UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SONOS, INC.
`Petitioner
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`v.
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`BLACK HILLS MEDIA LLC
`Patent Owner
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`DECLARATION OF ANDREW WOLFE IN SUPPORT OF THE INTER
`PARTES REVIEWS OF U.S. PATENT NOS. 6,757,517 AND 7,236,739
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`SONOS 1016 - Page 1
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SONOS, INC.
`Petitioner
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`v.
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`BLACK HILLS MEDIA LLC
`Patent Owner
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`DECLARATION OF ANDREW WOLFE IN SUPPORT OF THE INTER
`PARTES REVIEWS OF U.S. PATENT NOS. 6,757,517 AND 7,236,739
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`I, Andrew Wolfe, declare and state as follows:
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`I.
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`INTRODUCTION
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`1.
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`I have been retained as an expert witness for the Inter Partes Reviews
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`(“IPRs”) of U.S. Patent Nos. 6,757,517 (“the ‘517 Patent”) and 7,236,739 (“the
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`‘739 Patent”) filed by Sonos, Inc. (“Sonos”) against Black Hills Media LLC
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`(“BHM”). More specifically, I have been asked to render opinions for these IPRs
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`as to the patentability of Claims 6 and 13 of the ‘517 Patent and Claims 2 and 9 of
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`the ‘739 Patent (collectively “the Challenged Claims”).
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`2.
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`It is my understanding that the ‘739 Patent is a continuation of the
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`‘517 Patent, and that both of these patents share the same written description.
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`II. BACKGROUND AND QUALIFICATIONS
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`3.
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`A copy of my Curriculum Vitae (“CV”) is attached to this declaration
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`as Appendix 1.
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`4.
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`I have more than 30 years of experience as a computer architect,
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`computer system designer, personal computer graphics designer, educator, and
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`executive in the electronics industry. A detailed record of my professional
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`qualifications is attached as Appendix 1 to this declaration and summarized below.
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`5.
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`In 1985, I earned a B.S.E.E. degree in Electrical Engineering and
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`Computer Science from The Johns Hopkins University. In 1987, I received an
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`M.S. degree in Electrical and Computer Engineering from Carnegie Mellon
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`University. In 1992, I received a Ph.D. in Computer Engineering from Carnegie
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`Mellon University. My doctoral dissertation proposed a new approach for the
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`architecture of a computer processor.
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`6.
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`In 1983, I began designing touch sensors, microprocessor-based
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`computer systems, and I/O (input/output) cards for personal computers as a senior
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`design engineer for Touch Technology, Inc. During the course of my design
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`projects with Touch Technology, I designed I/O cards for PC-compatible computer
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`systems, including the IBM PC-AT, to interface with interactive touch-based
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`computer terminals that I designed for use in public information systems. I
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`continued designing and developing related technology as a consultant to the
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`Carroll Touch division of AMP, Inc., where in 1986 I designed one of the first
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`custom touch screen integrated circuits.
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`7.
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`From 1986 through 1987, I designed and built a high-performance
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`computer system as a student at Carnegie Mellon University. From 1986 through
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`early 1988, I also developed the curriculum, and supervised the teaching
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`laboratory, for processor design courses.
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`8.
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`In the latter part of 1989, I worked as a senior design engineer for
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`ESL-TRW Advanced Technology Division. While at ESL-TRW, I designed and
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`built a bus interface and memory controller for a workstation-based computer
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`system, and also worked on the design of a multiprocessor system.
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`9.
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`At the end of 1989, I (along with some partners) reacquired the rights
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`to the technology I had developed at Touch Technology and at AMP, and founded
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`The Graphics Technology Company. Over the next seven years, as an officer and
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`a consultant for The Graphics Technology Company, I managed the company’s
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`engineering development activities and personally developed dozens of touch
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`screen sensors, controllers, and interactive touch-based computer systems.
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`10.
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`I have consulted, formally and informally, for a number of fabless
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`semiconductor companies. In particular, I have served on the technical advisory
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`boards for two processor design companies: BOPS, Inc., where I chaired the board,
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`and Siroyan Ltd., where I served in a similar role for three networking chip
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`companies—Intellon, Inc., Comsilica, Inc, and Entridia, Inc.—and one 3D game
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`accelerator company, Ageia, Inc.
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`11.
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`I have also served as a technology advisor to Motorola and to several
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`venture capital funds in the U.S. and Europe. Currently, I am a director of Turtle
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`Beach Corporation, providing guidance in its development of premium audio
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`peripheral devices for a variety of commercial electronic products.
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`12. From 1991 through 1997, I served on the Faculty of Princeton
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`University as an Assistant Professor of Electrical Engineering. At Princeton, I
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`taught undergraduate and graduate-level courses in Computer Architecture,
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`Advanced Computer Architecture, Display Technology, and Microprocessor
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`Systems, and conducted sponsored research in the area of computer systems and
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`related topics. I was also a principal investigator for DOD research in video
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`technology and a principal investigator for the New Jersey Center for Multimedia
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`Research. From 1999 through 2002, I taught the Computer Architecture course to
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`both undergraduate and graduate students at Stanford University multiple times as
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`a Consulting Professor. At Princeton, I received several teaching awards, both
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`from students and from the School of Engineering. I have also taught advanced
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`microprocessor architecture to industry professionals in IEEE and ACM sponsored
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`seminars. I am currently a lecturer at Santa Clara University teaching graduate
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`courses on Computer Organization and Architecture and undergraduate courses on
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`electronics and embedded computing.
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`13. From 1997 through 2002, I held a variety of executive positions at a
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`publicly-held fabless semiconductor company originally called S3, Inc. and later
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`called Sonicblue Inc. I held the positions of Chief Technology Officer, Vice
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`President of Systems Integration Products, Senior Vice President of Business
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`Development, and Director of Technology, among others. At the time I joined S3,
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`the company supplied graphics accelerators for more than 50% of the PCs sold in
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`the United States.
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`14. Beginning in 1998, I began to work closely with S3’s largest
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`customer, Diamond Multimedia, to explore possible opportunities for a merger.
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`My investigation included evaluating the technology, market, and business model
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`related to the “Diamond Rio PMP300,” the first commercially viable flash-memory
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`MP3 player. In 1999, I led the merger negotiations between the two companies,
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`managed significant parts of company integration, and, after the merger was
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`complete, worked on new product development. Soon after the merger with
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`Diamond Multimedia, I helped introduce the “Diamond Rio PMP500,” a portable
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`music player that included USB capability and also the ability to play downloaded
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`files purchased from the Audible.com website. I also helped develop relationships
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`with MP3 music vendors, including eMusic and MP3.com.
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`15. While at Diamond Multimedia, I also helped develop the Rio 600 and
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`800 MP3 players, which included support for digital rights management (“DRM”)
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`protected music, using protocols from Microsoft. During the development of the
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`PMP500 and the Rio 600, I also helped develop a music delivery platform and
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`webstore backend service for selling DRM-protected music. In 1999, this business
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`segment was spun out as a separate company called RioPort.com. I served on the
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`RioPort.com board of directors and became involved in their product and
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`technology strategy. For example, I was involved in RioPort.com becoming the
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`provider of the backend services for what was known at the time as the
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`BestBuy.com music store and the MTV.com music store. I also worked with
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`Microsoft and various music studios in developing strategies, business models, and
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`technologies for DRM-protected music delivery. Further, I worked with a
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`company established by Sony Music Entertainment and Universal Music Group,
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`initially called “Duet,” that was created to deliver online music subscriptions to
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`users. While working on Duet, we developed a technology and business model
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`using Microsoft’s DRM solution that allowed monthly subscribers to download as
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`much music as they wanted to a Rio 600 and play the downloaded music offline.
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`This subscription download service launched as the “Pressplay” music service and
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`was later renamed “Napster.” I also managed engineering and marketing for the
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`Rio product line for a period of time as an interim general manager. I was also an
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`investor in Rioport.com.
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`16.
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`I served as a board member and technical advisor at KBGear Inc.
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`from 1999-2001. KBGear Inc. designed and produced digital cameras and music
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`players that included flash memory and/or used flash memory cards.
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`17.
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`I have published more than 50 peer-reviewed papers in computer
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`architecture and computer systems and IC design.
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`18.
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`I also have chaired IEEE and ACM conferences in microarchitecture
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`and integrated circuit design and served as an associate editor for IEEE and ACM
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`journals.
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`19.
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`20.
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`I am a named inventor on 41 U.S. patents and 26 foreign patents.
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`In 2002, I was the invited keynote speaker at the ACM/IEEE
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`International Symposium on Microarchitecture and at the International Conference
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`on Multimedia. From 1990 through 2005, I have also been an invited speaker on
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`various aspects of technology and the PC industry at numerous industry events
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`including the Intel Developer’s Forum, Microsoft Windows Hardware Engineering
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`Conference, Microprocessor Forum, Embedded Systems Conference, Comdex, and
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`Consumer Electronics Show, as well as at the Harvard Business School and the
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`University of Illinois Law School. I have been interviewed on subjects related to
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`computer graphics and video technology and the electronics industry by
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`publications such as the Wall Street Journal, New York Times, Los Angeles
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`Times, Time, Newsweek, Forbes, and Fortune as well as CNN, NPR, and the BBC.
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`I have also spoken at dozens of universities including MIT, Stanford, University of
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`Texas, Carnegie Mellon, UCLA, University of Michigan, Rice, and Duke.
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`III. COMPENSATION
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`21.
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`I am being compensated for the time that I spend consulting on these
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`IPRs at a rate of $450 per hour. My compensation is not dependent upon the
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`outcome of these IPRs.
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`IV. MATERIALS CONSIDERED
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`22.
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`In developing my opinions for these IPRs, I reviewed, among other
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`things, the ‘517 and ‘739 Patents, their prosecution histories, and numerous prior art
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`references in the relevant field of technology.
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`V. LEGAL STANDARDS
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`23.
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`I am not an attorney, and I will offer no opinions on the law.
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`However, I have an understanding of several principles concerning invalidity (and
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`other legal issues). I understand that a patent claim can be invalid under the United
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`States patent laws for various reasons, including, for example, anticipation or
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`obviousness in light of the prior art. In arriving at my opinions, I have applied the
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`following legal standards and analyses:
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`A. Anticipation
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`24. Regarding the legal doctrine of anticipation, my understanding is as
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`follows.
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`25. A claim is anticipated if the claimed invention was known or used by
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`others in the United States, or patented or described in a printed publication in the
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`United States or a foreign country, before the patentee invented the claimed
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`invention.
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`26. Also, a claim is anticipated if the claimed invention was patented or
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`described in a printed publication in the United States or a foreign country or in
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`public use or on sale in the United States, more than one year prior to the date that
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`the patentee filed an application for patent directed to the claimed invention.
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`27. Additionally, a claim is anticipated if the claimed invention was
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`described in either (1) a published patent application filed by another in the United
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`States before the patentee invented the claimed invention or (2) a patent granted on
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`an application for patent by another filed in the United States before the patentee
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`invented the claimed invention.
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`28. Anticipation must be found in a single reference, device, or process.
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`29. For a prior art reference to anticipate, each claim limitation, as
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`properly construed, must be disclosed, either expressly or inherently, in the prior
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`art reference, and the claimed arrangement or combination of those limitations
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`must also be disclosed, either expressly or inherently, in the prior art reference.
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`30. The requirement that the prior art limitations themselves be “arranged
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`as in the claim” means that claims cannot be treated as mere catalogs of separate
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`parts, in disregard of the part-to-part relationships set forth in the claims that give
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`the claims their meaning.
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`31.
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`In addition, the description provided in the prior art reference must be
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`such that a person of ordinary skill in the art in the field of invention could, based
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`on the reference, practice the invention without undue experimentation.
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`32. Although anticipation cannot be established through a combination of
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`references, additional references may be used to interpret an allegedly anticipating
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`reference by, for example, indicating what the allegedly anticipating reference
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`would have meant to one of ordinary skill in the art. For the claim to be
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`anticipated, however, the additional references must make clear that the missing
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`descriptive matter is inherent to the features described in the prior art references. In
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`other words, the missing feature is necessarily or implicitly present in the allegedly
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`anticipating reference.
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`33. For a prior art device to anticipate, each claim limitation, as properly
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`construed, must be embodied in the prior art device.
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`34.
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`If a prior art device, in its normal and usual operation, would
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`necessarily perform the method claimed, then the method claimed is anticipated by
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`the prior art device. When the prior art device is the same as a device described in
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`the specification for carrying out the claimed method, it can be assumed the device
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`will inherently perform the claimed process.
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`B. Obviousness
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`35. Regarding the legal doctrine of obviousness, my understanding is as
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`follows.
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`36. A claim may be invalid even if each and every claim limitation is not
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`present or disclosed in a single prior art reference or device.
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`37. Under the doctrine of obviousness, a claim may be invalid if the
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`differences between the invention and the prior art are such that the subject matter
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`as a whole would have been obvious at the time the invention was made to a
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`person having ordinary skill in the art to which the subject matter pertains.
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`38. A person of ordinary skill in the art is presumed to have knowledge of
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`the relevant prior art at the time of the claimed invention.
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`39. Obviousness is based on the scope and content of the prior art, the
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`differences between the prior art and the claim, the level of ordinary sill in the art
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`and secondary indicia of obviousness and non-obviousness to the extent such
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`indicia exist.
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`40. The scope of the prior art comprises any prior art that was reasonably
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`pertinent to the particular problems the inventor faced.
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`41. The determination of whether patent claims would have been obvious
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`to a person of ordinary skill in the art and, therefore, invalid, is not governed by
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`any rigid test or formula. Instead, a determination that a claim is obvious is based
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`on a common sense determination that the claimed invention is merely a
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`combination of known limitations to achieve predictable results.
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`42. Any of the following rationales are acceptable justifications to
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`conclude that a claim would have been obvious:
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`A. the claimed invention is a combination of known prior art methods to
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`yield predictable results;
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`B. the claimed invention is a substitution of one known element for
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`another to obtain predictable results;
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`C. the claimed invention uses known techniques to improve similar
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`devices (methods, or products) in the same way;
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`D. the claimed invention applies a known technique to a known device
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`(method, or product) ready for improvement to yield predictable
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`results;
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`E. the claimed invention was “obvious to try” – choosing from a finite
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`number of identified, predictable solutions, with a reasonable
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`expectation of success;
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`F. there is known work in one field of endeavor that may prompt
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`variations of it for use in either the same field or a different one based
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`on design incentives or other market forces if the variations would
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`have been predictable to one of ordinary skill in the art; or
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`G. there is some teaching, suggestion, or motivation in the prior art that
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`would have led one of ordinary skill in the art to modify the prior art
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`reference to combine prior art teachings to arrive at the claimed
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`inventions.
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`43.
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`In addition, a claim can be obvious in light of a single reference,
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`without the need to combine references, if the claim is obvious in view of the
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`common sense or knowledge of one of ordinary skill in the art.
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`44. An analysis of whether a claimed invention is obvious must not rely
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`on a hindsight combination of prior art. Instead, the analysis must proceed in the
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`context of the time of the invention or claimed priority date and consider whether
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`the invention as a whole would have been obvious to a person of ordinary skill in
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`the art, taking into consideration any interrelated teachings of the prior art, the
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`effects of demands known to the design community or present in the marketplace,
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`and the background knowledge possessed by a person having ordinary skill in the
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`art, all in order to determine whether there was an apparent reason to combine any
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`known elements in the fashion claimed by the patent at issue.
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`45. Secondary indicia of non-obviousness may include, for example:
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`A. a long felt but unmet need in the prior art that was satisfied by the
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`invention of the patent;
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`B. commercial success of a product or process covered by the patent;
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`C. unexpected results achieved by the invention;
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`D. praise of the invention by others skilled in the art;
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`E. taking of licenses under the patent by others; and
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`F. deliberate copying of the invention.
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`46.
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`I also understand that these secondary considerations are only relevant
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`to obviousness if there is a connection, or nexus, between them and the invention
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`covered by the patent claims. For example, commercial success is relevant to
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`obviousness only if the success of the product is related to a feature of the patent
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`claims. If commercial success is due to advertising, promotion, salesmanship or
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`the like, or is due to features of the product other than those claimed in the patents-
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`in-suit, then any commercial success should not be considered an indication of
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`non-obviousness.
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`47.
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`In forming my opinions on obviousness, I have not seen any evidence
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`that supports any secondary considerations.
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`C.
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`48.
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`Priority Date and Date of Invention
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`I understand that multiple dates may be relevant to a claimed
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`invention and the prior art that may be asserted against a claim.
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`49.
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`I am informed that in the underlying litigation, BHM has indicated
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`that it will not rely on any date prior to the May 10, 2001 filing date of the
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`application that issued as the ‘517 Patent. Therefore, it is my understanding that
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`for purposes of these IPRs, the priority date and date of invention for the ‘517 and
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`‘739 Patents is May 10, 2001, and I have analyzed the Challenged Claims of the
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`‘517 and ‘739 Patents using this May 10, 2001 priority date and date of invention.
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`VI. CLAIM CONSTRUCTION
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`50. My opinions related to the issue of patentability of the ‘517 and ‘739
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`Patents are based upon the claim constructions set forth in Sonos’s Petitions for
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`Inter Partes Review of the ‘517 and ‘739 Patents (“the Petitions”). To the extent
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`that a claim construction is not provided in the Petitions for a particular claim term
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`or element, I used the ordinary and customary meaning of the word(s), as would be
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`understood by one of ordinary skill in the art in the context of the field of the
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`invention at the time of the invention, to construe such a claim term or element.
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`VII. LEVEL OF ORDINARY SKILL IN THE ART
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`51. Based upon my personal knowledge and experience in the fields of
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`networking and consumer audio systems, in my opinion, a person of ordinary skill
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`in the art relevant to the ‘517 and ‘739 Patents at the time of the alleged inventions,
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`would have the equivalent of a four-year degree from an accredited institution
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`(usually denoted as a B.S. degree) in computer science, computer engineering,
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`electrical engineering, or the equivalent, and approximately 2-4 years of
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`professional experience in the fields of networking and consumer audio systems, or
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`an equivalent level of skill and knowledge.
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`52.
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`In forming the opinions set forth in this declaration, I applied this
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`level of ordinary skill in the art.
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`VIII. THE FIELD OF ART FOR THE ‘517 AND ‘739 PATENTS
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`53. The ‘517 and ‘739 Patents are in the field of media (e.g., music)
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`sharing and playback among multiple media player devices in a wireless network.
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`See, e.g., ‘517 Patent, 1:8-12 (“The present invention relates to a method and an
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`apparatus for music playback. More particularly, the present invention relates to a
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`method and an apparatus for coordinated and synchronized music playback in local
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`spatial proximity with wireless ad hoc networks.”); ‘517 Patent, 1:46-50 (“[I]t is an
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`objective of the present invention to provide a method and an apparatus that use
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`wireless ad-hoc networks to coordinate and synchronize song playback between
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`two or more users who wish to share mutual music listening.”).
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`IX. CLAIM LIMITATIONS OF THE ‘517 AND ‘739 PATENTS FOUND
`IN THE PRIOR ART
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`54. The ‘517 and ‘739 Patents identify purported shortcomings of prior art
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`audio systems that are supposedly overcome by the alleged invention(s) of the
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`Challenged Claims.
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`55. For example, the ‘517 and ‘739 Patents allege that, at the time of the
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`purported invention(s) of the ‘517 and ‘739 Patents, a group of music listeners
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`could not share and simultaneously listen to the same music on portable playback
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`devices such as a Walkman or portable CD player. ‘517 Patent, 1:15-30. These
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`alleged shortcomings of the prior art are addressed in the Challenged Claims, each
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`of which recites simultaneous playback of music on two playback devices.
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`Specifically, each of the Challenged Claims uses one of the terms “synchrony,”
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`“synchronously,” and “synchronizing,” to describe music playback on two devices.
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`56. The Challenged Claims are also directed to music playback devices
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`that are wirelessly connected to each other through an ad-hoc network. ‘517
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`Patent, 1:15-30. Specifically, each of the Challenged Claims requires the
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`establishment of “a wireless ad-hoc network” between the two devices.
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`57. The specification and claims of the ‘517 and ‘739 Patents expressly
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`identify Bluetooth as a preferred wireless ad-hoc network protocol for
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`implementing the alleged invention. See, e.g., ‘517 Patent, 1:24-28, 3:22-26, claim
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`23, and claim 29. In fact, the Challenged Claims merely describe (i) the standard
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`process for two Bluetooth devices to establish a wireless ad-hoc network
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`connection, combined with the allegedly novel “synchronous” playback of music
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`or (ii) the standard components of a Bluetooth device, combined with the ability
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`for the allegedly novel “synchronous” playback of music.
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`58. The Bluetooth Specification confirms the identification in the ‘517
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`Patent. The very title of the Bluetooth Specification identifies it as: “The ad hoc
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`SCATTERNET for affordable and highly functional wireless connectivity.” Core
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`Bluetooth Specification v1.0 A, p. 1.
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`59. The disclosure of the prior art references described herein show that,
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`contrary to the assertions in the ‘517 and ‘739 Patents, (i) the prior art already
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`addressed the supposed shortcomings identified in the ‘517 and ‘739 Patents and
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`(ii) the limitations recited in the Challenged Claims of the ‘517 and ‘739 Patents
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`were known and used by others in the fields of networking and audio playback
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`devices – not patentable advancements over prior art audio systems.
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`60. The extensive prior art, as shown and described in the references
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`discussed herein, illustrates that the Challenged Claims of the ‘517 and ‘739
`
`Patents were anticipated and/or rendered obvious at the time of the purported
`
`invention of the ‘517 and ‘739 Patents, i.e., May 10, 2001.
`
`X. BLUETOOTH AD-HOC NETWORKS AND DEVICES
`
`
`61. The Core Bluetooth Specification v1.0 A was released on July 26,
`
`1999. From its release in 1999 until the release of v1.1 in 2002, the Core
`
`Bluetooth Specification v1.0 A specified the requirements that needed to be met in
`
`order for a particular product to “comply with the [Bluetooth] Specification.” See,
`
`e.g., Core Bluetooth Specification v1.0 A, p. 811; see also, pp. 812-821.
`
`62. Although Core Bluetooth Specification v1.0 B was released on
`
`December 1, 1999, v1.0 B revised v1.0 A “from a linguistic point of view,” and
`
`only made minor changes to the Bluetooth Specification. See, e.g., Core Bluetooth
`
`Specification v1.0 B, pp. 868-878. For ease of reference, this declaration cites
`
`only to the Core Bluetooth Specification v1.0 A; however, it should be appreciated
`
`that the corresponding disclosure in the Core Bluetooth Specification v1.0 B is also
`
`applicable here. These specifications are referred to herein as the “Bluetooth
`
`Specification.”
`
`63. One of ordinary skill in the art would recognize Bluetooth as a
`
`standardized technology that is governed by the Bluetooth Specification, which
`
`
`
`18
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`SONOS 1016 - Page 19
`
`
`
`
`
`defines how Bluetooth-enabled devices connect and communicate with each other.
`
`See Core Bluetooth Specification v1.0 B, pp. 811-821. Chapter 1 of the Bluetooth
`
`Specification,
`
`titled “Scope,” states
`
`that “[t]his specification defines
`
`the
`
`requirements for a Bluetooth transceiver operating in this unlicensed band.” Id. at
`
`p. 18. “Requirements are defined for two reasons: Provide compatibility between
`
`the radios uses in the system[; and] Define the quality of the system.” Id. As such,
`
`one of ordinary skill in the art would understand that if a prior art reference
`
`expressly discloses using Bluetooth for communications between devices, then the
`
`corresponding communications between those devices must be consistent with the
`
`Bluetooth Specification.
`
`64.
`
`“Bluetooth is a short-range radio link intended to be a cable
`
`replacement between portable and/or fixed electronic devices.” Core Bluetooth
`
`Specification v1.0 A, p. 41.
`
`65. The Bluetooth system consists of a radio unit, a link control unit, and
`
`a support unit for link management and host terminal interface functions. Id. A
`
`functional block diagram of the Bluetooth system is shown in Figure 1.1 on page
`
`41:
`
`
`
`19
`
`SONOS 1016 - Page 20
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`
`
`
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`
`
`66. As shown in Figure 1.1, in the Bluetooth system, a wireless
`
`transceiver (radio) communicates with a controller (link controller), which in turn
`
`communicates with a host (e.g., an audio playback device). See, e.g., Core
`
`Bluetooth Specification v1.0 A, p. 18; p. 41. T he Bluetooth link controller
`
`manages the Bluetooth “link” (or connection) and supports the establishment of an
`
`ad-hoc network over the Bluetooth radio (wireless transceiver). As explained in
`
`more detail below, the transceiver and controller are used to establish a wireless
`
`ad-hoc network between a plurality of Bluetooth-enabled devices. See, e.g., Core
`
`Bluetooth Specification v1.0 A, p. 1 (“The ad-hoc SCATTERNET for affordable
`
`and functional wireless connectivity”); p. 18; pp. 41-42; p. 88; p. 497 (“ad-hoc
`
`characteristics of the Bluetooth environment”); pp. 536-538; p. 545; pp. 551-552;
`
`pp. 562-563; p. 881; pp. 1023-1032.
`
`67. As described in the Bluetooth Specification:
`
`The Bluetooth system provides a point-to-point connection (only two
`Bluetooth units involved), or a point-to-multipoint connection. In the
`point-to-multipoint connection, the channel is shared among several
`
`
`
`20
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`SONOS 1016 - Page 21
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`
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`Bluetooth units. Two or more units sharing the same channel form a
`piconet. One Bluetooth unit acts as the master of the piconet, whereas
`the other unit(s) host acts as slave(s). Up to seven slaves can be active
`in the piconet. . . . Multiple piconets with overlapping coverage areas
`form a scatternet. Each piconet can only have a single master.
`However, slaves can participate in different piconets on a time-
`division multiplex basis. In addition, a master in one piconet can be a
`slave in another piconet. The piconets shall not be time or frequency
`synchronized. Each piconet has its own hopping channel.
`
`Core Bluetooth Specification v1.0 A, pp. 41-42.
`
`68. Various Bluetooth piconets are shown in Figure 1.2 on page 42:
`
`
`
`69.
`
`“By definition, the master is represented by the Bluetooth unit that
`
`initiates the connection (to one or more slave units). Note that the names ‘master’
`
`and ‘slave’ only refer to the protocol on the channel: the Bluetooth units
`
`themselves are identical; that is, any unit can become a master of a piconet. Once
`
`
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`21
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`SONOS 1016 - Page 22
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`
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`a piconet has been established, master-slave roles can be exchanged.” Core
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`Bluetooth Specification v1.0 A, p. 95.
`
`70. The Bluetooth Specification has specific “Bluetooth Audio” sections
`
`dedicated to the use of Bluetooth for the streaming, transferring, and playback of
`
`audio signals. Core Bluetooth Specification v1.0 A, pp. 139-142; pp. 969-976. As
`
`stated in the Bluetooth Specification, “[t]he recommendation is formed such that a
`
`smooth audio interface of a Bluetooth terminal to other audio, electronic devices
`
`and cellular terminal equipment could be carried out.” Id. at 969. Thus, one type
`
`of Bluetooth-enabled electronic device is an audio (or more generally, media)
`
`playback device.
`
`71. The Bluetooth Specification further teaches the use of Bluetooth for
`
`synchronized communications. Core Bluetooth Specification v1.0 A, p. 41 (“The
`
`Bluetooth protocol uses a combination of circuit and packet switching. Slots can
`
`be reserved for synchronous packets. Bluetooth can support an asynchronous data
`
`channel, up to three simultaneous synchronous voice channels, or a channel which
`
`simultaneously supports asynchronous data and synchronous voice. Each voice
`
`channel supports a 64 kb/s synchronous (voice) channel in each direction.”); p. 45
`
`(“Between master and slave(s), different types of links can be established. Two
`
`link types have been defined: Synchronous Connection-Oriented (SCO) link [and]
`
`
`
`22
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`SONOS 1016 - Page 23
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`
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`
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`Asynchronous Connection-Less (ACL) link.”); p. 249 (“SCO links support real-
`
`time voice traffic using reserved bandwidth.”).
`
`72. Bluetooth-enabled electronic devices (e.g., Bluetooth-enabled audio
`
`playback devices) exchange messages to establish a wireless ad-hoc network. See,
`
`e.g, Core Bluetooth Specification v1.0 A, p. 1 (“The ad-hoc SCATTERNET for
`
`affordable and functional wireless connectivity”); p. 18; pp. 41-42; p. 88; p. 497
`
`(“ad-hoc characteristics of the Bluetooth environment”); pp. 536-538; p. 545; pp.
`
`551-552; pp. 562-563; p. 881 (“The Bluetooth baseband specifies the medium
`
`access and physical layers procedures to support the exchange of real-time voice
`
`and data information streams and ad-hoc networking between Bluetooth units.”);
`
`pp. 1023-1032.
`
`73. Specifically, in Bluetooth, the master device initially sends (or
`
`broadcasts) an inquiry message on a public channel that allows messages to be
`
`seen by any device on, or capable of joining, the ad-hoc network. The slave device
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`scans
`
`(or
`
`listens
`
`to)
`
`the public channel and
`
`receiv
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