Paper No. ________
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`MICRO MOTION, INC.
`Petitioner
`v.
`
`INVENSYS SYSTEMS, INC.
`Patent Owner
`
`Patent No. 6,311,136
`Issue Date: March 17, 2009
`Title: DIGITAL FLOWMETER
`_______________
`
`Inter Partes Review No. 2014-00170
`____________________________________________________________
`
`SUPPLEMENTAL DECLARATION OF DR. MICHAEL D. SIDMAN
`
`4841-5277-9296.1
`
`Micro Motion, Inc. 1068
`Mirco Motion, Inv. v. Invensys Systems, Inc.
`IPR2014-00393
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`MICRO MOTION, INC.
`Petitioner
`v.
`
`INVENSYS SYSTEMS, INC.
`Patent Owner
`
`Patent No. 6,311,136
`Issue Date: March 17, 2009
`Title: DIGITAL FLOWMETER
`_______________
`
`Inter Partes Review No. 2014-00170
`____________________________________________________________
`
`SUPPLEMENTAL DECLARATION OF DR. MICHAEL D. SIDMAN
`
`4841-5277-9296.1
`
`Micro Motion, Inc. 1068
`Mirco Motion, Inv. v. Invensys Systems, Inc.
`IPR2014-00393
`
`
`
`1.
`
`I, Dr. Michael D. Sidman, resident at 6120 Wilson Road Colorado
`
`Springs, CO, hereby declare as follows:
`
`2.
`
`Independent claim 36 concludes with “wherein the control and
`
`measurement system uses digital processing to adjust a phase of the drive signal to
`
`compensate for a time delay associated with the sensor and components connected
`
`between the sensor and the driver.” I previously opined that that Romano discloses
`
`this feature and therefore anticipates claim 36 of the ’136 patent.
`
`3.
`
`Romano discloses phase compensation for time delay due to the
`
`system components:
`
`Input circuit 310 samples both the left and right velocity sensor
`signals appearing over leads 165L and 165R, respectively, on an
`interleaved basis to produce “128” samples per tube cycle: “64”
`samples for right velocity sensor 160R interleaved between “64”
`samples for the left velocity sensor 160L, respectively (see FIG. 1).
`Specifically, both velocity signals cannot be sampled at the same
`time. Consequently, the two velocity sensor signals are
`continuously sampled on an alternating basis. As a result, the
`samples for one sensor, illustratively the left sensor, will always
`lead the corresponding samples for the right sensor by a phase shift
`of 2P/128 [sic 2π/128] radians. In calculating the fourier
`components, microprocessor 330, as shown in FIG. 2 and
`discussed in detail below, utilizes a “128” point look-up table of
`sine values. Now, to compensate for this phase shift between the
`sampled velocity signals, each of the “64” samples for every tube
`2
`
`4841-5277-9296.1
`
`
`
`cycle produced by the left velocity sensor is multiplied by a
`corresponding sine term, while, as discussed below, each of the
`“64” samples produced by the right channel is multiplied by a
`corresponding sine term that includes a phase shift of 2P/128 [sic
`2π/128] radians.
`(Romano, Ex. 1006, 22:10-32, emphasis added.)
`
`4.
`
`As I explained in my first declaration, it is my opinion that one of skill
`
`in the art would consider Romano to disclose the use of both the left and the right
`
`sensor signals to generate the drive signal using the alternative digital drive
`
`disclosed in column 24 of Romano. In the analog embodiment (Fig. 4), the right
`
`and left channel sensor signals are both used to generate the drive signal. One of
`
`skill in the art would interpret the digital drive embodiment to use the same scheme
`
`and to base the drive signal on both the left and the right sensor. In that case, as I
`
`have previously explained, Romano expressly teaches to correct for the phase shift
`
`of the right sensor signal.
`
`5.
`
`Invensys argues that the DFT routine 700 (Fig. 7) discloses using only
`
`a single channel (either the left or the right). However, this routine is merely used
`
`to determine the resonant frequency - by determining the frequency component
`
`with the maximum magnitude over a predetermined range of frequencies.
`
`(Romano, Ex. 1006 at 31:14-18.) “The only purpose in the magnitude is to
`
`determine the corresponding frequency at which the magnitude reaches a
`
`4841-5277-9296.1
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`3
`
`
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`maximum value.” Nevertheless, the drive signal still must be synchronized to the
`
`oscillation of the tube, as explained by the Romano patent: “[t]he drive circuit …
`
`produces a drive signal that is in phase with the sum of the left and right velocity
`
`sensor waveforms.” (Romano, Ex. 1006 at 18:46-49.) Just as this description of
`
`Figures 2 and 4 teaches to use both the left and the right sensor signal to produce a
`
`drive signal in phase with the left and right sensor signals, so one of skill in the art
`
`it would understand the digital drive embodiment of column 24 also to use the left
`
`and right sensor signals to produce an in-phase drive signal.
`
`6.
`
`In addition, contrary to Invensys’s arguments, Romano discloses the
`
`use of the right sensor signal in the determination of the resonant frequency in the
`
`digital drive embodiment discussed in column 24. As Invensys itself quotes, the
`
`discussion of the use of the left sensor signal throughout Romano is merely
`
`“illustrative”: “To save processing time, a power spectrum is computed at a fairly
`
`‘coarse’ resolution, using the discrete fourier transform, for one of the velocity
`
`waveforms, illustratively that produced by the left velocity sensor.” (Invensys Br.
`
`at 13, quoting Romano, Ex. 1006 at 29:17-21 (emphasis in Invensys brief)). This
`
`same use of the “illustrative” left sensor is found throughout the Romano patent,
`
`for example at col. 6, lines 60-64; col. 7, lines 49-53; col. 35, lines 21-26 and col.
`
`40, lines 26-31.
`
`4841-5277-9296.1
`
`4
`
`
`
`7.
`
`Column 40, lines 26-31 of the Romano patent expressly states that the
`
`right sensor could also be used: “Frequency changes are proportional to the phase
`
`difference between the real and imaginary components of either one of the velocity
`
`sensor waveforms measured with respect to the zero crossing of that waveform.
`
`Illustratively, the left velocity sensor waveform is used for these calculations.”
`
`8.
`
`Accordingly, one of skill in the art would understand that the
`
`disclosure of the use of the left sensor signal in column 24 merely to be illustrative
`
`and that the digital drive could also use the right sensor signal to determine the
`
`resonant frequency. Under those circumstances, as discussed above, and in my
`
`first declaration, Romano teaches that the phase of the right sensor signal would
`
`inherently be delayed by 2π/128 radians. Romano states that, after determining the
`
`frequency, the microprocessor accesses a “sine look up table” to produce the sine
`
`wave: “once the frequency component is found, microprocessor 330 could easily
`
`set the period at which a sine look up table (not shown and which can either be
`
`situated internal to or more likely external to the microprocessor) is successively
`
`and consecutively indexed, through well known circuitry not shown, to produce a
`
`continuous series of multi-bit digital values that represent this waveform.”
`
`(Romano, Ex. 1006 at 24:45-52.) As discussed above and in my first declaration,
`
`Romano had previous taught (in column 22) that, when the sine look up table is
`
`4841-5277-9296.1
`
`5
`
`
`
`used for processing the right sensor signal, a phase shift of 2n/128 radians is
`
`applied.
`
`9.
`
`I hereby declare under penalty of perjury under the laws of the United
`
`States of America that the foregoing is true and correct, and that all statements
`
`made of my own knowledge are true and that all statements made on information
`
`and belief are believed to be true. I understand that willful false statements and the
`
`like are punishable by fine or imprisonment, or both (18 U.S.C. § 1001).
`
`Executed on October 27, 2014
`
`Dr. Michael D. Sidman
`
`4841-5277-9296.1
`
`6
`
`
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