UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
`
`SAMSUNG ELECTRONICS CO., LTD.
`
`Petitioner
`
`v.
`
`SCRIPT SECURITY SOLUTIONS, LLC
`
`Patent Owner
`
`____________________
`
`Patent No. 6,828,909
`____________________
`
`DECLARATION OF DAVID H. WILLIAMS IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,828,909
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`
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`
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`Page 1 of 180
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`SAMSUNG EXHIBIT 10(cid:19)(cid:21)
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`

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`Declaration of David H. Williams
`Inter Partes Review of U.S. Patent No. 6,828,909
`TABLE OF CONTENTS
`
`I.
`
`II.
`
`INTRODUCTION ........................................................................................... 1
`
`BACKGROUND AND QUALIFICATIONS ................................................. 1
`
`III. MATERIALS REVIEWED ............................................................................ 6
`
`IV. PERSON OF ORDINARY SKILL IN THE ART .......................................... 8
`
`V. OVERVIEW OF THE ’909 PATENT ..........................................................10
`
`A.
`
`B.
`
`The ’909 Patent ...................................................................................10
`
`Priority Date of the ’909 Patent...........................................................14
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`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`Claims 15, 24 and 26-29 ...........................................................14
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`Claim 15 ....................................................................................19
`
`Claim 24 ....................................................................................23
`
`Claims 26-28 .............................................................................26
`
`Claim 29 ....................................................................................29
`
`Examiner’s Finding on Priority ................................................33
`
`VI. CLAIM CONSTRUCTION ..........................................................................35
`
`VII. TECHNOLOGICAL BACKGROUND & PRIOR ART SUMMARY ........40
`
`A.
`
`Technical Background .........................................................................40
`
`B. Overview of Glidewell ........................................................................45
`
`C. Overview of Greenwaldt .....................................................................52
`
`D. Overview of Saylor .............................................................................54
`
`E.
`
`Overview of Monroe ...........................................................................61
`
`VIII. THE PRIOR ART DISCLOSES ALL OF THE FEATURES OF
`CLAIMS 15, 24 and 26-29 IN THE ’909 PATENT .....................................67
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`Declaration of David H. Williams
`Inter Partes Review of U.S. Patent No. 6,828,909
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`A. Glidewell, Greenwaldt, and Saylor Disclose the Features of
`Claims 15 and 26-29............................................................................68
`
`1.
`
`Claim 15 ....................................................................................68
`
`a)
`
`b)
`
`c)
`
`d)
`
`e)
`
`f)
`
`g)
`
`[15pre] “A portable security alarm system for
`detecting the movement of an object and providing
`information relative to said movement, said system
`comprising” .....................................................................68
`
`[15a] “a motion sensor adapted to detect
`movement of an object and provide an indication
`of said movement including a unique identifier
`associated with said sensor,” ..........................................80
`
`[15b] “a transmitter associated with said sensor
`and adapted to wirelessly transmit a predetermined
`signal containing said indication, and” ...........................84
`
`[15c] “a receiver adapted to receive said
`predetermined signal,” ....................................................86
`
`[15d] “[the receiver adapted] to process said
`unique identifier for local or remote conversion to
`associated object identification information that
`identifies said object;” ....................................................90
`
`[15e] “a remote security administration system
`comprising a computer host, a communication
`interface, and a data storage resource” ...........................97
`
`[15f] “said data storage resource storing a
`subscriber database containing provisioned object
`identification information in association with
`provisioned unique identifier information for
`subscribers using said portable security alarm
`system; and” ..................................................................100
`
`h)
`
`[15g] “wherein said computer host is programmed
`to execute a subscriber registration function
`
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`Declaration of David H. Williams
`Inter Partes Review of U.S. Patent No. 6,828,909
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`allowing said subscribers to remotely subscribe for
`security service.”...........................................................108
`
`2.
`
`Claim 26 ..................................................................................114
`
`a)
`
`b)
`
`c)
`
`d)
`
`e)
`
`f)
`
`g)
`
`[26pre] “A security network comprising a security
`administration system and plural portable security
`alarm systems,” .............................................................114
`
`[26a] “said security administration system
`comprising a computer host programmed to
`provide subscriber registration and provisioning
`functions,” .....................................................................115
`
`[26b] “[said security administration system
`comprising] a communication interface, and”..............121
`
`[26c] “[said security administration system
`comprising] a data storage resource containing
`provisioned object identification information in
`association with provisioned unique identifier
`information for subscribers using said portable
`security alarm systems,” ...............................................122
`
`[26d] “said portable security alarm systems each
`comprising plural motion sensors adapted to detect
`movement of associated objects and provide an
`indication of said movement including a unique
`identifier associated with each sensor,” ........................122
`
`[26e] “[said portable security alarm systems each
`comprising] a transmitter associated with each
`sensor and adapted to wirelessly transmit a
`predetermined signal containing said indication,
`and” ...............................................................................124
`
`[26f] “[said portable security alarm systems each
`comprising] a receiver adapted to receive said
`predetermined signals from said sensors and to
`forward said unique identifiers for conversion to
`
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`Declaration of David H. Williams
`Inter Partes Review of U.S. Patent No. 6,828,909
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`associated object identification information that
`identifies said objects.” .................................................125
`
`3.
`
`Claim 27 ..................................................................................127
`
`a)
`
`“The system of claim 26 wherein each of said
`unique identifiers is unique relative to all other
`motion sensors in said security network.” ....................127
`
`4.
`
`Claim 28 ..................................................................................130
`
`a)
`
`“The system of claim 26 wherein each of said
`unique identifiers is unique relative to all other
`motion sensors in the same portable security alarm
`system.” ........................................................................130
`
`5.
`
`Claim 29 ..................................................................................131
`
`a)
`
`b)
`
`c)
`
`d)
`
`[29pre] “A method for providing portable security
`alarm service to a plurality of subscribers,” .................131
`
`[29a] “each subscriber having a portable security
`alarm system comprising plural motion sensors
`adapted to detect movement of associated objects
`and provide an indication of said movement
`including a unique identifier associated with each
`sensor,” .........................................................................132
`
`[29b] “[each subscriber having a portable security
`alarm system comprising] a transmitter associated
`with each sensor and adapted to wirelessly
`transmit a predetermined signal containing said
`indication, and” .............................................................132
`
`[29c] “[each subscriber having a portable security
`alarm system comprising] a receiver adapted to
`receive said predetermined signals from said
`sensors and to forward said unique identifiers for
`conversion to associated object identification
`information that identifies said objects,” ......................132
`
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`Inter Partes Review of U.S. Patent No. 6,828,909
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`e)
`
`f)
`
`g)
`
`[29d] “said method comprising the steps of
`establishing a communication dialog with a
`subscriber,” ...................................................................133
`
`[29e] “[said method comprising the steps of]
`requesting the subscriber to enter authentication
`information if the subscriber is registered for
`security service or to enter a registration dialog if
`the subscriber is not registered for security
`service,” ........................................................................137
`
`[29f] “[said method comprising the steps of]
`requesting the subscriber to establish data sets
`associating unique identifiers of one of said
`portable security alarm systems with
`corresponding object identification information,
`and” ...............................................................................142
`
`h)
`
`[29g] “[said method comprising the steps of]
`terminating said communication dialog.”.....................153
`
`B. Glidewell, Greenwaldt, Saylor, and Monroe Disclose the
`Features of Claim 24 .........................................................................156
`
`1.
`
`Claim 24 ..................................................................................156
`
`a)
`
`[24pre] A portable security alarm system for
`detecting the movement of an object and providing
`information relative to said movement, said system
`comprising ....................................................................156
`
`[24a] a motion sensor adapted to detect movement of an
`object and provide an indication of said movement
`including a unique identifier associated with said
`sensor, ...........................................................................156
`
`[24b] a transmitter associated with said sensor and
`adapted to wirelessly transmit a predetermined
`signal containing said indication, and ..........................156
`
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`Inter Partes Review of U.S. Patent No. 6,828,909
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`[24c] a receiver adapted to receive said predetermined
`signal and to process said unique identifier for
`local or remote conversion to associated object
`identification information that identifies said
`object; and” ...................................................................156
`
`b)
`
`[24d] wherein said motion sensor includes RF
`receiving means for receiving wireless
`transmissions from said receiver and control means
`responsive to said wireless transmissions for
`implementing control functions and providing
`operational information wirelessly to said receiver. ....156
`
`IX. CONCLUSION ............................................................................................164
`
`
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`Declaration of David H. Williams
`Inter Partes Review of U.S. Patent No. 6,828,909
`
`I, David H. Williams, declare as follows:
`
`I.
`
`INTRODUCTION
`
`1.
`
`I have been retained by Samsung Electronics Co., Ltd. (“Petitioner”)
`
`as an independent expert consultant in this proceeding before the United States
`
`Patent and Trademark Office (“PTO”).
`
`2.
`
`I am being compensated at my ordinary and customary consulting rate
`
`for my work.
`
`3. My compensation is in no way contingent on the nature of my
`
`findings, the presentation of my findings in testimony, or the outcome of this or
`
`any other proceeding. I have no other interest in this proceeding.
`
`4.
`
`I have been asked to provide my opinions regarding U.S. Patent No.
`
`6,828,909 (“the ’909 patent”)1, such as whether certain references disclose or
`
`suggest the features recited in claims of the ’909 patent. My opinions are set forth
`
`below.
`
`II. BACKGROUND AND QUALIFICATIONS
`I am an independent consultant. All of my opinions stated in this
`5.
`
`declaration are based on my own personal knowledge and professional judgment.
`
`
`1Where appropriate, I refer to exhibits that I understand are attached to the petition
`
`for Inter Partes Review of the ’909 patent.
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`1
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`Declaration of David H. Williams
`Inter Partes Review of U.S. Patent No. 6,828,909
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`In forming my opinions, I have relied on my knowledge, review of information,
`
`and experiences in designing, developing, researching, and/or working with
`
`networking and/or security systems.
`
`6.
`
`I am over 18 years of age and, if I am called upon to do so, I would be
`
`competent to testify as to the matters set forth herein. A copy of my current
`
`curriculum vitae, which details my education and professional and academic
`
`experience, is attached as an addendum to this declaration. The following provides
`
`an overview of some of my experience that is relevant to the matters set forth in
`
`this declaration.
`
`7.
`
`I received a B.S. in Electrical Engineering, with top honors, from the
`
`Purdue University, West Lafayette, Indiana in 1983. I received an MBA, with an
`
`emphasis on information management systems, from University of Texas at Austin
`
`in 1987. I graduated first in my class.
`
`8.
`
`After receiving my B.S. degree, I worked at Hughes Aircraft
`
`Company from 1983 to 1985, where I served as an electrical engineer. At Hughes,
`
`I was in the Radar Development group, where I worked as a microcomputer and
`
`digital system design engineer on the F-15 Radar system.
`
`2
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`Declaration of David H. Williams
`Inter Partes Review of U.S. Patent No. 6,828,909
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`9.
`
`After receiving my MBA degree, I worked at Deloitte Consulting
`
`(originally Touche Ross) from 1987 to 1991, where I served as a senior manager.
`
`At Deloitte, I provided consulting services for technology-intensive companies.
`
`10. From 1991 to 1993, I was a senior associate at Booz Allen &
`
`Hamilton, where I worked in the Information Technology practice. At Booz Allen,
`
`I provided and led consulting services for companies in the communication
`
`industry and other IT-intensive companies. For example, I consulted on developing
`
`technology strategies for addressing new marketing opportunities and internal
`
`operational issues.
`
`11. From 1993 to 2002, I was an associate partner at Accenture, where I
`
`worked in the Communications & High-Technology Strategy practice. At
`
`Accenture, I was responsible for development of their wireless location practice.
`
`Additionally, I led the development of business, technology, and product strategies
`
`for numerous wireless and wireline carriers looking to enter new markets.
`
`12. After leaving Accenture, I founded E911-LBS Consulting in 2002. I
`
`am currently president of the company, which provides services across all aspects
`
`of the wireless value chain. For example, I provide services with respect to
`
`technology and business strategic planning and product design and development
`
`associated with Location Based Services (LBS), Global Positioning Satellite (GPS)
`
`3
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`Inter Partes Review of U.S. Patent No. 6,828,909
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`systems, Wireless 911 (E911), Real-Time Location Systems (RTLS), Radio
`
`Frequency Identification (RFID), beacon, and other location determination and
`
`sensing technologies and services.
`
`13.
`
`I have been published and quoted by leading magazines and
`
`newspapers about location-related services, including: “The New York Times,”
`
`“CBS News.com,” “The Boston Globe,” “Computerworld,” “Directions
`
`Magazine,” “Mission Critical Communications,” “Popular Mechanics,” and the
`
`“RFID Journal.”
`
`14.
`
`I have very extensive experience in all aspects of Location Based
`
`Service delivery across the wireless location ecosystem including enabling
`
`network, map data, geospatial platform, chipset, data management, device, and
`
`location determination infrastructure and integration providers. I have experience
`
`in all related aspects of LBS, including data privacy and security management.
`
`15.
`
`I authored four books on wireless location, including:
`
`• The Definitive Guide to GPS, RFID, Wi-Fi, and Other Wireless
`
`Location-Based Services (2005 version);
`
`• The Definitive Guide to GPS, RFID, Wi-Fi, and Other Wireless
`
`Location-Based Services (2009 version);
`
`• The Definitive Guide to Wireless E911; and
`
`4
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`• The Definitive Guide to Mobile Positioning and Location
`
`Management (co-authored).
`
`16.
`
`In addition, I have authored dozens of research reports, and tracked
`
`and analyzed leading companies in the LBS industry, particularly with respect to
`
`their product and
`
`technology
`
`strategies, competitive capabilities and
`
`implementation issues. I am a recognized expert on all public policy and
`
`technology issues related to location data privacy and LBS privacy protection
`
`policies, processes, and systems. I am also the co-inventor of a U.S. Patent relating
`
`to providing mobile social networking privacy.
`
`17. Additional qualifications are detailed in my curriculum vitae, which is
`
`attached as Appendix A.
`
`18.
`
`I am not an attorney and offer no legal opinions, but in the course of
`
`my work, I have had experience studying and analyzing patents and patent claims
`
`from the perspective of a person skilled in the art. Based on my experience and
`
`education, I believe that I am qualified to opine as to knowledge and level of skill
`
`of a person of ordinary skill in the art at the time of the alleged invention of the
`
`’909 patent (which I further describe below) and what such a person would have
`
`understood at that time, and the state of the art during that time.
`
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`Declaration of David H. Williams
`Inter Partes Review of U.S. Patent No. 6,828,909
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`III. MATERIALS REVIEWED
`19. The opinions in this Declaration are based on the documents I
`
`reviewed, my knowledge and experience, and professional judgment. In forming
`
`my opinions expressed in this Declaration, I reviewed the following materials:
`
`the ’909 patent (Ex. 1001); the prosecution file history for the ’909 patent (Ex.
`
`1003); the prosecution file history for U.S. Application No. 09/785,702 (“the ’702
`
`application”) (Ex. 1004); the prosecution file history for U.S. Application No.
`
`09/271,511 (“the ’511 application”) (Ex. 1005); the prosecution file history for
`
`U.S. Application No. 08/865,886 (“the ’886 application”) (Ex. 1006); the file
`
`history for U.S. Provisional Application No. 60/018,829 (“the ’829 application”)
`
`(Ex. 1007); U.S. Patent No. 5,319,698 to Glidewell et al., (“Glidewell”) (Ex.
`
`1008); U.S. Patent No. 5,499,014 to Greenwaldt et al., (“Greenwaldt”) (Ex. 1009);
`
`U.S. Patent No. 5,499,196 to Pacheco; PCT Publication No. WO 00/21053 to
`
`Marman (Ex. 1011); U.S. Patent No. 5,748,083 to Rietkerk; U.S. Patent No.
`
`6,400,265 to Saylor (“Saylor”) (Ex. 1013); U.S. Patent No. 6,970,183 to Monroe
`
`(“Monroe”) (Ex. 1014); U.S. Patent No. 6,009,356 to Monroe (“Monroe ’356”);
`
`Claim Construction Memorandum Opinion and Order in Script Security Solutions
`
`L.L.C. v. Amazon.com, Inc. et al., Case No. 2:15-cv-01030 (E.D. Tex.) (Ex. 1020);
`
`Andree Brooks, TALKING: Security; Systems Getting Smarter, The New York
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`Times, February 5, 1989, http://www.nytimes.com/1989/02/05/realestate/talking-
`
`security-systems-getting-smarter.html?pagewanted=print#
`
`(Ex. 1022); Griffin
`
`Miller, Putting Out Unwelcome Mat for Burglars, The New York Times,
`
`December 10, 1992, http://www.nytimes.com/1992/12/10/garden/putting-out-
`
`unwelcome-mat-for-burglars.html?pagewanted=print (Ex. 1023); Rich Warren, Do
`
`It Yourself To Cut Alarming Cost of Security, Chicago Tribune, May 8, 1987,
`
`http://articles.chicagotribune.com/1987-05-08/entertainment/8702040433_1_
`
`schlage-adt-sensors (Ex. 1024); N.R. Kleinfield, This Long Island Industry Is
`
`Beating the Recession; Demand Remains Strong for Alarms and Security Systems
`
`to Keep Burglars Away, April 8, 1992, http://www.nytimes.com/1992/04/08/
`
`nyregion/this-long-island-industry-beating-recession-demand-remains-strong-for-
`
`alarms.html?pagewanted=print (Ex. 1025); and any other materials I refer to in this
`
`Declaration in support of my opinions.
`
`20. All of the opinions contained in this declaration are based on the
`
`documents I reviewed and my knowledge and professional judgment. My opinions
`
`have also been guided by my appreciation of how a person of ordinary skill in the
`
`art would have understood the claims and the specification of the ’909 patent at the
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`time of the alleged invention, which I have been asked to initially consider as early
`
`2002 (including April 8, 2002, which I understand is the filing date of U.S.
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`Declaration of David H. Williams
`Inter Partes Review of U.S. Patent No. 6,828,909
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`Application No. 10/119,535 (“the ’535 application”) corresponding to the ’909
`
`patent). My opinions reflect how one of ordinary skill in the art would have
`
`understood the ’909 patent and any of the applications that the ’909 patent claims
`
`priority to, the prior art to the patent, and the state of the art at the time of the
`
`alleged invention.
`
`21. Based on my experience and expertise, it is my opinion that certain
`
`prior art references disclose all the features recited in claims 15, 24 and 26-29 of
`
`the ’909 patent. I may refer to these claims collectively as “the challenged claims.”
`
`Also, it is my opinion that certain features included in the challenged claims are
`
`not disclosed in the applications that the ’909 patent claims priority to (which I will
`
`refer to collectively as “the ’909 patent priority applications”), and that none of the
`
`’909 patent priority applications suggest to one of ordinary skill in the art those
`
`certain features.
`
`IV. PERSON OF ORDINARY SKILL IN THE ART
`I was asked to provide my opinion on the level of one of ordinary skill
`22.
`
`in the art with respect to the invention of the ’909 patent as of the early 2002 time
`
`frame, including April 2002. Based on my review of the types of problems
`
`encountered in the art, prior solutions to those problems, the rapidity with which
`
`innovations were made, the sophistication of the technology, and the educational
`
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`Inter Partes Review of U.S. Patent No. 6,828,909
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`level of active workers in the field, I believe a person of ordinary skill in art at that
`
`time would have had at least (i) a Bachelor's degree in computer science, electrical
`
`engineering, or equivalent thereof, and (ii) at least two years of experience in the
`
`relevant field, e.g., networking or security. More education can supplement
`
`practical experience and vice versa. My opinions in this declaration take into
`
`account this understanding, and where appropriate are from the perspective of one
`
`of ordinary skill in the art as I have defined it here during the relevant time frame.
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`
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`Declaration of David H. Williams
`Inter Partes Review of U.S. Patent No. 6,828,909
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`V. OVERVIEW OF THE ’909 PATENT
`A. The ’909 Patent
`23. The ’909 patent, titled “portable motion detector and alarm system
`
`and method,” is directed to an alarm system that can detect movement of a door, a
`
`window, or a moveable object. Ex. 1001, 5:24-40, 3:1-6. An example of the
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`security system is shown in Figure 1 and includes “movement detecting and signal
`
`transmitting means 20” and a “receiver means 30.” In particular, the window 25
`
`and door 24 are equipped with movement detecting and transmitting means 20,
`
`e.g., a motion detector. Id., 5:24-40. The motion detectors include a transmitter that
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`wirelessly transmits an alarm signal to the receiver 30. Id., 9:8-13.
`
`Ex. 1001, FIG. 1.
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`Declaration of David H. Williams
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`24. The ’909 patent discusses identifying the particular detector that
`
`triggered the motion detector alarm. In one example, the ’909 patent associates a
`
`sensor code with each detector. Ex. 1001, 14:1-8. For example, as shown in FIG.
`
`18, one detector may be associated with sensor code “xxyyzz00” and another
`
`detector may be associated with sensor code “xxyyzz01.” Id., 15:22-29, FIG. 18. In
`
`one aspect, if the sensor associated with sensor code “xxyyzz00” is triggered, the
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`descriptive word “Front Door” may be displayed. Id., 14:56-60, 15:22-27, 15:37-
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`40.
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`Id., FIG. 18 (showing a simple look-up table 226 having data set entries 228
`
`associating a unique identifier field 230 and a descriptive word or phrase field
`
`232).
`
`25. To populate the information in this look-up table, the ’909 patent
`
`further explains that the computer host stores a subscriber registration and
`
`provisioning program 268 that allows subscribers to register for security service
`
`and provision user-specified object identification information to be associated with
`
`the unique identifiers associated with their motion sensing and transmitting means
`
`20. Ex. 1001, 16:57-67. For instance, the ’909 patent explains that a “network-
`
`attached computing device and a few moments of time to fill in an online form are
`
`all that is required.” Id., 18:25-27. As expected for a registration form, the user
`
`provides “registration information (e.g., user name and password) if they have an
`
`existing account, or to set up a new account if the subscriber is not yet registered.”
`
`Id., 18:27-33. If the user does not have an account, the computer prompts the user
`
`to enter “information as the subscriber's name, billing address, login name,
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`password, and an authentication identifier associated with the subscriber's receiver
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`means 30.” Id., 18:36-39. Once the user has registered or signed in, the user fills in
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`fields on a form to associate a sensor ID with an object name. Id., 18:45-63.
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`12
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`Declaration of David H. Williams
`Inter Partes Review of U.S. Patent No. 6,828,909
`
`26. Beyond identifying the name of an object associated with a sensor, the
`
`’909 patent explains the system can be “packed into a suitcase and transported with
`
`a traveler to be later installed on motel or hotel room doors, windows and/or any
`
`objects within the room, whenever additional protection is desired by the traveler.”
`
`Ex. 1001, 3:7-12. As shown in FIG. 1 above, the system’s receiver 30 can be
`
`plugged into a standard outlet and the wireless sensors 20 can be mounted on a
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`door or window. The ’909 patent explains that the sensors “can be installed on a
`
`temporary basis and removed from an object whose movement is to be detected.”
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`Id., 3:35-37. The ’909 patent explains that a sensor is temporarily installed when it
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`is firmly engaged to an object using a pressure-sensitive adhesive strip 70:
`
`Strips 70 are marketed under the trademark
`COMMAND of the 3M Company. . . . The
`main objective is that the mounting causes
`the signal transmitting means 20 be firmly
`mounted in a manner such that it will not
`move while mounted but which permits it to
`be removed so that it can be transported to
`another location.
`
`Ex. 1001, 9:47-10:7. See also id., FIGs. 7 and 8 (showing an example of a 3M
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`command strip 70 for removable attachment).
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`Declaration of David H. Williams
`Inter Partes Review of U.S. Patent No. 6,828,909
`
`B.
`27.
`
`Priority Date of the ’909 Patent
`
`I understand that the ’909 patent is a continuation-in-part of U.S.
`
`Application No. 09/785,702 (“the ’702 application”), filed on February 16, 2001,
`
`which is a continuation-in-part of U.S. Application No. 09/271,511 (“the ’511
`
`application”), filed on March 18, 1999, which is a continuation-in-part of U.S.
`
`Application No. 08/865,886 (“the ’886 application”), filed on May 30, 1997, which
`
`claims priority to U.S. Provisional Application No. 60/018,829 (“the ’829
`
`application”), filed on May 30, 1996. I have been asked to review the ’702, ’511,
`
`’886, and ’829 applications (“the ’909 patent priority applications”) and provide
`
`my opinion on whether they disclose certain features recited in the challenged
`
`claims (discussed below) or otherwise support the challenged claims. In my
`
`opinion, the challenged claims of the ’909 patent are not supported by any of the
`
`’909 patent priority applications for the reasons that I have detailed below.
`
`Claims 15, 24 and 26-29
`
`1.
`I have reviewed the claims of the ’909 patent and understand that each
`
`28.
`
`of the challenged claims requires a “unique identifier,” “object identification
`
`information that identifies said object,” and a “conversion” of the unique identifier
`
`“to associated” object identification information. See Ex. 1001, claims 15, 24, 26,
`
`29. For example, claim 15 below highlights claim limitations relating to these
`
`features.
`
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`Declaration of David H. Williams
`Inter Partes Review of U.S. Patent No. 6,828,909
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`
`
`Ex. 1001, 21:15-37.
`
`29. The unique identifier, object identification information, and the
`
`process of conversion are disclosed in portions of the ’535 application that resulted
`
`in the ’909 patent. Ex. 1003, 34-38, 41, 42, 45-47, 68, 69, 72; Ex. 1001, 14:1-46,
`
`14:56-67, 15:19-63, 16:61-17:31, 18:45-19:23, FIGs. 17, 18, 21. The specification
`
`for the ’909 patent describes these features as optional.
`
`15
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`Declaration of David H. Williams
`Inter Partes Review of U.S. Patent No. 6,828,909
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`
`
`Ex. 1001, 13:59-67.
`
`30.
`
`I have reviewed the ’702 application and determined that the above
`
`unique identifier and conversion features disclosed and claimed in the ’909 patent
`
`are not disclosed in the ’702 application. See generally Ex. 1004, and id., 7-41, 50-
`
`54. For example, the ’702 application does not disclose or mention any identifiers,
`
`let alone unique identifiers. Id. Nor does the ’702 application disclose unique
`
`identifiers associated with sensors. Id. The ’702 application does not provide any
`
`disclosure that suggests to one of ordinary skill in the art the above-identified
`
`missing unique identifier features. Likewise, the ’702 application does not disclose
`
`or mention anything relating to any conversion like that disclosed and claimed in
`
`the ’909 patent. For instance, the ’702 application does not disclose processing a
`
`unique identifier for local or remote conversion as recited in the challenged claims
`
`or disclosed in the ’909 patent. Id. Nor does the ’702 application provide any
`
`16
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`Declaration of David H. Williams
`Inter Partes Review of U.S. Patent No. 6,828,909
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`disclosure that suggests to one of ordinary skill in the art the above-identified
`
`conversion features.
`
`31.
`
`I have reviewed the ’511 application and determined that the above
`
`unique identifier and conversion features disclosed and claimed in the ’909 patent
`
`are not disclosed in the ’511 application. See generally Ex. 1005, and id., 7-33, 36-
`
`43. For example, the ’511 application does not disclose or mention any identifiers,
`
`let alone unique identifiers. Id. Nor does the ’511 application disclose unique
`
`identifiers associated with sensors. Id. The ’511 application does not provide any
`
`disclosure that suggests to one of ordinary skill in the art the above-identified
`
`missing unique identifier features. Likewise, the ’511 application does not disclose
`
`or mention anything relating to any conversion like that disclosed and claimed in
`
`the ’909 patent. For instance, the ’511 application does not disclose processing a
`
`unique identifier for local or remote conversion as recited in the challenged claims
`
`or disclosed in the ’909 patent. Id. Nor does the ’511 application provide any
`
`disclosure that suggests to one of ordinary skill in the art the above-identified
`
`conversion features.
`
`32.
`
`I have reviewed t