UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
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`SAMSUNG ELECTRONICS CO., LTD.
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`Petitioner
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`v.
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`SCRIPT SECURITY SOLUTIONS, LLC.
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`Patent Owner
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`____________________
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`Patent No. 6,542,078
`____________________
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`DECLARATION OF DAVID H. WILLIAMS
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW OF U.S.
`PATENT NO. 6,542,078
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`Page 1 of 98
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`SAMSUNG EXHIBIT 1002
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`TABLE OF CONTENTS
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`INTRODUCTION .......................................................................................... 1
`I.
`BACKGROUND AND QUALIFICATIONS ................................................ 1
`II.
`III. MATERIALS REVIEWED ........................................................................... 5
`IV. PERSON OF ORDINARY SKILL ................................................................ 8
`V. OVERVIEW OF THE ’078 PATENT ........................................................... 8
`A.
`The ’078 Patent .................................................................................... 8
`B.
`Priority Date of the ’078 Patent.......................................................... 13
`1.
`Claim 1 ..................................................................................... 13
`2.
`Claims 2-5 and 10 .................................................................... 16
`3.
`Claims 6-9 ................................................................................ 18
`VI. CLAIM CONSTRUCTION ......................................................................... 20
`VII. TECHNICAL BACKGROUND & PRIOR ART SUMMARY .................. 25
`A.
`Technical Background ........................................................................ 25
`B. Overview of Monroe .......................................................................... 28
`VIII. MONROE DISCLOSES ALL OF THE FEATURES OF THE
`CHALLENGED CLAIMS ........................................................................... 40
`A. Monroe Discloses the Features of Claim 1 ........................................ 40
`1.
`Claim 1 ..................................................................................... 40
`a)
`[pre] “A system for detecting the movement of an
`object and providing information relative to said
`movement to a remote location comprising”................. 40
`[a] “an object whose movement is to be detected,” ...... 52
`[b] “a detector adapted to detect movement of said
`object and provide an indication of said
`movement,” .................................................................... 53
`[c] “a first transmitter associated with said detector
`and adapted to wirelessly transmit a predetermined
`signal in response to said indication” ............................ 55
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`b)
`c)
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`d)
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`-i-
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`2.
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`3.
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`4.
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`5.
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`6.
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`7.
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`f)
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`e)
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`[d] “an information gathering device adapted to
`receive said predetermined signal, to gather
`information relating to said movement, and to
`transmit said information, and” ..................................... 58
`[e] “a remote notification device adapted to receive
`said information from said information gathering
`device, to establish data communication with a
`remote host, and to provide said information to
`said remote host.” .......................................................... 65
`Claim 2 ..................................................................................... 73
`a)
`“The system of claim 1 wherein said information
`gathering device comprises a camera aimed toward
`said object.” ................................................................... 73
`Claim 3 ..................................................................................... 74
`a)
`“The system of claim 2 wherein said camera is a
`digital camera and said information gathering
`device comprises a memory for storing digital
`images generated by said camera.” ............................... 74
`Claim 4 ..................................................................................... 75
`a)
`“The system of claim 2 wherein said information
`gathering device comprises a wireless transmitter
`for wirelessly transmitting said information.” ............... 75
`Claim 5 ..................................................................................... 76
`a)
`“The system of claim 4 wherein said remote
`notification device includes a wireless receiver for
`receiving said information.” .......................................... 76
`Claim 6 ..................................................................................... 76
`a)
`“The system of claim 5 wherein said remote
`notification device includes a network interface for
`communicating said information to a remote
`network host.” ................................................................ 76
`Claim 7 ..................................................................................... 77
`a)
`“The system of claim 6 wherein said network
`interface comprises one of an analog modem, a
`digital modem, or a network interface card.” ................ 77
`-ii-
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`8.
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`9.
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`Claim 8 ..................................................................................... 78
`a)
`“The system of claim 5 wherein said remote
`notification device communicates said information
`to a local computer to which said remote
`notification device is connected.” .................................. 78
`Claim 9 ..................................................................................... 81
`a)
`“The system of claim 8 wherein said computer
`comprises a network interface for communicating
`said information to a remote host.” ............................... 81
`10. Claim 10 ................................................................................... 83
`a)
`“The system of claim 1 wherein said information
`includes one or more of image information and
`audio information.” ........................................................ 83
`IX. CONCLUSION ............................................................................................. 85
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`-iii-
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`I, David H. Williams, declare as follows:
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`I.
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`INTRODUCTION
`1.
`I have been retained by Samsung Electronics Co., Ltd. (“Petitioner”)
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`as an independent expert consultant in this proceeding before the United States
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`Patent and Trademark Office (“PTO”).
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`2.
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`I am being compensated at my ordinary and customary consulting rate
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`for my work.
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`3. My compensation is in no way contingent on the nature of my
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`findings, the presentation of my findings in testimony, or the outcome of this or
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`any other proceeding. I have no other interest in this proceeding.
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`4.
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`I have been asked to provide my opinions regarding U.S. Patent No.
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`6,542,078 (“the ’078 patent”)1, such as whether certain references disclose the
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`features recited in claims of the ’078 patent. My opinions are set forth below.
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`II. BACKGROUND AND QUALIFICATIONS
`5.
`I am an independent consultant. All of my opinions stated in this
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`declaration are based on my own personal knowledge and professional judgment.
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`In forming my opinions, I have relied on my knowledge, review of information,
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`1 Where appropriate, I refer to exhibits that I understand are attached to the petition
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`for Inter Partes Review of the ’078 patent.
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`1
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`and experiences in designing, developing, researching, and/or working with
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`networking and/or security systems.
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`6.
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`I am over 18 years of age and, if I am called upon to do so, I would be
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`competent to testify as to the matters set forth herein. A copy of my current
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`curriculum vitae, which details my education and professional and academic
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`experience, is attached as Appendix A to this declaration. The following provides
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`an overview of some of my experience that is relevant to the matters set forth in
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`this declaration.
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`7.
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`I received a B.S. in Electrical Engineering, with top honors, from the
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`Purdue University, West Lafayette, Indiana in 1983. I received an MBA, with an
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`emphasis on information management systems, from University of Texas at Austin
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`in 1987. I graduated first in my class.
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`8.
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`After receiving my B.S. degree, I worked at Hughes Aircraft
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`Company from 1983 to 1985, where I served as an electrical engineer. At Hughes,
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`I was in the Radar Development group, where I worked as a microcomputer and
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`digital system design engineer on the F-15 Radar system.
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`9.
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`After receiving my MBA degree, I worked at Deloitte Consulting
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`(originally Touche Ross) from 1987 to 1991, where I served as a senior manager.
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`At Deloitte, I provided consulting services for technology-intensive companies.
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`2
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`10. From 1991 to 1993, I was a senior associate at Booz Allen &
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`Hamilton, where I worked in the Information Technology practice. At Booz Allen,
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`I provided and led consulting services for companies in the communication
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`industry and other IT-intensive companies. For example, I consulted on developing
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`technology strategies for addressing new marketing opportunities and internal
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`operational issues.
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`11. From 1993 to 2002, I was an associate partner at Accenture, where I
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`worked in the Communications & High-Technology Strategy practice. At
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`Accenture, I was responsible for development of their wireless location practice.
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`Additionally, I led the development of business, technology, and product strategies
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`for numerous wireless and wireline carriers looking to enter new markets.
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`12. After leaving Accenture, I founded E911-LBS Consulting in 2002. I
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`am currently president of the company, which provides services across all aspects
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`of the wireless value chain. For example, I provide services with respect to
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`technology and business strategic planning and product design and development
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`associated with Location Based Services (LBS), Global Positioning Satellite (GPS)
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`systems, Wireless 911 (E911), Real-Time Location Systems (RTLS), Radio
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`Frequency Identification (RFID), beacon, and other location determination and
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`sensing technologies and services.
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`3
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`13.
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`I have been published and quoted by leading magazines and
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`newspapers about location-related services, including: “The New York Times,”
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`“CBS News.com,” “The Boston Globe,” “Computerworld,” “Directions
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`Magazine,” “Mission Critical Communications,” “Popular Mechanics,” and the
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`“RFID Journal.”
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`14.
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`I have very extensive experience in all aspects of Location Based
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`Service delivery across the wireless location ecosystem including enabling
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`network, map data, geospatial platform, chipset, data management, device, and
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`location determination infrastructure and integration providers. I have experience
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`in all related aspects of LBS, including data privacy and security management.
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`15.
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`I authored four books on wireless location, including:
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` The Definitive Guide to GPS, RFID, Wi-Fi, and Other Wireless
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`Location-Based Services (2005 version);
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` The Definitive Guide to GPS, RFID, Wi-Fi, and Other Wireless
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`Location-Based Services (2009 version);
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` The Definitive Guide to Wireless E911; and
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` The Definitive Guide to Mobile Positioning and Location Management
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`(co-authored).
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`16.
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`In addition, I have authored dozens of research reports, and tracked
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`and analyzed leading companies in the LBS industry, particularly with respect to
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`4
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`their product and
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`technology
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`strategies, competitive capabilities and
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`implementation issues. I am a recognized expert on all public policy and
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`technology issues related to location data privacy and LBS privacy protection
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`policies, processes, and systems. I am also the co-inventor of a U.S. Patent relating
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`to providing mobile social networking privacy.
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`17.
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`I am not an attorney and offer no legal opinions, but in the course of
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`my work, I have had experience studying and analyzing patents and patent claims
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`from the perspective of a person skilled in the art. Based on my experience and
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`education, I believe that I am qualified to opine as to knowledge and level of skill
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`of a person of ordinary skill in the art at the time of the alleged invention of the
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`’078 patent (which I further describe below) and what such a person would have
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`understood at that time, and the state of the art during that time.
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`III. MATERIALS REVIEWED
`18. The opinions in this Declaration are based on the documents I
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`reviewed, my knowledge and experience, and professional judgment. In forming
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`my opinions expressed in this Declaration, I reviewed the following materials: the
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`’078 Patent (Ex. 1001), U.S. Patent No. 5,319,698 (“Glidewell”) (Ex. 1008), U.S.
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`Patent No. 5,610,580 (“Lai”), U.S. Patent No. 3,925,763 (“Wadhwani”), U.S.
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`Patent No. 6,970,183 to Monroe, issued November 29, 2005 (Ex. 1014), U.S.
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`Patent No. 6,009,356 to Monroe, issued December 28, 1999 (Ex. 1015), the File
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`5
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`History of U.S. Application No. 09/785,702 (Ex. 1004), the File History of U.S.
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`Application No. 09/271,511 (Ex. 1005), File History of U.S. Application No
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`08/865,886 (Ex. 1006), File History of U.S. Provisional Application No
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`60/018,829 (Ex. 1007), Script Security Solutions, LLC’s Opening Claim
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`Construction Brief in Script Security Solutions L.L.C. v. Amazon.com, Inc. et al.,
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`Case No. 2:15-cv-01030 (E.D. Tex.) (Ex. 1019), Claim Construction Memorandum
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`Opinion and Order in Script Security Solutions L.L.C. v. Amazon.com, Inc. et al.,
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`Case No. 2:15-cv-01030 (E.D. Tex.) (Ex. 1020), Andree Brooks, TALKING:
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`Security; Systems Getting Smarter, The New York Times, February 5, 1989,
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`http://www.nytimes.com/1989/02/05/realestate/talking-security-systems-getting-
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`smarter.html?pagewanted=print#
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`(Ex. 1022); Griffin Miller, Putting Out
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`Unwelcome Mat for Burglars, The New York Times, December 10, 1992,
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`http://www.nytimes.com/1992/12/10/garden/putting-out-unwelcome-mat-for-
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`burglars.html?pagewanted=print (Ex. 1023); Rich Warren, Do It Yourself To Cut
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`Alarming Cost
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`of
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`Security, Chicago Tribune, May
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`8,
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`1987,
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`http://articles.chicagotribune.com/1987-05-08/entertainment/8702040433_1_
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`schlage-adt-sensors (Ex. 1024); N.R. Kleinfield, This Long Island Industry Is
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`Beating the Recession; Demand Remains Strong for Alarms and Security Systems
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`to Keep Burglars Away, April 8, 1992, http://www.nytimes.com/1992/04/08/
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`nyregion/this-long-island-industry-beating-recession-demand-remains-strong-for-
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`6
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`alarms.html?pagewanted=print (Ex. 1025) and any other materials I refer to in this
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`Declaration in support of my opinions, while drawing on my experience and
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`knowledge of networking and security systems.
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`19. All of the opinions contained in this declaration are based on the
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`documents I reviewed and my knowledge and professional judgment. My opinions
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`have also been guided by my appreciation of how a person of ordinary skill in the
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`art would have understood the claims and the specification of the ’078 patent at the
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`time of the alleged invention, which I have been asked to initially consider as early
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`2001 (including February 16, 2001), which I understand is the filing date of U.S.
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`Application No. 09/785,702 (“the ’702 application”) corresponding to the ’078
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`patent). My opinions reflect how one of ordinary skill in the art would have
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`understood the ’078 patent and any of the applications that the ’078 patent claims
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`priority to, the prior art to the patent, and the state of the art at the time of the
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`alleged invention.
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`20. Based on my experience and expertise, it is my opinion that certain
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`prior art references disclose all the features recited in claims 1-10 of the ’078
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`patent. I may refer to these claims collectively as “the challenged claims.” Also, it
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`is my opinion that certain features included in the challenged claims are not
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`disclosed in the applications that the ’078 patent claims priority to (which I will
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`refer to collectively as “the ’078 patent priority applications”), and that none of the
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`7
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`’078 patent priority applications suggest to one of ordinary skill in the art those
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`certain features.
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`IV. PERSON OF ORDINARY SKILL
`21.
`I was asked to provide my opinion on the level of one of ordinary skill
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`in the art with respect to the invention of the ’078 patent as of the early 2001
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`timeframe, such as February 2001. Based on my review of the types of problems
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`encountered in the art, prior solutions to those problems, the rapidity with which
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`innovations were made, the sophistication of the technology, and the educational
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`level of active workers in the field, I believe a person of ordinary skill in art at that
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`time would have had at least (i) a Bachelor's degree in computer science, electrical
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`engineering, or equivalent thereof, and (ii) at least two years of experience in the
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`relevant field, e.g., networking or security. More education can supplement
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`practical experience and vice versa. My opinions in this declaration take into
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`account this understanding, and where appropriate are from the perspective of one
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`of ordinary skill in the art as I have defined it here during the relevant time frame.
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`V. OVERVIEW OF THE ’078 PATENT
`A. The ’078 Patent
`22. The ’078 patent, entitled “Portable Motion Detector and Alarm
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`System and Method,” discloses an alarm system which can detect the movement of
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`a door, a window, or a moveable object. (Ex. 1001, 4:34-49, 2:62-67). An example
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`of the security system is shown in Figure 1.
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`8
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`(Id., FIG. 1.)
`23. Figure 1 illustrates a system including multiple “movement detecting
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`and signal transmitting means 20,” a receiver 30, and a remote control 40. (Id.,
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`4:28-32.) The movement detectors 20 each have a retractable wire 22 that extends
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`from a moveable object, such as a door or window, to moveable magnets inside the
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`casing of detector 20. (Id., 4:49-56.) When the object moves, the wire is displaced,
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`causing a transmitter in detector 20 to send a wireless signal. The receiver 30
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`detects the wireless signal and initiates an alarm. (Id., 4:60-64, 5:14-19.)
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`24. According to the ’078 patent, the receiver 30 “initiates a local alarm
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`which can be audible or visual. In addition, receiver 30 may initiate contact with
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`police, medical, rescue or other emergency facilities or agencies.” (Id., 5:16-19.)
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`25. The ’078 patent describes an “enhanced version” of the alarm system
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`in connection with Fig. 12.
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`26. Referring to Figure 12 above, in addition to the detector 20 and
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`receiver 30 described above, the “enhanced version” includes an information
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`gathering device 90, a remote notification device 92, and a network computer host
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`96. (Id., 10:14-29.) When the object being monitored moves, the information
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`gathering device 90 receives a signal sent by detector 20. (Id., 10:31-34, 12:26-31.)
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`The information gathering device 90 may include a camera that acquires image
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`10
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`information. (Id., 12:26-31.) An RF transmitter in the information gathering device
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`90 then sends information related to the detected motion to remote notification
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`device 92. (Id., 12:34-36.) The remote notification device then forwards that
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`information to a remote network computer host 96. (Id., 12:39-52.)
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`27. The remote host 96 can be a host “that responds to the information
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`received from the remote notification device 92 as either an information processing
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`point or a store and-retrieval point,” or “that displays the received information on a
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`monitor for viewing by a security agent.” (Id., 12:53-65.)
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`28.
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`In my opinion, the language of claim 1 of the ’078 patent does not
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`expressly require recording or sending video information to a remote host.
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`29. The ’078 patent acknowledges
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`the existence of conventional
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`technologies like those discussed above before the alleged invention. For example,
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`it describes that the BLACK WIDOW receiver manufactured by LCD Co. was
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`“commercially available” and “may be purchased off-the-shelf from various
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`electronics supply companies such as Whitney electronics or Holsfelt Electronics.”
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`(Id., 5:35-45.) The ’078 patent explains that the BLACK WIDOW receiver unit
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`“was used as a receiver” (e.g., such as the receiver 30 in Fig. 1). (Id.) The ’078
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`patent also acknowledges that the disclosed RF receiver 106, which the patent
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`describes as a component of the disclosed information gathering device 90 in
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`Figure 12 (id., 10:31-35), “can be implemented using the RF receiving circuit
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`components of the previously-described receiver 30” (which relates to the
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`aforementioned prior art “BLACK WIDOW” receiver).
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`30. Also, the ’078 patent acknowledges that “a number of commercially
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`available surveillance products that can be used to implement the power supply
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`100, camera 102, and RF transmitter 104” components of the information
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`gathering device 90 of Figure 12 were known before the alleged invention. (Id.,
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`10:31-35, 10:57-60.) One such technology identified by the ’078 patent is the
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`“XCam2TM video camera kit available at the www.X10.com Internet website.” (Id.,
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`10:60-61.) The ’078 patent acknowledges that the XCam2 camera product
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`“integrates a color analog video camera that can transmit live color video (and
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`audio) signals up to 100 feet, a microphone (for audio signal generation), and a 2.4
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`GHz. transmitter into a single device of relative small size.” (Id., 10:62-65.)
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`31. The ’078 patent also acknowledges that the “XRay Vision Internet
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`KitTM [was] available at the aforementioned www.X10.com Internet website”
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`before the alleged invention. (Id., 11:29-31.) The ’078 patent explains that XRay
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`Vision technology could be used to implement the remote notification device of
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`Figure 12. (Id., 31-33.) Specifically, the ’078 patent acknowledges that the XRay
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`vision technology included,
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`an integrated RF receiver and USB converter to capture
`and manage images received from the X10™ wireless
`video camera referred to above. Software that is
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`provided with the product is adapted to forward the
`received images to any suitable remote network host,
`either in real time if the remote host is so equipped, or via
`e-mail.
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`(Id., 11:33-39 (emphasis added).)
`B.
`Priority Date of the ’078 Patent
`32.
`I understand that the ’078 patent is a continuation-in-part of U.S.
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`Application No. 09/271,511 (“the ’511 application”) (Ex. 1005), filed on March
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`18, 1999, which is a continuation-in-part of U.S. Application No. 08/865,886 (the
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`’886 application”) (Ex. 1006), filed on May 30, 1997, and also claims the benefit
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`of U.S. Provisional Application No. 60/018,829 (“the ’829 application”) (Ex.
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`1007), filed on May 30, 1996. I have been asked to review the ’511, ’886 and ’829
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`applications (the ’078 patent priority applications.) and provide my opinion on
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`whether they disclose certain features recited in the challenged claims (discussed
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`below) or otherwise challenged claims are supported by the ’511 application. In
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`my opinion, the challenged claims of the ’078 patent are not supported by any of
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`the ’078 patent priority applications for the reasons that I have detailed below.
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`1.
`Claim 1
`33. The challenged claims of the ’078 patent recite the concept of an
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`information gathering device. (See, e.g., Ex. 1001 at claim 1 (“information
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`gathering device adapted to receive said predetermined signal, to gather
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`information relating to said movement, and to transmit said information”).) The
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`claims further recite the concept of a remote notification device that establishes
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`data communication with a remote host, to provide data communication with a
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`remote host. (See, e.g., Ex. 1001, claim 1 (“a remote notification device adapted to
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`receive said information gathering device, to establish data communication with a
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`remote host, and to provide said information to said remote host”).) For example,
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`claim 1 below highlights claim limitations relating to these features.
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`
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`(Id., 13:8-21.) The ’078 patent describes these features in the “enhanced version”
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`portions of the specification. (See, e.g., id., 10:13-12:65.)
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`34.
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`I have reviewed the ’511 application and determined that these
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`features are not disclosed in the ’511 application. (See generally Ex. 1005, and id.,
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`10-11, 14-19, 28-32.) The ’511 application does not provide any disclosure of an
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`information gathering device or a concept of such a device that is adapted to
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`receive a predetermined signal, to gather information relating to object movement,
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`and to transmit the information like that recited in claim 1 or disclosed in the ’078
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`patent. Nor does the ’511 application provide any disclosure or concept of a remote
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`notification device that establishes data communication with a remote host, to
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`provide data communication with a remote host as recited in the challenged claims
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`or specification of the ’078 patent. (Id.) In my opinion, nothing in the specification,
`
`drawings, or elsewhere of the ’511 application discloses or suggests to one of
`
`ordinary skill in the art the above identified missing features.
`
`35.
`
`I have reviewed the ’886 application and determined that these
`
`features are not disclosed in the ‘866 application. (See generally Ex. 1006, and id.,
`
`8-10, 16-20.) The ’886 application does not provide any disclosure of an
`
`information gathering device or a concept of such a device that is adapted to
`
`receive a predetermined signal, to gather information relating to object movement,
`
`and to transmit the information like that recited in claim 1 or disclosed in the ’078
`
`patent. Nor does the ’886 application provide any disclosure or concept of a remote
`
`notification device that establishes data communication with a remote host, to
`
`provide data communication with a remote host as recited in the challenged claims
`
`or specification of the ’078 patent. (Id.) In my opinion, nothing in the specification,
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`drawings, or elsewhere of the ’886 application discloses or suggests to one of
`
`ordinary skill in the art the above identified missing features.
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`36.
`
`I have reviewed the ’829 application and determined that these
`
`features are not disclosed in the ’829 application. (See generally Ex. 1007, and id.,
`
`7-9, 14.) The ’829 application does not provide any disclosure of an information
`
`gathering device or a concept of such a device that is adapted to receive a
`
`predetermined signal, to gather information relating to object movement, and to
`
`transmit the information like that recited in claim 1 or disclosed in the ’078 patent.
`
`Nor does the ’829 application provide any disclosure or concept of a remote
`
`notification device that establishes data communication with a remote host, to
`
`provide data communication with a remote host as recited in the challenged claims
`
`or specification of the ’078 patent. (Id.) In my opinion, nothing in the specification,
`
`drawings, or elsewhere of the ’829 application discloses or suggests to one of
`
`ordinary skill in the art the above identified missing features.
`
`2.
`Claims 2-5 and 10
`37. Claims 2-5 and 10 additionally require the information gathering
`
`device to comprise a camera (claim 2) and that the camera is digital with a
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`“memory for storing digital images” (claim 3). Additionally, claim 10 requires that
`
`the information that is transmitted includes image or audio information. (Ex. 1001,
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`13:22-26, 13:45-47.)
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`38.
`
`I have reviewed the ’511 application and determined that these
`
`features are not disclosed in the ’511 application. (See generally Ex. 1005, and id.,
`
`10-11, 14-19, 28-32.) The ’511 application does not provide any disclosure of a
`
`camera, a digital camera, or a memory for storing digital images, or a concept of
`
`such features included in the information gathering device like that recited in
`
`claims 2-5 or disclosed in the ’078 patent. Nor does the ’511 application provide
`
`any disclosure or concept of the object related information including one or more
`
`of image and audio information as recited in claim 10 or the specification of the
`
`’078 patent. (Id.) In my opinion, nothing in the specification, drawings, or
`
`elsewhere of the ’511 application discloses or suggests to one of ordinary skill in
`
`the art the above identified missing features.
`
`39.
`
`I have reviewed the ’886 application and determined that these
`
`features are not disclosed in the ’866 application. (See generally Ex. 1006, and id.,
`
`8-10, 16-20.) The ’886 application does not provide any disclosure of a camera, a
`
`digital camera, or a memory for storing digital images, or a concept of such
`
`features included in the information gathering device like that recited in claims 2-5
`
`or disclosed in the ’078 patent. Nor does the ’886 application provide any
`
`disclosure or concept of the object related information including one or more of
`
`image and audio information as recited in claim 10 or the specification of the ’078
`
`patent. (Id.) In my opinion, nothing in the specification, drawings, or elsewhere of
`
`
`
`
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`17
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`the ’886 application discloses or suggests to one of ordinary skill in the art the
`
`above identified missing features.
`
`40.
`
`I have reviewed the ’829 application and determined that these
`
`features are not disclosed in the ’829 application. (See generally Ex. 1007, and id.,
`
`7-9, 14.) The ’829 application does not provide any disclosure of a camera, a
`
`digital camera, or a memory for storing digital images, or a concept of such
`
`features included in the information gathering device like that recited in claims 2-5
`
`or disclosed in the ’078 patent. Nor does the ’829 application provide any
`
`disclosure or concept of the object related information including one or more of
`
`image and audio information as recited in claim 10 or the specification of the ’078
`
`patent. (Id.) In my opinion, nothing in the specification, drawings, or elsewhere of
`
`the ’829 application discloses or suggests to one of ordinary skill in the art the
`
`above identified missing features.
`
`3.
`Claims 6-9
`41. Claims 6-9 additionally require that the remote notification device
`
`comprises a network interface (claim 6) that additionally comprises an analog
`
`modem, a digital modem or a network interface card (claim 7). Claims 8 and 9
`
`require that the remote notification device communicate with a local computer that
`
`further comprises a network interface for communicating the information to a
`
`remote host. (Ex. 1001, 13:33-44.)
`
`
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`42.
`
`I have reviewed the ’511 application and determined that these
`
`features are not disclosed in the ’511 application. (See generally Ex. 1005, and id.,
`
`at 10-11, 14-19, 28-32.) The ’511 application does not provide any disclosure of
`
`the remote notification device including a network interface, a network interface
`
`that includes a modem or network interface card, or communicates with a local
`
`computer, which can also include a network interface for communicating with a
`
`remote host, like that recited in claims 6-9 or disclosed in the ’078 patent. (Id.) In
`
`my opinion, nothing in the specification, drawings, or elsewhere of the ’511
`
`application discloses or suggests to one of ordinary skill in the art the above
`
`identified missing features.
`
`43.
`
`I have reviewed the ’886 application and determined that these
`
`features are not disclosed in the ’866 application. (See generally Ex. 1006, and id.,
`
`8-10, 16-20.) The ’886 application does not provide any disclosure of the remote
`
`notification device including a network interface, a network interface that includes
`
`a modem or network interface card, or communicates with a local computer, which
`
`can also include a network interface for communicating with a remote host, like
`
`that recited in claims 6-9 or disclosed in the ’078 patent. (Id.) In my opinion,
`
`nothing in the specification, drawings, or elsewhere of the ’886 application
`
`discloses or suggests to one of ordinary skill in the art the above identified missing
`
`features.
`
`
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`19
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`44.
`
`I