UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`HTC Corporation,
`HTC America, Inc,
`LG Electronics, Inc.,
`Samsung Electronics Co., Ltd., and
`Samsung Electronics America, Inc.
`Petitioners
`
`V.
`
`Parthenon Unified Memory Architecture LLC
`Patent Owner
`
`DECLARATION OF SANTHANA CHARI, PHD.
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`Page 1 0f 8
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`_
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`HTC-LG-SAMSUNG 1008
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`HTC-LG-SAMSUNG 1008
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`i, Santhana Chari, declare as follows:
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`i.
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`Ihave been retained by Petitioners as an independent consultant. I
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`have been asked to provide an opinion regarding the public accessibility of
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`International Organization for Standardization, “iSO/IEC 11172-2: Information
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`technology—~Coding of moving pictures and associated audio for digital storage
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`media at up to about 1,5 Mbit/s—PartZ: Video,” (ist ed. Aug. 1, 1993) (“MPEG
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`Standard”).
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`1 have been provided a copy of the MPEG Standard, which I
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`understand is Exhibit 1004 in this proceeding.
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`2.
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`I earned a Bachelor’s degree in Eiectronics and Communications from
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`the College of Engineering, Madras, lndia, in £989, a Master’s Degree in Electrical
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`Engineering from the University of Maryland, College Park, in 1994, and a
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`Doctorate in Electrical Engineering from the University of Maryland, College
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`Park, in 1995. While pursuing my Master’s and Doctorate degrees, I was active in
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`the field ol‘video and image processing, was aware ol‘ developments in MPEG
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`technology, and read about the MPEG standards as they became available to the
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`public.
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`3.
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`I have been centrally involved in the development of MPEG
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`technology since the mid 1990’s. For example, from 1995 to 1997, l worked as a
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`Senior Member of the technical staff as COMSAT Laboratories, developing
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`MPEG-2 based real~time hardware video codecs and multiplexers for satellite TV
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`applications. Front 1997 to 2002, white working at Philips Electronics, NV. as a
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`Project Lead and Senior Researcher, I developed algorithmic techniques to
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`prioritize MPEG compressed video and adaptive error control strategies for video
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`transport over 802.1 la wireless LANs. During this period, I also played a leading
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`role in Phiiips’ contribution to the MPEG—7 standardization. In 2002, Ijoined EG
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`Technology, Inc, as the Chief Architect of video compression product. As of
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`2009, l have been a Senior Director of Digital Video Systems at ARRIS Group,
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`currently responsible for a multi~site team working on various products addressing
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`the delivery ofvideo over IP networks, and high quality compression ofHD and
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`4K of digital video. My curriculum vitae is attached as Appendix A.
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`4.
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`As shown in my qualifications above, I was significantly involved in
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`the image/video coding field in the mid 1990’s, and was aware of the
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`standardization process used by the International Organization for Standardization
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`(“ESO”) for image/video-coding reiated standards such as MPEG-1 and MPEG—2.
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`5.
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`The MPEG Standard is the first formal edition of the l 1 172—2
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`standard (commonly referred to as MPEG-1), dealing with coding of moving
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`pictures and associated audio for digital storage media.
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`6.
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`The MPEG Standard lists a date of August 1, 1993 on its cover page,
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`and a copyright date ol’1993 on page ii. Ex. 1004 at 12. Moreover, thewebsite
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`for the ISO indicates that the MPEG Standard was “published on: 1993-0842”.
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`Ex. 1009 at 1. Exhibit 1009 is a true and correct copy of the 180’s website for the
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`MPEG Standard (available at
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`I
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`http:llwww.iso.org/iso/cataloguemdetail.htm?csnumber=224l l).
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`7.
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`In my experience, MPEG Standard would have been publicly
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`available as of August 1993, so that interested members of the public could have
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`obtained MPEG Standard with reasonable diligence if they so desired.
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`8.
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`As a published standard, those in the field of image/Video coding,
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`including those outside ofthe International Standards Organization that developed
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`the MPEG Standard, would have known about, sought out, and had access to the
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`MPEG Standard, at least as of August 1993. For example, those in the
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`image/video coding field at the time would have regularly checked the status of
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`standards relating to image/video coding, and with reasonable diligence would
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`have known when the MPEG' Standard was formalized and published as a
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`standard. Moreover, those in the image/Video coding field would have had access
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`to the MPEG Standard via the 180’s online presence and/or by ordering a copy of
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`the MPEG Standard.
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`9.
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`1 declare that all statements made herein of my knowledge are true,
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`and that all statements made on information and belief are believed to be true, and
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`that these statements were made with the knowledge that willful false statements
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`and the like so made are punishable by fine or imprisonment, or both, under
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`Section 1001 of Title 18 of the United States Code.
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`Dated: June24, 2015 ByJM; IQL
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`Santhana Cheri, PhD.
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`Appendix A
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`Santhana Chari
`
`385 Findley Way
`
`Phone: 678—5 17—33 15
`
`Email: santhana.chari@gmail.com
`Johns Creek, GA 30097
`
`
`Professional Summary
`I
`Expert and Innovator in the fields of video compression and digital signal processing
`I
`Twenty years of R&D and product development experience at companies of various sizes
`I
`Conceptualized and managed the release of several new pro ducts based on disruptive technologies
`I
`Strong expertise in developing embedded reaE—time software for DSP, multieore CPU, and GPU
`I
`Experienced engineering manager with full product life cycle experience
`I
`Communicated technology vision and product differentiators in industry panels and trade publications
`
`Work Experience
`2009—present ARRIS Group
`Sr. Director, Engineering - Digital Video Systems
`I came to ARRIS through the acquisition of my previous company EG Technology, Inc. Currently
`responsible for a multi—site team working on various products addressing the delivery of video over
`IP networks, and high quality compression of HD and 4K of digital video. In my current role, I also
`lead the technology strategy for migrating video compression products from a custom appliance to
`software only solution that can be deployed in the network cloud infrastructure.
`
`Suwanee, Georgia
`
`2002- 2009
`
`EG Technology, Inc
`VP, Engineering
`
`Atlanta, Georgia
`
`I joined the early stage start—up company as the Chief Architect of the video compression products
`and led the technology strategy.
`I was actively involved in the product strategy of the company and
`participated in several rounds of VC fundnraising. Hired and led the engineering team consisting of
`top quality experts in the areas of video algorithm, multi—core DSP software and hardware to bring
`innovative, embedded real-time video compression products to cable market. These products have
`been deployed at all major North American cable operators.
`,
`I Universal Transcoder and Ad~splicer: Led the architecture and software development for a
`product line based on Intel x86 processors to repurpose digital video content. The system ingests
`video content in MPEG2, H.264 and other video formats up to HD 1080i resolution. Ingested video
`is processed to convert the coding format, resolution and bitrate to output video at ED, SD and
`mobile resolutions. All video processing modules are implemented in software with proprietary,
`patented techniques to improve video quality.
`I Over—the~top IP Video Delivery: Developed a prototype system to deliver broadcast quality
`video over large 1? networks to customer premises devices. This system had nodes deployed at
`several locations in the IP network and utilized bandwidth measurement techniques to dynamically
`estimate the available bandwidth between overlay nodes. Knowledge of the instantaneous bandwidth
`availability was combined with video processing techniques to drastically improve the quality of
`video delivered to the end points.
`I H.264 and MPEG2 Encoders: Developed industry’s first fully DSP based professional broadcast
`quality real—time MPEG2 encoder. Brought to market a disruptive product based on Equator DSPs
`that offered superior video quality performance compared to competing ASIC based solutions at a
`substantially lower cost. More than 14,000 channels have been deployed at various cable MSOs. The
`H.264 encoder was developed using a custom hardware platform based on Texas Instruments
`DM642 and 6415 DSPs. The DSP software and proprietary algorithms
`for video quality
`enhancements Were internally developed.
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`1997-2002
`
`Briarcliff Manor, New York
`
`Philips Electronics, N.V.
`Project Lead and Senior Researcher
`- In-Home Wireless Streaming: Conceptualized and led the development of a prototype for‘
`transmitting video over wireless in-home networks with engineering team members from the US and
`France. Demonstrated robust transmission of video from a home media server to several display
`devices at home such as a large screen TV, PC and mobile devices. Algorithmic techniques to
`prioritize MPEG compressed video and adaptive error control strategies for video transport over
`802.11a wireless LANs were developed.
`I MPEG-7 Standardization: Played a leading role in establishing Philips' presence in MPEG-7
`standardization. Proposed two different technologies that became a part of the MPEG—7 standard.
`Managed joint activities with other organizations like NEC, Kodak and University of Rochester
`during the development of these technologies. Represented Philips actively in many MPEG-7
`meetings. Developed web—based demonstration modules using Java Servlets.
`
`1995-1997
`
`COMSAT Laboratories
`Senior Member of Technical Staff
`
`Clarksburg, Maryland
`
`I MPEG—2 Codec: Worked on the development of MPEG-2 based real—time hardware video codecs
`and multiplexers for satellite TV applications. Led the development of a statistical multiplexer that
`allowed more video channels to be transmitted over a given bandwidth. This system dynamically
`allocates optimal bit—rates to different MPEG2 streams by estimating the complexity of the video
`source based on certain MPEG coding parameters.
`- Fax Compression: Developed a compression algorithm for INMARSAT mini—M mobile network
`based on adaptive arithmetic coding and context prediction for two-level facsimile documents to
`achieve better compression over Group3 (T4) recommendation.
`
`Innovation
`
`Society
`
`of Cable
`
`Society of Cable
`
`Technical Publications: Published three book chapters and about 15 journal and conference papers.
`Patents : l have fifteen issued patents and severai pending in the areas of image and video compression,
`video processing and transmission, wireless networking, and MPEG-7.
`Presentations: Participated in several panel discussions at various cable industry technical conferences:
`I
`“Adaptive Bitrate Delivery Architecture
`and Virtualization”,
`Society
`of Cable
`Telecommunication Engineers’ Cable Tecn Expo, 2014
`“Emerging Video Coding
`and
`Streaming Technologies”,
`Telecommunication Engineers ’ Cable Teel; Expo, Denver, 2012.
`“Optimizing HD Video Quality: Tools
`and Architectures”,
`Telecommunication Engineers ‘ Cable Tcell Expo, 2009.
`
`0
`
`-
`
`Education
`
`1995
`1994
`1989
`
`Ph.D., Electrical Engineering, University of Maryland, College Park, Maryland
`M.S., Electrical Engineering, University of Maryland , College Park, Maryland
`B.E., Eiectronics and Communications, College of Engineering, Madras, India
`
`Professional Affiliations
`
`Member, institute of Electrical and Electronics Engineers (TEEE).
`Member, Society of Cable Telecommunication Engineers (SCTE)
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