`
`
`
`Filed on behalf of: Samsung Electronics Co., Ltd. and
`
`
`
`Samsung Electronics America, Inc.
`
`By:
`Steven L. Park (stevenpark@paulhastings.com)
`Naveen Modi (naveenmodi@paulhastings.com)
`Elizabeth L. Brann (elizabethbrann@paulhastings.com)
`Paul Hastings LLP
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`SAMSUNG ELECTRONICS CO., LTD. and
`SAMSUNG ELECTRONICS AMERICA, INC.
`Petitioner
`
`v.
`
`E-WATCH, INC.
`Patent Owner
`
`____________________
`
`Patent No. 7,643,168
`____________________
`
`DECLARATION OF DR. ALAN BOVIK
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`
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`I.
`
`TABLE OF CONTENTS
`
`Introduction ...................................................................................................... 1
`
`II. Qualifications ................................................................................................... 1
`
`III. Summary of Opinions ...................................................................................... 5
`
`IV. The ’168 Patent ................................................................................................ 7
`
`A. Overview of the ’168 Patent .................................................................. 7
`
`B.
`
`C.
`
`Level of Ordinary Skill .......................................................................10
`
`Claim Construction..............................................................................10
`
`1.
`
`2.
`
`“media being suitable to embody at least one
`compression algorithm” ............................................................11
`
`“commonly moving” .................................................................11
`
`V.
`
`The Prior Art Discloses or Suggests All of the Features of Claims 19
`and 20 of the ’168 Patent ...............................................................................12
`
`A.
`
`Summary of the Prior Art ....................................................................12
`
`1. McNelley ...................................................................................12
`
`2.
`
`Sarbadhikari ..............................................................................14
`
`3. Morita ........................................................................................16
`
`4. Wilska ........................................................................................17
`
`5.
`
`Yamagishi-992 ..........................................................................19
`
`B.
`
`The Combination of McNelley and Sarbadhikari Discloses or
`Suggests All of the Features of Claims 19 and 20 ..............................20
`
`1.
`
`2.
`
`3.
`
`Claim 1 ......................................................................................20
`
`Claim 19 ....................................................................................39
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`Claim 20 ....................................................................................46
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`C.
`
`The Combination of Morita, Sarbadhikari, and McNelley
`Discloses or Suggests All of the Features of Claims 19 and 20 .........47
`
`1.
`
`2.
`
`3.
`
`Claim 1 ......................................................................................47
`
`Claim 19 ....................................................................................63
`
`Claim 20 ....................................................................................64
`
`D.
`
`The Combination of Wilska, Yamagishi-992, and McNelley
`Disclose or Suggest All of the Features of Claims 19 and 20 ............65
`
`1.
`
`2.
`
`3.
`
`Claim 1 ......................................................................................66
`
`Claim 19 ....................................................................................83
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`Claim 20 ....................................................................................85
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`VI. Conclusion .....................................................................................................86
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`I, Alan Bovik, declare as follows:
`
`Declaration of Dr. Alan Bovik
`Inter Partes Review - Patent No. 7,643,168
`
`
`I.
`
`Introduction
`
`1.
`
`I have been retained by Samsung Electronics Co., Ltd. and Samsung
`
`Electronics America, Inc. (collectively “Petitioner”) as an independent expert
`
`consultant in this proceeding before the United States Patent and Trademark Office
`
`(“PTO”) regarding U.S. Patent No. 7,643,168 (“the ’168 patent”) (Ex. 1001),
`
`which I understand is owned by e-Watch, Inc. (“Patent Owner”). I have been
`
`asked to consider the ’168 patent and whether certain references disclose or
`
`suggest the features recited in claims 19 and 20 of the ’168 patent. My opinions
`
`are set forth below.
`
`2.
`
`Although I am being compensated at my rate of $500 per hour for the
`
`time I spend on this matter, no part of my compensation is dependent on the
`
`outcome of this proceeding or any other proceeding involving the ’168 patent or
`
`any related patent. Nor do I have any other interest in this proceeding or any other
`
`proceeding involving the ’168 patent or any related patent.
`
`II. Qualifications
`I received a B.S. degree in Computer Engineering in 1980, a M.S.
`3.
`
`degree in Electrical and Computer Engineering in 1982, and a Ph.D. degree in
`
`Electrical and Computer Engineering in 1984, all from the University of Illinois,
`
`Urbana-Champaign.
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`
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`Declaration of Dr. Alan Bovik
`Inter Partes Review - Patent No. 7,643,168
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`I am currently a tenured full Professor and hold the Cockrell Family
`
`4.
`
`Regents Endowed Chair in Engineering at The University of Texas at Austin. My
`
`appointments at The University of Texas are in the Department of Electrical and
`
`Computer Engineering, the Department of Computer Sciences, and the Department
`
`of Biomedical Engineering. I am also the Director of the Laboratory for Image and
`
`Video Engineering (“LIVE”).
`
`5. My research is in the general area of image and video processing,
`
`computational vision, digital microscopy, and modeling of biological visual
`
`perception. I have published over 700 technical articles in these areas and hold
`
`four U.S. patents. I am also the author of The Handbook of Image and Video
`
`Processing, Second Edition (Elsevier Academic Press, 2005); Modern Image
`
`Quality Assessment (Morgan & Claypool, 2006); The Essential Guide to Image
`
`Processing (Elsevier Academic Press, 2009); and The Essential Guide to Video
`
`Processing (Elsevier Academic Press, 2009); as well as numerous other
`
`publications.
`
`6.
`
`Among other awards and honors, I received the 2013 IEEE Signal
`
`Processing Society’s “Society Award,” which is the highest honor given by the
`
`Society, “[f]or fundamental contributions to digital image processing theory,
`
`technology, leadership and education”; the Technical Achievement Award of the
`
`IEEE Signal Processing Society in 2005, which is the highest technical honor
`
`
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`given by the Society, for “Broad and Lasting Contributions to the Field of Digital
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`Declaration of Dr. Alan Bovik
`Inter Partes Review - Patent No. 7,643,168
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`Image Processing”; and the Education Award of the IEEE Signal Processing
`
`Society in 2008, which is the highest education honor given by the Society, for
`
`“Broad and Lasting Contributions to Image Processing, including popular and
`
`important image processing books, innovative on-line courseware, and for the
`
`creation of the leading research and educational journal and conference in the
`
`image processing field.”
`
`7. My technical articles have been widely recognized as well. For
`
`example, I received the 2009 IEEE Signal Processing Society Best Paper Award
`
`for a paper titled, “Image quality assessment: From error visibility to structural
`
`similarity,” published in IEEE Transactions on Image Processing, volume 13,
`
`number 4, April 2004; and the 2013 Best Magazine Paper Award for a paper titled,
`
`“Mean squared error: Love it or leave it? ― A new look at signal fidelity
`
`measures,” published in IEEE Transactions on Image Processing, volume 26,
`
`number 1, January 2009.
`
`8.
`
`I have also been honored by other technical organizations, including
`
`the Society for Photo-optical and Instrumentation Engineers (SPIE), from which I
`
`received the Technology Achievement Award in 2013 “[f]or Broad and Lasting
`
`Contributions to the Field of Perception-Based Image Processing”; and the Society
`
`for Imaging Science and Technology, which accorded me Honorary Membership,
`
`
`
`3
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`which is the highest recognition by that Society given to a single individual, “[f]or
`
`Declaration of Dr. Alan Bovik
`Inter Partes Review - Patent No. 7,643,168
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`his impact in shaping the direction and advancement of the field of perceptual
`
`image processing.” I was also elected as a Fellow of the Institute of Electrical and
`
`Electronics Engineers (IEEE) “[f]or Contributions to Nonlinear Image Processing”
`
`in 1995; a Fellow of the Optical Society of America (OSA) for “fundamental
`
`research contributions to and technical leadership in digital image and video
`
`processing” in 2006; and as a Fellow of the Society of Photo-Optical and
`
`Instrumentation Engineers (SPIE) for “pioneering technical, leadership, and
`
`educational contributions to the field of image processing” in 2007.
`
`9.
`
`Among other relevant research, I have worked with the National
`
`Aeronautics and Space Administration (“NASA”) to develop high-compression
`
`image sequence coding and animated vision technology for various military
`
`projects for the Air Force Office of Scientific Research, Phillips Air Force Base,
`
`the Army Research Office, and the Department of Defense. These projects have
`
`focused on developing local spatio-temporal analysis in vision systems, scalable
`
`processing of multi-sensor and multi-spectral imagery, image processing and data
`
`compression tools for satellite imaging, AM-FM analysis of images and video, the
`
`scientific foundations of image representation and analysis, computer vision
`
`systems for automatic target recognition and automatic recognition of human
`
`activities, vehicle structure recovery from a moving air platform, passive optical
`
`
`
`4
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`modeling, and detection of speculated masses and architectural distortions in
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`Declaration of Dr. Alan Bovik
`Inter Partes Review - Patent No. 7,643,168
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`digitized mammograms. My research has also recently been funded by Texas
`
`Instruments, Intel, Cisco, and the National Institute of Standards and Technology
`
`(NIST) for research on image and video quality assessment. I have also received
`
`numerous grants from the National Science Foundation for research on image and
`
`video processing and on computational vision.
`
`10.
`
`I understand that my curriculum vitae, which includes a more detailed
`
`summary of my background, experience, and publications, is being filed
`
`concurrently with this declaration as Exhibit 1008.
`
`III. Summary of Opinions
`11. All of the opinions contained in this declaration are based on the
`
`documents I reviewed, my experience and background, and my knowledge and
`
`professional judgment. In forming the opinions expressed in this declaration, I
`
`reviewed the following documents, and other material and information identified in
`
`this declaration:
`
`• The ’168 patent (Ex. 1001), and its prosecution file history;
`
`• U.S. Patent No. 7,365,871 (“the ’871 patent”), and its prosecution file
`
`history;
`
`• U.S. Patent Application No. 09/006,073, and its prosecution file history;
`
`
`
`5
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`Declaration of Dr. Alan Bovik
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`• JP Patent Application Pub. No. H06-133081 to Morita, including an
`
`English-language translation and a certificate of translation (“Morita”)
`
`(Ex. 1002); 1
`
`• U.S. Patent No. 5,477,264 to Sarbadhikari et al. (“Sarbadhikari”) (Ex.
`
`1003);
`
`• U.S. Patent No. 5,550,754 to McNelley et al. (“McNelley”) (Ex. 1004);
`
`• U.K. Patent Application Pub. No. GB 2289555 to Wilska et al.
`
`(“Wilska”) (Ex. 1005); and
`
`• European Patent Application Pub. No. 0594992 to Yamagishi
`
`(“Yamagishi-992”) (Ex. 1006).
`
`12. My opinions have also been guided by my appreciation of how a
`
`person of ordinary skill in the art would have understood claims 19 and 20 of the
`
`’168 patent at the time of the alleged invention, which I have been asked to
`
`initially assume is January 12, 1998.
`
`13. Based on my experience and expertise, it is my opinion that certain
`
`references identified in this declaration, which I occasionally refer to as “prior art,”
`
`disclose or suggest all the features recited in claims 19 and 20 of the ’168 patent.
`
`
`1 Citations to Morita are to the English-language translation.
`6
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`Declaration of Dr. Alan Bovik
`Inter Partes Review - Patent No. 7,643,168
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`IV. The ’168 Patent
`A. Overview of the ’168 Patent
`14. The ’168 patent is entitled “Apparatus for Capturing, Converting and
`
`Transmitting a Visual Image Signal via a Digital Transmission System.” I
`
`understand it was filed on December 28, 2006, and issued on January 5, 2010,
`
`from U.S. Patent Application No. 11/617,509. I understand that the ’168 patent
`
`claims priority as a continuation of U.S. Patent Application No. 10/336,470, filed
`
`on January 3, 2003, which issued as U.S. Patent No. 7,365,871. I further
`
`understand that the ’168 patent also claims priority as a divisional of U.S. Patent
`
`Application No. 09/006,073, filed on January 12, 1998, which is now abandoned.
`
`Ex. 1001 at 1:6-12.
`
`15. The ’168 patent is generally “directed to an image capture,
`
`compression and transmission system for use in connection with land line and
`
`wireless telephone systems.” Id. at 1:16-20. In particular, the ’168 patent
`
`describes a device for capturing, converting, and transmitting images. See, e.g., id.
`
`at 2:28-36, 6:29-7:43. Images may be captured by one of a number of different
`
`types of devices, including “a digital camera, an analog camera, or a video camera
`
`such as a camcorder.” See id. at 2:37-39; see also id. at 11:19-24, 11:57-59, Figs.
`
`6A-C, 7A-B. The images can then be converted into an appropriate signal for
`
`transmission to a remote device using, for example, cellular transmission, radio
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`
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`signal, satellite transmission, or hard line telephonic transmission. See, e.g., id. at
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`Declaration of Dr. Alan Bovik
`Inter Partes Review - Patent No. 7,643,168
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`2:28-31, 2:64-3:1, 5:66-6:15, 6:38-7:43. In one configuration, each image is
`
`transmitted as it is captured. See, e.g., id. at 6:9-13, 6:29-7:12. In another
`
`configuration, images are captured, stored, and selectively recalled for
`
`transmission. See, e.g., id. at 6:9-13, 7:13-43.
`
`16. An example of a device for capturing, converting, and transmitting
`
`images is shown in Figure 6B below. Id. at 11:24-38. The device includes “a
`
`battery powered portable module 160 having a self-contained power source 162,”
`
`“an integral RAM and/or the removable memory module as indicated by the image
`
`card 72,” an “analog camera 10,” a “viewfinder 170,” and “a cellular telephone.”
`
`Id. “The camera 10 can be an integral feature of the portable module 160, or can
`
`be a detached unit, as desired.” Id. at 11:28-30. “[T]he cellular phone can be used
`
`as both an input and an output device.” Id. at 11:35-38. For example, the cellular
`
`phone can be used to transmit an image data signal. Id. at 11:30-35. The
`
`viewfinder can be used to view incoming data or stored images. Id. at 11:35-38.
`
`According to the ’168 patent, such a “modular” configuration (i.e., components can
`
`be “integrated or independent units”) provides maximum “flexibility.” Id. at 2:32-
`
`36.
`
`
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`Declaration of Dr. Alan Bovik
`Inter Partes Review - Patent No. 7,643,168
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`17. The ’168 patent includes thirty-one claims. I have only been asked to
`
`analyze claims 19 and 20, which are dependent claims. Claim 19 depends from
`
`independent claim 1, and claim 20 depends from claim 19. Claim 1 is generally
`
`directed to a portable housing having an image collection device, display, and a
`
`mobile phone, among other components, and claims 19 and 20 are generally
`
`directed to the positioning and movability of those components.
`
`18. For example, claim 19 recites that the portable housing of claim 1
`
`comprises a first housing section supporting the image collection device adjoined
`
`to a second housing section supporting the display, the housing sections being
`
`movable in common with each other and the first housing section being movable
`
`relative to the second housing section. Claim 20 merely adds that the first housing
`
`section is supported for pivotal movement relative to the second housing section
`
`about a pivot axis. In my opinion, the positioning and movability features of
`
`
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`Declaration of Dr. Alan Bovik
`Inter Partes Review - Patent No. 7,643,168
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`claims 19 and 20, as well as the features of claim 1 (alone or in combination), were
`
`commonplace and well known at the time of the alleged invention, as discussed
`
`further below.
`
`B.
`19.
`
`Level of Ordinary Skill
`
`In my opinion, based on the materials and information I have
`
`reviewed, and on my extensive experience working in the technical areas relevant
`
`to the ’168 patent, a person of ordinary skill in the art at the time of the alleged
`
`invention would have had at least a B.S. degree in electrical engineering, computer
`
`science, or equivalent thereof, and at least 3-5 years of experience in the field of
`
`digital imaging devices. More education could substitute for experience, and
`
`experience, especially when combined with training, could substitute for formal
`
`college education.
`
`C. Claim Construction
`I understand that a claim subject to inter partes review receives the
`20.
`
`broadest reasonable interpretation in light of the specification of the patent in
`
`which it appears. I also understand that any term that is not construed should be
`
`given its plain and ordinary meaning under the broadest reasonable interpretation.
`
`I have followed these principles in my analysis.
`
`21.
`
`I understand that the Patent Trial and Appeal Board (“Board”),
`
`applying the broadest reasonable interpretation standard, construed two claim
`
`
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`Declaration of Dr. Alan Bovik
`Inter Partes Review - Patent No. 7,643,168
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`terms in its Institution Decision in IPR2014-00989, which involves the ’168 patent.
`
`Ex. 1009 at 6-8. I have been asked to and use these constructions in my analysis. I
`
`have used the plain and ordinary meaning, under the broadest reasonable
`
`interpretation, of the remaining claim terms in the ’168 patent in my analysis.
`
`1.
`
`“media being suitable to embody at least one compression
`algorithm”
`
`22.
`
`I understand that, in its Institution Decision in IPR2014-00989, the
`
`Board construed “media being suitable to embody at least one compression
`
`algorithm,” which appears in claim 1, from which claim 19 depends, as “a storage
`
`device for storing software to perform, among other functions, image
`
`compression.” Id. I have been asked to and use this construction and
`
`understanding in my analysis.
`
`“commonly moving”
`
`2.
`I understand that, in its Institution Decision in IPR2014-00989, the
`
`23.
`
`Board construed “commonly moving,” which appears in claim 1, from which claim
`
`9 depends, as “that the movement of the portable housing causes movement of the
`
`image collection device or display.” Id. at 8. I have been asked to and use this
`
`construction and understanding in my analysis.
`
`
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`Declaration of Dr. Alan Bovik
`Inter Partes Review - Patent No. 7,643,168
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`V. The Prior Art Discloses or Suggests All of the Features of Claims 19 and
`20 of the ’168 Patent
`
`24.
`
`In forming my opinions, I have reviewed, among other materials, the
`
`following references: McNelley (Ex. 1004), Sarbadhikari (Ex. 1003), Morita (Ex.
`
`1002), 2 Wilska (Ex. 1005), and Yamagishi-992 (Ex. 1006). In my opinion, these
`
`references disclose or suggest each feature recited in claims 19 and 20 of the ’168
`
`patent.
`
`A.
`
`Summary of the Prior Art
`1. McNelley
`25. McNelley is a U.S. Patent (No. 5,550,754) entitled “Teleconferencing
`
`Camcorder.” I understand it is prior art because it was filed on May 13, 1994, and
`
`issued on August 27, 1996, which is before the assumed earliest priority date of
`
`January 12, 1998.
`
`26. As illustrated in Figure 8 below, McNelley describes a portable, hand-
`
`held “camcorder (telecamcorder),” which “operates either as a conventional
`
`camcorder or a teleconferencing terminal.” Ex. 1004 at 5:1-11; see also id. at
`
`Abstract, 1:6-11, 2:44-61, 6:35-9:50, Figs. 8, 10-13.
`
`
`2 Citations to Morita are to the English-language translation.
`12
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`Declaration of Dr. Alan Bovik
`Inter Partes Review - Patent No. 7,643,168
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`27.
`
`In the context of teleconferencing, McNelley explains that its device
`
`includes “an integral video-phone capable of receiving and sending
`
`teleconferencing signals and includes a built-in display to view an incoming
`
`teleconferencing signal and a video pickup device that can produce an image of the
`
`operator for transmission during teleconferencing.” Id. at 5:1-9. McNelley
`
`explains that “the telecamcorder can serve as a portable wireless teleconferencing
`
`terminal much like a portable cellular phone.” Id. at 14:28-31; see also id. at
`
`Abstract, 1:6-11, 2:35-40, 4:61-5:11, 7:66-8:9, 18:55-57, claim 1, Figs. 8, 10-13.
`
`As shown in Figure 8, the telecamcorder includes a “display 100,” “camera 102,”
`
`“microphone 114,” “speaker 112,” and a “separate handset unit 174.” Id. at 6:35-
`
`
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`45, 7:38-8:1. Alternatively, the capabilities of the handset unit are provided by the
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`Declaration of Dr. Alan Bovik
`Inter Partes Review - Patent No. 7,643,168
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`main housing of the telecamcorder. Id. at 8:10-18; see also id. at Figs. 9, 12.
`
`28. McNelley explains that “digital recording can be advantageously
`
`employed in the telecamcorder.” Id. at 12:35-39. According to McNelley, the
`
`advantages include “the ease with which digital recording devices . . . may be
`
`employed” and that “data compression techniques . . . require data in a digital
`
`form.” Id. at 12:50-13:2. Therefore, McNelley describes the use of “a charge
`
`coupled device (CCD) optical pickup.” Id. at 13:5-7. McNelley explains that “[a]s
`
`electrical values are read from the CCD, the values are immediately converted into
`
`digital values and remain digital through all subsequent processing.” Id. at 13:7-9.
`
`Sarbadhikari
`2.
`Sarbadhikari is a U.S. Patent (No. 5,477,264) entitled “Electronic
`
`29.
`
`Imaging System Using a Removable Software-Enhanced Storage Devce.” I
`
`understand it is prior art because it was filed on March 29, 1994, and issued on
`
`December 19, 1995, which is before the assumed earliest priority date of January
`
`12, 1998.
`
`30.
`
`Sarbadhikari describes, for example, “an electronic imaging system
`
`include[ing] a digital electronic camera for capturing and storing images in a
`
`removable storage device.” Ex. 1003 at Abstract. As shown below in Figure 2,
`
`
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`Sarbadhikari discloses an “electronic still camera . . . divided generally into an
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`Declaration of Dr. Alan Bovik
`Inter Partes Review - Patent No. 7,643,168
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`input section A and a compression and recording section B.” Id. at 5:55-59.
`
`
`
`31.
`
`Input section A includes “an exposure section 10 for directing image
`
`light from a subject (not shown) toward an image sensor 12” and “[a] flash unit
`
`11.” Id. at 5:59-62. “[T]he exposure section 10 includes conventional optics,” and
`
`“[t]he sensor . . . is a conventional charge-coupled device (CCD).” Id. at 5:62-6:3.
`
`“The analog image signals are applied to an A/D converter 16, which generates a
`
`digital image signal from the analog input signals for each picture element” (id. at
`
`6:8-10), which are stored in “an image buffer 18” (id. at 6:10-13). Referring to
`
`section B, Sarbadhikari explains that “[t]he digital signal processor 22 compresses
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`each still image stored in the image buffer 18 according to a known image
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`compression algorithm, such as the well-known JPEG (Joint Photographic Experts
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`Group) discrete cosine transformation-based compression algorithm” (id. at 6:32-
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`37), which is stored in “the algorithm memory 28” (id. at 6:30-32). Sarbadhikari
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`also explains that the compression algorithms can be modified or updated to
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`improve existing device capabilities or provide new capabilities. Id. at 4:47-5:40.
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`3. Morita
`32. Morita is a Japanese Patent Applicatoin (JP H06-133081) entitled
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`“Electronic Still Camera with Portable Telephone Function.” I understand it is
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`prior art because it was published on May 13, 1994, which is before the assumed
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`earliest priority date of January 12, 1998.
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`33. Morita discloses “a portable phone equipped with an electronic still
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`camera.” Ex. 1002 at 5:6-10; see also id. at Abstract, 3:14-4:5, 4:15-5:3, 5:16-20,
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`7:1-6, 7:17-8:7, 11:21-12:25. Morita explains that its device is capable of storing
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`and wirelessly communicating captured images. Id. at Abstract, 2:20-23, 3:14-15,
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`4:15-5:10, 5:16-6:7, 6:15-21, 7:1-15, 7:26-8:22, 9:7-19, 11:6-7, 11:10-12, Figs. 1,
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`2(a)-(b), 3, 4(a)-(d), 5(a)-(b), 11. Figure 2 below shows one possible external
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`configuration of Morita’s device, which includes a camera “lens 1,” “display 8,”
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`and “antenna 23,” among other components. Id. at 7:17-8:7.
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`16
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`Fig. 2(a)
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`4. Wilska
`34. Wilska is a U.K. Patent Application Publication (GB 2289555)
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`entitled “Device for Personal Communications, Data Collection and Data
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`Processing and a Circuit Card.” I understand it is prior art because it was
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`published on November 22, 1995, which is before the assumed earliest priority
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`date of January 12, 1998.
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`35. Wilska describes a portable “device for personal communication, data
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`collection, and data processing.” Ex. 1005 at Abstract. As shown in Figure 1
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`below, the device, referred to as “a notebook computer,” includes, for example, “a
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`data processing unit (2)”; “a display (9)”; “a user interface (10, 11)”; “a camera
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`
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`17
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`unit (14)”; a “cellular mobile phone unit (17)”; “at least one memory unit (13)”; “a
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`power source, preferably a battery (3)”; and “application software.” See, e.g., id. at
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`Abstract, 3:17-6:23, Figs. 1-3.
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`
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`36. The device described in Wilska includes software that provides
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`functionalities including “telephone services which are based on the cellular
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`mobile phone (data transmission and/or speech transmission properties), facsimile
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`services, electronic mail, short message service/SMS, . . . camera functions to
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`record images and paper documents,” etc. Id. at 6:4-12
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`37. Wilska explains that the device’s camera unit is a “data collection unit
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`[that] can be used to transfer data presented on paper or the like as well as an
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`image taken of the surroundings, for instance of a person, to the notebook
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`computer to be processed further.” Id. at 5:5-7. The camera unit can be “fixedly
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`integrated to the notebook computer or connectable to the card slot of the notebook
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`
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`18
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`computer as camera card 15.” Id. at 7:21-23; see also id. at Abstract, 4:27-30, 5:9-
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`10, Figs. 4-6. Preferably, the camera unit is “implemented as a CCD camera
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`comprising a two-dimensional light-sensitive CCD sensor.” Id. at 7:9-11, Fig. 5.
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`Once data is collected using the camera unit, such as an image, it can be
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`transmitted to a receiver “via cellular mobile phone unit 17.” Id. at 9:28-10:7.
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`Yamagishi-992
`5.
`38. Yamagishi-992 is a European Patent Application Publication (No.
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`0594992) entitled “Information Signal Processing Apparatus.” I understand it is
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`prior art because it was published on April 5, 1994, which is before the assumed
`
`earliest priority date of January 12, 1998.
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`39. Yamagishi-992 describes an electronic still video system (see, e.g.,
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`Ex. 1006 at 12:28-15:48, 35:1-40:9, 97:1-102:20, 118:37-122:19, Figs. 1, 13, 32,
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`43), which can be implemented as part of a “portable telephone set” (id. at
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`Abstract, 147:3-10). In one embodiment, “[t]he process for transmitting data
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`between the electronic still camera 3200 and an external device . . . is executed by
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`means of a modem 3028 . . . .” Id. at 118:58-119:6. Yamagishi-992 explains that
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`the body of the “electronic still video system” may incorporate “an image display
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`device,” which may, for example, operate to reproduce images and/or “as an
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`electronic viewfinder.” Id. at 35:54-36:15, 97:54-98:4, 119:53-120:4, 127:13-43,
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`Figs. 13 (element 1038), 32 (element 2038), 43 (element 3038), 50. Yamagishi-
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`
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`19
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`992’s device also “includes an image compressing circuit 22 for compressing
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`Declaration of Dr. Alan Bovik
`Inter Partes Review - Patent No. 7,643,168
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`image data by a compression method such as adaptive discrete cosine transform
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`(ADCT).” Id. at 12:53-57; see also id. at 35:27-53, 97:27-53, 119:38-52, Figs. 1
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`(element 22), 13 (element 1022), 32 (element 2022), 43 (element 3022).
`
`B.
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`40.
`
`The Combination of McNelley and Sarbadhikari Discloses or
`Suggests All of the Features of Claims 19 and 20
`In my opinion, the combination of Wilska, Yamagishi-114, and
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`Kurashige discloses or suggests each feature recited in claims 19 and 20 of the
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`’168 patent.
`
`41. Claims 19 and 20 are dependent claims. Claim 19 depends from
`
`claim 1, and claim 20 depends from claim 19. I understand that a dependent claim
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`includes all of the limitations of the claim from which it depends. Therefore,
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`below I address claims 1, 19, and 20.
`
`Claim 1
`1.
`In my opinion, McNelley discloses or suggests “[a]pparatus
`
`42.
`
`comprising” and “a portable housing, the portable housing being wireless,” as
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`recited in claim 1.
`
`43. As illustrated in Figures 8 and 10-13, McNelley discloses “[a]
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`camcorder (telecamcorder),” which contains “an integral video-phone capable of
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`receiving and sending teleconferencing signals and includes a built-in display to
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`view an incoming teleconferencing signal and a video pickup device that can
`20
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`produce an image of the operator for transmission during teleconferencing.” Ex.
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`Inter Partes Review - Patent No. 7,643,168
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`1004 at 5:1-9; see also id. at Abstract, 1:6-11, 6:35-9:50, 14:28-31, Figs. 8, 10-13.
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`McNelley also discloses that “the telecamcorder can serve as a portable wireless
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`teleconferencing terminal much like a portable cellular phone.” Id. at 14:28-31; see
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`also id. at Abstract, 1:6-11, 2:35-40, 4:61-5:11, 7:66-8:9, 18:55-57, claim 1, Figs.
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`8, 10-13.
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`44. For example, Figure 8 below illustrates one configuration of the
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`telecamcorder disclosed by McNelley. The configuration of Figure 8 includes a
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`“main housing 148” and a “camera boom 156.” Id. at 6:35-8:9, Fig. 8. As shown
`
`in Figure 8, the main housing contains, for example, a “display 100.” See, e.g., id.
`
`at 6:35-45, Fig. 8. The “camera boom 156” includes, for example, a “camera 102,”
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`a “microphone 114,” and a “speaker 112.” Id. at 6:37-7:38, Fig. 8. When the
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`telecamcorder is used in teleconferencing mode, “the speaker 112 and the
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`microphone 114 serve as a speaker phone.” Id. at 7:24-38. McNelley discloses
`
`that “[a] separate handset unit 174 that includes a microphone 176 and a speaker
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`178 may serve in addition to