E-Watch, Inc.
`Exhibit 2014
`Petitioner - Iron Dome LLC
`Patent Owner - E-Watch, Inc.
`IPR2014-00439
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`Page 1 of 41
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`Exhibit 2014
`Petitioner - Iron Dome LLC
`Patent Owner - E-Watch, Inc.
`IPR2014-00439
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`Page 1 of 41
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`1, David A. Monroe, pursuant to the provisions of 28 U.S.C. {$1746 and 37 C.F.R. §1.I31,
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`declare:
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`l.
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`2.
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`My name is David A. Monroe.
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`I am over 21 years of age and am competent to make this declaration.
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`I am the named inventor on United States Patent Application No. 09/006,073
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`(“’073 patent application”).
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`The ‘073 patent application was filed on January 12, 1998 and is the patent
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`application to which United States Patent No. 7,365,871 (“’871 patent”),
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`the
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`patent that is the subject of the above-captioned inter partes review proceeding
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`(“these pending IPR proceedings”), claims priority.
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`I originally conceived of the invention claimed in claims 1-15 of the ‘871 patent
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`no later than March 18, 1993.
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`I conceived of the invention claimed in claims 1-15
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`of the ‘871 patent during a timeframe between about 1989 to about 1993 (“the
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`period of conception”) during which I
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`initiated and led several product
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`development projects for apparatuses directed to various aspects of a handheld
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`selfncontained cellular telephone and integrated image processing system for both
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`sending and receiving telephonic audio signals and for capturing a visual image
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`and transmitting it
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`to a compatible remote receiving station of a wireless
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`telephone network. Examples of internal designations for these projects included,
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`but were not limited to, FAX-CAM, Mini—RIT, CAM—RIT, ICE, Micro-ICE,
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`HCT, Micro-R11“, Military Micro~RlT, L—RIT, and PICS.
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`For example,
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`apparatuses within the scope of the FAX-CAM, CAM-RIT, Micro-RH, and Mini-
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`RIT product development projects were various configurations of hand-held
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`electronic devices capable of capturing visual images and wirelessly transmitting
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`them to a remote receiving station.
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`6.
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`Winston Ninh, who worked under my direction with respect to at
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`least one
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`product development project relating to the invention claimed in claims 1~15 of
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`the ‘871 patent, can independently corroborate that
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`I fully conceived of the
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`invention claimed in claims 1—15 of the ‘871 patent no later than March 18, 1993.
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`To this end, Winston Ninh has executed a declaration pursuant to the provisions
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`of 28 U.S.C. §1746 and 37 C.F.R. §1.131 (“the Ninh declaration,” which is
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`submitted in these pending IPR proceedings as exhibit EXH 2015) to corroborate
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`facts supporting my conception of the invention claimed in claims 1-15 of the
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`‘871 patent.
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`7.
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`The
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`evidentiary documentation included in the Ninh Declaration shows
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`schematics and associated technical documents that were contemporaneously
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`generated during my conception of the invention claimed in claims 1-15 of the
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`‘871 patent and that corroborate my conception of the invention claimed in claims
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`1-15 of the ‘871 patent at least as early as March of 1992 and not later than March
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`18, 1993.
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`8.
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`On or prior to the date indicated during the period of conception, I created various
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`sketches and other conception materials in relation to at least the FAX-CAM
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`product development project These sketches and other conception materials
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`include the following:
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`a. As shown in page 27 of this declaration (FAX—CAM apparatus conceptual
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`schematic; date of disclosure at least by 11/04/1989), a hand—held, self-
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`contained apparatus conceived in relation to the FAX—CAM product
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`development project
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`included a processor and power supply having
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`memory coupled thereto, an image card coupled thereto, video signal input
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`circuitry coupled thereto through an analog-to-digitai conversion device, a
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`display coupled thereto, telephonic system coupled thereto and including a
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`cellular interface, and a button interface coupled thereto with keypad
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`buttons coupled thereto. The power supply supplies power to electronic
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`components of the apparatus. The processor digitally processes signals
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`generated by electronic components of the apparatus. The memo1y and/or
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`the image card enable visual images to be stored thereon.
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`The video
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`signal input circuitry (cg, including video sensor and electronic camera)
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`generates a visual
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`image signal and the analog-to-digital conversion
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`device outputs the visual image signal in a digital format. The display
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`enables information generated by the electronic components of the
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`apparatus to be viewed. The button interface with keypad buttons coupled
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`thereto enables alphanumeric signals to be manually inputted.
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`The
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`telephonic system (e.g., via the cellular
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`interface) enables
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`signals
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`generated by electronic components of the apparatus to be transmitted to a
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`remote receiving station of a wireless telephone network and enables at
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`least telephonic audio signals to be received from the remote receiving
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`station.
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`As shown in pages 2863 of this declaration (FAX—CAM apparatus
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`conceptual sketches and artistic rendering; date of disclosure at least by
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`03/03/1990), a handheld, self—contained apparatus conceived in relation to
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`the FAX-CAM product development project included a housing having a
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`wireless communication device (e.g., including a speaker, microphone and
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`antenna)
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`therein, a display supported thereon, a telephone keyboard
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`supported thereon, a memory card removably insertable therein, a camera
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`therein, a user interface (e.g., button) thereon for enabling sending of a
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`visual image signal corresponding to an image captured by the camera, a
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`user interface (e.g., button) thereon for enabling viewing of a image
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`captured by the camera, a user interface (e.g., knob) thereon for enabling
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`adjustment of a sharpness of a displayed image, and power supply
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`supported thereon. Although not specifically shown, functionalities that
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`affected sharpness or other visual attributes of a displayed and/or Viewed
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`image and that were well known in the art of electronic (i.e., digital)
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`cameras to be controlled via digital and/or analog signaling included, for
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`example, gain, pedestal, setup, white clip, lens focus, white balance, lens
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`iris,
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`lens zoom and other functions of the camera from a local
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`input
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`device, a remote device or as automatic or programmed functions.
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`0. As shown in page 34 of this declaration (FAX-CAM apparatus conceptual
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`schematic; date of disclosure at least by 03/05/1990), a hand—held, self—
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`contained apparatus conceived in relation to the FAXACAM product
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`development project included a processor having memOIy coupled thereto,
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`an electronic camera (e.g., CCD chip) coupled thereto through an analog-
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`to-digital conversion device, a display coupled thereto with a user
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`interface for affecting content presented on the display, and a fax modem
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`chip coupled thereto.
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`The fax modem chip is coupled between the
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`processor and communications interfaces (e.g., RJ—ll
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`jack) such that
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`signaling between the processor and the communications interfaces is in a
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`digital format. The processor digitally processes signals generated by
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`eiectronic components of the apparatus. The memory enabies Visual
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`images to be Stored thereon.
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`The electronic camera generates a visual
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`image signal and the analog—to-digital conversion device outputs the visual
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`image signal
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`in a digital
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`format.
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`The display enables information
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`generated by the electronic components of the apparatus to be viewed.
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`The communications interface enables signals generated by electronic
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`components of the apparatus to be transmitted to a remote receiving
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`station.
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`As shown in pages 35-36 of this declaration (FAX—CAM apparatus
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`conceptual sketches; date of disclosure at least by 07/20/1990), a hand-
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`held, self-contained apparatus conceived in relation to the FAX-CAM
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`product development project included a motherboard with power supply, a
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`keyboard coupled to the motherboard, a processor coupled to the
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`motherboard, an image card coupled to the motherboard, a camera coupled
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`to the motherboard, a Viewfinder coupled to the motherboard, a modern
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`coupled to the motherboard, a video card coupled to the motherboard, and
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`a liquid crystal display (LCD) coupled to the motherboard. The video
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`card enables generation of a video input signal corresponding to capture of
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`images within a field of View of the camera. The viewfinder enables
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`display of the video input signal as the video input signal
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`is being
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`generated. The keyboard enables alpha and numerical information to be
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`inputted. The modem enables reception and transmiSSion of a signal
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`comprising digital information (e.g., a digital signal). The image card
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`enables visual images captured by the camera to be stored thereon. The
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`processor digitally processes signals generated by electronic components
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`of the apparatus.
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`The LCD enables information generated by the
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`electronic components (e.g., visual
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`images, alphanumeric information,
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`etc.) of the apparatus to be viewed.
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`As shown in page 37 of this declaration (FAX—CAM apparatus artistic
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`renderings; date of disclosure at least by 07/31/1990), a handheld, self-
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`contained apparatus conceived in relation to the FAX-CAM product
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`development project included a housing having a camera therein, a display
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`supported thereon, the display being operable for enabling display icuns of
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`visual images captured by the camera and to allow a particular one of the
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`visual
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`images to be selected and transmitted, and the display being
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`operable for enabling a recipient of the particular one of the visual image
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`to be designated and the particular one of the visual images sent thereto.
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`As shown in page 38 of this declaration (FAX—CAM apparatus artistic
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`renderings; date of disclosure at least by 07/31/1990), a hand-held, self-
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`contained apparatus conceived in relation to the FAX-CAM product
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`development project included a housing having a camera therein, a display
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`supported thereon, the display being operable for enabling display icons of
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`visual images captured by the camera and to allow a particular one of the
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`visual
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`images to be selected and transmitted, and the display being
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`operable for enabling a recipient of the particular one of the Visual image
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`to be designated and the particular one of the Visuai images sent thereto.
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`. As shown in pages 39-40 of this declaration (FAX—CAM apparatus
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`conceptual sketch; date of disclosure at least by 09/29/1990), a hand—held,
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`self-contained apparatus conceived in relation to the FAX-CAM product
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`development project included a housing having display (i.e., Cathode ray
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`tune (CRT)) implemented in a manner such that an image being captured
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`by a camera of the apparatus is displayed on the display and such that a
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`user can View the image on the display through a viewfinder.
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`In this
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`manner, the user can frame the Visual image prior to being captured and
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`thereafter capture it using the “shutter” button. Following capture of the
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`Visual image, it can be recalled for playback using the “playback user
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`interface” buttons.
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`. As shown in page 41 of this declaration (FAX-CAM apparatus conceptual
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`rendering; date of disclosure at least by November 11/10/1990), a hand-
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`held, self—contained apparatus conceived in relation to the FAX—CAM
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`product development project
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`included a housing having a wireless
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`communication device (i.e., including a speaker, microphone and antenna)
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`therein, a display supported thereon, a memory card removabiy insertable
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`therein, and a camera therein.
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`9.
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`During the period of conception, I secured the services of Winton Ninh to perform
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`professional services consisting of formalizing content of biock diagrams created
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`by me and articulated to Winston Ninh verbally and/or in writing by me,
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`designing circuit schematics for same, building breadboards for same, and testing
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`such breadboards. These apparatuses were conceived by me in relation to at least
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`the FAX—CAM, CAM—KIT, and Mini-RIT product development projects. As
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`corroborated by the Ninh declaration, i disclosed to Winston Ninh the following
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`subject matter on or prior to the date indicated:
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`a. As shown in page 11 of the Ninh Declaration (FAX-CAM apparatus
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`conceptual schematic; date of disclosure at
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`least by 03/05/1990), an
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`apparatus conceived in relation to the FAX—CAM product development
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`project included a processor having memory coupled thereto, an electronic
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`camera (e.g., CCD chip) coupled thereto through an analog-to—digital
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`conversion device, a display coupled thereto with a user interface for
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`affecting content presented on the display, and a fax modem chip coupled
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`thereto. The fax modem chip is coupled between the processor and
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`communications interfaces (e.g., RJ-ll jack) such that signaling between
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`the processor and the communications interfaces is in a digital format.
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`The processor digitally processes
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`signals generated by electronic
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`components of the apparatus. The memory enables visual images to be
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`stored thereon. The electronic camera generates a visual image signal and
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`the analog~to~digital conversion device outputs the visual image signal in a
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`digital
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`format.
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`The display enables information generated by the
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`electronic
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`components of
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`the
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`apparatus
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`to
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`be
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`viewed.
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`The
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`communications
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`interfaces
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`enable
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`signals generated by
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`electrOnic
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`components of the apparatus to be transmitted to a remote receiving
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`station.
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`As shown in pages 12-15 of the Ninh Declaration (FAX-CAM apparatus
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`conceptual schematic; date of disclosure at
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`least by 03/30/1990), an
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`apparatus conceived in relation to the FAX-CAM product development
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`project
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`included a processor, various types of memory, an electronic
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`camera (e.g., CCD chip), image processing circuitiy, a display, a keyboard
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`for enabling input of alphanumeric information, a user interface for
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`enabling image capture and transmission, a modem, a modem driver, a
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`data access arrangement, a digital—tomanalog converter, and analog—to-
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`digital converter, and various communication interfaces for enabling 2—
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`way communication with a remote receiving station (e.g., RJ—l 1, RS-232).
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`As shown in page 16 of the Ninh Declaration (CCD Camera Module; date
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`of disclosure at least by July 20, 1990), an apparatus conceived in relation
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`to the FAX-CAM product development project included a camera module
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`having a physical size allowing it to be integrated into a hand-held
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`housing. The CCD camera module was the smaliest size camera module
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`that was identified by David Monroe in or shortly before July of 1990.
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`As shown in pages 17-18 of the Ninh Declaration (FAX-CAM apparatus
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`processor board schematic; date of disclosure at least by 12/03/ 1990), an
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`apparatus conceived in relation to the FAX~CAM product development
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`project included processor configured (e.g., with the use of software) for
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`providing the following functionality: control the electronics to allow
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`viewing of a live image to be framed, control
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`the keypad/keyboard
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`electronics to allow input of commands, control
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`the keypad/keyboard
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`electronics to allow input of alpha or numeric data, run the operating
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`system software, run the applications software, control the internal RAM
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`memory, control the external memory, control the display of video and
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`images, control the display of text, control the backlight of the display,
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`control the electronics to capture an image, provide one or more image
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`compression algorithms, perform gray scale to bit map conversion for
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`FAX machine compatibility, store the captured image in fixed RAM
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`memory, store the capture image in removable memory, recall a captured
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`image from RAM, recall a captured image from removable memory,
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`monitor the status of the memory card door (open/closed), control memory
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`based on memory card door, control the electronics to display a captured
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`image, select the means of transmission of the image, control the modem,
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`control dialing functions of the telephone and the cellular telephone,
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`control the telephone line communications, control the cellular telephone
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`communications, control
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`the serial chamiel communications, control
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`communications encryption/decryption functions, provide one or more
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`protocols for the telephone line, provide one or more protocols for the
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`cellular telephone, provide one or more protocols for the serial channel,
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`control sending of an image over the telephone line, control sending of an
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`image over the cellular telephone, control sending of an image over the
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`serial channel, control receiving of an image over the telephone line,
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`control receiving of an image over the cellular telephone, control receiving
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`of an image over
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`the serial channel, provide one or more image
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`decompression algorithms, control the power supply system, control the
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`Video parameters of the electronic camera, control the video parameters of
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`the A/D conversion, control the video parameters of the D/A conversion,
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`control audio inputs, control the audio parameters of the microphone,
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`control the audio parameters of the audio line input, control audio outputs,
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`control the audio parameters of the speaker, control generation of tones
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`for the speaker, provide Busy status (can’t capture an image), provide
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`Main Battery Low status indication, provide Card Battery Low status
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`indication, provide
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`card Write Protect status indication, provide Video
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`Overlay Data, provide Strobe Light Control, provide a system debug
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`facility, provide a Real—Time Clock, provide a Time/Date function,
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`provide attachment of Time/Date to an image, and load instructions and
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`data held in non-volatile storage (the EPROM).
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`As shown in page 19 of the Ninh Declaration (FAXHCAM apparatus
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`keyboard schematic; date of disclosure at
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`least by 12/03/1990), an
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`apparatus conceived in relation to the FAX—CAM product development
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`project included a keyboard for enabling alphanumeric information to be
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`inputted by a user through use of a keyboard.
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`f. As shown in pages 20-31 of the Ninh Declaration (CAM—RIT apparatus
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`hardware schematics; date of disclosure at
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`least by 03/6/1992), an
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`apparatus conceived in relation to the CAM-RIF product development
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`project included circuitry interconnect for the following components and
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`printed wiring assemblies:
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`21 Viewfinder, a deflection yoke, a Micro
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`Processor Unit (MPU), audio logic, one or more status indicators, a
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`microphone, a speaker, at serial connector, a power supply, video backend
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`and frontend, a video interface, a liquid crystal display, audio logic, and a
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`MPU, The MPU included a “H-S” micro controller chip with AID D/A
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`and related circuitry, RAM memory chips and related circuitry, a 286 LC
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`microprocessor chip and related circuitry,
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`internal
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`time-of—day clock,
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`alarm, a 100 year calendar, a parallel Interface Memory Unit chip and
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`related circuitry, a CMOS Flash Memory chip and related circuitry, a
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`RAMCARD connector to an image storage card, a RAMCARD controller
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`chip and related circuitry, a RAMCARD power chip and related circuitry,
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`various crystal oscillator/timebase components, various power supply
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`chips and related circuitry, a microprocessor monitor chip and related
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`circuitry “Main Reset”, a fax modem chip and related circuitry, image
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`capture button interfaces, memory addressing decoder logic, a UART chip
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`and related circuitry, a serial connector, a lithium battery for the internal
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`real
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`time clock and CMOS memory, a power switch connection and
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`related circuitry, a cellular telephone data and clock interface for control
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`of cell phone and data transfers a liquid crystal display module, a battery,
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`power control and distribution circuitry, an electronic viewfinder, and
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`video circuitry and logic.
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`This hand‘held, selfucontained apparatus
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`provided functionality for enabling a user to acquire and frame an image
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`using the electronic viewfinder, capture the framed image to produce a
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`digitized framed image, optionally input
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`and view alphanumeric
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`information, selectively recall the digitized framed image from memory,
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`and thereafter selectively transmit
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`the digitized framed image and,
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`optionally, alphanumeric information for reception by a remote receiving
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`station.
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`As shown in pages 32-37 of the Ninh Declaration (Mini-RIT functionality
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`summary sheet; date of disclosure at least by 03/1/1993), an apparatus
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`conceived in relation to the Mini—RIT product development project
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`included a digital camera, Video circuitry for processing information
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`generated by the digital camera, PCMCIA circuitry, and a programmable
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`sequence instruction unit.
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`11.
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`As shown in page 38 of the Ninh Declaration (digital camera functionality
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`summary sheet; date of disclosure at least by 03/1/1993), an apparatus
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`conceived in relation to the Mini-RIT product development project
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`included a digital camera with digital signal processing, electronic light
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`control, gain control, balance control,
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`red/blue level control,
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`light
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`compensation control, shutter speed control, tracing white control, etc.
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`As shown in pages 39-44 of the Ninh Declaration (CAM-RIT apparatus
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`hardware schematics; date of disclosure at
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`least by 08/20/1991), an
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`apparatus conceived in relation to the CAM—RIT product development
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`project included a camera, processor, memory, keyboard, power supply,
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`audio circuitry/logic, video circuitry/logic, an electronic viewfinder, a
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`device
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`for
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`enabling alphanumeric
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`input,
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`and power
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`control
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`and
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`distribution circuitly. This hand-held, self-contained apparatus provided
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`functionality for enabling a user to acquire and frame an image using the
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`electronic viewfinder, capture the framed image to produce a digitized
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`framed image, optionally input and view alphanumeric information,
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`selectively recall the digitized framed image from memory, and thereafter
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`selectively transmit
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`the
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`digitized framed
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`image
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`and, optionally,
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`alphanumeric information for reception by a remote receiving station.
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`As shown in pages 45—58 of the Ninh DeciaratiOn (Mini-RIT apparatus
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`hardware schematics; date of disclosure at
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`least by 03/ 1/ 1993), an
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`apparatus conceived in relation to the Mini-RIT product development
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`project included a camera, audio circuitry/logic, video circuitry/logic, an
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`electronic viewfinder, a device for enabling alphanumeric input, cellular
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`telephone, and power supply. This hand~held, self—contained apparatus
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`provided functionality for enabling a user to acquire and frame an image
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`using the electronic viewfinder, capture the framed image to produce a
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`digitized framed image, optionally input
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`and View alphanumeric
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`information, selectively recall the digitized framed image from memory,
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`and thereafter selectively transmit
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`the digitized framed image and,
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`optionally, alphanumeric information for reception by a remote receiving
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`station.
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`10.
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`In these pending IPR proceedings, Claims 1~15 have been alleged to be
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`unpatentable under 35 U.S.C. §103(a) over United States Patent No.
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`6,122,526 (“the Parulski reference) in view of United States Patent No.
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`5,893,037 (“the Reele reference).
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`ll.
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`It is my understanding that the Parulski reference has an effective filing date
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`of April 24, 1995 and that the Reele reference has an effective filing date of
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`December 9, 1994.
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`12.
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`Although I conceived of the invention claimed in claims 1—15 of the ‘871
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`patent at least as early as March 18, 1993 and was diligent in reducing it to
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`practice from that time to filing of the ’073 patent application,
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`it
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`is my
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`understanding that I only need to show diligence in reduction to practice from
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`before April 24, 1995 to the filing date of the ‘073 application on January 12,
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`1998 to antedate the Parulski reference and, consequently, the combination of
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`the Parulski reference and the Reele reference.
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`13.
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`I believe I was diligent in reducing the invention claimed in claims 1-1 5 of the
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`‘871 patent to practice from 1993 all
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`the way to the filing of the ‘073
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`application in 1998, but 1 will focus only on the relevant period of time from
`
`just before April 24, 1995 to January 12, 1998 (“the required diligence
`
`period”) for purposes of showing evidence of reasonable diligence.
`
`14.
`
`During ail or a portion of the required diligence period, 1 worked with and/or
`
`supervised the work of certain persons whom had professional responsibilities
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`Page 16 of41
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`16
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`Page 16 of 41
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`relating to activities associated with actual reduction to practice of the
`
`invention claimed in eiaims 1-15 of the ‘871 patent. These persons included
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`Stephen Baker, Dorothy Calderon, Glen Davis, Michael Forman, Donald
`
`Kayser, Michael Kight, Vinh Le, and Aaron Paul Stone Jr. Each of these
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`persons have executed a declaration pursuant to the provisions of 28 U.S.C.
`
`§1746 and 37 C.F.R. §1.131 (“the diligence-corroborating declarations”),
`
`which are submitted in these pending IPR proceedings as a respective exhibit
`
`for corroborating facts supporting reasonable diligence in actual reduction to
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`practice of the invention claimed in claims 1-5 of the ‘871 patent during the
`
`required diligence period.
`
`15.
`
`Stephen Baker was a software engineer whose work involved design and
`
`developing software that at
`
`least partially supported functionality of
`
`apparatuses configured in accordance with the invention claimed in claims 1~
`
`15 of the ‘871 patent. As described in greater detail
`
`in the diligence-
`
`corroborating declaration of Stephen Baker, which is submitted in these
`
`pending IPR proceedings as exhibit EXH 2016, the software that he was
`
`involved in designing and developing was utilized as the image capture,
`
`storage, reception and transmission software in one or more apparatuses each
`
`having construction and functionality configured at
`
`least partially in
`
`accordance with. the invention ciaimed in claims 1-15 of the ‘871 patent.
`
`This software, on which he worked diligently from July of 1995 to December
`
`of 1997, was essential to the reduction to practice of one or more limitations
`
`of at least independent claims 1, 6, 9, and 12 of the ‘871 patent such as, for
`
`Page 17 of41
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`17
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`Page 17 of 41
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`example, capturing a visual image and transmitting it to a compatible remote
`
`receiving station of a wireless telephone network, sending image data signals
`
`(i.e., a non—audio digital signal such as that corresponding to a visual image
`
`that has been framed and digitized), and transmitting digitized signals (e.g.,
`
`that representing a digitized framed image) to a compatible remote receiving
`
`station from a wireless communications device of a cellular telephone.
`
`16.
`
`Glen Davis was a mechanical draftsman whose work involved drafting project
`
`packaging and housings relating to apparatuses configured in accordance with
`
`the invention claimed in claims 1—15 of the ‘871 patent. As described in
`
`greater detail in the diligence-corroborating declaration of Glen Davis, which
`
`is submitted in these pending lPR proceedings as exhibit EXH 2017, the
`
`packaging and housings that he was involved in drafting were utilized in one
`
`or more apparatuses each having construction and functionality configured at
`
`least partially in accordance with the invention claimed in claims 1-15 of the
`
`‘871 patent. The packaging and housings, on which he worked diligently
`
`from November of 1995 to December of l 997, were essential to the reduction
`
`to practice of one or more limitations of at least independent claims 1, 6, 9,
`
`and 12 of the ‘871 patent such as, for example, a manually portable housing
`
`configured for having an electronic camera (i.e.,an image capture device)
`
`contained therein or supported thereon, for having a display contained therein
`
`or suppmted thereon, for having a wireless transmitter/receiver of a wireless
`
`(e.g., cellular) telephone contained therein or supported thereon, for having a
`
`set of input (e.g., alphanumeric) keys contained therein or supported thereon,
`
`Page 18 of41
`
`18
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`Page 18 of 41
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`
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`for having a power supply contained therein or supported thereon, and for
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`having necessary electronic circuitry (e.g., circuit boards with associated
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`electronic components) contained therein or supported thereon.
`
`17.
`
`Michael Forman was an electrical engineer whose work involved design and
`
`development of circuits and processors relating to apparatuses configured in
`
`accordance with the invention claimed in claims 1—15 of the ‘871 patent. As
`
`described in greater detail
`
`in the diligence-corroborating declaration of
`
`Michael Formal], which is submitted in these pending IPR proceedings as
`
`exhibit EXH 2018,
`
`the circuits and processors that he was involved in
`
`designing and developing were utilized in one or more apparatuses each
`
`having construction and functionality configured at
`
`least partially in
`
`accordance with the invention claimed in claims 1-15 of the ‘871 patent.
`
`The circuits and processors, on which he worked diligently from March of
`
`1995 to December of 1997, were essential to the reduction to practice of one
`
`or more limitations of at least independent claims 1, 6, 9, and 12 of the ‘871
`
`patent such as, for example, a processor for generating an image data signal
`
`representing an image framed by a camera, a processor for capturing and
`
`digitizing the framed image in a format for transmission over the cellular
`
`telephone network via the cellular telephone, circuitly configured for being
`
`operably coupled to the processor and that includes a camera, memory, a user
`
`interface apparatus, a telephonic system (e.g., celiular telephone) including a
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`wireless communication device (e.g., wireless transmitter/receiver), and
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`associated digital and analog circuits.
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`Page 19 of41
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`l9
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`Page 19 of 41
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`18.
`
`Donald Kayser was a software engineer whose work involved design and
`
`developing software that
`
`at
`
`least partially supported functionality of
`
`apparatuses configured in accordance with the invention claimed in claims 1-
`
`15 of the ‘871 patent. As described in greater detail
`
`in the diligence—
`
`corroborating declaration of Donald Kayser, which is submitted in these
`
`pending IPR proceedings as exhibit EXH 2019,
`
`the software that he was
`
`involved in designing and developing was utilized as the image capture,
`
`storage, reception and transmission software in one or more apparatuses each
`
`having construction and functionality configured at
`
`least partially in
`
`accordance with the invention claimed in claims 1-15 of the ‘871 patent.
`
`This software, on which he worked diligently from July of 1995 to December
`
`of 1996, was essential to the reduction to practice of one or more limitations
`
`of at least independent claims 1, 6, 9, and 12 of the ‘871 patent such as, for
`
`example, capturing a visual image and transmitting it to a compatible remote
`
`receiving station of a wireless telephone network, sending image data signals
`
`(Le, a non-audio digital signal such as that corresponding to a Visual image
`
`that has been framed and digitized), and transmitting digitized signals (e.g.,
`
`that representing a digitized framed image) to a compatible remote receiving
`
`station from a wireless communications device of a cellular telephone.
`
`19.
`
`Michel Kight was a software engineer whose work involved design and
`
`developing software that
`
`at
`
`least partially supported functionality of
`
`apparatuses configured in accordance with the invention claimed in claims 1—
`
`15 of the ‘871 patent. As described in greater detail
`
`in the diligence—
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`Page 20 of 41
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`20
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`
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`Page 20 of 41
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`
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`corroborating declaration of Michael Kight, which is submitted in these
`
`pending IPR proceedings as exhibit EXH 2020, the software that he was
`
`involved in designing and developing was utilized as the image capture,
`
`storage, reception and transmission software in one or more apparatuses each
`
`having construction and functionality configured at
`
`least partially in
`
`accordance with the invention claimed in claims 1—15 of the ‘871 patent.
`
`This software, on which he worked diligently from February of 1996 to
`
`December of 1997, was essential to the reduction to practice of one or more
`
`limitations of at least independent claims 1, 6, 9, and 12 of the ‘871 patent
`
`such as, for example, capturing a visual
`
`image and transmitting it
`
`to a
`
`compatible remote receiving station of a wireless telephone network, sending
`
`image data signals (Le
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