throbber
IPR2015-01444
`Patent 7,039,033
`
`
`By: Andy H. Chan, Reg. No. 56,893
`Pepper Hamilton LLP
`333 Twin Dolphin Drive
`Suite 400
`Redwood City, CA 94065
`(650) 802-3602 (telephone)
`(650) 802-3650 (facsimile)
`chana@pepperlaw.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., AND APPLE INC.,
`Petitioner
`v.
`
`IXI IP, LLC
`Patent Owner
`___________________
`
`Case No. IPR2015-01444
`Patent 7,039,033
`___________________
`
`DECLARATION OF DR. NARAYAN MANDAYAM
`IN SUPPORT OF IXI IP, LLC’S
`PATENT OWNER RESPONSE
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`IXI 2301
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`IPR2015-01444
`Patent 7,039,033
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`I, Narayan Mandayam, do hereby declare:
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`1.
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`I am making this declaration at the request of Patent Owner IXI IP,
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`LLC in the matter of Inter Partes Review of U.S. Patent No. 7,039,033 (the ’033
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`Patent”) to Amit Haller et al.
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`2.
`
`In the preparation of this declaration, I have studied:
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` the ’033 Patent (Ex. 1001);
`
` S. M. Bellovin et al., Network Firewalls, Network Firewalls, IEEE
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`Communications Magazine, Vol. 32, Issue 9, pp. 50-57, 1999 (“Bellovin”;
`
`Ex. 1002)
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` PCT Publication No. WO 01/76154 A2 22(“Marchand PCT”; Exhibit 1005);
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` U.S. Patent Application No. 09/451,529 (“Marchand Priority”; Ex. 1006);
`
` Handley et al., Request for Comments 2543 SIP: Session Initiation Protocol,
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`The Internet Society, March, 1999 (“RFC 2543”; Ex. 1007);
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` U.S. Patent No. 6,836,474 (“Larsson”; Ex. 1008);
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` K. Arnold et. al., The JINITM Specification, Addison-Wesley, June 1, 1999
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`(“JINI Spec.”; Ex. 1009);
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` U.S. Patent No. 6,560,642 (“Nurmann”; Ex. 1010);
`
` U.S. Patent No. 6,771,635 (“Vilander”; Ex. 1011);
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` R. Droms, Request for Comments 2131 Dynamic Host Con-figuration
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`Protocol, The Internet Society, March, 1997 (“RFC 2131”; Ex. 1014);
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` Claim Chart from IXI’s Infringement Contentions of U.S. Patent No.
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`7,039,033 in 14-cv-4428 (April 9, 2015) (Ex. 1012);
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` Claim Chart from IXI’s Infringement Contentions of U.S. Patent No.
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`7,039,033 in 14-cv-4355 (March 27, 2015) (Ex. 1013);
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`IPR2015-01444
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` Petition for Inter Partes Review (Paper 2);
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` Kiaei Declaration (Ex. 1003);
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` Patent Owner’s Preliminary Response (Paper 6);
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` Decision Institution of Inter Partes Review (“Paper 8”);
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` March 15, 2016 Deposition Transcript of Dr. Kiaei regarding IPR2015-
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`01443 (Ex. 2302);
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` March 16, 2016 Deposition Transcript of Dr. Kiaei regarding IPR2015-
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`01444 (Ex. 2303);
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` March 17, 2016 Deposition Transcript of Dr. Kiaei regarding IPR2015-
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`01445 and IPR2015-01446 (Ex. 2304);
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` Specifcation of the Bluetooth System, Specification Volume 1 (December 1,
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`1999) (“Bluetooth Specification”; Ex. 2305)1.
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` “IP Network Address Translator (NAT) Terminology and Considerations,”
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`RFC 2663, August 1999 (“RFC 2663”; Ex. 2306).
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`3.
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`In forming the opinions expressed below, I have considered the
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`documents listed above;he relevant legal standards, including the standard for
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`obviousness and any additional authorities as cited in the body of this declaration;
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`and my knowledge and experience based upon my work is this area as described
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`below.
`
`
`1 The Bluetooth Specification was obtained from
`http://grouper.ieee.org/groups/802/15/Bluetooth/core_10_b.pdf. (Last accessed Apr. 5, 2016). The front page of the
`Bluetooth Specification identifies that it is from December 1, 1999. Based on my experience with Bluetooth
`technology, the Bluetooth Specification would have been publicly available on or about December 1, 1999.
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`I.
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`QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
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`4.
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`I received a bachelor degree (with Honors) in 1989 from the Indian
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`Institute of Technology, Kharagpur, and M.S. and Ph.D. degrees in 1991 and 1994
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`from Rice University, Houston, TX, all in electrical engineering.
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`5.
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`I was a Research Associate at the Wireless Information Network
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`Laboratory (“WINLAB”), Department of Electrical & Computer Engineering,
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`Rutgers University, between 1994 and 1996. In September 1996, I joined the
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`faculty of Department of Electrical & Computer Engineering at Rutgers where I
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`became Associate Professor in 2001, Professor in 2003, and Distinguished
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`Professor in 2014. I also served as the Peter D. Cherasia Endowed Faculty Scholar
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`at Rutgers University from 2010 to 2014. Currently, I also serve as Associate
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`Director at WINLAB where I conduct research in various aspects of wireless
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`systems and networks. I teach courses at Rutgers on the topics of Wireless
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`System Design, Wireless Communication Technologies, Wireless Revolution,
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`Detection and Estimation Theory and Introduction to Computing for Engineers. I
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`was a visiting faculty fellow in the Department of Electrical Engineering,
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`Princeton University in Fall 2002 and a visiting faculty at the Indian Institute of
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`Science in Spring 2003.
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`6. My research focuses on wireless networks and communications, and I
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`have worked on various aspects of networking and wireless devices. Over the last
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`25 years, I have published a wide range of articles on various aspects of wireless
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`systems including techniques for data transmission, resource allocation strategies,
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`mathematical modeling, and performance analysis. Using constructs from game
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`theory, communications and networking, my work has focused on system
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`modeling and performance, signal processing as well as radio resource
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`management for enabling wireless technologies to support various applications. I
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`have coauthored 2 books on wireless networks (Principles of Cognitive Radio,
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`Cambridge (2012) and Wireless Networks: Multiuser Detection in Cross-Layer
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`Design, Springer (2005)), 6 book chapters and published over 200 papers in
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`prestigious international journals and conferences. I have also given numerous
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`invited presentations at a variety of industry, government, and academic forums.
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`7.
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`Specifically, I have been doing precompetitive research in various
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`aspects of wireless data transmission for over 25 years addressing PHY, MAC and
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`Network layer issues. I have made seminal research contributions to wireless data
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`communications on issues ranging from the systems level (such as power control,
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`capacity evaluation, protocol design, medium access control, and radio resource
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`management) to the physical layer (such as detection and estimation). My
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`expertise includes cellular systems such as for 2G, 3G and 4G and I have published
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`papers on a wide variety of topics related to the design and operation of
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`GSM/TDMA, CDMA and LTE based systems. During this time, I have also
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`worked extensively on wireless local area network (WLAN) technologies as well
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`as wireless ad-hoc and sensor networks, and as such I am quite familiar with
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`802.11 and Bluetooth.
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`8.
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`I also teach both graduate and undergraduate courses at Rutgers where
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`I introduce students to the wide area network (WAN) cellular and local area
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`network (LAN) technologies mentioned above. I have also served as a technical
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`consultant since its inception in 2002 to the company Mojo Networks Inc., a world
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`leader in enterprise network security for WLANs that offers the next generation of
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`intelligent edge, secure, and flexible WiFi solutions. I am familiar with the early
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`developments in the area of Bluetooth technology and have served on graduate
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`thesis defense committees even as early as the year 2000.
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`9.
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`I have received several prestigious awards relating to my research on
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`wireless networks and communications: the 2015 IEEE COMSOC Advances in
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`Communications Award for seminal work on power control in wireless data
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`networks (this is the highest paper award given by the IEEE Communications
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`Society), the 2014 IEEE Donald G. Fink Award (recognizes the most outstanding
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`tutorial paper across all IEEE publications) for the paper titled “Frontiers of
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`Wireless and Mobile Communications” that discusses the historical and future
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`landscape of both WAN and LAN wireless technologies, and the Fred W. Ellersick
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`Prize from the IEEE Communications Society in 2009 for work on dynamic
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`spectrum access models and spectrum policy. I also received the Peter D. Cherasia
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`Faculty Scholar Award from Rutgers University in 2010, the National Science
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`Foundation Career Award in 1998, and the Institute Silver Medal from the Indian
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`Institute of Technology, Kharagpur in 1989.
`
`10.
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`I have served as an Editor for the journals IEEE Communication
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`Letters (1999- 2002) and IEEE Transactions on Wireless Communications (2002-
`
`2004). I have also served as a guest editor of the IEEE JSAC Special Issues on
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`Adaptive, Spectrum Agile and Cognitive Radio Networks (2007) and Game
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`Theory in Communication Systems (2008). I was elected Fellow of the IEEE for
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`“contributions to wireless data transmission.” I have also served as a
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`Distinguished Lecturer of the IEEE Communications Society. My curriculum
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`vitae is attached to this declaration.
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`II. RELEVANT LEGAL STANDARDS
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`11. My understanding of the relevant legal standards is based on
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`information given by Patent Owner’s counsel. I understand from counsel that in
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`the inter partes review proceeding, such as this one, the claims of a patent are
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`construed from the perspective of one of ordinary skill in the art at the time of the
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`claimed invention and are given their broadest reasonable construction consistent
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`with the specification.
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`12.
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`It is my understanding that an invention is unpatentable if the
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`differences between the invention and the prior art are such that the subject matter
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`of the invention as a whole would have been obvious at the time the invention was
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`made to a person having ordinary skill in the art. I further understand that
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`obviousness is determined by evaluating: (1) the scope and content of the prior art,
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`(2) the differences between the prior art and the claim, (3) the level of ordinary
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`skill in the art, and (4) secondary considerations of nonobviousness. To establish
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`obviousness based on a combination of the elements disclosed in the prior art, it is
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`my understanding that a petitioner must identify a specific combination that
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`teaches all limitations and establish that a person of ordinary skill in the art at the
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`time of the claimed invention would have found it obvious to make that
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`combination.
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`13. To guard against hindsight and an unwarranted finding of
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`obviousness, I understand that an important component of any obviousness inquiry
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`is whether the petitioner has identified any teaching, suggestion or motivation that
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`would have prompted a person of ordinary skill in the art to make the claimed
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`combination and have a reasonable expectation of success in doing so. I
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`understand that this test should not be rigidly applied, but can be an important tool
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`to avoid the use of hindsight in the determination of obviousness.
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`14.
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`I further understand that the teaching, suggestion, or motivation may
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`be found explicitly or implicitly: (1) in the prior art; (2) in the knowledge of those
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`of ordinary skill in the art that certain references, or disclosures in those references,
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`are of special interest or importance in the field; or (3) from the nature of the
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`problem to be solved. Additionally, I understand that the legal determination of
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`the motivation to combine references allows recourse to logic, judgment, and
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`common sense. In order to resist the temptation to read into prior art the teachings
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`of the invention in issue, however, it should be apparent that “common sense”
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`should not be conflated with what appears obvious in hindsight.
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`15.
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`I understand that if the teachings of a prior art reference would lead a
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`person of ordinary skill in the art to make a modification that would render another
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`prior art device inoperable, then such a modification would generally not be
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`obvious. I also understand that if a proposed modification would render the prior
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`art invention being modified unsatisfactory for its intended purpose, then there is
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`no suggestion or motivation to make the proposed modification.
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`III. DEFINITION OF THE PERSON OF SKILL IN THE ART
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`16. Dr. Kiaei and Petitioner have alleged a person of ordinary skill in the
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`art in the field of the invention claimed in the ’033 patent, would have had a
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`Master’s of Science Degree (or a similar technical Master’s Degree, or higher
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`degree) in an academic area emphasizing electrical engineering, computer
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`engineering, or computer science with a concentration in communication and
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`networking systems or, alternatively, a Bachelor’s Degree (or higher degree) in an
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`academic area emphasizing electrical or computer engineering and having two or
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`more years of experience in communication and networking systems. For the
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`purposes of my opinions, I have used this definition.
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`17.
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`I am familiar with the knowledge and capabilities of one of ordinary
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`skill in the field of the ’033 Patent in 2001, at the time of the filing of the patent
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`application leading to the ’033 Patent, based on my experience (1) with
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`collaboration with the industry, (2) with undergraduate and post-graduate students,
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`(3) with colleagues from academia, and (4) with my role as Associate Director of
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`WINLAB at Rutgers. Unless otherwise stated, my statements made herein refer to
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`the knowledge of one of ordinary skill in the field of the invention claimed in the
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`’033 Patent.
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`IV.
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` THE ’033 PATENT
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`18. The ’033 Patent is directed to “a system that accesses information
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`from a wide area network (‘WAN’), such as the Internet, and local wireless devices
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`in response to short-range radio signals.” Ex. 1001, 4:8–11; Abstract. The system
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`includes a wireless gateway device that is coupled to the WAN and to a personal
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`area network (“PAN”). Id. at Abstract; FIG. 1. The wireless gateway device
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`allows devices connected on the PAN to connect to the WAN. The wireless
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`gateway device also includes software components that allow devices on the PAN
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`to communicate and share services, and includes the ability to provide security to
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`the network.
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`19. Figure 1 provides an illustration of the system described in the ’033
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`Patent and is depicted below:
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`Figure 1: ’033 Patent, Figure 1
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`The Gateway Device 106 communicates with one or more terminals 107 to form a
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`personal area network (“PAN”) using short-range radio signals 110. Id. at 4:16-21.
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`The PAN is implemented using local wireless technology such as Bluetooth or
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`802.11, which is commonly referred to as Wi-Fi. Id. at 4:25-35. The Gateway
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`Device 106 is coupled to cellular network 105 and can communicate with, for
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`example, Server 101 and Server 102 via carrier backbone 104. Id. at 4:36-59. In
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`so doing, Servers 101 and 102 can provide information, such as web pages or
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`application software components, to terminals 107 in the WLAN by way of the
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`Gateway Device 106. Id. at 4:49-54.
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`20. The software components described in the ’033 Patent are what
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`enables the Gateway Device to connect the terminals on the PAN to the WAN and
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`offer network management and security functions. As part of the architecture, the
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`Gateway Device includes a “service repository software component 704.” The
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`service repository software component “allows applications 406, which run on a
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`gateway device 106 or terminals 107, to discover what services are offered by a
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`PAN, and to determine the characteristics of the available services.” Id. at 12:11-
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`14.
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`21. The Gateway Device 106 also includes a “plug and play component.”
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`The “plug and play” capability of Gateway Device 106 allows it to identify a new
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`terminal and determine the necessary software required to support the new
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`terminal. Id. at 10:11-37; Fig. 7. Terminals connecting to the PAN are not
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`necessarily readily supported by the Gateway Device 106. For example, the ’033
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`Patent identifies the introduction of “thin” terminals to the PAN as an example of
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`utilizing the “plug and play” capability of the Gateway Device 106. Id. at 10:18-
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`35. Thin terminals do not have embedded application code or data. Id. In order to
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`support these types of devices, the “plug and play component” uses the terminals’
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`identification to find, download, and execute the software necessary for the
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`Gateway Device 106 to support the terminal. Id. at 10:11-37.
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`V. OPINION ON CLAIM CONSTRUCTION
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`22.
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`It is my understanding that in this inter partes review proceedings, the
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`claim terms are to be given their broadest reasonable interpretation consistent with
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`the specification and file history of the ’033 Patent, as understood by one of
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`ordinary skill in the art. I understand that claim construction is the common
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`terminology used to describe the interpretation of claim terms.
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`23.
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`It is also my understanding that Petitioner argues that claim language:
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`“identifies whether the service is available at a particular time,” found in claim 4 of
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`the ’033 Patent, should be construed to encompass “the service being registered.”
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`Paper 2, 9. Consistent with my understanding of claim interpretation, my review
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`of the specification, and as one of ordinary skill in the art at the time of the
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`invention, I disagree with Petitioner that the identified claim language needs a
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`construction. Further, I disagree that a person of ordinary skill in the art would
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`have understood the language “identifies whether the service is available at a
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`particular time” to encompass “the service being registered.”
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`24.
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` It is my opinion that the claim language of claim 4 would have been
`
`understood by a person of ordinary skill in the art without the need for claim
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`construction. Claim 4 states:
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`The system of claim 1, wherein the service repository software
`component identifies whether the service is available at a particular
`time.
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`Ex. 1001, 16:4-6 (emphasis added). It is my opinion that in light of the
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`specification of the ’033 Patent, a person of ordinary skill in the art would have
`
`understood the language of claim 4 without a construction and that person’s
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`understanding would not encompass “the service being registered.”
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`25.
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`It is clear from the specification of the ’033 Patent that the service
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`repository software component 704 is capable of identifying whether a service is
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`available at a particular time. The specification states:
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`In an embodiment of the present invention, service repository
`component 704 describes the terminals and the services that are
`available at a particular time, but service repository software
`component 704 does not describe the current status of the service.
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`Ex. 1001, 13:5-9 (emphasis added). This action is separate and distinct from
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`registering a service.
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`26. A person of ordinary skill in the art would have understood that
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`“identifying whether a service is available at a particular time” necessarily occurs
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`after a service has been registered and is not the same process. In fact, the ’033
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`Patent describes that the service repository software component offers a plurality
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`of functions and identifies service registration as the first function. The ’033
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`Patent states “[f]irst, service repository software component 704 provides service
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`registration of a service offered by application, or a hardware capability offered by
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`terminal driver.” Ex. 1001, 12:35-37. A service must be registered before it can
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`be identified.
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`27. The distinction between the service registration and service
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`identification is further illustrated by Figure 7 of the ’033 Patent. Below, I have
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`included an annotated version of Figure 7. As shown below, the service repository
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`704 separately identifies “service registration and unregistration” and “service
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`enumeration.” A person of ordinary skill in the art would have recognized that
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`these are two separate functions.
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`Figure 2: ’033 Patent, Figure 7 (Annotated)
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`VI. BACKGROUND OF TECHNOLOGY
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`A. Bluetooth
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`28. Bluetooth is a local wireless technology that connects devices using
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`short-range radio signals. Ex. 2305, p. 41. The Bluetooth system provides a point-
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`to-point connection, if only two devices are connected, or a point-to-multipoint
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`connection, if more than two devices are connected. This is illustrated below:
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`Figure 3: Ex. 2305, Figure 1.2
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`Section (a) in the figure above depicts a point-to-point connection of two devices.
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`When two or more devices are connected they share the same “channel” using
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`frequency hopping. “Two or more units sharing the same channel form a piconet.”
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`Id. The piconet depicted in Section (b) in the figure above depicts a point-to-
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`multipoint connection of four devices. A piconet can be formed by up to eight
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`devices. Id. at 42.
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`29.
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`In each piconet, one Bluetooth device acts as the master and the
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`remaining units act as slaves. Id. at 41-42. “The piconet is synchronized by the
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`system clock of the master.” Id. at 87. Slave devices use a timing offset to adapt
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`their native clocks to match the master clock. Id. As depicted above, the master
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`device establishes the connection between the slave devices. The master device
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`controls all communication in a piconet. There is no direct communication
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`between slave devices on the piconet channel.
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`30. A Bluetooth device may participate concurrently in two or more
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`piconets. When multiple piconets are connected in this manner, they form a
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`scatternet. Id. at 42. A scatternet is depicted in Section (c) of the figure above.
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`Each piconet can only have one master device. A master device in one piconet can
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`be a slave device in another piconet. I have depicted an example of this below:
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`
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`Figure 4: Illustration of a Bluetooth Scatternet
`
`31.
`
`In the figure above, the laptop computer is the master (MA) of piconet
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`A, with the mobile phone (SA) and the printer (SA) as slave devices in piconet A.
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`The mobile phone is the master of piconet B (MB), with only the laptop (SB) as its
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`slave device. Both the laptop and the mobile phone simultaneously act as master
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`and slave devices on independent piconets, with piconet B, being a “sub-piconet”
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`within piconet A.
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`VII. THE COMBINATION OF MARCHAND, NURMANN, AND
`VILANDER
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`A. Marchand
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`32. Marchand2 (PCT Publication Number WO 2000/041529 and U.S.
`
`Patent Application No. 09/541,529) is directed at a Bluetooth piconet that has been
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`extended into an Internet Protocol (IP) wireless local area network implementing
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`JINI java technology in order to utilize JINI technology for sharing services
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`between devices in the piconet. Ex. 1005, Abstract; 5:23-25; 6:25-27.
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`Additionally a mobile phone connected to the piconet is configured to act as a
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`gateway to provide a call control interface between the wireless IP network and
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`other devices in the piconet. Ex. 1005, Abstract.
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`1.
`
`Underlying Technology
`
`33. A person of ordinary skill in the art would have understood that the
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`operation of the network and the devices described in Marchand are dependent on
`
`the underlying technology. Specifically, when evaluating Marchand, a person of
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`
`2 In my opinion there are no substantive differences between Marchand PCT
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`and Marchand Priority that affect my analysis.
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`ordinary skill in the art would have considered the implementation of Bluetooth
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`wireless technology extended into an IP wireless LAN and JINI java technology.
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`Marchand makes clear that the use of a Bluetooth piconet extended into an Internet
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`Protocol (IP) wireless LAN implementing JINI java technology is essential to the
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`operation of the network and devices described in Marchand. Marchand explains
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`that in order for devices in the Bluetooth piconet to share services each device
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`must be Bluetooth compliant and JINI/Java capable. Ex. 1005, 7:9-11.
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`34. Marchand states that to be Bluetooth compliant, each device would
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`include a Bluetooth chipset. Ex. 1005, Abstract; 2:11-16. Further, each device
`
`operates using a specific protocol stack. The protocol stack is defined in Marchand
`
`and illustrated in Marchand’s Figure 2, as shown below:
`
`
`Figure 5: (Ex. 1005) Marchand, Figure 2
`
`35. As shown in Figure 2, each device in Marchand’s Bluetooth piconet
`
`includes a physical layer 15 and a link layer 16, identified as Bluetooth layers of
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`the protocol stack. Ex. 1005, Fig. 2. In addition, each device includes a network
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`transport (IP) layer 17, an operating system layer 18, a Java technology layer 19,
`
`and a JINI technology layer 20. Ex. 1005, 6:14-22.
`
`36. Marchand describes that the underlying technology used to create the
`
`local area network is Bluetooth wireless technology. Ex. 1005, Abstract; 2:7-25;
`
`FIGs. 1-4. Marchand states that “Bluetooth wireless technology allows users to
`
`make effortless, wireless, and instant connections between various communication
`
`devices such as mobile phones and desktop and laptop computers.” Ex. 1005, 2:7-
`
`9. Marchand includes an overview of how Bluetooth devices connect and operate.
`
`Id. at 2:7-26. Specifically, two or Bluetooth devices more devices connect to form
`
`a piconet. Id. When a piconet is established one device acts as the master while
`
`the rest of the devices are slaves, and all of the devices have the same priority
`
`synchronized. As discussed above in Section VI.A, all of the devices are
`
`synchronized to the master devices clock. Ex. 2305, p. 87. The devices connect in
`
`point-to-point and point-to-multipoint connections. Ex. 1005, 2:20-21. These
`
`types of connections are supported because the master device is connected to each
`
`of the slave devices and all of the communications pass between the slave devices
`
`and the master. Slave devices on the same piconet cannot communicate directly
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`with one another. Marchand also identifies that devices may be connected to more
`
`than one piconet. See Ex. 1005, 2:25-26.
`
`37.
`
`In Marchand, JINI technology is used to allow devices in its described
`
`network to share services. JINI technology is “a Java-technology-centered,
`
`distributed software system for simplicity, flexibility and federation.” Ex. 1005,
`
`2:27-28, Abstract. “The JINI architecture provides mechanisms for machines or
`
`programs to enter into a federation where each machine or program offers
`
`resources to other members of the federation and uses resources as needed. Ex.
`
`1005, 2:28-31. A person of ordinary skill in the art would have understood, at
`
`least, the general operation of JINI technology.
`
`38. The JINI architecture exploits the ability to move java language code
`
`from machine to machine, to allow various connected devices to use services
`
`offered by other devices in the network. Ex. 1005, 2:28-31. JINI technology relies
`
`on the use of a JINI lookup service (LUS) to offer and share services. Ex. 1009, p.
`
`23. The JINI LUS contains a list of all services offered on a network and allows
`
`devices to share those services. Ex. 1005, 3:11-12. There are a wide variety of
`
`services that can be offered through JINI technology including, “devices such as
`
`printers, displays, or disks; software such as applications or utilities; information
`
`such as databases and files; and users of the system.” Ex. 1009, pp. 79-80.
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`Without the JINI LUS, devices on Marchand’s network would not be able to share
`
`and use services.
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`39. When a device implementing JINI technology joins a JINI-Java
`
`network, the devices undergo a discovery and join process. Ex. 1009, p. 23.
`
`Through this process, the joining device discovers a JINI Lookup service (LUS)
`
`and publishes the services that it can offer to the network. Id. As part of
`
`publishing its service, the joining device transfers java code to the JINI LUS. Id.
`
`The java code is referred to a proxy object or java object. Id. This java language
`
`code is a small amount of code used to identify the services the device offers and
`
`to establish an interface with that service. Id.; see also Ex. 1005, 3:13-14. The
`
`JINI Lookup service stores this java object and creates a list of all of the services
`
`available on the network. Ex. 1009, pp. 22-23; Ex. 1005, 3:11-12.
`
`40. When a JINI java capable device on the network would like to use a
`
`service offered by another device in the network, it sends a request to the JINI
`
`LUS. Ex. 1009, p. 22. The JINI LUS then transfers the java code necessary to
`
`access that service. Id. at p. 23. For example, if a printer joins a network utilizing
`
`JINI technology, the printer will publish its printing service to the network by
`
`transferring java code to the JINI LUS. Id. at 22. The java code includes the
`
`printer’s information and a method to implement its printer interface. Ex. 1009,
`
`22
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`23. When another device in the network needs to print, the device will ask the
`
`JINI LUS if any printer services are available. Id. The JINI LUS provides the
`
`printer’s java code to the requesting device, which will automatically download
`
`that java code from the JINI LUS, if it was not previously downloaded. Id. at 24.
`
`The device can send the printer requests by invoking the methods provided by the
`
`java code to implement the printer interface. Id.
`
`41. When the client issues the printer request it invokes the methods
`
`established by the proxy object. Id. The proxy object, now contained on the
`
`device, communicates with the printer as it needs to in order to execute the
`
`requests. Id. A person of ordinary skill in the art would have appreciated that JINI
`
`technology does not define the protocol between the proxy object on the device
`
`and the printer. Id. at 24-25. The protocol is defined by printer and the proxy
`
`object. Id.
`
`2. Operation of Marchand’s Network and Devices
`
`42. Operating in accordance with the underlying technology, Marchand
`
`describes that the devices are able to connect to form a Bluetooth piconet. Each
`
`device includes the protocol stack described above that allows the Bluetooth
`
`piconet to be extended into an IP wireless LAN and implement JINI and Java
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`23
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`technologies. This allows the devices on Marchand to share services with one
`
`another.
`
`43. While identifying the various services that can be used, Marchand
`
`particularly describes the protocol for implementing a call control service offered
`
`by the mobile phone. The call control service is the only service that Marchand’s
`
`mobile gateway is described as providing.
`
`44. Marchand describes that the mobile phone is able to connect to the
`
`piconet and act as a gateway between the other devices and a wireless IP network.
`
`Id. at 10:15-16, 12:6-10, 7:12-14. This gateway mobile phone “publishes” its call
`
`control service to the LUS allowing other devices in the piconet to detect and
`
`utilize this service. Id. at 8:11-15; FIG. 3. The other Bluetooth devices on the
`
`piconet perform JINI defined “discovery and join” protocols “to locate the LUS
`
`and upload all of its services’ interfaces, including call control services.” Id. at
`
`8:12-20. Through this process, other Bluetooth devices are able to utilize the call
`
`control client of the gateway mobile phone to connect to the wireless IP network.
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`24
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`Figure 6: (Ex. 1005) Marchand, Figure 3
`
`45. The gateway mobile phone has both a radio access modem and a
`
`Bluetooth chi

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