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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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`HTC CORPORATION and HTC AMERICA, INC.
`Petitioners
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`v.
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`E-WATCH, INC. and E-WATCH CORPORATION
`Patent Owner
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`CASE: To Be Assigned
`Patent No. 7,643,168 B2
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`DECLARATION OF KENNETH PARULSKI IN SUPPORT OF PETITION
`FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,643,168 B2
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`TABLE OF CONTENTS
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`Page
`INTRODUCTION .......................................................................................... 1
`I.
`SUMMARY OF OPINIONS .......................................................................... 3
`II.
`III. QUALIFICATIONS AND EXPERIENCE .................................................... 4
`A.
`Education and Work Experience .......................................................... 4
`B.
`Compensation ....................................................................................... 8
`C. Documents and Other Materials Relied Upon ..................................... 8
`IV. STATEMENT OF LEGAL PRINCIPLES ..................................................... 8
`A.
`Claim Construction .............................................................................. 8
`B. Anticipation .......................................................................................... 9
`C. Obviousness .......................................................................................... 9
`LEVEL OF ORDINARY SKILL IN THE ART .......................................... 10
`V.
`VI. TECHNOLOGY BACKGROUND OF CLAIMED SUBJECT
`MATTER OF THE 168 PATENT................................................................ 11
`A.
`Evolution of Digital Cameras ............................................................. 11
`B.
`Image Processing in Digital Cameras ................................................ 14
`C.
`Proliferation of Commercially Available Digital Cameras ................ 16
`D.
`Integrated versus Modular Implementations ...................................... 22
`E.
`Image Compression Technologies ..................................................... 25
`F.
`Evolution of Mobile Telephony and Image Transmission................. 27
`VII. OVERVIEW OF THE 168 PATENT ........................................................... 34
`VIII. IDENTIFICATION OF THE PRIOR ART AND SUMMARY OF
`OPINIONS .................................................................................................... 35
`IX. CLAIM CONSTRUCTION ......................................................................... 36
`A.
`“Media being suitable to embody … algorithm” in Claims 1-31 ...... 37
`X. UNPATENTABILITY OF THE 168 PATENT CLAIMS ........................... 38
`A. GROUND 1: CLAIMS 1-6, 8, 10-11, 13-15, 21-29 AND 31
`ARE UNPATENTABLE UNDER 35 U.S.C. § 103(A) AS
`OBVIOUS OVER MORITA IN VIEW OF SARBADHIKARI ....... 38
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`TABLE OF CONTENTS
`(continued)
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`Page
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`B. GROUND 2: CLAIMS 16-18 ARE UNPATENTABLE
`UNDER 35 U.S.C. § 103(a) AS BEING OBVIOUS OVER
`MORITA AND SARBADHIKARI, COMBINED WITH
`LONGGINOU .................................................................................... 62
`C. GROUND 3: CLAIMS 1-6, 8, 10-11, 16-18, 21-22, 24, 26-27
`AND 29 ARE UNPATENTABLE UNDER 35 U.S.C. § 103(a)
`AS OBVIOUS OVER WILSKA IN VIEW OF YAMAGISHI-
`992 ...................................................................................................... 68
`D. GROUND 4: CLAIMS 13-15, 23, 25, 28 AND 31 ARE
`UNPATENTABLE UNDER 35 U.S.C. § 103(a) AS BEING
`OBVIOUS OVER WILSKA AND YAMAGISHI-992,
`COMBINED WITH MCNELLEY .................................................. 103
`ATTACHMENTS A-D
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`DECLARATION OF KENNETH PARULSKI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,643,168 B2
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`
`I.
`
`INTRODUCTION
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`1. My name is Kenneth Parulski. I was the former Chief Scientist in the Digital
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`Camera and Devices Division of Eastman Kodak Company and I am currently
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`Chief Scientist and Managing Member of aKAP Innovation, LLC, which I
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`founded in June 2012. aKAP Innovation, LLC provides innovation and
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`digital photography related consulting services, and participates in the
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`development of ISO (“International Organization for Standardization”)
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`standards for digital photography.
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`2.
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`I have been engaged by HTC Corporation and HTC America, Inc. (“HTC”) to
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`investigate and opine on certain issues relating to U.S. Patent No. 7,643,168
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`B2 entitled “APPARATUS FOR CAPTURING, CONVERTING AND
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`TRANSMITTING A VISUAL IMAGE SIGNAL VIA A DIGITAL
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`TRANSMISSION SYSTEM” (“168 Patent”) in HTC’s Petition for Inter
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`Partes Review of the 168 Patent (“HTC IPR Petition”) which requests the
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`Patent Trial and Appeal Board (“PTAB”) to review and cancel Claims 1-6, 8,
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`10-11, 13-18, 21-29 and 31 of the 168 Patent, which, based on my
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`understanding, are all the claims that are currently being asserted in a patent
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`litigation against HTC.
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`DECLARATION OF KENNETH PARULSKI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,643,168 B2
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`3.
`
`I understand that, according to USPTO assignment records of the 168 Patent,
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`the 168 Patent is owned by E-Watch, Inc. It is also my understanding that E-
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`Watch Corporation claims to be the exclusive licensee of the 168 Patent. E-
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`Watch, Inc. and E-Watch Corporation are asserting the 168 Patent in litigation
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`against HTC and others and are therefore referred to as the “Patent Owner” in
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`this Declaration.
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`4.
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`In this declaration, I will discuss the technology related to the 168 Patent,
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`including an overview of that technology as it was known prior to, and up to
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`the January 12, 1998 filing date to which the parent of the 168 Patent claims
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`priority. This overview of the relevant technology provides some of the bases
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`for my opinions with respect to the 168 Patent.
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`5. This declaration is based on the information currently available to me. To the
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`extent that additional information becomes available, I reserve the right to
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`continue my investigation and study, which may include a review of
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`documents and information that may be produced, as well as testimony from
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`depositions that may not yet be taken.
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`6.
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`In forming my opinions, I have relied on information and evidence identified
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`in this declaration, including the 168 Patent, the prosecution history of the 168
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`Patent, and prior art references listed as Exhibits to the Petition for Inter
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`Partes Review of the 168 Patent. I have also relied on my own experience
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`DECLARATION OF KENNETH PARULSKI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,643,168 B2
`
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`and expertise in the relevant technologies and systems that were already in use
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`prior to, and within the timeframe of the earliest priority date of the claimed
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`subject matter in the 168 Patent— January 12, 1998.
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`II.
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`SUMMARY OF OPINIONS
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`7. The claims of the 168 Patent are directed to technical issues or needs that were
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`recognized and well understood, and technical solutions that were well
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`developed to address the technical issues or needs, at the time of filing the 168
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`Patent – January 12, 1998.
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`8. For purpose of my analysis in this declaration only and based on the
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`disclosure and file history of the 168 Patent, I provide my proposed
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`construction of certain terms in Claims 1-6, 8, 10-11, 13-18, 21-29 and 31 in
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`detail in a later part of this declaration.
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`9.
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`In simple terms, Claims 1-6, 8, 10-11, 13-18, 21-29 and 31 of the 168 Patent
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`attempt to claim the combination of a handheld wireless telephone and a
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`digital camera having components and features which were well-known at the
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`time. It is my opinion that there is nothing novel in the claims of the 168
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`Patent and Claims 1-6, 8, 10-11, 13-18, 21-29 and 31 of the 168 Patent merely
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`recite routine and common features that were well known and were published
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`before the filing of the 168 Patent and are rendered obvious by the prior art
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`cited in the HTC IPR Petition.
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`DECLARATION OF KENNETH PARULSKI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,643,168 B2
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`10. The subsequent sections of this declaration will first provide my qualifications
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`and experience and then describe details of my analysis and observations of
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`Claims 1-6, 8, 10-11, 13-18, 21-29 and 31 of the 168 Patent.
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`III. QUALIFICATIONS AND EXPERIENCE
`A. Education and Work Experience
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`11. I received a Master of Science degree and a Bachelor of Science degree in
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`Electrical Engineering from the Massachusetts Institute of Technology in
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`1980. I completed my master’s thesis research while working at Motorola
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`Corporate Research Labs from 1978 through 1980, where I developed a
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`system for transmitting a series of digital images from a moving vehicle over
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`an FM radio communications link to a base station. The laboratory where I
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`worked was managed by Dr. Martin Cooper, who led the Motorola team that
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`built and demonstrated the world’s first handheld cellular telephone.
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`12. I joined Kodak Research Labs in 1980, and began developing and
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`implementing image processing algorithms. Beginning in 1984, I led a
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`project to develop the world’s first color megapixel digital camera system
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`prototype. Prints made using this system were exhibited at the Photokina
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`trade show in 1986, in Kodak’s first public demonstration of its digital
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`photography technology. Photokina is the world’s largest trade show for the
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`imaging industry. I also lead teams which developed an image processing
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`DECLARATION OF KENNETH PARULSKI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,643,168 B2
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`VLSI chipset for digital video cameras, and designed high performance video
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`cameras for industrial and government applications.
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`13. From approximately 1986 through 1992, I served as Kodak’s technical
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`representative to the Advanced Television Research Program at MIT, which
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`developed “source adaptive” video compression technologies now used in
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`most HDTV transmission systems. As part of this project, I became a named
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`inventor on a television decoding patent which was licensed by MIT to many
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`HDTV manufacturers.
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`14. Beginning in 1992, I served as architect of Kodak’s first generation of
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`consumer-oriented digital still cameras, which included the Kodak DC40
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`camera as well as the Apple QuickTake 100 camera, the first digital camera
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`marketed by Apple. In my role as digital camera architect at Kodak and
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`through my participation in various projects I acquired experience in all
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`aspects of digital camera design, including the selection of hardware and
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`software components, user interfaces, and image formats.
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`15. I am a named inventor on more than 200 issued United States patents. Most
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`of these inventions related to digital cameras and digital photography systems,
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`and have been broadly licensed by Kodak to more than 40 companies for use
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`in digital cameras, smartphones, and photo sharing services. Licensing these
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`DECLARATION OF KENNETH PARULSKI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,643,168 B2
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`patents provided Kodak with earnings of more than $2 Billion dollars from
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`2005 to 2010.
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`16. I have authored more than 50 presentations and papers, including invited talks
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`on digital cameras in the US, Europe and Asia. I authored the “Digital
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`Photography” chapter in the Consumer Digital Electronics Handbook by
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`McGraw-Hill 1997, and co-authored the “Color Image Processing for Digital
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`Cameras” chapter in the Digital Color Imaging Handbook; CRC Press 2003. I
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`have also developed and taught Kodak internal courses on video technology
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`and digital cameras.
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`17. I have served as Chair of the IT10 standards committee for digital
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`photography since 1994. This group provides the officially recognized United
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`States input for many international standards used by digital cameras,
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`including smart phone digital cameras. In addition, from March 2007 through
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`February 2013, I was chair of ISO technical committee 42 (ISO/TC42), which
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`is responsible for all international photography standards. In May 2013, I was
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`elected chair of the US technical advisory group to ISO/TC42. From June 3-
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`7, 2013, I served as head of the US delegation to the 23rd plenary meeting of
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`ISO/TC42, held at the National Museum in Copenhagen, Denmark.
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`18. I currently serve as an expert in ISO Technical Committee 42 (Photography),
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`and am co-project leader (with Mr. Toru Nagata of Canon) for both ISO
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`DECLARATION OF KENNETH PARULSKI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,643,168 B2
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`12234-1:2012 Electronic still-picture imaging -- Removable memory -- Part
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`1: Basic removable-memory model, which standardizes image formats,
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`including the Exif image format, used in digital cameras and ISO/WD 12234-
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`3, which is intended to standardize the use of XMP metadata in digital
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`photography.
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`19. I am a Fellow of the Society of Motion Picture and Television Engineers. In
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`2001, Kodak received a Technical Emmy Award for contributions I made to
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`the development of the 24P HDTV production standard, which is used by
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`Hollywood studios to produce movies and TV programs. In 2002, I received
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`the Photo-imaging Manufacturing & Distributors Association Technical
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`Achievement Award for “pioneering work in the development of digital
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`imaging technology,” becoming the first digital photography expert to be
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`honored by this photographic association. In 2008, I received the
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`International Imaging Industries Association (I3A) Achievement Award, for
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`“significant contributions to the advancement and growth of the imaging
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`industry.”
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`20. A copy of my resume is provided as Attachment A at the end of this
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`Declaration.
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`DECLARATION OF KENNETH PARULSKI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,643,168 B2
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`B. Compensation
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`21. I am being compensated at the rate of $525 per hour for the services I am
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`providing in this case. The compensation is not contingent upon my
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`performance, the outcome of this inter partes review or any other proceeding,
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`or any issues involved in or related to this inter partes review.
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`C. Documents and Other Materials Relied Upon
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`22. The documents on which I rely for the opinions expressed in this declaration
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`are documents and materials identified in this declaration, including the 168
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`Patent, related patents and applications in the same family as the 168 Patent,
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`the prosecution histories for the 168 Patent and related family members of the
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`168 Patent, the prior art references and information discussed in this
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`declaration, and any other references specifically identified in this declaration,
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`in their entirety, even if only portions of these documents are discussed here in
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`an exemplary fashion.
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`IV. STATEMENT OF LEGAL PRINCIPLES
`A. Claim Construction
`23. I understand that, when construing claim terms, a claim subject to inter partes
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`review receives the “broadest reasonable construction in light of the
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`specification of the patent in which it appears.” I further understand that the
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`broadest reasonable construction is the broadest reasonable interpretation
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`DECLARATION OF KENNETH PARULSKI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,643,168 B2
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`(BRI) of the claim language, and that any term that lacks a definition in the
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`specification is also given a broad interpretation.
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`B. Anticipation
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`24. I understand that in order for a patent claim to be valid, the claimed invention
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`must be novel. I further understand that if each and every element of a claim
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`is disclosed in a single prior art reference, then the claimed invention is
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`anticipated, and the invention is not patentable according to pre-AIA 35
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`U.S.C. § 102 effective before March 16, 2013. In order for the invention to be
`
`anticipated, each element of the claimed invention must be described or
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`embodied, either expressly or inherently, in the single prior art reference. In
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`order for a reference to inherently disclose a claim limitation, that claim
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`limitation must necessarily be present in the reference. I also understand that
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`a prior art reference must be enabling in order to anticipate a patent claim.
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`C. Obviousness
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`25. I understand that obviousness under pre-AIA 35 U.S.C. § 103 effective before
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`March 16, 2013 is a basis for invalidity. Specifically, I understand that where
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`a prior art reference discloses less than all of the limitations of a given patent
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`claim, that patent claim is invalid if the differences between the claimed
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`subject matter and the prior art reference are such that the claimed subject
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`matter as a whole would have been obvious at the time the invention was
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`DECLARATION OF KENNETH PARULSKI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,643,168 B2
`
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`made to a person having ordinary skill in the relevant art. Obviousness can be
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`based on a single prior art reference or a combination of references that either
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`expressly or inherently disclose all limitations of the claimed invention.
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`V. LEVEL OF ORDINARY SKILL IN THE ART
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`26. I understand that the claims and specification of a patent must be read and
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`construed through the eyes of a person of ordinary skill in the art at the time of
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`the priority date of the claims. I also understand that to determine the
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`appropriate level of a person having ordinary skill in the art, the following
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`factors may be considered: (a) the types of problems encountered by those
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`working in the field and prior art solutions thereto; (b) the sophistication of
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`the technology in question, and the rapidity with which innovations occur in
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`the field; (c) the educational level of active workers in the field; and (d) the
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`educational level of the inventor.
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`27. The relevant technologies to the 168 Patent are those used in digital cameras
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`and other digital imaging devices which capture, compress, store, and
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`wirelessly transmit images, and also provide wireless telephony. The 168
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`Patent describes embodiments which capture a video image using a digital
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`camera, analog camera, or a camcorder, convert the image to a digital format,
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`and transmit the image to a remote location using, for example, the Group-III
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`fax protocol. (See Col. 2, lines 37-45).
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`DECLARATION OF KENNETH PARULSKI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,643,168 B2
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`28. Based on the above considerations and factors, it is my opinion that a person
`
`having ordinary skill in the art would have at least a bachelor’s degree in
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`electrical engineering, computer science, or a related field, and 3-5 years of
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`experience in designing digital imaging devices. This description is
`
`approximate and additional educational experience in digital imaging could
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`make up for less work experience and vice versa.
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`VI. TECHNOLOGY BACKGROUND OF CLAIMED SUBJECT
`MATTER OF THE 168 PATENT
`A. Evolution of Digital Cameras
`
`29. The first known working prototype digital camera was designed by Mr.
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`Steven Sasson of Kodak between 1974 and 1976. This work lead to U.S.
`
`Patent No. 4,131,919, titled “Electronic still camera,” and issued to Lloyd and
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`Sasson. Sasson’s prototype digital camera was publicly revealed for the first
`
`time many decades later, in the digital camera history portion of an invited
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`paper entitled “The Continuing Evolution of Digital Cameras and Digital
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`Photography Systems,” which I personally presented in Geneva, Switzerland
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`at the IEEE International Symposium on Circuits and Systems in May 2000.
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`30. The Sasson prototype digital camera used the lens and optical viewfinder from
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`a Kodak XL55 Super 8mm film movie camera. The image sensor was a
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`Fairchild type 201 CCD array having 100 x 100 pixels. The sensor’s analog
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`DECLARATION OF KENNETH PARULSKI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,643,168 B2
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`output signal was digitized using a 4-bit A/D converter. The prototype
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`camera captured and stored black and white still images using a standard
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`Phillips digital cassette tape. The tape recorded 2275 bits/sec, moving at 5-1/4
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`inches/sec. It took 23 seconds to capture and store each image, and each tape
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`could store up to 30 images.
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`31. Despite this primitive technology, Mr. Sasson recognized that images from
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`electronic cameras could be sent over conventional communication channels
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`with little or no modification, and mentioned this possibility in the 1977
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`Kodak technical report he authored which described the camera and playback
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`system he had just developed. (See “Driving desired futures – turning design
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`thinking into real innovation”, Shamiyeh, Birkhauser Verlag GmbH, Basel,
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`2014, pp. 238-247)
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`32. On Aug 24, 1981, Sony chairman Akio Morita demonstrated the Sony
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`MAVICA electronic still camera and described the Sony MAVICA system,
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`which included a printer and a telephone transmission unit for transmitting
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`images captured by the MAVICA camera. I personally attended the IEEE
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`Conference on Consumer Electronics in June 1982, where Sony presented
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`their first technical papers describing their MAVICA camera and transmission
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`system. The MAVICA camera stored up to 50 images on an approximately 2”
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`MAVIPAK floppy disk (See Kihara, et al, “The electronic still camera – a
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`DECLARATION OF KENNETH PARULSKI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,643,168 B2
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`new concept in photography,” IEEE Trans Consumer Electronics, Vol. CE-28,
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`No. 3, Aug 1982). A slightly modified version of the “MAVIPAK” was later
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`standardized as the “still video floppy” (SVF).
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`33. Canon was the first company to sell electronic still cameras in the US, when
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`they introduced the Canon RC-701 electronic camera in 1986. The Canon
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`RC-701 system components included the camera, a player/recorder, a printer,
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`and a unit for phone transmission of images captured by the camera. Early
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`prototypes of the camera and phone transmission unit were designed for the
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`1984 Los Angeles Olympic Games so that images of Olympic events could be
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`captured with the camera and wirelessly transmitted using the Canon
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`electronic transmitter connected to an automobile telephone to a Japanese
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`newspaper, Yomiuri Shimbun. (See http://www.canon.com/camera-
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`museum/history/canon_story/1976_1986/1976_1986.html)
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`34. By 1989, many other companies, including Fuji, Konica, Minolta, Nikon,
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`Olympus, Sony and Panasonic were selling electronic still cameras using the
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`SVF format. (See Kriss, et al. “Critical technologies for electronic still
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`imaging systems,” SPIE vol. 1082, pp. 157-184 at p. 159) Systems assembled
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`from products available at the time included the ability to send images
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`anywhere in the world, using image transceivers connected to telephone
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`communication systems. (ibid at p.158)
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`DECLARATION OF KENNETH PARULSKI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,643,168 B2
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`35. All digital cameras envisioned, designed or produced prior to the 1998 priority
`
`date of the 168 Patent include essentially the same fundamental components:
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`an optics section that receives the light from an object, a semiconductor image
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`sensor, such as a CCD array, that receives the light and produces
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`corresponding electrical signals, an analog-to-digital converter that converts
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`the analog signals into digital image data, at least one processing component,
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`such as a microprocessor or specialized circuitry which controls image capture
`
`operations and performs subsequent digital image processing, and a memory
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`which stores the digital images. The very same fundamental components that
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`were known as early as the 1970s appear as claim elements in the 168 Patent.
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`B.
`
`Image Processing in Digital Cameras
`
`36. By the early 1990s, it was widely known that digital camera images could be
`
`processed using custom hardware circuitry or using programmable processors
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`which execute software algorithms. For example, the first publication
`
`describing an experimental digital camera was made by NHK in 1983 (See
`
`“Fully Digitalized Electronic Still Camera”, Ohnishi, et. al., J. Inst. TV Engnrs
`
`of Japan, Vol. 37, No. 10 (1983) pp. 863-868). In this camera, images were
`
`captured by a color image sensor and stored using a detachable static RAM
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`memory. An Intel 8086 microprocessor, located in a playback device, was
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`DECLARATION OF KENNETH PARULSKI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,643,168 B2
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`used to perform image processing, including color separation, white balance,
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`and gamma correction.
`
`37. Custom digital processing integrated circuits were then developed for use in
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`digital still and video cameras. (See “A Basic Approach to a Digital Color
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`Camera System”, O’Keefe, et al., IEEE Trans on Consumer Electronics, Vol.
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`CE-30, No. 3, Aug. 1984, pp 409-415 and “A High-Performance Digital Color
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`Video Camera”, Parulski et al., SPIE Vol. 1448 Camera and Input Scanner
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`Systems, 1991, pp 45-58). These hardwired integrated circuits performed
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`specific digital image processing functions, in order to rapidly produce full-
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`color images from a single-chip color image sensor. A microprocessor could
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`be used to set some of the image processing parameters, in order to perform
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`functions such as white balancing and flare correction, and adjust the
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`processing to match the user’s preferences.
`
`38. Digital cameras developed as early as the 1980s included a software
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`programmable processor which controlled the camera hardware in order to
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`capture, store, and retrieve images. For example, the world’s first D-SLR
`
`camera, which was called the “Electro-optic” camera and was designed and
`
`constructed by Eastman Kodak Company under a U.S. Government contract
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`between 1987 and 1988, used software commands executed by an Intel
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`80C196 16 bit microcontroller to control the camera. (See
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`DECLARATION OF KENNETH PARULSKI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,643,168 B2
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`http://eocamera.jemcgarvey.com/). The software commands were written in
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`the PL/M language, and included, for example, commands which opened the
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`camera shutter and exposed the image sensor to light, controlled a SCSI
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`magnetic hard disk drive in order to write and read image data, and controlled
`
`the camera status display module. (See
`
`http://eocamera.jemcgarvey.com/pdf/firmware.pdf).
`
`C.
`
`Proliferation of Commercially Available Digital Cameras
`
`39. The Fuji DS-1P digital camera, announced in September 1988, was the first
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`digital still camera to be publicly demonstrated. The camera stored digital
`
`images using a removable card having RAM semiconductor memory ICs.
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`Rechargeable batteries on the removable card were used to power the RAM,
`
`in order to retain the images. In 1990, Dycam introduced their “Model 1”
`
`portable digital still camera, the first digital camera with a list price of under
`
`$1,000. The Dycam Model 1 stored up to 32 monochrome, QVGA resolution
`
`(376 x 240 pixel) images in internal RAM memory, which was continuously
`
`powered by batteries in order to retain the images. (See “Point and shoot
`
`digital electronic camera introduced”, Electronic Photography News, Sept
`
`1990, p. 7)
`
`40. In 1991, Kodak introduced the Kodak Professional Digital Camera System,
`
`later known as the DCS-100, which consisted of a camera back fitted to a
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`DECLARATION OF KENNETH PARULSKI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,643,168 B2
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`Nikon F3 camera and a separate digital storage unit (DSU) connected to the
`
`camera back using a digital interconnect cable. The DSU included a magnetic
`
`hard drive which stored the captured images and an LCD display which
`
`displayed a user interface and the images captured by the digital camera. The
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`DSU also included a set of 12 keys which enabled the camera operator to
`
`select images and perform operations such as image transmission. The DSU
`
`also included a keyboard connector, which enabled the user to enter text, such
`
`as image titles, captions, and keywords, using a separate keyboard. A Telebit
`
`T2500 modem was used to transmit user-selected image files from the digital
`
`storage unit over a telephone line to a remote Macintosh computer. Captured
`
`images were selected for transmission using the display and keys on the DSU.
`
`(See “User’s Manual, Kodak Professional Digital Camera System”, 1991-
`
`1992)
`
`41. The Apple QuickTake 100 was introduced in February 1994. I was the
`
`architect of the Apple QuickTake 100 and 150 cameras, which were designed
`
`by Kodak and marketed by Apple. The QuickTake 100 stored a maximum of
`
`8 VGA (640 x 480 pixels) “high resolution” images or 32 QVGA (320 x 240
`
`pixels) “standard resolution” images in a 1 MB internal Flash EPROM
`
`memory. The digital images were compressed prior to storage in the camera
`
`using a Kodak developed ADPCM (Adaptive Differential Pulse Code
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`DECLARATION OF KENNETH PARULSKI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,643,168 B2
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`Modulation) software compression algorithm contained in the camera’s
`
`firmware memory. In 1994, I co-authored a paper at the Imaging Science and
`
`Technology (IS&T) Conference that detailed the architecture and components
`
`of this camera. The presentation was subsequently published as “Digital,
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`Still-Optimized Architecture for Electronic Photography”, IS&T’s 47th
`
`Annual Conference/ICPS 1994, pp. 665-667, which is reproduced in
`
`Attachment B at the end of this Declaration. The digital image compression
`
`algorithm in this camera was executed by a Texas Instruments (TI) digital
`
`signal processor (DSP), controlled by Kodak developed software instructions.
`
`The TI DSP read the image data from a RAM buffer memory, performed
`
`image compression, and stored the compressed image data in the camera’s
`
`Flash EPROM memory.
`
`42. I was also the architect of the Kodak DC40 camera, which was introduced in
`
`April 1995. The DC40 used 4 Mbytes of internal Flash EPROM memory to
`
`store 48 images at 400K pixel resolution, or 99 lower resolution images. It
`
`took approximately 6 seconds in order to capture, compress, and store each
`
`digital image. The camera used an improved Kodak designed RADC (Rate
`
`Adaptive Different Compression) image compression algorithm, which was
`
`executed by a TI DSP within the camera. (See “The digital camera using new
`
`compression and interpolation algorithm”, Shimizu et. al., SPSTJ 70th
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`DECLARATION OF KENNETH PARULSKI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,643,168 B2
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`Anniversary Symposia on Fine Imaging, pp 69-72, Oct 1995, Tokyo, Japan, in
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`Japanese)
`
`43. The Olympus VC-1100 camera, introduced in 1994, included image
`
`transmission capabilities. The user could connect an accessory modem to the
`
`VC-1100 and transmit digital photos over cellular and analog phone lines to a
`
`s