Inter Partes Review of USPN RE42,678
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`Declaration of Joseph E. Ford, Ph.D.f Joseph E. Ford, Pdd
`optical signal. Id. at 2:49–65; 4:39–42; 4:59–67. Sparks explains that the control
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`means controls the operation of the MEMS mirrors to misalign the paths of the
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`reflected beams, and thus to effect a predetermined output power for each of the
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`channels passing through the switch. Id. at 2:45–48; 6:2–10.
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`166. A PHOSITA would have been motivated to combine Bouevitch with
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`Sparks for a number of independent reasons. A PHOSITA would have been
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`motivated to combine Bouevitch with Sparks for many of the same reasons
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`discussed above with respect to the combination of Bouevitch and Carr.
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`Fundamentally, the two references cover highly related subject matter. Each
`Fundamentally, the two references cover highly related subject matter. Each
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`reference discusses devices in the same field of fiber optic communications. Id. at
`reference discusses devices in the same field of fiber optic communications. Id. at
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`2:20-25; Ex. 1002 at 1:10–19. Each reference is directed at the same application in
`2:20-25; Ex. 1002 at 1:10–19. Each reference is directed at the same application in
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`that field—optical switching for wavelength-division-multiplexed (WDM)
`that field—dd optical switching for wavelength-division-multiplexed (WDM)
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`communications. Each reference discloses an optical add/drop switch using a
`communications. Each reference discloses an optical add/drop switch using a
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`MEMS-based WSS for switching. As a result, using the known 2-axis mirrors
`MEMS-based WSS for switching. As a result, using the known 2-axis mirrors
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`from Sparks in the Bouevitch COADM would have been nothing more than using
`from Sparks in the Bouevitch COADM would have been nothing more than using
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`known techniques to improve similar devices. Because of the similarity between
`known techniques to improve similar devices. Because of the similarity between
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`the devices disclosed in each reference, a PHOSITA would expect that each of
`the devices disclosed in each reference, a PHOSITA would expect that each of
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`these well-known techniques could be applied to the devices of the other patent. A
`these well-known techniques could be applied to the devices of e other patent. A
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`PHOSITA would find it natural and obvious to combine teachings of Sparks with
`PHOSITA would find it natural and obvious t
`teachings of Sparks with
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`the disclosure of Bouevitch, e.g., in light of my discussion in Sec. XI.D.1 above of
`the disclosure of Bouevitch, e.g., in light of my discussion in Sec. XI.D.1 above of
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`86
`86
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`0001
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`Capella 2011
`Fujitsu v. Capella
`IPR2015-00727
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`

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`Inter Partes Review of USPN RE42,678Inter Partes Review of USPN RE42,678
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`Declaration of Joseph E. Ford, Ph.D.Declaration of Joseph E. Ford, Ph.D.dd
`the functional schema of Bouevitch. Namely, providing the MEMS mirrors of
`the functional schema of Bouevitch. Namely, providing the MEMS mirrors of
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`Bouevitch with two-axis tilt capability enables the spatial positioning of returning
`Bouevitch with two-axis tilt capability enables the spatial positioning of returning
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`beams in both transverse directions at the face of microlens array 12. Thus, errors
`beams in both transverse directions at the face of microlens array 12. Thus, errors
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`in system alignment arising, e.g., from imperfect assembly or temperature
`in system alignment arising, e.g., from imperfect assembly or temperature
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`changes—well known problems in free space optical systems—could be better
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`changes—well known problems in free space optical systems— —could be better
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`compensated.
`compensated.
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`167. For example, a PHOSITA would have been motivated to combine the
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`two-axis movable MEMS mirrors of Sparks with the COADM of Bouevitch based
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`on the teachings of the references, common sense and knowledge generally
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`available to a PHOSITA, as the proposed combination would merely entail
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`substituting known elements to yield predictable results. Bouevitch discloses a
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`COADM where multi-wavelength light is spatially dispersed into channels by a
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`diffraction grating and each channel is reflected by a different mirror in an array of
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`MEMS mirrors along a different path for adding and dropping optical signals. Ex.
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`1002 at 14:14–15:18, FIG. 11. Sparks discloses using movable micromirrors
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`capable of two axis movement so that “each of the channels passing through the
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`switch may be attenuated to whatever degree necessary to achieve the desired
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`effect.” Ex. 1006 at 2:30–35; 4:39–47. As a result, using the known two-axis
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`mirrors of Sparks in the Bouevitch COADM entails nothing more than the use of
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`known techniques to improve similar devices.
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`0002