PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 8,185,964
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`Exacq Technologies, Inc.
`Exhibit 1003
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`Exacq Technologies, Inc.
`Exhibit 1003
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`Attorney Docket: EXC-964IPR
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`DECLARATION OF GREG THOMPSON
`REGARDING U.S. PATENT NO. 8,185,964
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`Inter partes Review Case No. IPR2016-_______
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`Inter partes Review of: U.S. Patent No. 8,185,964
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`Issued: May 22, 2012
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`To: Joseph Robert Marchese
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`For: Digital Video System Using Networked Cameras
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`Exacq
`Ex. 1003
`Page 1
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`Table of Contents
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`Page
`I. Personal Background and Qualifications ............................................................ 3
`II. Understanding of Legal Standards ................................................................... 7
` Validity .......................................................................................................... 8
`A.
` The Level of Ordinary Skill in the Art ........................................................ 11
`B.
`III. Materials Reviewed and Considered .............................................................. 13
`IV. THE STATE OF THE ART BEFORE THE ’964 PATENT’S EARLIEST
`PRIORITY DATE .................................................................................................... 14
`A.
` Systems of Networked Cameras Were Known ........................................... 14
` MAC Addresses Were Used to Identify and Authorize Network Devices
`B.
`Long Before the Alleged Invention ...................................................................... 17
`C.
`It Was Obvious to Apply Networking Techniques to Systems of
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`Networked Cameras ............................................................................................. 19
`V. Claims 1-4 of the ’964 Patent are Unpatentable ............................................ 20
` Claims 1 and 3 are Anticipated by Acosta .................................................. 20
`A.
` Claims 2 and 3 are Rendered Obvious by Acosta in view of Axis 200 ...... 32
`B.
` Claim 4 is Rendered Obvious by Acosta, Axis 200, and Nelson ............... 36
`C.
`VI. Conclusion ...................................................................................................... 43
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`Exacq
`Ex. 1003
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`I, Greg Thompson, declare:
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`1.
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`I make this declaration based on personal knowledge, and I am
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`competent to testify about the matters set forth herein.
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`2.
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`I have been retained by counsel for the Petitioner to review relevant
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`materials and render my expert opinion in connection with technical matters
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`related to U.S. Patent No. 8,185,964 (“’964 patent”) (Ex. 1001). I submit this
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`declaration in connection with Petitioner’s Petition for Inter Partes Review of
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`Claims 1-4 of U.S. Patent No. 8,185,964 (“Petition”). I am being compensated for
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`my time at a rate of $200 per hour, plus actual expenses. My compensation is not
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`dependent in any way upon the outcome of this Petition.
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`3.
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`For at least the reasons expressed in this declaration, I agree with the
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`contents of the Petition.
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`I.
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`PERSONAL BACKGROUND AND QUALIFICATIONS
`4. My professional career has spanned close to 38 years. During these
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`years, I have gained extensive experience in the analysis, design, architecture,
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`standards, and development of products and services in the areas of multimedia
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`and networked video delivery (including MPEG, IPTV and Video-on-Demand),
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`computer networks (including TCP/IP and Ethernet), application development
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`(including web-based technologies), and cloud-based services.
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`5.
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`I am currently a Mentor, Venture Advisor and Consultant to multiple
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`startup companies out of the i-GATE Innovation Hub in Livermore, California,
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`which is supported by Lawrence Livermore National Labs (LLNL), Sandia
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`National Labs, the Tri-Valley cities including Livermore, Pleasanton, Dublin, and
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`Danville, and the County of Alameda.
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`6.
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`Previously, I was Chief Technology Officer for Multimedia at Huawei
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`Technologies USA. Huawei is the world’s largest provider of Information and
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`Communication Technology (ICT) solutions. From November 2010 to the present
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`time, both at Huawei and i-GATE, I have focused on helping drive collaboration
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`and innovation using lean-startup methods and modern networking, multimedia,
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`cloud and maker technologies, while also educating others on its standards and best
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`practices.
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`7.
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`Prior to Huawei, I was a Sr. Director and Chief Video Architect at
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`Cisco Systems Inc., a leader in network technologies. From September 2003 to
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`October 2008, and later as a consultant to Cisco through November 2010, I was as
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`a video technology expert across multiple business units (“BUs”) helping design
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`and architect products, including Cisco’s EdgeQAMs for cable Video-on-Demand
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`(VoD) and its Video Quality Enhancement (VQE) offerings. I organized cross-BU
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`video architecture summits and presented at industry conferences including Cisco-
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`Live Networkers, Society of Motion Picture and Television Engineers (SMPTE),
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`National Telecommunications Cooperative Association (NTCA), Society of Cable
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`Telecommunications Engineers (SCTE), and other conferences.
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`8. While at Cisco, I also served as a video technology evaluator in three
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`potential acquisitions (UTStarcom, Scientific Atlanta, and Arroyo Video Solutions
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`Inc.). Following the Scientific Atlanta acquisition, I taught IPTV technology to
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`Scientific Atlanta employees. I was also a member of Cisco’s Video Cisco Patents
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`Online (CPOL) committee through which I evaluated and advanced video-related
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`patents. I was also a visiting engineer to Comcast during their RNG generation
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`video Set Top Box design.
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`9.
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`I was also co-chair of Cisco’s video-related standards efforts in the
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`ITU-T, ATIS-IIF, DVB, MSF and other SDOs and co-led Cisco’s efforts in the
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`International Telecommunications Union’s (ITU-T) IPTV Focus Group developing
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`International standards for the delivery of multimedia Television services over
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`Internet Protocol (IPTV) from July 2006 through early 2008.
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`10. Prior to Cisco, I was Chief Technology Officer for Larry Ellison’s
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`nCUBE company, a super-computer company that pivoted into the development of
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`service provider Video-on-Demand. From March 1993 to September 2003 at
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`nCUBE, I led the development of its MediaCUBE video server products in
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`conjunction with the OMS/OVS team at Oracle, applying super-computer and
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`networking technologies in the world’s first VoD Telco trials at British Telecom,
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`US West, and in Bell Atlantic’s Stargazer trial in Reston VA. The nCUBE VoD
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`servers delivered MPEG-2 TS video over ATM, channelized T3 and Ethernet. We
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`later deployed what was at that time the world’s largest VoD deployment in New
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`York City for Time Warner Cable. During this period, I also worked extensively
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`with leading broadcast Conditional Access System (CAS) companies in updating
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`their CAS systems to support the random access “trick-mode” operations needed
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`for VoD.
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`11. Between February 1983 and March 1993, I was a co-founder of
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`Interlink Computer Sciences Inc. (INLK), where we developed DECnet and
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`TCP/IP networking for IBM’s MVS and VM systems. The company went public
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`on NASDAQ in 1996. I led the design and implementation of the 3711 Network
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`Controller, connecting IBM channels to an Ethernet network, and the VM/DECnet
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`product in support of DuPont, its initial and lead customer.
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`12. From January 1978 to February 1983 I worked at Digital Equipment
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`Corp (DEC), consulting to multiple customers including LLNL, NASA/Ames
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`Research Center, and the US Navy regarding DEC products and network
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`technologies. At LLNL, I helped design the control system for the ATA particle
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`beam accelerator at Site 300. For NASA/Ames, I supported the development of
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`their DECnet network of VAX/VMS and RSX-11 systems. For the US Navy in
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`Monterey CA, I debugged and corrected problems with their third-party developed
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`2780/3780-based communications subsystem.
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`13.
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`I received a B.S. in Computer Science and Engineering in 1978 at the
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`Massachusetts Institute of Technology (MIT) after winning a Hertz Foundation
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`undergraduate scholarship. Later, in 2007 at Cisco, I also earned a Stanford
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`Certificate in Advanced Project Management (SCPM) from Stanford University.
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`14.
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`I am a long time member of the Institute of Electrical and Electronics
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`Engineers (IEEE), the Society of Motion Picture and Television Engineers
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`(SMPTE), and the Society of Cable Telecommunications Engineers (SCTE).
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`15.
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`I have given the Introduction to IPTV Architectures, Technologies,
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`and Standards tutorial at the 2007 SMPTE Fall Technical conference in Brooklyn
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`NY. I was an invited guest editor of the IEEE Internet Computing journal’s
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`May/June 2009 special issue on IPTV and the July 2009 online issue of IEEE
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`Computing Now.
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`16.
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`I am also a current member of MIT’s Education Council, interviewing
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`high school applicants who apply to attend MIT.
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`17. A copy of my CV is attached to this declaration as Appendix A.
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`II.
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`UNDERSTANDING OF LEGAL STANDARDS
`18.
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`I am not a lawyer and I have no legal training. I have been informed
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`by Petitioner’s counsel about certain legal principles and standards, which I have
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`assumed and applied for purposes of this declaration. Some of these, which form
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`the legal framework for the opinions I am providing, are summarized below.
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`A.
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`19.
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`Validity
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`I have been informed that a patent claim may be found invalid if it is
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`anticipated or rendered obvious by prior art. I have considered references such as
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`patents and publications to be prior art to the ’964 patent if they were patented or
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`published more than one year before the alleged priority date of the ’964 patent, or
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`if they were patented or filed as an application for a patent, which was
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`subsequently published, with a date prior to the date the subject matter of the
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`claims of the ’964 patent was allegedly invented. For purposes of this declaration,
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`I have assumed that the priority date of the claims of the ’964 patent is March 14,
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`2000, the date on which the provisional application to which the ’964 patent claims
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`priority was filed.
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`20.
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`I have been informed that a patent claim is anticipated under 35
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`U.S.C. § 102 if each and every limitation of the claim is disclosed in a single prior
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`art reference as arranged in the claim. I understand that each element of a patent
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`claim may be disclosed by a prior art reference either expressly or inherently. My
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`understanding is that even an “express” disclosure does not necessarily need to use
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`the same words as the claim. I also understand that an element of a patent claim is
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`inherent in a prior art reference if the element must necessarily be present, and its
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`presence would be recognized by a person of ordinary skill in the art. However, I
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`understand that inherency cannot be established by mere probabilities or
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`possibilities.
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`21.
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`I understand that not all innovations are patentable; even if a claimed
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`product or method is not disclosed in its entirety in a single prior art reference, the
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`claim is nonetheless invalid if the differences between the patented subject matter
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`and the prior art are such that the subject matter as a whole would have been
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`obvious to a person of ordinary skill in the art at the time of the alleged invention.
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`I am informed that this standard is set forth in 35 U.S.C. § 103(a).
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`22.
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`I understand that when considering the issues of obviousness, I am to
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`do the following: (i) determine the scope and content of the prior art; (ii) ascertain
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`the differences between the prior art and the claims at issue; (iii) resolve the level
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`of ordinary skill in the pertinent art; and (iv) consider objective evidence of non-
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`obviousness (so-called “secondary considerations”). I appreciate that secondary
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`considerations must be assessed as part of the overall obviousness analysis, and
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`should not be considered merely to decide whether they alter any initial
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`obviousness conclusions that could be drawn based on the prior art. I understand
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`examples of evidence of secondary considerations of non-obviousness include
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`evidence of commercial success, long-felt but unsolved needs, failure of others,
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`and unexpected results. I am not aware of any secondary considerations that
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`would rebut my opinion that claims 1-4 of the ’964 patent would have been
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`obvious (and I reserve the right to address any supposed secondary considerations
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`to the extent the patent owner attempts to raise them in this proceeding).
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`23. To the contrary, the claimed invention of the ’964 patent did not solve
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`a long-felt but unsolved need, fix the failure of others, or achieve unexpected
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`results considering the prior art had already addressed and solved the same issues
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`in the same way. I am not aware of any evidence showing a nexus between the
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`commercial success of any product and the claimed invention of the ’964 patent.
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`24.
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`In determining whether the subject matter as a whole would have been
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`obvious at the time that the invention was made to a person having ordinary skill in
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`the art, I have been informed of several principles regarding the combination of
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`elements of the prior art.
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`25. First, a combination of familiar elements according to known methods
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`is likely to be obvious when it yields predictable results. Second, simple
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`substitution of one known element for another is likely to be obvious when it
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`yields predictable results. Third, the use of known techniques to improve similar
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`devices (methods, or products) in the same way is likely to be obvious when it
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`yields predictable results. Fourth, applying a known technique to a known device
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`ready for improvement is likely to be obvious when it yields predictable results.
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`Fifth, merely choosing from a finite number of identified, predictable solutions, is
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`likely to be obvious when there is a reasonable expectation of success. Sixth,
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`known work in one field of endeavor may prompt variations of it for use in either
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`the same field or a different one based on design incentives or other market forces
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`and such variations are likely to be obvious if the variations are predictable to one
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`of ordinary skill in the art.
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`26.
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`I understand that the “teaching, suggestion, or motivation” test is a
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`useful guide in establishing a rationale for combining elements of the prior art.
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`This test poses the question as to whether there is an explicit teaching, suggestion,
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`or motivation in the prior art to combine prior art elements in a way that realizes
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`the claimed invention. Though useful to the obviousness inquiry, I understand that
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`this test should not be treated as a rigid rule. It is not necessary to seek out precise
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`teachings; it is permissible to consider the inferences and creative steps that a
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`person of ordinary skill in the art would employ.
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`B.
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`27.
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`The Level of Ordinary Skill in the Art
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`I understand that “a person of ordinary skill in the relevant field” is
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`presumed to be a person with standard skill, creativity, and knowledge in a
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`particular field or industry. This person thinks along the line of conventional
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`wisdom in the art but is neither an automaton nor one who undertakes to innovate,
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`whether it is by patient, expensive, and systematic research or by extraordinary
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`28.
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`In assessing the level of ordinary skill, I further understand one may
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`consider several factors, including: (1) the educational level of the inventor; (2) the
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`educational level of active workers in the field; (3) type of problems encountered
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`in the art; (4) prior art solutions to those problems; (5) the rate of innovation in the
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`field; and (6) the sophistication of the technology.
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`29. Based on my experience, I have an understanding of the capabilities
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`of a person of ordinary skill in the relevant fields. I have supervised, directed, and
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`worked with many such persons over the course of my career. Further, I had at
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`least those capabilities myself on the priority date of the ’964 patent.
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`30.
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`I have been informed that the level of skill in the art is evidenced by
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`prior art references. The prior art discussed herein demonstrates that a person of
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`ordinary skill in the field, on the assumed priority date of the ’964 patent, was
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`aware of networked camera systems, commonplace networking techniques, and the
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`applicability of those networking techniques to the networked camera systems.
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`31.
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`I have been asked to offer an opinion on the characteristics of a person
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`having ordinary skill in the art as of the priority date of the ’964 patent. In view of
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`the specification of the ’964 patent and the prior art references of record, it is my
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`opinion that a person of ordinary skill at that time in the relevant field of the ’964
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`patent would have an undergraduate degree in computer science or electrical
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`engineering and 2-3 years of experience designing and programming video
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`management system software, or an equivalent combination of education and
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`experience.
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`32. Regarding the above factors for determining the level of ordinary skill
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`in the art, I considered the following in developing my opinion: the educational
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`level of active workers in the field, in my experience, is typically a bachelor’s
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`degree in computer science or electrical engineering; the problems encountered in
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`the art generally relate to connecting applications to networked devices so they are
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`interoperable; the prior art solutions include networked video camera systems and
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`networking techniques collectively using the same concepts, techniques, and
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`technologies as claimed in the ‘964 patent; the rapidity with which innovations
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`were made in this field was high because the technologies described and claimed in
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`the ’964 patent were largely based on software that could be developed quickly and
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`expanded to include then-known features in expected ways to achieve increasingly
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`useful results; and the sophistication of the technology was moderate because in
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`order to make it accessible to users and professional system builders, there was
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`reduced technical complexity.
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`III. MATERIALS REVIEWED AND CONSIDERED
`33.
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`In connection with my work on this matter, I have reviewed the
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`following documents:
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`Description
`Exhibit
`1001 USPN 8,185,964 (patent under Inter Partes Review)
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`1002 The file history for the ’964 patent
`1004 USPN 6,166,729 to Acosta et al. (“Acosta”)
`1005 USPN 5,905,859 to Holloway et al. (“Holloway”)
`1006 USPN 6,292,838 to Nelson (“Nelson”)
`1007 AXIS 200 User’s Manual (“Axis 200”)
`1008 AXIS 2100 Network Camera User’s Guide (“Axis 2100”)
`1009 AXIS 2400 and AXIS 2401 Video Servers Administration Manual
`(“Axis 2400”)
`1010 Declaration of James Marcella
`1011 USPN 6,438,530 to Heiden et al. (“Heiden”)
`1012 USPN 6,477,648 to Schell et al. (“Schell”)
`1013 ANSI/IEEE Std 802.3-1985 (“Carrier Sense Multiple Access with
`Collision Detection (CSMA/CD) Access Method and Physical Layer
`Specifications”) (“802.3 Standard”)
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`IV. THE STATE OF THE ART BEFORE THE ’964 PATENT’S
`EARLIEST PRIORITY DATE
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`A.
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`Systems of Networked Cameras Were Known
`34. At the time of the ’964 patent’s earliest priority date, network cameras
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`and video servers were well known. The ’964 patent acknowledges this in its
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`background section:
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`There now exists commercially available networkable cameras that
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`can be accessed over networks running TCP/IP, including both LANs
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`and global networks such as the Internet. Ethernet-based digital video
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`servers are now common that are small, autonomous, and usually
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`contain a web-based configuration utility, as well as administration
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`(’964 patent, 2:1-6 (Ex. 1001).) For example, there were several commercially-
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`available network cameras and network video servers produced by Axis
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`Communication AB. (See Axis 200 (describing prior art network camera) (Ex.
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`(1007).) (See Axis 2100 (describing prior art network camera) (Ex. 1008).), (See
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`Axis 2400 (describing prior art network video server) (Ex. 1009).).
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`35. Systems also existed that connected together multiple network
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`cameras and video servers. These systems tracked the cameras to which they
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`connected, managed network communications with the network cameras, and
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`obtained image data from the network cameras. For example, U.S. Patent No.
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`6,166,729 to Acosta, filed May 7, 1997, discloses a remote viewing system 10 that
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`included “camera devices 12, a wireless network 14, a central office video
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`management system (COVMS) 16.” (Acosta, 4:26-28 (Ex. 1004).)
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`Acosta describes that “at the camera 12, the digital data is processed, compressed,
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`and then transmitted over the wireless network 14 to the COVMS 16.” (Acosta,
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`7:29-31 (Ex. 1004).) “The COVMS 16 processes the images and then transfers
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`them to the storage facility for archive, to the World Wide Web 18, and to
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`dedicated connections with the COVMS 16 of certain users, if any.” (Acosta, 8:9-
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`12 (Ex. 1004).) Acosta also discloses using serial IDs identifying the camera
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`elements 12 to determine whether the COVMS 16 is authorized to receive image
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`data from the camera elements 12. (See Acosta, 17:41-18:4 (the COVMS makes a
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`“determination [] in a step 514 whether the camera element 12 is authenticated. If
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`not, the process continues to the step 510 with an unauthorized access alarm and
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`then returns to step 502.”) (Ex. 1004).)
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`B.
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` MAC Addresses Were Used to Identify and Authorize Network
`Devices Long Before the Alleged Invention
`36. MAC addresses, and using them to identify devices in a network,
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`were well known in computer networking long before the’964 patent’s earliest
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`priority date. Indeed, the Ethernet standard expressly states that a MAC address
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`can be used for that purpose. For example, the 1985 edition of the IEEE 802.3
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`standard describes the Media Access Control (“MAC”) Frame Structure. (802.3
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`Standard at 23-27 (Ex. 1013).) The standard provides that “[e]ach MAC frame
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`shall contain two address fields: the Destination Address field and the Source
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`Address field, in that order.” (802.3 Standard at 24 (Ex. 1013).) “The Source
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`Address field shall identify the station from which the frame was initiated.” (802.3
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`Standard at 24; see also 26 (“The Source Address field specifies the station sending
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`the frame. The Source Address field is not interpreted by the CSMA/CD MAC
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`sublayer.”) (Ex. 1013).)
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`37. Further, the prior art expressly recognizes advantages of using a MAC
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`address as an identifier for a network device, including widespread use and near-
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`uniqueness. For example, U.S. Patent No. 6,438,530 to Heiden et al., filed
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`December 29, 1999, uses MAC addresses as a personal computer (“PC”)
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`“signature,”: “[a]nother example of a PC signature for a computer that has Ethernet
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`interface standard equipment is a unique ID called a ‘MAC address’ and every
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`piece of Ethernet hardware ever manufactured has been assigned one under the
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`supervision of a standards organization.” (Heiden, 7:13-17 (Ex. 1011).) (See,
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`also, Nelson, 1:54-58 (“[a] MAC layer address is usually statically associated with
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`an individual network interface of a device, for example as stored within a non-
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`volatile memory of a network interface card.”) (Ex. 1006).)
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`38. Using a MAC address to determine whether communications between
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`systems on a network are authorized was also a known technique. Networking
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`technologies predating the alleged invention used a device’s MAC address to
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`determine whether to allow devices to communicate with other devices on the
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`network. For example, Holloway, which was filed January 9, 1997, describes prior
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`art systems where “[t]here are token ring and Ethernet managed hubs that allow a
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`network administrator to define, by MAC address, one or more authorized users
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`per hub port. If an unauthorized MAC address is detected at the hub port, then the
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`port is automatically disabled.” (Holloway, 2:6-10 (Ex. 1005).) As another
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`example, U.S. Patent No. 6,477,648 to Schell et al., filed March 23, 1997,
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`describes using MAC addresses to determine which network devices are
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`authorized to communicate: “the [network interface card] also includes a receive
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`address confirmation circuit that functions to ensure that the trusted workstation
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`does not receive packets from entities other than known/authorized servers. That
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`is, the [network interface card] compares the source address of a packet received
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`over the network to verify that it is from a authorized server.” (Schell, 2:25-30
`
`(Ex. 1012).)
`
`
`
`C.
`
`It Was Obvious to Apply Networking Techniques to Systems of
`Networked Cameras
`39. The claims of the ’964 patent merely recite applying commonplace
`
`networking techniques in the context of networked camera systems then known in
`
`the art.
`
`40. A person of ordinary skill in the art at the time would have been well-
`
`acquainted with these networking techniques and appreciated their applicability to
`
`systems of networked cameras because the techniques are as applicable to
`
`connecting networked camera as they are to connecting other networked devices.
`
`Many of the same problems are addressed, such as how devices on the network
`
`identify each other and how to control which devices on the network are able to
`
`communicate. For example, a person of ordinary skill at the time of the alleged
`
`invention, and long before, would have understood and appreciated that a MAC
`
`address can be used to identify devices on a network, including networked
`
`cameras. Further, a person of ordinary skill would also appreciate that the MAC
`
`address could be used for authorization purposes, such as by comparing the MAC
`
`address of a network device to a list of authorized MAC addressed.
`19
`
`
`
`
`Exacq
`Ex. 1003
`Page 19
`
`
`
`41. To one of ordinary skill, the use of these networking techniques
`
`amounts to routine design choices. As discussed above, identifying networked
`
`devices by their MAC addresses was a common approach taken in networked
`
`systems, as was using the MAC address as a device identifier for authorization.
`
`Accordingly, applying these well-known networking techniques to prior art
`
`networked camera systems would have been obvious to one of skill in the art at the
`
`time of the alleged invention.
`
`V.
`
`CLAIMS 1-4 OF THE ’964 PATENT ARE UNPATENTABLE
`
`A.
`
`
`
`42.
`
`Claims 1 and 3 are Anticipated by Acosta
`
`In my opinion, Acosta anticipates claims 1 and 3.
`
`1.
`
`Claim 1
`
`a.
`
`[1p.] A method of controlling access by a computer to
`a video server
`43. Acosta discloses “a method of controlling access by a computer to a
`
`video server.” For example, Acosta discloses a method of controlling access by
`
`the computer running a central office video management system (“COVMS”) 16 to
`
`a camera element 12 over a network 14. (See Acosta, 17:41-18:30 (Ex. 1004).)
`
`44.
`
`In particular, Acosta discloses that the CommLink Manager of the
`
`COVMS 16 controls access to the camera elements 12 and makes “[a]
`
`determination . . . whether the camera element 12 is authenticated.” (Acosta,
`
`17:62-64 (Ex. 1004).) If the camera element is not authenticated, the CommLink
`
`20
`
`
`
`
`
`Exacq
`Ex. 1003
`Page 20
`
`
`
`Manager of the COVMS 16 sends “an unauthorized access alarm” and does not
`
`configure the COVMS 16 to receive image data from the camera element 12. (See
`
`Acosta 17:53-66 (Ex. 1004).)
`
`45. Acosta discloses the COVMS 16 runs on one or more host computers
`
`78 that each are “a dual Pentium Pro 180 MHZ system with 128-256 MB of
`
`memory running the FreeBSD operating system.” (Acosta, 6:18-20; See also
`
`13:36-41 (“the COVMS 16 determines whether there are one or more of the host
`
`computers 78 of the COVMS 16. If there are more than one of the host computers
`
`78 in the COVMS 16, then each is assigned an ordinal ID from one of the host
`
`computers 78 arbitrarily designated as the master of the host computers 78.”) (Ex.
`
`1004).) Thus, the COVMS restricts the host computer’s 78 access to camera
`
`elements 12.
`
`46. Further, the camera elements 12 are video servers because they
`
`transmit image data over network 14 to the COVMS 16 running on host computer
`
`78. Acosta discloses “the camera device 12 includes a camera 24, a video digitizer
`
`26, a processor card 28, a remote communications link module 30, an antenna 32,
`
`and a power supply 34.” (Acosta, 4:42-45 (Ex. 1004).) In operation, “the cameras
`
`12 acquires images at the site at which located and converts those images to digital
`
`data information,” and “[a]t the camera 12, the digital data is processed,
`
`21
`
`
`
`
`
`Exacq
`Ex. 1003
`Page 21
`
`
`
`compressed, and then transmitted over the wireless network 14 to the COVMS
`
`16.” (Acosta, 7:27-31 (Ex. 1004).)
`
`b.
`
`[1a.] sending a request from the computer to a video
`server over a network;
`47. Acosta discloses “sending a request from the computer to a video
`
`server over a network.” For example, Acosta discloses the “COVMS 16, in a step
`
`522, then sends a transmit request to the camera element 12 for the particular
`
`configuration record applicable to the camera element 12.” (Acosta, 18:7-10 (Ex.
`
`1004).)
`
`22
`
`
`
`
`
`Exacq
`Ex. 1003
`Page 22
`
`
`
`
`
`
`
`c.
`
`[1b.] receiving at the computer from the video server
`a unique identifier stored in and identifying the video
`server, wherein the unique identifier is received by
`the computer over the network
`48. Acosta discloses “receiving at the computer from the video server a
`
`unique identifier stored in and identifying the video server, wherein the unique
`
`23
`
`
`
`
`
`Exacq
`Ex. 1003
`Page 23
`
`
`
`identifier is received by the computer over the network.” For example, Acosta
`
`discloses receiving at the COVMS 16, from camera element 12, a serial ID
`
`uniquely identifying the camera element. Acosta further discloses the serial ID is
`
`stored on the camera element 12, and sent by the camera element 12 to the
`
`COVMS 16 over network 14.
`
`49. Acosta illustrates in “FIG. 20, a process 500 of the CommLink
`
`Manager begins with the COVMS 16 listening for the camera elements 12 sending
`
`existent broadcasts in a step 502.” (Acosta, 17:41-44 (Ex. 1004).) Then, “[i]n a
`
`step 504, the COVMS 16 tests whether an incoming broadcast is detected. . . .[and]
`
`[i]f an incoming broadcast is detected, that broadcast includes the serial ID for the
`
`camera 12.” (Acosta, 17:44-48 (Ex. 1004).) FIG. 20 is reproduced below:
`
`24
`
`
`
`
`
`Exacq
`Ex. 1003
`Page 24
`
`
`
`
`
`Accordingly, Acosta discloses the COVMS 16 receiving the serial ID from camera
`
`element 12.
`
`50. One of skill in the art would understand that the serial ID identifies
`
`camera element 12 to the COVMS 16. For example, the COVMS 16 uses the
`
`serial ID to identify the camera for authentication purposes. (See, e.g., Acosta,
`
`25
`
`
`
`
`
`Exacq
`Ex. 1003
`Page 25
`
`
`
`17:60-63 (“the camera element 12 is authenticated according to the ID and is
`
`assigned an IP address in a step 512”) (Ex. 1004).)
`
`51. One of skill in the art would further understand that because the serial
`
`ID is used to identify and authenticate the camera element 12, it must be unique
`
`within the system described by Acosta for the authentication function to be
`
`effective. Acosta discloses the COVMS 16 receives the serial ID over network 16
`
`because “[t]he cameras 12 communicate with the COVMS 16 over the wireless
`
`network 14.” (Acosta, 7:43-44 (Ex. 1004).) Finally, one of ordinary skill in the art
`
`would appreciate that the serial ID is necessarily stored by the camera element 12.
`
`For example, it would be necessary for the camera element to store the serial ID in
`
`order to then transmit it as described in Acosta.
`
`d.
`
`[1c.] determining that access to the video
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