UNITED STATES PATENT AND TRADEMARK OFFICE
`
`PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.,
`
`Petitioner,
`
`COMARCO WIRELESS TECHNOLOGIES, INC.,
`Patent Owner.
`
`Case No. IPR2015~01879
`
`U.S. Patent No. 8,492,933
`
`DECLARATION OF MASSOUD PEDRAM, Ph. D.,
`
`IN SUPPORT OF PATENT OWNER'S RESPONSE
`
`Comarco Ex. 2001
`
`
`
`PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.,
`
`Petitioner,
`
`COMARCO WIRELESS TECHNOLOGIES, INC.,
`Patent Owner.
`
`Case No. IPR2015~01879
`
`U.S. Patent No. 8,492,933
`
`DECLARATION OF MASSOUD PEDRAM, Ph. D.,
`
`IN SUPPORT OF PATENT OWNER'S RESPONSE
`
`Comarco Ex. 2001
`
`
`
`I, Massoud
`
`’edram, have been retained by Comarco Wireless
`
`Technologies, Inc., to testify as an expert witness in this matter. To that end, I
`
`declare, pursuant to 28 USC. § 1746, as follows:
`
`I.
`
`Bac
`
`round
`
`1.
`
`I am the Stephen and Etta Varra Professor in the Viteri School
`
`of Engineering of the University of Southern California. This is an endowed
`
`position that I have held since 2013.
`
`I was a Professor in the Department of
`
`Electrical Engineering at USC from 2000 to 2012, Associate Professor from 1996
`
`to 2000, and an Assistant Professor from 1991 to 1996.
`
`2.
`
`I graduated from the University of California at Berkeley with a
`
`Doctor of Philosophy in Electrical Engineering and Computer Science in 1991, and
`
`a Master of Science in Electrical Engineering and Computer Science in 1989.
`
`I
`
`received a Bachelor of Science in Electrical Engineering in 1986 from the
`
`California Institute of Technology.
`
`3.
`
`I have continuously taught undergraduate and graduate courses
`
`in electrical engineering since 1991 concerning a variety of subjects, including
`
`Advanced Switching Theory and Logic Design, Metal-Oxide-Semiconductor
`
`Very~Large-— Scale Integration (VLSI) Circuit Design, VLSI System Design I and
`
`II, Computer Aided Design of Digital Systems I and II.
`
`
`
`4.
`
`I have authored or co-authored nearly 600 peer-reviewed
`
`conference and archival papers, 20 book chapters, and four books. A complete list
`
`of my publications, articles, reports, and invited lectures in the fields of electrical
`
`engineering and computer science is included in my resume, which is attached as
`
`Exhibit A.
`
`5.
`
`I am a fellow of the Institute of Electrical and Electronics
`
`Engineers
`
`(IEEE),
`
`and a distinguished scientist of Advanced Computing
`
`Machinery (ACM).
`
`I was a Distinguished Lecturer/Speaker for the Association for
`
`Computing Machinery (ACM) (2007-2014), and the IEEE Solid State Circuits
`
`Society (2001-2007).
`
`6.
`
`I have served as a member of research or technical advisory
`
`boards for a number of high technology companies, including Atrenta Inc. (2003-
`
`2015), Fulcrum Microsystems (2001-2004), Magma Design Automation Inc.
`
`(1997-2002), and EPIC Design Technology (1994-1997).
`
`7.
`
`Among other awards and honors, I have received the following:
`
`—- Charles A. Desoer Technical Achievement Award in 2015
`
`from the IEEE Circuits and Systems Society " for contributions to modeling and
`
`design of low power VLSI circuits and systems, and energy efficient computing."
`
`
`
`-- Frequent Author Award (Top Three Author Award) at the
`
`Asia and South Pacific Design Automation Conference 20th Anniversary Award
`
`(2015)
`
`-- Bronze Cited Author at the 50th Anniversary of the Design
`
`Automation Conference (2013)
`
`-- ACM SIGDA Distinguished Service Award (2014 and 2000)
`
`-- Seven Best Paper Awards at seven major conferences and
`
`symposia in the field of microelectronic design and electronic design automation
`
`-— Presidential Early Career Award for Scientists and Engineers
`
`(1996), and the National Science Foundation’s Young Investigator Award (1994).
`
`8.
`
`I served as the inaugural Editor—in-Chief of the IEEE Journal on
`
`Emerging and Selected Topics in Circuits and Systems (2010-2013), and as Editor-
`
`in—Chief of the ACM Transaction on Design Automation of Electronic Systems
`
`(2008-2014).
`
`I also co-founded the IEEE/ACM International Symposium on Low
`
`Power Electronics and Design in 1996, and have served as its General Chair,
`
`Technical Program Chair, and am currently Chair of its Executive Committee.
`
`9.
`
`I am a co-inventor of ten United States Patents as listed on my
`
`resume.
`
`10. A list of the matters in which I have provided expert testimony
`
`is attached as Exhibit B.
`
`
`
`11.
`
`I am being compensated by Comarco at my normal consulting
`
`rate of $750 per hour.
`
`I have no financial or other interest in Comarco, Apple, or
`
`the outcome of this matter.
`
`II.
`
`The Basis of My Testimony and Materials Considered
`
`12.
`
`I have reviewed the opinion of the Board instituting a trial to
`
`determine whether claims 1 and 2 of United States Patent No. 8,492,933 (the ‘"933
`
`patent") are patentable, and understand that the question for resolution is whether
`
`claims 1 and 2 (the "challenged claims") are obvious in light of U.S. Patent No.
`
`7,243,246 to Allen, et al. (Ex. 1003, "Allen"), in combination with U.S. Patent No.
`
`7,296,164 to Breen, et al. (Ex. 1004, "Breen") and U.S. Patent No. 6,054,846 to
`
`Castleman, et al. (Ex. 1005, "Castleman").
`
`13.
`
`In formulating my testimony I have reviewed and considered
`
`Apple's Petition for Inter Partes Review, the Declaration of Nathaniel J. Davis, IV,
`
`Ph. D., Dr. Davis's deposition testimony, as well as the ‘933 patent and the Allen,
`
`Breen, and Castleman patents.
`
`14.
`
`In addition to my background and experience as summarized
`
`above, I believe that I am qualified to render testimony that may assist the Board in
`
`resolving the question presented for the following supplementary reasons.
`
`15.
`
`The
`
`challenged claims
`
`cover power
`
`supply
`
`equipment
`
`comprised of an adapter containing circuitry for producing an analog data signal
`
`
`
`for use by the electronic device to control an amount of power drawn by the
`
`electronic device; a cable that conveys converted DC power from the adapter to the
`
`electronic device; and an output connector containing circuitry that receives a data
`
`request
`
`from an electronic device and transmits a data output
`
`in response
`
`identifying the power supply equipment, including the adapter and the connector.
`
`16.
`
`I have been involved in the design and analysis of application
`
`specific integrated circuits, microprocessor—based devices and systems, and
`
`embedded systems since at least mid 19905. All of these matters are implicated by
`
`the current trial. For example, my research projects have included design and
`
`runtime control of a microcomputer system equipped with various power
`
`optimization and management features (the APOLLO and POLAR projects funded
`
`by the Department of Defense), analysis and optimization of power consumption in
`
`different computing systems comprised of one or more CPUS, different types of
`
`memory, and various I/O devices (e. g., a project on power management in battery-
`
`powered embedded systems and another on power management in multi-«processor
`
`systems, both funded by the National Science Foundation).
`
`In addition, a review
`
`of my publications and lectures will demonstrate that much of my work is related
`
`to power management systems,
`
`including the design of power converters and
`
`power efficiency considerations
`
`in computing systems
`
`including embedded
`
`systems and mobile devices.
`
`
`
`17. My testimony is also informed by my understanding of the law
`
`of obviousness based on my experience as a patentee and as an expert witness in
`
`other matters.
`
`In this regard, it is my understanding that a claimed invention is
`
`obvious if the differences between the claimed subject matter and the prior art are
`
`such that the subject matter as a whole would have been obvious to a person
`
`having ordinary skill.
`
`In part relevant here, it is also my understanding that, in
`
`evaluating the obviousness of the challenged claims, I should consider the scope
`
`and teachings of the prior art, the differences between the claimed invention and
`
`the prior art, and the level of ordinary skill in the art at the time of the invention.
`
`18.
`
`I am also aware that a patent claim composed of known
`
`components in the prior art is not necessarily obvious because many patented
`
`inventions are comprised of combinations of known components.
`
`It is, therefore,
`
`my understanding that
`
`there must be an articulated reason with a rational
`
`underpinning that would have led a person of ordinary skill to modify a prior art
`
`reference in a particular way, or to combine two or more prior art references, in
`
`order to render a claimed invention obvious.
`
`19. A rational reason for combining known components may be
`
`based on the general knowledge of a person of ordinary skill of a market demand
`
`or need to combine components in a way that would satisfy that need or demand,
`
`or when the combination would lead to a predictable result.
`
`
`
`20.
`
`Conversely,
`
`it is my understanding that a person of ordinary
`
`skill would have no reason or motivation to combine known elements from the
`
`prior art when,
`
`in so doing, the prior art would have to be redesigned for no
`
`apparent benefit, or the combination would change the basic principle of operation
`
`of a prior art reference, or the combination of elements would render the prior
`
`inoperable.
`
`21.
`
`I am informed and believe that one cannot use a claimed
`
`invention as a map to pick and choose elements or components from the prior art in
`
`order to replicate a claimed invention. Thus, I understand that obviousness is
`
`evaluated from the perspective of a person of ordinary skill at the time of the
`
`invention and that hindsight reconstruction of the prior art in light of the patented
`
`invention is improper.
`
`22.
`
`I agree with Dr. Davis's description of the qualifications and
`
`experience of a person of ordinary skill.
`
`I disagree with Dr. Davis’s reasoning and
`
`conclusions that that person of ordinary skill would consider the challenged claims
`
`obvious, for the reasons that follow.
`
`I begin with understandings of the nature and
`
`operation of the challenged claims as well as the teachings of Allen, Breen, and
`
`Castleman.
`
`I then explain why, in my view, the challenged claims are not obvious.
`
`
`
`III. The '933 Patent
`
`23.
`
`The '933 patent discloses power supply equipment that provide
`
`DC power to an electronic device 335, such as a laptop computer or cell phone.
`
`The equipment includes an adapter 340 that converts different levels of power
`
`drawn from either an AC power source 300 or a DC power source 305 into an
`
`appropriate level of DC power to operate and/or charge the batteries of an
`
`electronic device safely.
`
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`A cable 350 running from the adapter has an output connector or tip 330 at its
`
`distal end that plugs into the electronic device and carries converted DC power
`
`from the adapter to the electronic device. Because electronic devices usually have
`
`power input ports of different shapes and sizes, the output connector or tip 330
`
`may be detachable from the cable and replaced with a differently configured
`
`connector that fits the power port of a particular electronic device. Apple 1001 at
`
`3:57-60. Thus, the power supply equipment of the '933 patent can supply power
`
`drawn from either AC or DC sources to a plurality of different electronic devices
`
`having different power requirements and power input configurations.
`
`Id. at 3:57-
`
`60; 4:15-18.
`
`24.
`
`The '933 patent also discloses comparison circuitry 320 in a
`
`power adapter that transmits an analog data signal -- Vdata, identified as value or
`
`character string 980 in Figure 9A -- through an output connector to an electronic
`
`device.
`
`Id. at 6:65-68 and 7:7—l2; 9:8-10. Vdam generally indicates the maximum
`
`amount of power the adapter can provide to the electronic device.
`
`Id. at 7:7—l2;
`
`9:8-20.
`
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`FIG. 9A
`
`Vdata may be based on the differing levels of power capability of a standard AC
`
`source, such as a wall socket, or DC sources, such as those provided in motor
`
`vehicles or airplanes. Apple 1001 at 9:10-14. Alternatively, or in addition, Vdam
`
`may be based on the output power capacity of an adapter. For example, Vdm "may
`
`represent that only 70 watts of power are available from the power adapter because
`
`the power adapter has been limited to that output power." Id. at 727-13; 9:14-20.
`
`Vdata enables an electronic device to manage power drawn from the adapter to, for
`
`example, prevent recharging of its battery if the amount of power is insufficient, or
`
`to simultaneously charge its batteries and operate its other functions if there is
`
`sufficient power.
`
`Id. at 4:54-64; 5:46-54; 614-18.
`
`10
`
`
`
`25.
`
`In addition, the ’933 patent teaches the use of a cable output
`
`connector or tip with circuitry that can communicate with an electronic device.
`
`For example, Figure 9B and the associated text depict and describe a tip 900 that
`
`contains a controller 950 comprising a receiver 952, a memory 954, and a
`
`transmitter 956. Id at 7:26-34.
`
`'»»’w, (Rom adapter 940)
`
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`
`This circuitry is capable of receiving a data request signal from an electronic
`
`device and transmitting a signal
`
`in response that
`
`identifies the power supply
`
`equipment providing power to the electronic device. Id. at 7:34-42 and 47-49. The
`
`ability of the tip to respond to an identification inquiry from an electronic device
`
`enables electronic device manufacturers to identify the power supply equipment to
`
`the electronic device and ensure that only approved power supply equipment,
`
`including adapters and tips, are connected to the electronic device.
`
`11
`
`
`
`26.
`
`As discussed below,
`
`the disclosure of the
`
`‘933 patent
`
`concerning the use of (i) an analog data signal to enable an electronic device to
`
`control the amount of power drawn from an adapter, and (ii) an output connector
`
`with reception/response circuitry to identify the power supply equipment to the
`
`electronic device, distinguish the challenged claims from the prior art. These
`
`features are recited in limitations l(b) and l(e) of claim 1 of the '933 patent. The
`
`challenged claims provide, in full:
`
`1.
`
`Power supply equipment comprising:
`
`an adapter to convert power from a power
`[a]
`source, external to the adapter, to DC power
`for
`powering an electronic device,
`
`the adapter including circuitry for producing
`[b]
`an analog data signal for use by the electronic
`device to control
`an amount of power drawn by
`the electronic device; and
`
`[c] a cable having proximal and distal ends, the
`proximal end being electrically coupled to the
`adapter and the distal end terminating in an output
`connector, the output connector including:
`
`[(1] a plurality of conductors to transfer the DC
`power and the analog data signal to the electronic
`device; and
`
`[e] circuitry to receive a data request from the
`electronic device and in response transmit a data
`output to the electronic device to identify the
`power supply equipment to the electronic device.
`
`12
`
`
`
`2.
`
`The power supply equipment of claim 1 wherein
`the output connector can be detached from the
`cable.
`
`IV. Allen, Breen, and Castleman
`
`A.
`
`Allen
`
`27. Allen discloses a power adapter that converts power from either
`
`an AC power source or a DC power source and outputs DC power to an electronic
`
`device. As depicted in Figure 4, Allen's adapter 12 contains a power detection
`
`circuit 74 that detects whether the power source for adapter is AC or DC.
`
`
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`
`Detection circuit 74 activates either AC identification circuit 77 or DC
`
`identification circuit 78 and thereby causes a data signal to be transmitted to an
`
`electronic device that indicates whether the DC power carried on DC power lines
`
`38 to the electronic device is generated from an AC or a DC power source. Apple
`
`13
`
`
`
`1003 at 5:17-30. The power management components of the electronic device use
`
`the data signal to implement various power management functions. Id. at 5:31-42.
`
`28. Allen discloses that AC and DC identification circuits 77 and
`
`78 can be implemented with a memory circuit or chip that generates a 64-bit data
`
`word containing information related to numerous parameters of the power adapter
`
`including the model and revision number of the adapter, the output voltage, current
`
`output, and error checking data. Id. at 5:43-51.
`
`29.
`
`Referring to Allen’s Figure 3, the external power identification
`
`signal produced by either the AC identification circuit 77 or the DC identification
`
`circuit 78 inside the power adapter is transmitted to a subsystem manager 56 in the
`
`electronic device. The subsystem manager 56 is a Super I/O processor (e.g., one
`
`from Silicon Microsystem Corp) which manages the operations of the electronic
`
`device. Apple 1003 at 4230-33, 4:56-66. An external power state machine 60,
`
`which is implemented as a software module running on the subsystem manager 56,
`
`executes instructions to determine the status of external power sources.
`
`Id. at
`
`4:30-55.
`
`30. Allen's subsystem manager and power state machine do not
`
`send a data request to the adapter and the adapter does not contain circuitry that
`
`responds to a data request. This is confirmed by the flow diagram of Allen's
`
`Figure 5 and the associated text, which depict and describe the process by which
`
`14
`
`
`
`the power state machine follows to determines the status of external power sources.
`
`Precisely,
`
`the power state machine polls the identification chip of the power
`
`adapter to obtain the power identification signal while also reading a power
`
`available status signal generated by charger 50. Apple 1003 at 4:21-24; 4:33-40.
`
`These signals are subsequently used by the power state machine to determine
`
`whether the external power is available, not available, or faulty.
`
`Id. at 4:35-55. If
`
`an external power source is available, the power state machine can determine an
`
`external power state corresponding to an AC power source or DC power source.
`
`Id. at 5:52-6:24.
`
`31.
`
`The subsystem manager 56 in the electronic device uses the AC
`
`or DC power source signal "to implement various power management functions."
`
`Id. at 5:30-42.
`
`"For example, if the data signal .
`
`.
`
`. indicates that the external
`
`power source is AC, the power management components may allow the battery to
`
`be fully charged .
`
`.
`
`.
`
`.
`
`If, on the other hand, the data signal .
`
`.
`
`. indicates that the
`
`external power is from a DC source, the power management components may limit
`
`the charging of the battery and also limit the power consumption of the various
`
`system components." Id. at 5:33-42.
`
`B.
`
`Breen
`
`32.
`
`Breen discloses a power supply system in which
`
`power
`
`H
`
`peripherals," such as power adapters and external batteries, are identified in order
`
`15
`
`
`
`to maintain compatibility and operational coordination among various 'mix-n-
`
`match’ power peripherals connected to an electronic device or
`
`Information
`
`Handling System ("IHS") as Breen calls it. Apple 1004 at 1:52-2:2; 2:9-14; 3:9-1 1.
`
`In this system, each peripheral adapter or external battery contains a semiconductor
`
`chip with power supply identification information ("PSID") for the peripheral.‘
`
`Apple 1004 at 5:67-6:2.
`
`33.
`
`The IHS or electronic device 101 in Breen's system contains a
`
`controller 260 that "sends a request signal to one or more power peripherals over a
`
`bi-directional PSID line [250] to request PSID information" whenever there is a
`
`power event, such as "when power peripherals are attached or detached."
`
`Id. at
`
`5:31-37; 5:47-53; 725-9. The controller makes such a request because a peripheral
`
`battery or adapter may provide power at different levels and create a danger that "a
`
`mismatch of component specifications such as wattage, voltage and current may
`
`result in unsafe operation" of an electronic device. Id. at 2:12-14.
`
`34.
`
`Thus, the controller uses the PSID information transmitted by
`
`each peripheral to ensure "compatibility and co-ordination of operation between
`
`various mix-n-match components of the power supply system 100." Id. at 219-11;
`
`2:67-3:12; 3:57-67. This, for example, means that "when a legacy AC-DC adapter
`
`"Information included in a PSID for each power peripheral may include
`1
`attributes such as power type (e.g., AC or DC), wattage/voltage/current rating,
`peripheral manufacturer, part number, country of origin and similar others." Apple
`1004 at 5:3-7.
`
`16
`
`
`
`without PSID is attached to the portable IHS device 101, .
`
`.
`
`. the BIOS [the basic
`
`input/output system of the portable IHS device] sets the operation of the device
`
`101 in a safe, battery optimized mode and disables the charging of the internal
`
`batteries." Apple 1004 at 5:12-18. As another example, "when an AC-DC adapter
`
`with PSID is electrically coupled to the portable IHS device 101, the source of
`
`power is known. The portable IHS device 101 will operate at a pre-determined
`
`power level (identified by BIOS), based on the AC-DC adapter capacity identified
`
`in the PSID information for that peripheral." Id. at 5:18-25.
`
`35.
`
`Breen's system is illustrated in Figure 2, reproduced below:
`
`1» 2&3
`
`
`
`HG. 2
`
`As shown, power peripheral 230 is an AC/DC converter that is connected by a
`
`cable to external battery 240, which, in turn, is connected by a cable to IHS or
`
`electronic device 101. The cable conveys DC power along lines 220 and 225 and
`
`PSID information along PSID line 250.
`
`36.
`
`The external battery 2 0 contains a power event
`
`trigger
`
`component 270.
`
`Id. at 6:35-40. When an AC/DC converter is plugged or
`
`17
`
`
`
`unplugged from the wall socket (which in turn causes a change in the intermediate
`
`voltage line 220), the power event trigger component 270 in the battery causes a
`
`switch in the battery to momentarily interrupt power supplied on line 225 and a
`
`pulse or trigger signal to be sent to the electronic device. Apple 1004 at Abstract;
`
`2:51-55; 417-12, 6:40—46, 7:54-63. The pulse or trigger signal,
`
`in turn, causes
`
`controller 260 in the electronic device to transmit a PSID request to peripheral
`
`devices. Apple 1004 at 5:32-36. Each power peripheral, which is queried, sends a
`
`response signal over the PSID line 250. Id. at 5:36-37.
`
`37.
`
`Breen's Figure 3 illustrates a pulse signal triggering a power
`
`event
`
`in an electronic device. With this arrangement, when any peripheral
`
`is
`
`attached or detached, the controller 260 in the electronic device is automatically
`
`triggered to send a PSID request to peripherals 230 and 240 along PSID line 250,
`
`and read/update the PSID information to adjust power parameters and device
`
`performance accordingly. Apple 1004 at 5:32-37; 7:5-9.
`
`C.
`
`Castlema
`
`38.
`
`Castleman discloses a power supply connection system that can
`
`deliver different levels of power to a multiplicity of different electronic devices (or
`
`power adapters associated with any of such electronic devices) from one source of
`
`electrical power. Apple 1005 at Abstract; 6:54-57; 8:42-47; 10:18-24. The power
`
`supply system includes means
`
`for accepting electronic—device identification
`
`18
`
`
`
`information from any connected electronic device or power adapter associated with
`
`any such electronic device. Apple 1005 at 6:66-7-1, 10:27-30. This identification
`
`information is encoded in a memory chip and identifies the device to the power
`
`supply system and is used to select power parameters for passage of power to the
`
`electronic devices.2 Id. at Abstract; 7:4-8; 8:6-9; 8:64-9:2; 10:35-40; 11:9—12;
`
`12:13-17. This identification information includes, for example, power parameters
`
`for associated power adapter(s) inside one or more of the electronic devices.
`
`In
`
`one of Castleman's embodiments, the output connector of a cable that plugs into an
`
`electronic device contains a memory chip with information about
`
`the power
`
`requirements of the electronic device.
`
`Id. at 5:6-11; 16:58-67; Figure 2. A
`
`microprocessor in Castleman's multiple port supply system "read[s]" the memory
`
`in the output connector and causes the system to provide power
`
`to the
`
`corresponding electronic device at the appropriate level.
`
`Id. at Abstract; 16:4-8;
`
`19:1-3.
`
`V.
`
`Allen and Breen Do _Not Disclose Limitation 1(B)
`
`39.
`
`Limitation 1(b) of the challenged claims requires an adapter
`
`with circuitry that produces an analog data signal that enables an electronic device
`
`Castleman explains: "[I]nformation about each device can be encoded in a
`2
`memory chip and provided to the power-supply apparatus whenever that device
`respectively is connected to receive power from the supply apparatus. In other
`words each device can be caused to have an associated respective memory chip
`which provides the needed identification." Apple 1005 at 4:60-65.
`
`19
`
`
`
`to control the amount of power drawn from an adapter.
`
`I disagree with Petitioner's
`
`contentions that Allen and Breen disclose this limitation either explicitly or
`
`implicitly.
`
`21.
`
`Allen
`
`40.
`
`In my view, a person of ordinary skill would understand that
`
`Allen's AC and DC identification circuits are digital circuits that produce and
`
`transmit digital signals. This view is supported by the fact that Allen's external
`
`power state machine, which receives and processes the power identification signal
`
`produced by the AC or DC identification circuit as well as the power source
`
`available signal produced by the charger, operates on exclusively digital data.
`
`41. Allen employs a "power source detector 74" in the adapter to
`
`determine whether the adapter is drawing power from an AC source or a DC
`
`source. A person of ordinary skill would understand that detection circuit 74
`
`generates a digital signal (e.g., on/off; one/zero) indicating whether an AC or a DC
`
`source is providing power to the adapter. This is confirmed, in part, by the fact
`
`that the complete absence of AC and DC power sources is identified to the
`
`electronic device by the external power source available signal 54, which is
`
`produced by charger 50 acting on external power bus lines 48, which in turn
`
`correspond to DC power lines 38 carrying power from the adapter. Apple 1003 at
`
`413-24 and Figure 3. Furthermore, when present, the type of power source (AC or
`
`20
`
`
`
`DC) is reported to the electronic device by appropriate activation of either the AC
`
`identification circuit 77 or the DC identification circuit 78 and subsequent
`
`generation of a digital power source identification signal on Data Out 42.
`
`Id. at
`
`5:17-30. There is no need for Allen’s power detection circuit 74 to produce
`
`anything other than a simple binary—valued logic signal
`
`indicating whether the
`
`adapter is drawing power from an AC or DC power source.
`
`42. Allen confirms that
`
`the AC and DC identification circuits
`
`output a digital signal by stating that "in an embodiment .
`
`.
`
`. the AC identification
`
`circuit 77 and the DC identification circuit 78 are implemented using DS250l
`
`circuits." Apple 1003 at 5243-48. A DS250l circuit
`
`is a standard EPROM
`
`(Erasable Programmable Read Only Memory) semiconductor chip, which,
`
`in
`
`Allen's system, stores information indicative of the power source and "data relating
`
`to numerous parameters of the adapter" such as the model and revision number of
`
`the power adapter, the output voltage, current output, and error checking data.
`
`Id.
`
`at 5: 3-51.
`
`43.
`
`A DS250l chip produces a digital output. As such, a person of
`
`ordinary skill would understand that Allen's AC identification circuit 77 or DC
`
`identification circuit 78 transmits a digital data signal
`
`indicative of the power
`
`source, together with information relating to the identity of the adapter an: /or its
`
`capabilities.
`
`Id. Allen would not have disclosed implementing the AC/DC
`
`21
`
`
`
`identification circuits with DS2501 chips if the output of the identification circuits
`
`were analog.
`
`44. Allen's description of the operation of the external power state
`
`machine (a software module) in an electronic device also demonstrates that Allen
`
`discloses and contemplates a digital output from the AC and DC identification
`
`circuits. This is so because the power state machine "ping[s]" the external power
`
`identification signal transmitted by either AC or DC identification circuit 77 or 78
`
`for connection (by polling the identification chips of the power adapter) and takes
`
`the power available status signal provided by the charger. The external power state
`
`machine then checks whether either the AC identification circuit 77 is active, the
`
`DC identification circuit 78 is active, or whether neither is active. Apple 1003 at
`
`5:52~6:24.
`
`If the AC or DC power source identification signals were analog, a
`
`person of ordinary skill would expect Allen to explain that the power state machine
`
`software evaluated the output of an analog to digital converter that converted the
`
`analog signal coming from the adapter.
`
`Indeed Allen does not provide any hint of
`
`or justification for the output of the identification circuits to be analog. Nor does he
`
`describe any embodiment
`
`in which the output of the identification circuits is
`
`analog.
`
`5.
`
`I am aware that Petitioner's expert, Dr. Davis, asserted during
`
`his deposition that the digital output of Allen's AC or DC identification circuits
`
`22
`
`
`
`could be converted to an analog signal and transmitted to an electronic device in
`
`analog form. Comarco 2002 at 73:1 -17; 17:13-21. That might be possible if
`
`consecutive bit outputs of DS2501 were bundled into, say, eight-bit digital data,
`
`which is subsequently converted into analog data using an eight—bit digital-to-
`
`analog converter and transmitted as an analog signal to the electronic device. On
`
`the electronic device side, the eight-bit digital data would have to be reconstructed
`
`by applying an eight—bit analog-to-digital converter to each received analog signal.
`
`Considering that the full output of the DS2501 in Allen’s design is a 6 -bit digital
`
`word,
`
`the receiver must
`
`repeatedly apply the aforesaid procedure to the
`
`consecutively received analog signals and assemble the corresponding eight—bit
`
`digital data into a 6 -bit digital word. This approach would add significant
`
`complexity and cost for no apparent gain.
`
`It would be far more practical and less
`
`costly to simply transmit the output of the DS2501 in its original, digital form, just
`
`as Allen discloses.
`
`46.
`
`In another possible scenario, which appears to be what Dr.
`
`Davis has in mind (see Comarco 2002 at 73:12-17), the full 64-bit output of
`
`DS2501 could theoretically be directly converted into analog data and transmitted
`
`to the electronic device. This would result in unavoidable loss of information
`
`because the only possible output from a 64-bit digital to analog converter would be
`
`a voltage value that is the sum of all of the discrete bits of the 6 -bit word
`
`23
`
`
`
`generated by the DS250l (multiplied by their respective weights); that is, a voltage
`
`with 1.845 x 1019 distinct values. No digital to analog converter exists with that
`
`degree of resolution. Under this scenario, the digital to analog conversion that Dr.
`
`Davis proposes would render Allen inoperable.
`
`48..
`
`It is my opinion, in sum, that a person of ordinary skill would
`
`not conclude that Allen's AC/DC identification circuits output an analog signal or
`
`cause an analog signal to be transmitted to an electronic device. Nor would a
`
`person of ordinary skill have any motivation to transform Allen's digital circuits
`
`into analog circuits on the ground that an analog implementation might be
`
`"simpler" or "more convenient." Apple Brief at 17; Apple 1010, 11 72. Plainly, as
`
`dis cussed above, it would be neither simple nor convenient to do so.
`
`b.
`
`Breen
`
`49.
`
`I also disagree with Apple's contention that Breen's power event
`
`trigger signal meets the requirements of the analog data signal as dictated by
`
`limitation l(b). Apple Brief at 33; Apple 1010, 11 89.
`
`50.
`
`Breen discloses that a power event is generated by a power
`
`trigger component 270 in an external battery 240 that is coupled between an
`
`adapter and an electronic device when there is a change of input power to the
`
`battery peripheral 240 resulting, for example, from ”the plugging or unplugging" of
`
`an AC-DC adapter to or from an AC wall outlet. Apple 1004 at 2:51-55; 523137;
`
`24
`
`
`
`5:47-452; 7:5-9. The power trigger component produces two binary o
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