`
`1. I have personal knowledge of the facts set forth herein, and, if called upon to do so, I could and
`
`would testify competently to them.
`
`2. I have been asked to offer my opinion regarding the Petition for Inter Partes Review of U.S.
`
`Patent No. 9,282,396 in IPR2016-01639, and in particular to compare U.S. Patent No. 9,282,396 against
`
`the prior art references raised in the IPR Petition, and to consider the opinions of Petitioner’s declarant,
`
`John Moring, offered in support of the IPR Petition.
`
`3. I am being compensated at my customary hourly rate for my time spent on this opinion. I have
`
`no personal interest in the outcome of this or any related proceeding.
`
`Expert Qualifications
`
`4. I am a Registered Professional Engineer (#79454) and have been retained by Patent Owner One-
`
`E-Way, Inc. (“One-E-Way”) to provide my expert opinion.
`
`5. I am President of McAlexander Sound, Inc., and the Managing Director of McAlexander Sound
`
`Pte Ltd. I am also a Manager with QM Partners, LP, supporting clients in managing their Intellectual
`
`Property and the president and CEO of MDFHoldings, Inc., an IP holding company engaged in the field
`
`of GPS tracking. I hold a Bachelor of Science degree in Electrical Engineering from North Carolina State
`
`University and have over 44 years of experience in microcircuit and semiconductor technologies. I am an
`
`inventor of 31 issued United States patents and a number of foreign patents.
`
`6. My skills and experience are in areas of software development, management, circuit design and
`
`analysis, device fabrication and assembly, testing, marketing, control system design and analysis,
`
`manufacturing operations, and respective areas of quality, reliability, and defect/failure analysis.
`
`Specifically, I have:
`
`designed memories, including Dynamic Random Access Memories (DRAMs),
`
`Static Random Access Memories (SRAMs), Charge Coupled Devices (CCDs),
`
`Shift Registers (SRs), and functional circuits including I/O buffers for address and
`
`data, decoders, clocks, sense amplifiers, fault tolerant (incorporating both
`
`nonvolatile EPROM and random access memory components), parallel-to-serial
`
`data paths for video applications, level shifters, converters, pumps, and logic, as
`
`well as wireless communication systems and MEMs;
`
`
`
`1
`
`One-E-Way Ex. 2001
`Sony Corporation v. One-E-Way, Inc.
`IPR2016-1639
`
`
`
`managed operations including engineering, training, and quality assurance for
`
`device fabrication, assembly, test, analysis, and reliability assessment, as well as
`
`manufacturing control, each of which involved both volatile and non-volatile
`
`memory; testing, analysis, and control involved use of mechanical calibration and
`
`measuring equipment, including optical, scanning e-beam, IR, capacitive, and laser
`
`using phase contrast and FFT for HARI applications;
`
`taught courses in solid-state device physics, integrated circuit design, integrated
`
`circuit fabrication, and statistical control;
`
`provided expert services, investigating both process and design technologies of
`
`various devices (microprocessor and controller, volatile and non-volatile memory,
`
`programmable logic, card, tag, module, mixed signal, custom, and other), systems
`
`(PC and peripheral, computer, control, laser measurement, switch, architecture,
`
`software, and other), and consumer products (medical, TV, telephone, VCR,
`
`facsimile, copier, lighting, game, and other);
`
`designed and managed development, testing, and evaluation of memory devices
`
`and systems incorporating such devices, including simulation of operation. I have
`
`also had experience in programming, erasing, and wearout of electrically
`
`programmable and erasable non-volatile memories; and
`
`managed the design and installation of audio sound systems for private and
`
`commercial enterprises.
`
`7. Because of my background, training, and experience, I am qualified as an expert to opine as set
`
`forth herein. A more detailed account of my work experience and other qualifications is listed in my
`
`Curriculum Vitae attached as Appendix A.
`
`Materials Considered
`
`8. In the course of developing this declaration, I examined the following materials:
`
`• U.S. Patent No. 9,282,396 to Woolfork (the “’396 patent”);
`• File history of the ’396 patent (Appl. No.: 13/775,754), and file histories of patents related to
`
`the ’396 patent;
`
`•
`
`IPR2016-01639, Petition for Inter Partes Review of U.S. Patent No. 9,282,396 (the
`
`“Petition”) and the exhibits to the Petition;
`
`
`
`2
`
`
`
`• U.S. Patent No. 6,563,892 to Haartsen et al. (the “’892 patent”);
`• Haartsen, J., “Bluetooth—The Universal Radio Interface for Ad Hoc, Wireless Connectivity”,
`
`Ericsson Review, Telecommunications Technology Journal No. 3, 1998, pp. 110–117 (“the
`
`1998 Haartsen paper”);
`• Giannakis, G. B. , et al., “Load-Adaptive MUI/ISI-Resilient Generalized Multi-Carrier
`
`CDMA with Linear and DF Receivers”, European Transactions on Telecommunications,
`
`Volume 11, Issue 6, pages 527–537; November–December 2000 (“the Giannakis paper”);
`• Excerpts from the ‘396 patent file history, including file histories of its parent applications
`
`such as Appl. No.: 10/648,012 (“the 2003 application”), Application No. 13/356,949 (“the
`
`2012 application”), etc.
`• Order No. 12 Construing Terms of the Asserted Patents, Inv. No. 337-TA-943, July 24, 2015
`
`(“ITC claim constructions”);
`• S. Zhou, G. Giannakis, and A. Swami, titled “Frequency-Hopped Generalized MC-CDMA
`
`for Multipath and Interference Suppression,” MILCOM 2000 Proceedings;
`• Haartsen, J., “The Bluetooth Radio System”, IEEE Personal Communications, February 2000
`
`(“the 2000 Haartsen paper”); and
`• U.S. Patent No. 5,530,929 to Lindqvist et al.
`
`Level of Ordinary Skill in the Art
`
`9. In this analysis, I have assumed that a person has ordinary skill in the art if the person has a Bachelor
`
`of Science degree in electrical engineering or a related field and around two years of experience in the
`
`design or implementation of wireless communications systems, or the equivalent, or six years of experience
`
`in the design or implementation of wireless communications systems, or the equivalent. I am very familiar
`
`with the level of knowledge meeting this standard. My own experience and education exceeds those levels,
`
`and did so throughout the time of the applications. Additional details are shown in my attached Curriculum
`
`Vitae.
`
`Claim term constructions
`
`10. I have applied the following claim constructions in this analysis:
`
`Claim Term
`
`Petitioner’s Requested Construction
`
`“reduced intersymbol interference coding”
`
`“coding that reduces intersymbol interference”
`
`(cl. 1, 2, 6, 9, 14, 16)
`
`
`
`3
`
`
`
`“configured for independent code division
`multiple access (CDMA) communication
`operation”
`
`“configured for code division multiple access
`(CDMA) communication operation performed
`independent of any central control”
`
`(cl. 1, 2, 6, 9, 14, 16)
`
`“unique user code” / “unique user code bit
`sequence”
`
`“fixed code (bit sequence) specifically associated
`with one user of a device(s)”
`
`(cl. 1, 2, 6, 9, 14, 16)
`
`“direct conversion module”
`
`(cl. 1, 2, 6, 9, 14, 16)
`
`
`
`“a module for converting radio frequency to
`baseband or very near baseband in a single
`frequency conversion without an intermediate
`frequency”
`
`The ’892 Patent’s Reference to the 1998 Paper
`
`11. I have reviewed the ’892 patent and the 1998 paper. In particular, I have considered the
`
`following paragraph:
`
`Although channel effects are a dominant disturbance in conventional cellular
`
`systems, in other types of systems the dominant disturbance to transmitted signals
`
`may arise from other sources. For example, a new relatively low cost, low range
`
`wireless transmission system (defined by the recently developed “Bluetooth”
`
`technology) has been proposed for localized two-way data transmissions.
`
`Bluetooth systems are envisioned as a universal radio interface in the 2.45 GHz
`
`frequency band that enable portable electronic devices to connect and
`
`communicate wirelessly via short-range, ad hoc networks. Readers interested in
`
`various details regarding the Bluetooth technology are referred to the article
`
`entitled “BLUETOOTH—The universal radio interface for ad hoc, wireless
`
`connectivity” authored by Jaap Haartsen and found in the Ericsson Review,
`
`Telecommunications Technology Journal No. 3, 1998, the disclosure of which is
`
`incorporated here by reference. Of particular interest for this discussion is the fact
`
`that channel effects associated with the Bluetooth air interface may not be the
`
`dominant disturbance to transmitted signals in such systems, due to the short-range
`
`nature of the air interface links. Accordingly, other slowly varying disturbances
`
`may be more problematic than channel effects in such systems.
`
`12. In reading the above paragraph, I do not understand it to refer to or incorporate any particular
`
`material from the 1998 paper into the ’892 patent. One of ordinary skill in the art would understand that
`
`
`
`4
`
`
`
`paragraph as a sort of informative aside, suggesting the 1998 paper as distinct, but potentially interesting
`
`read for readers who might be interested in its details.
`
`Detection vs. Demodulation
`
`13. Signal detection is recognizing the existence of a signal. Signal demodulation is translating a
`
`modulated carrier wave into the information that it contains. Signal detection is distinct from signal
`
`demodulation. A system could detect signals but decide not to demodulate the signal or be unable to
`
`demodulate the signal. Demodulation by definition relies upon a demodulator. However, detection does
`
`not necessarily rely upon a demodulator.
`
`Bluetooth History
`
`14. Today, the term Bluetooth is widely associated with wireless music transmission and other local
`
`wireless connections. That was not always the case. Bluetooth did not become useful and widely adopted
`
`for such audio transmission until after the introduction of the Bluetooth version 2.0 Specification with
`
`Enhanced Data Rate (EDR) in 2004. The Bluetooth version 1.0 and 1.0B Specifications were widely
`
`considered flawed and received little industry adoption. The next Bluetooth Specification versions, 1.1 and
`
`1.2 improved upon 1.0 but still did not provide bandwidth sufficient for wirelessly transmitting audio
`
`received from a portable audio player. The Bluetooth version 2.0 Specification was the next released
`
`version after 1.2, and was released in 2004, bringing about Bluetooth’s widespread use for music
`
`transmission. However, during the 2000-2002 timeframe, Bluetooth was known primarily for its use in
`
`lower-bandwidth data connections such as those between a keyboard and a computer, or between a
`
`computer and a printer. Although there were some early Bluetooth hands-free headsets in that era, quality
`
`was poor and audio transmission was generally unsuccessful. One of ordinary skill in the art, in 2001,
`
`would have primarily associated the term Bluetooth with lower-bandwidth data connections—not for
`
`wireless transmissions of audio received from a portable audio player.
`
`
`
`DPSK Encoding vs. Viterbi Decoding
`
`15. The Viterbi algorithm is a decoding algorithm used to decode convolutional encoding.
`
`Convolutional encoding is a type of error-correcting encoding.
`
`16. Differential phase shift keying (DPSK) is not a convolutional encoding, and is not an error-
`
`correcting encoding. DPSK is an information modulation scheme that represents transmitted data as
`
`
`
`5
`
`
`
`changes in a wave’s phase. Applying a Viterbi decoder to a DPSK signal would not decode the DPSK
`
`encoding of that signal. The Viterbi algorithm can be used to undo intersymbol interference effects
`
`introduced by a filter. This is sometimes called equalization, and the component applying the Viterbi
`
`algorithm is often referred to as a Viterbi equalizer. Filter-induced intersymbol interference results from
`
`the filter hardware, and the Viterbi equalizer is correcting for that—the Viterbi equalizer is not decoding an
`
`encoding.
`
`Interference: Avoiding vs. Suppressing
`
`17. One of ordinary skill in the art would understand suppressing interference to be a partial reduction
`
`in interference, and also would understand that avoiding interference would be a greater reduction than
`
`merely suppressing it.
`
`Sub-Carrier Matrix for Frequency Hopping
`
`18. I have reviewed the Giannakis paper. In particular, I have reviewed the statement on page 531 of
`
`Giannakis claiming that its work has practical appeal in “ad hoc (Bluetooth[8]-like) networking if
`
`frequency-hopping is introduced via ɸm along the lines of [26].” Giannakis states that ɸm is a subcarrier
`
`selector matrix defined on page 531 as:
`
` [ɸm]l,k = 1, if exp(j2πl/N) ɛ Fm, and 0 otherwise
`
`19. The ’892 patent does not include any disclosure of a subcarrier selector matrix, let alone such a
`
`matrix defined using the specific algorithm for ɸm. Similarly, the 1998 paper does not include any
`
`disclosure of a subcarrier selector matrix, let alone such a matrix defined using the specific algorithm for
`
`ɸm. Giannakis explains that it is only applicable to an ad-hoc (Bluetooth-like) network if a subcarrier
`
`selector matrix is used, and specifically, such a matrix meeting the definition of ɸm. Accordingly, Giannakis
`
`itself acknowledges that it cannot be combined with either the ’892 patent or the 1998 paper. One of
`
`ordinary skill in the art, reading Giannakis, the ’892 patent, and the 1998 paper would conclude that it is
`
`not practical to combine Giannakis with either the ’892 patent or the 1998 paper.
`
`20. The Giannakis paper states on page 536 that it was received on April 18, 2000. Version 1.0b of the
`
`Bluetooth Specification was the current version of Bluetooth at that time. Bluetooth 1.0b is a fast
`
`frequency-hopping system. It uses a frequency hopping pattern of 1600 hops per second. That is a standard
`
`feature across other versions of Bluetooth as well, including versions 1.0, 1.1, 2.0, and 2.1 – which are all
`
`also fast frequency-hopping systems.
`
`
`
`6
`
`
`
`21. I have reviewed the paper by S. Zhou, G. Giannakis, and A. Swami, titled “Frequency-Hopped
`
`Generalized MC-CDMA for Multipath and Interference Suppression,” MILCOM 2000 Proceedings. I
`
`noticed that the paper explains that “coding for fast hopping systems is beyond the scope of this paper.”
`
`One of ordinary skill in the art would understand that Zhou was not applicable to Bluetooth, because
`
`Bluetooth is a fast hopping system. Reading that express disclaimer, one of ordinary skill in the art would
`
`not have a reason or motivation to combine Giannakis with the ’892 patent.
`
`22. Orthogonality in wireless communications refers to multiple transmissions being perfectly
`
`separable from each other based on the mathematical property of having a dot product equal to zero.
`
`Bluetooth wireless piconets do not coordinate amongst each other. As a result, there are sometimes
`
`collisions in time and frequency. A fundamental design aspect of a wireless transmission system is whether
`
`or not it requires coordination between different pairs of wireless transmission. Bluetooth’s design depends
`
`on a lack of central coordination. This is fundamentally different from a system in which multiple
`
`transmitting pairs use centrally coordinated frequency hopping patterns to achieve orthogonality.
`
`I declare under penalty of perjury under the laws of the United States of America that this declaration
`
`is true, complete, and accurate to the best of my knowledge.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`___________________________
`
`Joseph C. McAlexander III, P.E.
`
`7
`
`
`
`Date: November 25, 2016
`
`
`
`
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`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`CURRICULUM VITAE
`
`
`
`
`
`
`
`
`
`
`
`
` Joseph C. McAlexander III
`
`PROFESSIONAL SUMMARY
`
`Currently a Registered Professional Engineer (#79454) and recognized as an inventor on 31 US
`and a number of foreign patents, I am President of McAlexander Sound, Inc., and the Managing
`Director of McAlexander Sound Pte Ltd. I have focused my expertise to support a number of
`clients in product, process, and operations analysis and investigation. Thirty-nine years of
`experience in microcircuit and semiconductor technologies has developed my skills in areas of
`circuit design and analysis, device fabrication and assembly, testing, marketing, control system
`design and analysis, manufacturing operations and respective areas of quality, reliability, and
`defect / failure analysis. I am, among others, a Manager with QM Partners, LP, supporting
`clients in IP management, and the President and CEO of MDFHoldings, Inc., an IP holding
`company currently engaged in the field of GPS Tracking. I have:
`
`
`- designed Dynamic Random Access Memories (DRAMs), Static Random Access
`Memories (SRAMs), Charge Coupled Devices (CCDs), Shift Registers (SRs), and
`functional circuits including I/O buffers for address and data, decoders, clocks, sense
`amplifiers, fault tolerant, parallel-to-serial data paths for video applications, level shifters,
`converters, pumps, and logic, as well as wireless communication systems and MEMs
`applications;
`
` -
`
` managed operations including engineering, software programming, training, and quality
`assurance for device fabrication, assembly, test, analysis, and reliability assessment, as well
`as manufacturing control (testing, analysis, and control involved use of mechanical
`calibration and measuring equipment, including optical, scanning e-beam, IR, capacitive,
`and laser using phase contrast and FFT for HARI applications); managed software program
`development departments for assembly manufacturing, process control, and testing;
`
` -
`
` taught courses in solid state device physics, integrated circuit design, integrated circuit
`fabrication, and statistical control;
`
` -
`
` provided expert services, investigating both process and design technologies of various
`devices (microprocessor and controller, memory, programmable logic, card, tag, module,
`mixed signal, custom, and other), systems (PC and peripheral, computer, control, laser
`measurement, switch, architecture, software, and other), and consumer products (medical,
`TV, telephone, VCR, facsimile, copier, lighting, game, and other); and
`
` -
`
` provided nuclear radiation hardness testing services for military and space clients.
`
`
`From 1986-1990, I was Executive Vice President of EPI Technologies, Inc., prior to joining
`the staff at Cochran Consulting, Inc. where I served as senior managing consultant from 1991-
`2002. From 1972 to 1986, I was employed by Texas Instruments Incorporated - two years as
`the Quality and Reliability Manager for the 256K DRAM wafer fabrication facility, three years
`as the Engineering/QRA Manager for the TI Singapore test and assembly operation, and nine
`years in semiconductor design and product engineering management functions.
`
`APPENDIX A
`
`
`
`CURRICULUM VITAE
`
`
`
`
`
`
`
`
`
`
`
`
` Joseph C. McAlexander III
`
`EXPERIENCE PROFILE
`
`
`2006-present
`
`QM Partners, L.P. – Texas
`Manager
`
`o Management of development,
`exploitation of intellectual property.
`
`licensing, prosecution and
`
`
`
`
`
`2006-present
`
`Guardian Technologies, LLC – Texas
`Manager
`
`o IP holding and licensing company.
`
`
`
`
`
`2006-present
`
`Appropriate Holdings, LLC – Delaware
`Manager
`
`o IP holding company.
`
`McAlexander Sound Pte Ltd - Singapore
`Managing Director
`
`o System, Product, and Process investigation, expert witness
`services for protection of intellectual property;
`
` o
`
` o
`
`
`
` Patent portfolio development and valuation;
`
` Contract consultation.
`
`MDFHoldings, Inc. – Las Vegas, NV
`CEO
`
`o IP holding and licensing company.
`
`
`
`
`
`2005-present
`
`
`
`
`2002-present
`
`
`
`
`
`1996-2010
`
`RMC Management, LLP - Plano, TX
`Partner
`
`o Asset management.
`
`
`
`
`
`APPENDIX A
`
`
`
`
`
`
`
`
`
` Joseph C. McAlexander III
`
`McAlexander Sound, Inc. (McASI) - Plano, TX
`President
`
`o System, Product, and Process investigation, expert witness
`services for protection of intellectual property;
`
` o
`
` Patent portfolio development and valuation;
`
` o
`
` Product liability and insurance claim investigation, expert
`witness services for matters involving such claims;
`
` o
`
` Quality Systems consulting and engineering;
`
`o Radiation Hardness Testing Technical Representative;
`
` o
`
` Technical Advisor in High Aspect Ratio and Surface Contour
`Measurement using Direct-to-Digital Holography.
`
`1991-2002
`
`Cochran Consulting, Inc. (CCI) - Richardson, TX
`Managing Consultant
`
`o System, Product, and Process investigation, expert witness
`services for protection of intellectual property;
`
`o Design, process, and product reliability;
`
`o Defect and failure analysis.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`1986-Nov'90
`
`EPI Technologies, Inc. - Richardson, TX
`Executive Vice President and Company Officer
`
`
`
`
`
`
`
`
`
`o Managed Advanced Technology Div., QA, and
`Engineering, including software program development;
`
`o Developed strategic, space/energy market growth plans;
`
`o Negotiated the acquisition of a radiation company;
`
`o Designed and managed physical analysis, radiation effects, and
`environmental stress laboratories, including optical and e-beam
`measurement;
`
`
`
`
`
`CURRICULUM VITAE
`
`EXPERIENCE PROFILE (continued)
`
`1988-present
`
`APPENDIX A
`
`
`
`CURRICULUM VITAE
`
`EXPERIENCE PROFILE (continued)
`
`
`
`
`
`
`
`
`
`
`
` Joseph C. McAlexander III
`
`
`
`o Achieved > 30% annual revenue growth and profitability for
`each laboratory the first 12 months;
`
` o
`
` Product and Process investigation services for protection of
`intellectual property.
`
`
`
`1972 – 1986
`
`
`'84 - '86
`
`Texas Instruments, Inc. - Dallas/Houston, TX; Singapore
`
`Quality/Reliability Assurance Manager, TI Dallas Advanced DRAM
`semiconductor wafer fabrication facility
`
`o Developed/implemented on-line, computerized SPC software
`tools
`for dimensioning analysis and control and pattern
`recognition;
`
`o Coordinated people development, design-of-experiments;
`
` o
`
` Managed chemical and physical analysis laboratories;
`
` o
`
` Implemented control systems to assure product, process,
`material, equipment, and facility compliance, including Cost of
`Quality analysis.
`
`'82 - '84
`
`Quality/Reliability Assurance and Engineering Manager, TI
`Singapore assembly/test facility
`
`effective
`an
`operated
`and
`implemented,
`o Developed,
`Quality/Reliability Assurance program for assembly processing
`including optical pattern recognition for equipment registration;
`
`o Supervised 225 people for 7 day/week operation, including
`QRA, Computer Systems software development, and Training;
`
`o Trained engineers in Solid State Physics, device fabrication, and
`statistical process control.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`APPENDIX A
`
`
`
`CURRICULUM VITAE
`
`EXPERIENCE PROFILE (continued)
`
`
`
`
`
`
`
`
`
`
`
`
` Joseph C. McAlexander III
`
`'81 - '82
`
`Engineering Operations Manager, TI Houston
`
`o Managed DRAM memory product cost center;
`
`o Responsible for division test software generation, product
`assembly and test quality / yield, cost reduction and quality
`improvement;
`
`o Provided technical customer interface for marketing;
`
`o Coordinated TI Singapore engineering test/assembly.
`
`'79 - '81
`
`Product Engineering Manager, TI Houston
`
`o Responsible for yield improvement, technical customer interface,
`quality
`improvement,
`design
`evaluation,
`and
`device
`characterization for DRAM and CCD products;
`
`o Developed device specifications and test software.
`
`
`'72 - '79
`
`Design Section Manager / Engineer, TI Houston
`
`o Responsible for design and development, process compatibility,
`production introduction of Dynamic Ram products;
`
` o
`
` Activities included electrical and physical layout, SPICE model
`simulation, test program generation, and product implementation
`for MOS Dynamic Ram products.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`1969 - 1972
`
`U. S. Army - Coventry, Rhode Island; Seoul, Korea
`Captain, Air Defense Artillery
`
`
`
`
`
`
`
`o Served one year as Communications Officer in Korea;
`
`o Served two years as Tactical Officer, New England
`Defense.
`
`
`
`APPENDIX A
`
`
`
`CURRICULUM VITAE
`
`
`
`
`
`
`
`
`
`
`
`
` Joseph C. McAlexander III
`
`ORGANIZATIONS, PUBLICATIONS, EDUCATION
`
`PROFESSIONAL ORGANIZATIONS AND AWARDS
`
` - Institute of Electrical and Electronics Engineers, Inc. (IEEE), Senior Member. Societies:
`Computer, Electron Devices, Solid State Circuits
`
` – Licensing Executives Society (LES)
`
` – National Society of Professional Engineers
`
`
`
` 1
`
` 2
`
` 3
`
`
`4 – Texas Board of Professional Engineers, Registered License #79454
`
` 5
`
` 5
`
` 6
`
`
`
` – Society of Flight Test Engineers
`
` - 2000/2001 Nationwide Register’s Who’s Who in Executives and Businesses
`
` - 1996/1997 Strathmore's Who's Who Registry of Business Leaders
`
`
`PUBLICATIONS
`
`
`1- NUS Proceedings of Engineering Convention '83, Aug '83, pgs. 139-142, The Memory
`Challenge.
`
`
`2- Archives of Biochemistry and Biophysics, Dec'81, Vol. 212, No. 2, Equilibrium Constants
`under Physiological Conditions for the Reactions of D-3-Phosphoglycerate Dehydrogenase
`and L-Phosphoserine Aminotransferase.
`
`
`3- International Electron Devices Meeting, Dec '79, pgs. 355-357, Sub 100ns 16K x 1 MOS
`Dynamic RAM Using a Grounded Substrate.
`
`
`
`
`1980 - 1985
`
`1975 - 1976
`
`
`1965 - 1969
`
`EDUCATION PROFILE
`
`Taught Solid State Device Physics, Semiconductor Processing, and Circuit
`Design Techniques
`
`Taught Statistical Quality Control methods
`
`Effectiveness Training and Japanese Manufacturing Techniques,
`Participative Problem Solving courses
`
`1.5 years Graduate study in Neural Science, the University of Texas
`Graduate School of Biomedical Science
`
`BSEE, North Carolina State University
`
`APPENDIX A
`
`
`
`CURRICULUM VITAE
`
`
`
`
`
`
`
`
`
`
`
`
` Joseph C. McAlexander III
`
`PATENTS (US-31 Foreign-8)
`
`
`
`
`
`
`
`4,239,993
`
`
`4,280,070
`
`
`4,288,706
`
`
`4,370,575
`
`
`4,418,293
`
`
`4,533,843
`
`
`4,543,500
`
`
`4,543,501
`
`
`4,748,349
`
`6,172,640 B1
`
`6,236,358 B1
`
`6,421,001 B1
`
`6,441,778 B1
`
`6,480,147 B2
`
`6,518,919 B1
`
`6,771,213 B2
`
`59,171 B2
`
`
`
`(1980) High Performance Dynamic Sense Amplifier with
`Active Loads
`
`(1981) Balanced Input Buffer Circuit for Semiconductor
`Memory
`
`(1981) Noise Immunity
`Semiconductor Memory
`
`in Input Buffer Circuit for
`
`(1983) High Performance Dynamic Sense Amplifier with
`Active Loads
`
`(1983) High Performance Dynamic Sense Amplifier with
`Multiple Column Outputs
`
`(1985) High Performance Dynamic Sense Amplifier with
`Voltage Boost for Row Address Lines
`
`(1985) High Performance Dynamic Sense Amplifier
`Voltage Boost for Row Address Lines
`
`(1985) High Performance Dynamic Sense Amplifier with
`Dual Channel Grounding Transistor
`
`(1988) High Performance Dynamic Sense Amplifier with
`Voltage Boost for Row Address Lines
`
`(2001) Pet Locator
`
`(2001) Mobile Object Locator
`
`(2002) Object Locator
`
`(2002) Pet Locator
`
`(2002) Portable Position Determining Device
`
`(2003) Mobile Object Locator
`
`(2004) Object Locator
`
`(2005) Mobile Object Locator
`
`APPENDIX A
`
`
`
`CURRICULUM VITAE
`
`
`
`
`
`
`
`
`
`
`
` Joseph C. McAlexander III
`
`
`PATENTS (continued)
`
`
`7,113,126 B2
`
`7,179,674 B2
`
`7,209,075 B2
`
`7,324,044 B2
`
`7,336,227 B2
`
`7,340,260 B2
`
`
`7,353,706 B2
`
`7,397,097 B2
`
`
`7,564,405 B2
`
`7,657,265 B2
`
`
`7,760,137 B2
`
`7,764,228 B2
`
`7,989,906 B2
`
`8,334,775 B2
`
`
`JP 55-053640 B4
`
`JP 59-044720 B4
`
`DE2935121 C2
`
`
`DE3043651 A1
`
`
`GB2032211 B2
`
`
`
`
`(2006) Portable Positioning Determining Device
`
`(2007) Bi-Directional Released-Beam Sensor
`
`(2007) Mobile Object Locator
`
`(2008) Object Locator
`
`(2008) Portable Position Determining Device
`
`(2008) System and Method for Tracking the Location of Multiple
`Mobile Radio Transceiver Units
`
`(2008) Weighted Released-Beam Sensor
`
`(2008) Integrated Released Beam Layer Structure Fabricated in
`Trenches and Manufacturing Method Thereof
`
`(2009) Object Locator
`
`(2010) System and Method for Tracking the Location of Multiple
`Mobile Radio Transceiver Units
`
`(2010) Portable Positioning Determining Device
`
`(2010) Portable Positioning Determining Device
`
`(2011) Bi-Directional released-Beam Sensor
`
`(2012) RFID-Based Asset Security and Tracking System,
`Apparatus and Method
`
`(1980) Defect Resistant Semiconductor Memory Cell
`
`(1984) Semiconductor High Speed Read/Write Memory Unit
`
`(1980) Clock Voltage Generator for Semiconductor Memory with
`Reduced Power Dissipation
`
`
`
`(1981) Clock Voltage Generator for Semiconductor Memory with
`Reduced Power Dissipation
`
`(1980) High Performance Dynamic MOS Read/Write Memory
`
`APPENDIX A
`
`
`
`CURRICULUM VITAE
`
`
`
`
`
`
`
`
`
`
`
` Joseph C. McAlexander III
`
`
`PATENTS (continued)
`
`
`
`EP 1 557 058 B1
`
`
`
`
`
`(2011) System and method for tracking the location of multiple
`mobile radio transceiver units
`[States: AT BE BG CH CY CZ DE DK EE ES FI FR GB GR HU
`IE IT LI LU MC NL PT RO SE SI SK TR]
`
`EP 1 676 809 B1
`
`
`
`
`EP 1 676 810 B1
`
`
`
`
`(2010) Weighted released-beam sensor
`[States: DE FR GB IT]
`
`(2010) Bi-directional released-beam sensor
`[States: DE FR GB IT]
`
`APPENDIX A
`
`
`
`CURRICULUM VITAE
`
`
`
`
`
`
`
`
`
`
`
` Joseph C. McAlexander III
`
`CASES
`
`
`
`
`
`Cases over at least the past 5 years, either active or closed, in which I have signed a Protective
`Order, have testified as an expert either at a trial, hearing, or deposition, or have submitted
`statements / opinions, are:
`
`CASE NUMBER
`
`LOCATION
`
`00-792-RRM
`
`Wilmington, DE
`
`CASE1
`YEAR
`2000-
`Micron* v. Rambus
`2009
`(*firm: Weil Gotshal)
`(Patents related to RDRAM, synchronous clocks applied against SDRAMs)
`
`2005 -
`C 05-02298 WDB
`Rambus v. Samsung*
`2009
`C 05-02398 RMW
`(*firm: Weil Gotshal)
`(Patents related to RDRAM, synchronous clocks applied against SDRAMs)
`
`
`TYPE2
`
`P,t
`
`P
`
`P
`
`P,t
`
`San Jose, CA
`
`2005 -
`C 05 00334 EDL
`Rambus v. Samsung*
`2009
`C 05 00334 RMW
`(*firm: Weil Gotshal)
`(Patents related to RDRAM, synchronous clocks applied against SDRAMs)
`
`San Francisco, CA
`
`
`2006 -
`Rambus v. Micron*
`2009
`(*firm: Weil Gotshal)
`(Patents related to RDRAM, synchronous clocks applied against SDRAMs)
`
`
`C 06-00244 RMW
`
`San Jose, CA
`
`FormFactor v. Phicom*
`(*firm: Mitchell Silberberg)
`
`05-6062-HO
`
`Oregon
`
`(Patents related to probe cards)
`
`
`Mosaid v. Micron*
`(*firm: Kirkland & Ellis)
`
`
`Fenner* v. Microsoft et al
`(*firm: Fulbright &
`
`Jaworski)
`
`2:06-CV-302-DF
`
`ED, TX
`
`
`
`(Patents related to memory devices)
`
`6:07-CV-08 (LED) Tyler, TX
`
`(Patent related to joystick interface to low voltage port)
`
`
`
`Agere v. Samsung*
`(*firm: Quinn Emanuel)
`
`2-06-CV-185
`(TJW-CE)
`(Patent License Dispute)
`
`
`ED, TX
`
`
`1 * = Client
`
`2005 -
`2009
`
`
`
`P
`
`2006 -
`2009
`
`
`
`P, t
`
`2007 -
`2009
`
`P, t
`
`2007 -
`2010
`
`P
`
`2 P = Patent; C = Contract; TS = Trade Secret, AT = Antitrust; CA = Class Action; t = testified
`
`APPENDIX A
`
`
`
`
`
`
`
`
`
`
`
`
`
` Joseph C. McAlexander III
`
`CURRICULUM VITAE
`
`Cases (continued)
`
`
`
`CASE1
`DESA* v. EML
`(*firm: Fitch Even)
`
`CASE NUMBER
`
`LOCATION
`
`8-04-0160
`
`MD TN, Nashville
`
`YEAR
`2008 -
`2009
`
`TYPE2
`
`P
`
`DCS* v. McData
`(*firm: Haynes Boone)
`
`
`Bennett Marine v. Lenco*
`(*firm: Malen Haley)
`
`(Patent related to lighting)
`
`
`3:06-CV-812-L
`
`ND TX, Dallas
`
`(Breach of Contract)
`
`04-cv-60326-KAM SD FL, Ft Laud.
`
`(Patent related to Automated Boat Trim Retraction)
`
`
`Samsung* v. ON Semi
`(*firm: Kirkland & Ellis)
`
`
`FormFactor v. Phicom*
`(*firm: Finnegan,
`
`Henderson, F G & D)
`
`Orica* v. Austin Powder
`(*firm: McDermott Will
`
`07-CV-449 (JJF)
`
`DE
`
`(Patents related to circuits and process)
`
`337-TA-621
`
`ITC
`
`(Patents related to probe cards)
`
`
`CV-07-3337-AHM CD CA,
`
`(Patents related to blasting electronic controls)
`
`
`AMS* v. Crane & Seaga
`(*firm: Davidson Berquist
`
`
`
`Myriad v. Alltech, Inc.*
`(*firm: Duane Morris)
`
`SciCo* v. Boston Scientific
`(*firm: Jeffer Mangel)
`
`3:03-CV88-JPB,
`3:08-CV-97-JPB
`and 3:04-CV-
`80,75,48
`(Patents related to vending machines)
`
`
`ND WVA
`
`1:08-CV-00253-SS WD TX, Austin
`
`(Trade Secret & © related to software)
`
`
`9:07-CV-00076-
`RHC
`(Patent related to catheters)
`
`
`ED TX, Lufkin
`
`2008 -
`2009
`
`C, t
`
`2008-
`2009
`
`2008-
`2009
`
`P, t
`
`P
`
`2008 -
`2009
`
`
`
`P, t
`
`2008 -
`2010
`
`P
`
`2008-
`2012
`
`P, t
`
`2008 -
`2010
`
`TS, t
`
`2008 -
`2009
`
`P, t
`
`APPENDIX A
`
`
`
`
`
`
`
`
`
`
`
`
`
` Joseph C. McAlexander III
`
`CURRICULUM VITAE
`
`Cases (continued)
`
`
`
`CASE1
`Renishaw* v. TESA
`(