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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`TRW AUTOMOTIVE U.S. LLC,
`Petitioner,
`
`v.
`
`MAGNA ELECTRONICS INC.,
`Patent Owner.
`
`
`
`
`Case IPR2014-01351
`Patent 8,513,590
`
`
`
`
`DECLARATION OF MICHAEL NRANIAN
`
`
`
`
`
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`MAGNA 2005
`TRW v. Magna
`IPR2014-01351
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`

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`TABLE OF CONTENTS
`
`Qualifications ................................................................................................... 3
`I.
`II. My Understanding of Legal Standards .......................................................... 14
`III. Legal Standards for Claim Construction ....................................................... 16
`IV. The ’590 Patent .............................................................................................. 17
`V.
`The Asserted References ............................................................................... 17
`A.
`Blank .................................................................................................... 18
`B.
`Kakinami ............................................................................................. 21
`C.
`Schofield .............................................................................................. 24
`D.
`Carter ................................................................................................... 25
`E.
`Anderson ............................................................................................. 26
`F.
`Klappenbach ........................................................................................ 27
`VI. Analysis ......................................................................................................... 27
`A.
`The references do not disclose a cluster of individual sensors ........... 29
`B.
`The references do not disclose a bus communication ......................... 37
`C.
`The references do not disclose “wherein, with said structure attached
`at said receiving structure, an operator at a vehicle assembly plant
`attaches said cover at said structure.” ................................................. 44
`Claim 89 .............................................................................................. 46
`A POSA would not have combined Blank, Kakinami, Schofield,
`Carter, Anderson, and Klappenbach. .................................................. 47
`VII. Conclusion ..................................................................................................... 67
`
`
`D.
`E.
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`i
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`IPR2014-01351
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`I, Michael Nranian, hereby declare as follows.
`
`1.
`
`I have been retained on behalf of Magna Electronics Inc. (Magna) for
`
`the above-captioned inter partes review proceeding. I understand that this
`
`proceeding involves U.S. Patent No. 8,513,590 (the ’590 Patent) titled “Vehicular
`
`Accessory System with a Cluster of Sensors on or near an In-cabin Surface of the
`
`Vehicle Windshield” by Patrick Heslin et al. and that the ’590 Patent is currently
`
`assigned to Magna.
`
`2.
`
`I have reviewed and am familiar with the specification of the ’590
`
`Patent. I understand that the ’590 Patent is a continuation of U.S. Application No.
`
`13/410,620, filed on March 2, 2012 (now U.S. Patent No. 8,288,711), which is a
`
`continuation of U.S. Application No. 13/191,802, filed on July 27, 2011 (now U.S.
`
`Patent No. 8,134,117), which is a continuation of U.S. Application No.
`
`13/026,591, filed on February 14, 2011 (now U.S. Patent No. 7,994,471), which is
`
`a continuation of U.S. Application No. 12/467,660, filed on May 18, 2009 (now
`
`U.S. Patent No. 7,888,629), which is a continuation of U.S. Application No.
`
`12/197,660, filed on August 25, 2008 (now U.S. Patent No. 7,538,316), which is a
`
`continuation of U.S. Application No. 11/828,880, filed on July 26, 2007 (now U.S.
`
`Patent No. 7,420,159), which is a continuation of U.S. Application No.
`
`11/699,271, filed on January 29, 2007 (now U.S. Patent No. 7,265,342), which is a
`
`continuation of U.S. Application No. 11/418,906, filed on May 5, 2006 (now U.S.
`
`
`
`1
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`IPR2014-01351
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`Patent No. 7,262,406), which is a continuation of U.S. Application No.
`
`10/913,748, filed on August 6, 2004 (now U.S. Patent No. 7,041,965), which is a
`
`continuation of U.S. Application No. 10/618,334, filed on July 11, 2003 (now U.S.
`
`Patent No. 6,774,356), which is a continuation of U.S. Application No.
`
`09/997,579, filed on November 29, 2001 (now U.S. Patent No. 6,593,565), which
`
`is a continuation of U.S. Application No. 09/433,467, filed on November 4, 1999
`
`(now U.S. Patent No. 6,326,613), which is a continuation-in-part of U.S.
`
`Application No. 09/003,966, filed on January 7, 1998 (now U.S. Patent No.
`
`6,250,148). I understand that the ’590 Patent has been provided as Exhibit 1002. I
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`will cite to the specification using the following format: (Ex. 1002, 1:1-10). This
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`example citation points to the ’590 Patent specification at column 1, lines 1-10.
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`3.
`
`I have also reviewed and am familiar with the following documents:
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`Paper /
`Exhibit #
`
` 1
`
`6
`
`7
`
`1005
`
`1006
`
`Description
`
`Petition for Inter Partes Review (dated August 20, 2014)
`(Petition)
`Patent Owner Magna Electronics Inc.’s Preliminary Response to
`Petition (dated December 2, 2014) (POPR)
`Decision on Institution of Inter Partes Review (dated February 10,
`2015) (Institution Decision)
`Blank et al., U.S. Patent No. 5,708,410, “Vehicle Information
`Display” (issued January 13, 1998) (Blank)
`Schofield et al., U.S. Patent No. 4,930,472, “Rearview Mirror and
`Accessory Mount for Vehicles” (issued June 15, 1990) (Schofield)
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`Description
`
`Carter et al., U.S. Patent No. 5,667,896, “Vehicle Window
`Assembly for Mounting Interior Vehicle Accessories” (issued
`September 16, 1997) (Carter)
`Anderson et al., U.S. Patent No. 5,602,457, “Photovoltaic Solar
`Cell Laminated in Vehicle Windshield” (issued February 11,
`1997) (Anderson)
`Kakinami et al., U.S. Patent No. 5,096,287, “Video Camera for an
`Automobile” (issued March 17, 1992) (Kakinami)
`Klappenbach et al., U.S. Patent No. 5,710,633, “Fastening and
`Coupling of an Optoelectronic to a Pane and Structure of the
`Sensor” (issued January 20, 1998) (Klappenbach)
`Declaration of Homayoon Kazerooni (Kazerooni Declaration)
`
`I have been asked to provide my technical review, analysis, insights,
`
`Paper /
`Exhibit #
`1008
`
`1009
`
`1010
`
`1011
`
`1012
`
`4.
`
`and opinions regarding the ’590 Patent and the above-noted references that form
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`the basis for the grounds of unpatentability set forth in the Petition and the
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`Institution Decision.
`
`I.
`
`Qualifications
`5. My academic background is in engineering. I received a Bachelor of
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`Science Degree in Chemical Engineering from Wayne State University in 1984. I
`
`received a Master of Science in Electrical Engineering from Wayne State
`
`University in 1991. I received another Bachelor of Science Degree from Wayne
`
`State University in 1993, this time in Electrical and Computer Engineering. I also
`
`received a Juris Doctor Degree from Wayne State University in 1999. I also
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`received a Master of Business Administration from the University of Michigan in
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`2002. I also am a licensed Professional Engineer, Certified Project Management
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`Professional, as well as a Lean Six Sigma Black Belt certified through the
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`American Society for Quality and the International Quality Federation.
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`6.
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`I have extensive industry experience in the automotive industry for
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`multiple companies. More specifically, I have experience in designing sensors and
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`safety devices for use in automobiles, as well as designing the systems to
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`incorporate these sensors and safety devices into automobiles.
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`7.
`
`A copy of my curriculum vitae is attached hereto and incorporated by
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`reference. My curriculum vitae lists cases on which I have testified as an expert in
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`the prior four years. I have not authored any publications over the prior ten years.
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`8.
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`I currently work as a contractor for the U.S. Army, for the Chief
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`Scientist’s Office, in the Tank and Automotive Research, Development and
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`Engineering Center (TARDEC) in Warren, Michigan.
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`9.
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`Prior to my employment with the Army, I worked as a design
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`engineer and engineering manager in the automotive industry from 1985 to 2007.
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`This included experience at Ford, General Motors, and Allied Signal. I worked at
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`Allied Signal from 1992 to 1993, General Motors from 1993 to 1995, and Ford
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`Motor Company from 1985 to 1992, and from 1995 to 2007.
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`10. While at Allied Signal and General Motors I worked as a Senior
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`Project Engineer, where my work included the design and development of
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`automotive safety systems and components for various different types of
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`automotive applications. This included testing and development of sensing systems
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`and components for active and passive safety, vehicle diagnostics, status, displays,
`
`and warnings to the driver and vehicle occupants. This also included vehicle
`
`electrical system architectures including message, data, status, and warning
`
`prioritization and the transmission and display of information to vehicle users and
`
`occupants across different types of communication channels (including CAN, LIN,
`
`and other vehicle network architectures and busses).
`
`11. Areas of my work included both active and passive sensing systems
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`which can be used in the vehicle interior or exterior, including the design and
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`development of sensing components and systems that incorporate electromagnetic
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`wave sensing (including but not limited to vision, camera, radar, lidar, infrared
`
`ultraviolet, and night vision) as well as acoustical sensing. Areas of my work also
`
`specifically included automotive vehicle safety systems, sensing systems, electrical
`
`systems and architectures, electrical and data communication protocols, vehicle
`
`system diagnostics, warnings, vision systems, occupant and infant/child seat
`
`sensing and detection systems, out of position occupant detection, electrical and
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`safety system diagnostics, occupant ergonomic evaluations, user and occupant
`
`
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`IPR2014-01351
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`audio and visual interfaces and displays, infrared, vision, camera, sonar, acoustic,
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`radar, lidar, sensing and detection technologies and systems.
`
`12.
`
`I conducted numerous system and component evaluations, laboratory
`
`tests, supplier and technology assessments, quality and reliability evaluations, as
`
`well as developed design validation plans and reports and failure modes and effects
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`analyses to design and develop automotive safety, sensing, and electrical systems,
`
`including the integration of sensor fusion technologies, and the components and
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`systems for information and diagnostics storage and communication and retrieval,
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`computer, microprocessor and interface architectures, and automotive electrical
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`system architectures and communication protocols.
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`13. My responsibilities also included technology assessments and proper
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`supplier and sourcing evaluation and selection, quoting and bidding, and the
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`overall source selection for numerous technologies. My responsibilities also
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`included ensuring compliance with Federal Motor Vehicle Safety Standards, ECE
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`regulations, Industry Standards, Corporate Standards, and Due-Care Requirements.
`
`14.
`
`I worked on the development of occupant sensing and infant/child seat
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`detections systems, including infrared, RFID, vision, camera, laser, LED, beam,
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`acoustical, ultrasonic, capacitance, inductance, seat weight sensing, and other types
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`of sensing technologies. I also worked on sensing systems for various automotive
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`IPR2014-01351
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`applications, including sensor fusion technologies, for image and object detection,
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`discrimination, and identification and the appropriate status notifications to vehicle
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`drivers and occupants. My work included analyses involving statistical information
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`from NASS and FARS databases. Also, for example, General Motors applied for
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`and was granted a Statutory Invention Registration for rear facing infant seat
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`occupant detection using a technology that I conceived of and developed.
`
`15. While at Ford, my experience included working as a Product Design
`
`Engineer, a Technical Specialist, a Design Analysis Engineer, and an Engineering
`
`Manager. My work included the design and development of automotive safety
`
`systems and components for various different types of automotive applications.
`
`This also extensively involved the testing and development of sensing systems and
`
`components for active and passive safety, vehicle diagnostics, status, displays, and
`
`warnings to the driver and vehicle occupants, as well as the development of vehicle
`
`electrical system architectures including message, data, status, and warning
`
`prioritization and the transmission and display of information to vehicle users and
`
`occupants across different types of communication channels (including CAN and
`
`other vehicle network architectures and busses). This also extensively involved
`
`active and passive sensing systems which can be used in the vehicle interior or
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`exterior, including systems that incorporate electromagnetic wave sensing
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`(including but not limited to vision, camera, radar, lidar, infrared, ultraviolet, and
`
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`IPR2014-01351
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`night vision), as well as acoustical, automotive, sensing and electrical systems and
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`architectures, electrical and data communication protocols, as well as the
`
`appropriate notifications to vehicle drivers, occupants, and service personnel.
`
`16.
`
`I worked extensively on vehicle system diagnostics and fault codes
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`analyses, information and diagnostics communication and retrieval from vehicle
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`modules and systems, vehicle parameter information communication and retrieval
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`from vehicle modules, sensor fusion technologies assessments and integration,
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`vision systems, image and object detection and identification, occupant and
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`infant/child seat sensing systems, occupant and out of position occupant sensing
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`and detection, critical parameter communication storage and retrieval, warnings,
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`occupant ergonomic evaluations, user and occupant audio and visual interfaces and
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`displays, vehicular compatibility analyses and assessments, storage and
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`communication of critical parameter information related to automotive vehicle
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`systems as well as the interfaces involved in communication and retrieval of this
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`information. This included communication of sensor and vehicle information
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`through automotive vehicle computer, microprocessor, and electrical systems and
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`architectures, electrical and data communication protocols and interfaces, vehicle
`
`electrical networks and network interfaces.
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`IPR2014-01351
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`17. My work included the design and development of these automotive
`
`safety components and systems to meet corporate and industry requirements and
`
`standards. My work also involved systems utilizing infrared, vision, camera, sonar,
`
`acoustic, radar sensing, monitoring, and detection technologies and systems for
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`vehicle occupants and appropriate sensor information signal discrimination and
`
`identification.
`
`18.
`
`I conducted numerous system and component evaluations, laboratory
`
`tests, supplier and technology assessments, quality and reliability evaluations, as
`
`well as developed design validation plans and reports and failure modes and effects
`
`analyses, corporate standards and specifications, and design guidelines, to design
`
`and develop sensing systems, as well as the related computer, microprocessor, and
`
`electrical/electronic architecture networks, data and critical parameter storage,
`
`retrieval, transfer, notification and communication systems.
`
`19. My work also involved analyses of information from NASS and
`
`FARS databases. My responsibilities also included technology assessments and
`
`proper supplier and sourcing evaluation and selection, quoting and bidding, and the
`
`overall source selection for numerous technologies. My responsibilities also
`
`involved extensive inspection, investigation, and analysis of field events involving
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`automotive safety systems, analysis of occupant kinematics and injury causation,
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`IPR2014-01351
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`and testifying as an expert witness and corporate representative in litigation
`
`matters. I also reported back my findings to the engineering and product
`
`development activities for continuous product improvements. My responsibilities
`
`also included ensuring compliance with Federal Motor Vehicle Safety Standards,
`
`ECE regulations, Corporate Standards, Industry Standards, and Due-Care
`
`Requirements.
`
`20. Subsequent to my employment at Ford, I worked as a Systems
`
`Engineer for Raytheon and General Dynamics, where I developed defense systems
`
`for military vehicles. Part of my responsibilities also included technology
`
`assessments and proper supplier and sourcing evaluation and selection, quoting and
`
`bidding, and
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`the overall source selection for numerous defense system
`
`technologies. This includes conducting and leading technology and sourcing trade
`
`studies and analyses using preset requirements for evaluation and the preparation
`
`of the proper documentation to ensure source selection is conducted fairly and
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`adequately and meets or exceeds the requirements and specifications for the
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`components, system, vehicle, and overall mission system integration requirements
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`as well as Department of Defense 5000 and 5001 protocols.
`
`21.
`
`In my current position, I possess an Active Secret Security Clearance.
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`My responsibilities include working with internal scientists, researchers and
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`IPR2014-01351
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`technical staff, as well as outside collaborators and universities, to develop
`
`technologies, innovation, and inventions for the protection of our soldiers and the
`
`enhancement of our soldiers’ survivability in military vehicles. This includes the
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`development and assessment of vehicle and robotic data communication and
`
`electrical system architectures, vision systems, infrared systems, object and image
`
`detection, identification, enhancement, notification and display, critical parameter
`
`diagnostics and storage operating across vehicle data busses as well as cellular and
`
`radio networks.
`
`22. My responsibilities include technologies involving camera and vision
`
`systems, human interface displays, acoustic, ultrasonic, IR, radar, night vision, and
`
`electromagnetic wave sensing, sensor fusion integration, algorithm, and pattern
`
`recognition development, sensor information discrimination and identification,
`
`robotic systems, Improvised Explosive Device (IED) detection and injury
`
`mitigation
`
`systems,
`
`armor
`
`and
`
`electromagnetic
`
`armor
`
`development,
`
`electromagnetic wave sensing and frequency determination, Command, Control,
`
`Communications, Computers, Intelligence, Surveillance and Reconnaissance
`
`(C4ISR) systems development, 360 degree surveillance, active and passive safety
`
`system development and occupant injury mitigation.
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`IPR2014-01351
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`23. This also includes 360 degree visual situational awareness systems
`
`including electro-optical (e.g. CMOS, CCD) sensors, thermal viewers, and scalable
`
`machine interfaces using various operating systems, geographic information
`
`systems, image enhancement and recognition, image and object detection
`
`discrimination and identification, augmented displays with friend and foe target
`
`enhancement for location and identification, GPS and mapping location systems
`
`(including the use of differential GPS, pseudolites, repeaters, base stations, and
`
`relays), mobile data terminals, split-screen augmented information and visual
`
`displays and controllers, on-board vehicle displays as well as soldier handheld
`
`devices, and the transfer of this information across satellite systems to command
`
`centers to soldiers and vehicles in the field, as well as the real-time communication
`
`of this information across command systems through satellite, cellular, radio
`
`frequency, wireless mediums, and related techniques.
`
`24.
`
`I have extensive experience with different types of automotive and
`
`vehicle sensing systems and safety systems, as well as the discrimination of sensor
`
`information for implementation of active and passive safety devices. I also have
`
`extensive experience in the establishment of safety requirements, the testing and
`
`development of components and systems to meet these requirements, the design
`
`and development of these components and systems per vehicle specific
`
`characteristics, as well as the associated data and communication interfaces and
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`IPR2014-01351
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`systems, including computer, microprocessor, wireless and physical hardware
`
`electrical and system architectures. I also have extensive experience in the
`
`development of automotive active and passive safety systems for injury prevention
`
`and mitigation, proper sensor parameter and information discrimination for these
`
`active and passive safety systems, and the proper overall design of these safety
`
`systems and the components integrated into these systems, for compliance to
`
`rigorous FMVSS, regulatory, corporate, and Due-Care, requirements, standards,
`
`and specifications.
`
`25.
`
`I have testified as an expert in over 20 cases involving automotive
`
`sensors, sensing systems, and safety systems, as well as diagnostic and information
`
`systems, and the discrimination and communication of critical sensor parameter
`
`information.
`
`26.
`
`I am a member of the Project Management Institute, American
`
`Society for Quality, International Quality Federation, and the Forensic Expert
`
`Witness Association.
`
`27. My work on this case is being billed at a rate of $350.00 per hour,
`
`with reimbursement for actual expenses. My compensation is not contingent upon
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`the outcome of this inter partes review.
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`IPR2014-01351
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`II. My Understanding of Legal Standards
`28.
`It is my understanding that the claims of the ’590 Patent are only
`
`challenged under obviousness grounds, and not anticipation grounds. But for
`
`background, it is my understanding that a claim may be “anticipated” and thus
`
`unpatentable if a single prior art reference teaches each and every limitation recited
`
`in the claim. My understanding of the law of obviousness is as follows.
`
`29.
`
`I understand that a patent claim is unpatentable if the claim would
`
`have been obvious to a person of ordinary skill in the field at the time the invention
`
`was made (a “POSA”). This means that even if all of the requirements of the claim
`
`cannot be found in a single reference, the claim can still be invalid for obviousness.
`
`30.
`
`I have been asked to assume for the purposes of this obviousness
`
`inquiry that the time the invention was made was November 4, 1999, the filing
`
`date for U.S. Application No. 09/433,467 (now U.S. Patent No. 6,326,613), of
`
`which the ’590 Patent is a continuation. If the actual time of the invention was
`
`earlier in time than November 4, 1999, my opinions regarding obviousness would
`
`still hold true.
`
`31. As part of this inquiry, I have been asked to consider the level of
`
`ordinary skill in the field that someone would have had at the time the claim was
`
`made. In deciding the level of ordinary skill, I considered the following:
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`
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`

`• the levels of education and experience of persons working in the field;
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`IPR2014-01351
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`• the types of problems encountered in the field; and
`
`• the sophistication of the technology.
`
`32. Using these factors, a POSA would have at least a Bachelor’s degree
`
`in electrical, electronic, or mechanical engineering, and two years of experience in
`
`the relevant field, such as in the integration of electronics into consumer products.
`
`33.
`
`I understand that to obtain a patent, a claim must have been, as of the
`
`priority date, nonobvious in view of the references in the field. I understand that a
`
`claim is obvious when the differences between the subject matter sought to be
`
`patented and the reference are such that the subject matter as a whole would have
`
`been obvious to a POSA at the time the invention was made.
`
`34.
`
`I understand that to prove that a reference or a combination of
`
`references renders a claim obvious, it is necessary to (1) identify the particular
`
`references that, singly or in combination, make the patent obvious; (2) specifically
`
`identify which elements of the patent claim appear in each of the asserted
`
`references; and (3) explain how the references could have been combined in order
`
`to create the features recited in the patent claims.
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`IPR2014-01351
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`35.
`
`I understand that certain objective indicia can be important evidence
`
`regarding whether a claim is obvious or nonobvious. Such indicia include:
`
`commercial success of products covered by the patent claims; a long-felt need for
`
`the claimed invention; failed attempts by others to make the claimed invention;
`
`copying of the claimed invention by others in the field; unexpected results
`
`achieved by the claimed invention as compared to the closest reference; praise of
`
`the claimed invention by the infringer or others in the field; the taking of licenses
`
`under the patent by others; expressions of surprise by experts and those skilled in
`
`the art at the making of the claimed invention; and the patentee proceeding
`
`contrary to the accepted wisdom of the reference.
`
`36.
`
`I also understand that in this proceeding the Petitioner has the burden
`
`of proving the obviousness of the challenged claims by a preponderance of the
`
`evidence. In other words, the Petitioner must prove that the challenged claims are
`
`reasonably likely to be unpatentable.
`
`III. Legal Standards for Claim Construction
`37.
`I understand that, in an inter partes review, the claims of an unexpired
`
`patent are given the broadest reasonable construction in light of the specification of
`
`the patent in which it appears as understood by a POSA.
`
`
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`IPR2014-01351
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`IV. The ’590 Patent
`38. The ’590 Patent specification describes a vehicle accessory system
`
`with a structure that accommodates a plurality of electrical accessories. (Ex. 1002,
`
`6:36-44.) The vehicle accessory system, as described in the ’590 Patent, may
`
`include a receiving structure attached at a vehicle windshield. (Id. at 3:37-42.) For
`
`example, the receiving structure may be an annular mounting button. (Id.) A
`
`structure is attached at the receiving structure. (Id. at 3:23-42.) This structure may
`
`include one or more compartments that can accommodate a cluster of individual
`
`sensors. (Id. at 3:29-37; 11:31-32.) When the structure is attached at the receiving
`
`structure, the cluster of individual sensors resides on or near the in-cabin surface of
`
`the vehicle windshield. (Id. at Abstract.)
`
`39. The ’590 Patent further teaches that one of the sensors could be a
`
`forwardly-viewing camera located somewhere on the assembly. (Id. at 7:47-50.) At
`
`least one of the sensors may receive an input via a bus communication and/or
`
`deliver an output via a bus communication. (Id. at Abstract.) There may be a light-
`
`absorbing layer at the windshield with an opening for one of the sensors. (Id. at
`
`3:51-59.) A detachable cover may be attached at the structure. (Id. at 6:54-56.)
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`V. The Asserted References
`40. As I will explain in further detail below, it is my opinion that the
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`challenged claims are not obvious over Blank, Kakinami, Schofield, Carter,
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`Anderson, and Klappenbach, individually or in combination. I briefly summarize
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`these asserted references below.
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`A. Blank
`41. Blank describes a vehicle information display. (Ex. 1005, 1:15.)
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`Blank’s primary purposes include providing a display in a manner that minimizes
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`the need for the driver to redirect or refocus his vision (id. at 1:31-37, 41-43; 2:18-
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`21), that does not obstruct the driver’s field of view (id. at 2:18-21), and that is
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`separate from, rather than integral with, the rearview mirror assembly (id. at 1:66-
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`2:12). Blank also discourages expensive displays. (Id. at 1:66-2:1.)
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`42. According to Blank’s primary purposes, Blank provides its vehicle
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`information display behind and substantially concealed by the rearview mirror. (Id.
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`at 2:24-34.) Blank’s housing “preferably has a low profile having a height less than
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`either its length or width so that it can be concealed behind the outline 54 of mirror
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`40.” (Id. at 7:1-3.) Blank’s display is part of a module that includes a circuit board
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`associated with the display. (Id. at 7:30-38.) I reproduce Figure 3B of Blank below
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`to illustrate an exemplary embodiment of its vehicle information display.
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`In particular, note that Blank discloses an electronic compass module
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`43.
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`which houses the electronic circuit of the compass: “FIGS. 4B and 10 depict an
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`integrated compass module which houses the electronic circuit of the compass and
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`also the display 154 or 254.” (Id. at 7:46-48.) Blank describes that the circuit board
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`150 “may be configured for any one of a number of other displays, including: a
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`clock, an odometer, a speed indicator, a hazard warning indicator, a turn indicator,
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`a thermometer (both interior and exterior), a trip computer, a global positioning
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`satellite (GPS) system, a cellular telephone, a supplemental vision system
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`(including camera, sonar, infrared and microwave detection), and/or warning lights
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`(such as a low fuel indicator), and other indicia.” (Id. at 7:51-59.) Blank also
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`describes that:
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`Portions 114, 118 are detachably coupled to each other to form
`housing 110. Any one of a number of coupling schemes may be
`employed including clips extending upwardly from portion 118 which
`cooperatively join with tabs extending downwardly from skirt 128. In
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`IPR2014-01351
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`this manner, housing 110 can be opened for servicing if need be and
`reassembled. Also defined on the interior of housing portions 114, 118
`are bosses and guides 144 to receive and position a circuit-containing
`board 150 which is coupled to and powered by a remote power source
`(not shown) through a conductor 152 extending through housing 110.
`An information display 154 is, in turn, operably coupled to conductor
`152 and circuit board 150 and is mechanically fixed in window 62 by
`screws, friction coupling, or the like.
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`(Id. at 7:25-38.) I reproduce Figure 4B of Blank below, which clearly shows that
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`housing 110 formed of detachable coupled portions 114 and 118, is intended to
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`hold a circuit board having circuitry for the display 154, and not to hold a camera.
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`44. Other than the display, circuit board, and conductor, Blank does not
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`disclose including anything else within its module. (Id.) Instead, Blank discloses
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`that the information display assembly may be coupled to a remote device that is
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`“unable to be wholly retained within the display housing.” (Id. at 9:46-56.) For
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`example, if Blank’s information display was a supplemental vision system that
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`included camera detection (id. at 7:56-58), the display would be connected to a
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`remote camera rather than including a camera within its module. Blank does not
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`disclose a camera in its module, a cluster of individual sensors, or a bus
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`communication. Further, there is no opening, aperture, channel or method
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`disclosed in Blank to allow for a camera to view forward through the vehicle
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`windshield.
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`B. Kakinami
`45. Kakinami describes “a video camera mounted in an automobile to
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`take pictures of the scenes ahead of the automobile.” (Ex. 1010, 1:7-9.) Kakinami
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`recognizes and seeks to overcome problems of mounting a camera both inside and
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`outside the automobile. (Id. at 1:21-28.) While mounting a camera inside an
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`automobile avoids “snow, rain, or dirt from the road, there may still be problems
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`caused by moisture or dust in the automobile.” (Id.)
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`46. To resolve these problems, Kakinami places its camera within an arm
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`of a header-mounted rearview mirror. (Id. at 2:15-21.) Kakinami’s camera does not
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`mount to the windshield, but rather mounts to the vehicle header. In fact, as shown
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`in Figure 2b of Kakinami, which I reproduce below, “air pipe 21 is placed between
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`a roof 2 and an interior ceiling 4 and is connected to the duct DCT1 and duct
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`DCT2.” (Id. at 2:55-63.) This clearly shows