Communication Letters (1999-
`
`2002) and IEEE Transactions on Wireless Communications (2002-2004). I
`
`#29351438 v1
`
`-4-
`
`

`

`
`
`have also served as a guest editor of the IEEE JSAC Special Issues on
`
`Adaptive, Spectrum Agile and Cognitive Radio Networks (2007) and Game
`
`Theory in Communication Systems (2008). I was elected Fellow of the IEEE
`
`for “contributions to wireless data transmission.” I am currently serving as a
`
`Distinguished Lecturer of the IEEE Communications Society. My curriculum
`
`vitae is attached to this declaration.
`
`12.
`
`In the field of the invention claimed in the ‘970 patent, a person of ordinary
`
`skill in the art has a bachelor of science degree in computer science, electrical
`
`engineering or a comparable degree and at least two years of experience and
`
`knowledge in wide area digital communications systems such as cellular,
`
`including system level issues related to active mobile location tracking.
`
`13.
`
`I am familiar with the knowledge and capabilities of one of ordinary skill in the
`
`field of the ‘970 patent in 1999, the time of the filing of the provisional patent
`
`application leading to the ’970 patent, based on my experience (1) in the
`
`industry, (2) with undergraduate and post-graduate students, (3) with colleagues
`
`from academia, and (4) with my role as faculty of Department of Electrical &
`
`Computer Engineering at Rutgers. Unless otherwise stated, my statements
`
`made herein refer to the knowledge of one of ordinary skill in the field of the
`
`invention claimed in the ‘970 patent.
`
`Relevant Legal Standard
`
`#29351438 v1
`
`-5-
`
`

`

`
`
`14.
`
`I have been asked to compare the disclosure of Elliot to claim 18 of the ‘970
`
`patent, and to determine whether or not Elliot discloses the limitations of the
`
`claim 18 to a person of ordinary skill in the art. It is my understanding that to
`
`anticipate a claim under 35 U.S.C. § 102, a reference must disclose each and
`
`every element of the claim.
`
`Claim Construction
`
`15.
`
`It is my understanding that in the inter partes review proceedings, the claim
`
`terms of a patent are given their broadest reasonable interpretation consistent
`
`with the specification and file history of the ‘970 patent, as understood by one
`
`of ordinary skill in the art. Consistent with that understanding, it is my opinion
`
`that no explicit constructions for claim terms or phrases are necessary beyond
`
`their ordinary and customary meanings.
`
`The ‘970 Patent
`
`16. The ‘970 patent is directed to a system and method for location tracking of
`
`mobile platforms. Ex. 1001, Abstract; col. 2, ll. 2-28; col. 3, ll. 4-24. The
`
`system architecture of the location tracking system described in the ‘970 patent
`
`requires a number of system elements associated with one another to achieve
`
`the specific operation and functionality disclosed therein. FIG. 1 illustrates an
`
`exemplary schematic diagram of a system for tracking the locations of mobile
`
`platforms described by the ‘970 patent:
`
`#29351438 v1
`
`-6-
`
`

`

`
`
`
`
`More specifically, FIG. 1 is a diagram that shows location tracking systems 11,
`
`12, 13 and 14 for tracking the locations of various mobile platforms, such as a
`
`mobile telephone 21, a car 22, a laptop computer 23, and a briefcase 24. Id. at
`
`col. 3, l. 44-col. 4, l. 5. The location tracking systems 11-14 communicate with
`
`a communication subsystem 3 of a location determination system 1. Id. at col.
`
`4, ll. 6-11. The location determination system 1 is linked to a map server 4
`
`operating a map engine for accessing a map database 5. Id. at col. 4, ll. 15-17;
`
`FIG. 3.
`
`17. A subscriber to the location determination system 1 equipped with a computer
`
`60 running an Internet browser can request the location of a specific mobile
`
`platform by selecting the mobile platform on the website 50. Id. at col. 4, ll. 29-
`
`39. The request is passed from the website 50 to the location determination
`
`#29351438 v1
`
`-7-
`
`

`

`
`
`system 1, which accesses a database 2 to determine the appropriate location
`
`tracking system 11-14 for locating the subscriber-selected mobile platform. Id.
`
`at col. 4, ll. 39-42. The communication subsystem 3 then formats the request
`
`and transmits it to the respective location tracking system 11-14 via the Internet
`
`30. Id. at col. 4, ll. 46-48.
`
`18. The respective location tracking system 11-14 receives the request, determines
`
`the location of the subscriber-selected mobile platform, and transmits the
`
`location information back to the communication subsystem 3. Id. at col. 4, ll.
`
`48-52. The communication subsystem 3 associates the location information
`
`with the request and passes it to the location determination system 1. Id. at col.
`
`4, ll. 52-55. The location determination system 1 then passes the location of the
`
`subscriber-selected mobile platform to the map server 4. Id. at col. 4, ll. 55-56.
`
`19. The map server 4 incorporates data related to the determined location on the
`
`output map. Id. at col. 5:13-18. The map server 4 obtains a map of the area in
`
`which the subscriber-selected mobile platform is located from the map database
`
`using the map engine, marks the position of the mobile platform on the map and
`
`passes it to the location determination system 1. Id. at col. 4, ll. 56-59; see also
`
`col. 2, ll. 28-35. The map, including subscriber selected or all related map and
`
`location data, showing the location of the mobile platform is then passed to the
`
`subscriber’s computer 60. Id. at col. 4, ll. 60-61, col. 5, ll. 45-50.
`
`#29351438 v1
`
`-8-
`
`

`

`
`
`20. Claim 18 requires, among other things, that “each one of said mobile platform
`
`location systems being associated with a map database and map engine for
`
`manipulating said map database.” (emphasis added.) Claim 18 reads:
`
`18. A system for location tracking of mobile platforms,
`each of which is equipped each with a tracking unit, each
`being adapted to determine the location of a respective
`mobile platform according to a property that is
`predetermined for each mobile platform; the system
`comprising:
`
`(a) a location server communicating through a user interface
`with at least one subscriber equipped with a browser; said
`communication having inputs that include at least the
`subscriber identity, the mobile platform identity and map
`information;
`
`(b) at least one mobile platform location system coupled to
`said location server for receiving the mobile platform
`identity and map information that pertain to mobile
`platforms associated with the respective mobile platform
`location system; each one of said mobile platform location
`systems being associated with a map database and map
`engine for manipulating said map database;
`
`(c) at least one remote tracking service communicating with
`said respective mobile platform location system for
`receiving mobile platform identity and returning mobile
`platform location information;
`
`the at least one mobile platform location system being
`adapted to receive said mobile platform location information
`and access said map database for correlating map to said
`location information, so as to obtain correlated location
`information;
`
`said location server being adapted to receive the correlated
`location information and forward them to said browser.
`
`#29351438 v1
`
`-9-
`
`

`

`
`
`(emphasis added.)
`
`21. As described in the ‘970 patent, the map database 5 stores “maps formatted as
`
`at least one of the following: Raster Map in various scales, vector maps and air
`
`photo.” Id. at col. 2, ll. 46-48; see also id. at col. 4, ll. 20-22; col. 5, ll. 3-5.
`
`The map server 4 operates the map engine for, among other functions,
`
`accessing the map database and obtaining a map from the map database. Id. at
`
`col. 4, ll. 16-17 (“a map server (4) operating a map engine for accessing a map
`
`database”); col. 4, ll. 55-58 (“[t]he location determination system (1) passes the
`
`location of the vehicle (22) to the map server (4) which obtains a map of the
`
`area in which the vehicle (22) is located using the map engine . . .”). In
`
`addition, the map server 4 functions to obtain data from the databases on a
`
`mobile platform location determined by the location determination system 1
`
`and incorporate such data in the output map from the map database via the map
`
`engine. Id. at col. 5, ll. 13-18 (“. . . all data on the location determined by the
`
`location determination system (1) that is available from the databases is
`
`obtained from the location data server (120) by the map server (4) and
`
`incorporated in the output map.”).
`
`22. Moreover, the map server 4 is capable of correlating between maps stored in the
`
`map database 5 and the positioning information received from the respective
`
`location tracking system 11-14. Id. at col. 4, ll. 17-22. The map server 4 may
`
`#29351438 v1
`
`-10-
`
`

`

`
`
`support various types of maps, such as Raster maps in various scales, vector
`
`maps and air photographs. More specifically, the map server 4 can obtain a
`
`map in which the mobile platform is located from the map database, and mark
`
`the position of the mobile platform on the map. Id. at col. 4, ll. 56-59; see also
`
`col. 2, ll. 28-35.
`
`23. Furthermore, each mobile platform location system is associated with a map
`
`database 5 and map engine. See, e.g., Ex. 1001, FIGS. 1 and 3 (showing that
`
`the location determination system 1 is associated with the map database 5); col.
`
`2, ll. 28-31 (“[t]he location determination system may communicate with a
`
`mapping system having at least one map database . . .”).
`
`Elliot
`
`24. Elliot describes a wireless communication system which tracks the current and
`
`historical locations of a device worn or carried by a person, and provides access
`
`to the data referencing these locations. Ex. 1003, col. 2, ll. 29-35.
`
`25. More specifically, to track the locations of a device 12 worn or carried by a
`
`person, the device 12 in Elliot is required to send a data signal to a central
`
`receiver-transmitter 16. Id. at col. 5, ll. 13-31. The data signal transmitted by
`
`the device 12 generally includes the current GPS coordinates, current time,
`
`device identification code of the transmitting device, and an activation
`
`indicator. Id. at col. 5, ll. 32-39. The centralized control system 20 that
`
`#29351438 v1
`
`-11-
`
`

`

`
`
`receives the data signal from the device 12 via a central receiver-transmitter 16
`
`can then determine and track the location of the device 12. Id. at col. 5, ll. 41-
`
`43; col. 2, ll. 55-59. Elliot discloses a web server 34 with its associated files
`
`providing graphical maps showing the current and historical locations of the
`
`device 12. Id. at col. 3, ll. 2-4. An “X” mark for pointing to the location of the
`
`device 12 may be superimposed on the map image. Id. at col. 9, ll. 28-30.
`
`26. Elliot does not anticipate independent claim 18 because Elliot fails to disclose
`
`“each one of said mobile platform location systems being associated with a map
`
`database and map engine for manipulating said map database” as recited in
`
`claim 18. In particular, the disclosure in Elliot is missing key elements of
`
`claim 18, namely: (1) a “map database”; (2) a “map engine” for manipulating
`
`the map database; and (3) each one of the mobile platform location systems
`
`being associated with a corresponding map database and map engine.
`
`Elliot does not disclose the claimed “map database”
`
`27. Petitioner generally points to: (1) “[a] web server with its associated files
`
`provides graphical maps capable of showing the current and historical locations
`
`of the device” (Paper 6 at 31; Paper 18 at 16 (quoting Ex. 1003, col. 3, ll. 2-4))
`
`and (2) “[m]any commercial software programs are available for producing and
`
`manipulating graphics and images including road map graphics images” (Paper
`
`6 at 31-32; Paper 18 at 16 (quoting Ex. 1003, col. 9, ll. 17-27)). In other words,
`
`#29351438 v1
`
`-12-
`
`

`

`
`
`Petitioner argues that a general description of a web server that provides
`
`graphical maps and commercial software programs for producing and
`
`manipulating graphics images somehow disclose the claimed “map database”.
`
`Neither of these general passages from Elliot describe the “map database” of
`
`claim 18.
`
`28. The “web server” that provides graphical maps in Elliot does not and cannot
`
`describe a “map database”. See Paper 6 at 31; Paper 18 at 16 (quoting Ex.
`
`1003, col. 3, ll. 2-4). The terms “map” and “database” are commonly used
`
`terms. For instance, the ordinary and customary meaning of the term map
`
`“database” as understood by a person of ordinary skill in the art as well as a
`
`layperson is a collection of map data that is organized so that it can easily be
`
`accessed, searched, managed, and updated. See Dictionary of Computer Words,
`
`Houghton Mifflin Company (1998), Ex. 2017 at 61 (database: “An organized
`
`collection of information that can be searched, retrieved, changed, and sorted
`
`using a collection of programs known as a database management system.”);
`
`Personal Computer Dictionary, Random House (2nd Ed. 1996), Ex. 2018 at 126
`
`(database: “A collection of information organized in such a way that a computer
`
`program can quickly select desired pieces of data.”). The specification of the
`
`‘970 patent is consistent with this ordinary and customary meaning of map
`
`“database”. See, e.g., Ex. 1001 at col. 4, ll. 15-22 (“correlating between maps
`
`#29351438 v1
`
`-13-
`
`

`

`
`
`stored in the database (5) and positioning information”); col. 5, ll. 45-50 (“street
`
`names derived from map databases”); col. 2, ll. 46-48 (“[t]he map database may
`
`include maps formatted as at least one of the following . . .”). Thus, the “web
`
`server” in Elliot fails to describe any data organization, management, or
`
`functionality required for a database. As such, the description of a “web server”
`
`in Elliot does not describe the claimed “map database” based on the ordinary
`
`and customary meaning of a “database”.
`
`29.
`
`In addition, the “web server” that “provides” graphical maps in Elliot does not
`
`describe where such graphical maps come from—let alone that the graphical
`
`maps come from a “map database,” as required by claim 18. The graphical
`
`maps, for example, could be downloaded by the “web server” from a different
`
`location, e.g., from a web page on the Internet. There is simply no disclosure of
`
`the source of the graphical maps “provided” by the “web server” described in
`
`Elliot. Nor does the “web server” in Elliot disclose that it “provides” anything
`
`other than graphical maps, including map data or information pertaining to the
`
`graphical maps such as street names. Ex. 1001, col. 5, ll. 45-50 (“. . . supply
`
`locations as coordinates, street names derived from map databases or other
`
`location data . . .”) (emphasis added).
`
`30. Petitioner’s reliance on the statement that “[m]any commercial software
`
`programs are available for producing and manipulating graphics and images
`
`#29351438 v1
`
`-14-
`
`

`

`
`
`including road map graphics images” further confirms that the location system
`
`in Elliot does not disclose a “map database.” See Paper 18 at 16. If the road
`
`map graphics images are “produced” using software programs, the map
`
`information necessarily is not contained or stored within a database, as required
`
`by claim 18. See ‘970 patent at col. 4, ll. 15-20 (“The location determination
`
`system (1) is also linked to a map server (4) operating a map engine for
`
`accessing a map database (5). The map server (4) is capable of correlating
`
`between maps stored in the database (5) and positioning information received
`
`from the respective location tracking system (11-14)”) (emphasis added).
`
`Elliot does not disclose the claimed “map engine”
`
`31. Petitioner generally relies on two passages: (1) “[m]any commercial software
`
`programs are available for producing and manipulating graphics and images
`
`including road map graphics images” (Paper 6 at 31-32; Paper 18 at 16 (quoting
`
`Ex. 1003, col. 9, ll. 17-27)) and (2) “[t]he ‘X’ mark for pointing to the current
`
`location of the child (i.e., the device) may be superimposed in the map image.”
`
`(Paper 6 at 32; Paper 18 at 16 (quoting Ex. 1003, col. 9, ll. 28–30)). Thus,
`
`Petitioner contends that a suggestion of commercially available software
`
`programs for producing and manipulating graphics images and a description of
`
`superimposing a mark on a map image somehow disclose the claimed “map
`
`#29351438 v1
`
`-15-
`
`

`

`
`
`engine”. Neither of these general passages from Elliot describe the “map
`
`engine” of claim 18.
`
`32. The term “engine” is a commonly used term in conjunction with databases. For
`
`instance, the ordinary and customary meaning of the term map database
`
`“engine” as understood by a person of ordinary skill in the art and a layperson is
`
`a program or module for accessing, searching, managing, and updating the map
`
`database. See Webster’s New World Dictionary of Computer Terms,
`
`Macmillan, (5th ed. 1994), Ex. 2019 at 208 (engine: “The portion of the
`
`program that determines how the program manages and manipulates data.
`
`Another name for processor.”). Indeed, the specification of the ‘970 patent and
`
`the express language of claim 18 is consistent with this ordinary and customary
`
`meaning of map database “engine”. See Ex. 1001 at col. 4, ll. 16-17 (“a map
`
`server (4) operating a map engine for accessing a map database”); col. 4, ll. 55-
`
`58 (“[t]he location determination system (1) passes the location of the vehicle
`
`(22) to the map server (4) which obtains a map of the area in which the vehicle
`
`(22) is located using the map engine . . .”); claim 18 (“a map engine for
`
`manipulating said map database”).
`
`33. The description in Elliot suggesting commercially available software programs
`
`for producing and manipulating graphics images is inapposite to and does not
`
`disclose the claimed “map engine”. See Paper 18 at 16. There is simply no
`
`#29351438 v1
`
`-16-
`
`

`

`
`
`disclosure of the functions of a map database engine, such as accessing,
`
`searching, managing, and updating the map database. Moreover, as discussed
`
`above, Elliot does not disclose a “map database”; therefore, it necessarily also
`
`does not disclose a “map engine for manipulating said map database,” as
`
`required by claim 18.
`
`34. Likewise, while Elliot describes modifying a map image by superimposing a
`
`mark on the map image, it fails to disclose a map engine that functions to
`
`manipulate the “map database” as claimed. Merely superimposing or
`
`overlaying a “X” mark on a map image does not teach a person of ordinary skill
`
`in the art to use a program or module to access, search, manage, or update a
`
`map database. Thus, none of the descriptions in Elliot relied upon by Petitioner
`
`disclose the claimed “map engine”.
`
`Elliot does not disclose “each one of said mobile platform location systems
`being associated with a map database and map engine”
`
`35. The system architecture of the ‘970 patent requires that each mobile platform
`
`location system be associated with a “map database” and a “map engine”. See
`
`Ex. 1001, FIGS. 1 and 3 (showing that the location determination system 1 is
`
`associated with the map database 5). For example, the “map database” and
`
`“map engine” recited in claim 18 allow a system subscriber to customize a map
`
`by selecting which data to be incorporated on the map or the level of detail
`
`displayed on the map, such as street names, etc. Ex. 1003, col. 5, ll. 13-18 (“As
`
`#29351438 v1
`
`-17-
`
`

`

`
`
`an automatic procedure, or upon request of a subscriber, selected or all data on
`
`the location determined by the location determination system (1) that is
`
`available from the databases is obtained from the location data sever (120) by
`
`the map server (4) and incorporated in the output map.”); id. at col. 5, ll. 45-50
`
`(discussing street names derived from map databases).
`
`36. The ‘970 patent’s specific system architecture, including the associated “map
`
`database” and “map engine,” also enables dynamic functions such as supplying
`
`navigation information, managing movement of resources, such as for route
`
`planning between multiple destinations, billing and/or advertising and
`
`emergency service management. See Ex. 1001, col. 5, ll. 37-42, FIG. 3. Such
`
`dynamic functionality is achieved in the ‘970 patent using the mobile platform
`
`location systems associated with a corresponding “map database” and “map
`
`engine,” as required by claim 18. In contrast, as discussed above, the “web
`
`server 34” in Elliot fails to describe any associated “map database” or “map
`
`engine”. See Paper 18 at 16; Ex. 1003, FIG. 3. Elliot simply teaches
`
`superimposing an “X” mark to depict the location of the tracked device on a
`
`static map image; therefore, Elliot fails to disclose each and every element as
`
`set forth in claim 18.
`
`37.
`
`I declare under penalty of perjury that the foregoing is true and correct to the
`
`best of my knowledge and belief, and further that these statements were made
`
`#29351438 v1
`
`-18-
`
`

`

`
`
`
`
`with the knowledge that willful false statements are punishable by fine or
`
`imprisonment, or both, under Section 1001 of Title 18 of the United States
`
`Code.
`
`
`
`
`
`
`
`By: _______
`
`_________
`
`
`
`Dr. Narayan Mandayam
`
`Dated: August 10, 2014
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`#29351438 v1
`
`-19-
`
`

`

`NARAYAN B. MANDAYAM
`
`HOME
`5 Penny Ct.
`East Brunswick, NJ 08816
`Email: narayan@winlab.rutgers.edu
`WeB: www.winlab.rutgers.edu/˜ narayan
`
`OFFICE
`WINLAB, Rutgers University
`671 Rt. 1 South
`North Brunswick, NJ 08902
`Phone: (848)-932-0947
`
`EDUCATION:
`Ph. D in Electrical Engineering, May 1994
`Rice University, Houston, Texas
`M.S. in Electrical Engineering, May 1991
`Rice University, Houston, Texas
`B. Tech (Hons.) in Electrical Engineering, May 1989
`Indian Institute of Technology, Kharagpur, India
`
`EXPERIENCE:
`Dept. of ECE, Rutgers University, Piscataway, New Jersey
`Distinguished Professor, July 2014 - present
`Peter D. Cherasia Endowed Faculty Scholar, June 2010 - June 2014
`Professor, July 2003 - June 2014
`Associate Professor, July 2001 - June 2003
`Assistant Professor, July 1996 - June 2001
`
`WINLAB, Dept. of ECE, Rutgers University, Piscataway, New Jersey
`Interim Director, January 2001 - July 2001
`Associate Director, December 1999 - present
`Research Associate, Sep. 1994 - June 1996
`
`Princeton University, Princeton, New Jersey
`Faculty Fellow in Dept. of EE, Sep. 2002 - Dec. 2002
`
`Indian Institute of Science, Bangalore, India
`Visiting Faculty in Dept. of ECE, Jan. 2003 - Jun. 2003
`
`AWARDS AND HONORS:
`• Donald G. Fink Award from the IEEE (2014)
`• National Academies Keck Futures Initiative (NAKFI) Grant Award, May, 2013
`• Invitee to National Academies Keck Futures Initiative (NAKFI) Informed Brain in a Digital
`World, 2012 (one of 100 invitees in the U.S. selected by the National Academy of Engineer-
`ing (NAE), National Academy of Sciences (NAS), and Institute of Medicine (IOM))
`• Distinguished Lecturer of the IEEE (2012-15)
`• Peter D. Cherasia Faculty Scholar Award (2010)
`• Technical Program Co-Chair, WiOPT 2011
`• Briefer to JASON (an elite advisory group to the U.S. government) study on Cognitive Radio
`Networks (2010)
`• Fred W. Ellersick Prize from the IEEE Communications Society (2009)
`• Fellow, IEEE for contributions to “wireless data transmission” (2009)
`• Guest Editor, IEEE JSAC - Game Theory in Communications and Networking (2008)
`
`1
`
`

`

`• Guest Editor, IEEE JSAC - Spectrum Agile Cognitive Radio Networks (2007)
`• Editor, IEEE Transactions on Wireless Communications, 2002-2005
`• Outstanding Engineering Faculty Recognition, Rutgers University, 2000
`• Associate Editor, IEEE Communications Letters, December 1999-2003
`• Invitee to Annual Symposium on Frontiers of Engineering, National Academy of Engineering
`(NAE), 1999 (one of hundred engineers in the U.S. selected by the NAE)
`• National Science Foundation (NSF) CAREER Award, 1998
`• Outstanding Branch Counselor and Advisor Award Nominee, IEEE, 1998-99
`• William Marsh Rice Fellowship, Rice University, 1989-1990
`• Institute Silver Medal, Indian Institute of Technology (I.I.T.), Kharagpur, 1989 (Awarded to the
`graduating student with the highest G.P.A. in Electrical Engineering)
`• National Talent Search Scholarship (1983-1989). Awarded by the National Council of Educa-
`tional Research and Training, New Delhi, India
`
`CURRENT RESEARCH INTERESTS:
`• Prospect Theory in the Design of Wireless Networks
`• Cognitive Radios for Open Access to Spectrum
`• Radio Resource Management for Wireless Networks using Microeconomic Theories
`• Cooperation and Coexistence in Shared Spectrum
`• Network Coding as a Dynamical System
`• Green Techniques for Wireless
`• Physical-layer based methods for Wireless Security
`• Modeling of Social Knowledge Creation
`
`GRANTS:
`
`1. “ From Informed Human Brains to Society-Scale Silicon Brains: Uncovering the DNA of So-
`cial Knowledge” NAKFI Grant Award ($ 50,000), May 2013, PI: Oded Nov, co-PI: Narayan
`Mandayam, Ofer Arazy
`2. “NeTS: Visual MIMO Networks” National Science Foundation (NSF) Grant No. CNS-1065463
`($ 685,000), April 2011; - PI: Marco Gruteser, co-PI: Narayan Mandayam, Kristin Dana
`3. “Bandwidth Exchange: A Framework for Enhancing the Performance of Cognitive Radio
`Networks” Office of Naval Research (ONR) ($ 300,000), Awarded to start in February 2011;
`- PI: Narayan Mandayam
`4. “DEDI: A New Framework for the Practice of Wireless Network Coding” National Science
`Foundation (NSF) CIF Grant ($ 427,000 ), September 2010; - PI: Narayan Mandayam
`5. “MIAMI: Mobile Infrastructures for Advancing Military Information Technologies” US Army-
`TACOM-ARDEC ($ 659,401), September 2009; - PI: Wade Trappe, co-PI: Narayan Man-
`dayam, D. Raychaudhuri, I. Seskar
`6. “RF Equipment Upgrades to Enable Scalable Crosslayer Protocol Experimentation on the
`ORBIT Radio Grid Testbed” Army Research Office ($ 65,000), September 2008; - PI: Wade
`Trappe, co-PI: Narayan Mandayam
`7. “NeTS-WN: A Joule for your Byte: Barter-Exchange Incentive Mechani