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Stuart J. Lipoff
`
`Mr. Lipoff is president of IP Action Partners Inc, a consulting practice in TIME
`(telecommunications, information technology, media, electronics, and ebusiness) industries and
`technologies. He draws upon his 30+ years of experience in a wide variety of technologies and
`industries to assist clients with knowledge based consulting services involving complex business
`decisions and problem resolution.
`
`Mr. Lipoff was employed 25 years by Arthur D Little, Inc (ADL) as VP and Director of
`Communications, Information Technology, and Electronics (CIE); 4 years by Bell & Howell
`Communications Company as a Section Manager, and 3 years by Motorola's Communications
`Division as a Project Engineer. At ADL he was responsible for the firm's global CIE practice in
`laboratory based contract engineering, product development, and technology based consulting. At
`both Bell & Howell and Motorola, he had project design responsibility for wireless
`communications and paging products.
`
`Stuart Lipoff has Bachelor's Degrees in Electrical Engineering and in Engineering Physics, both
`from Lehigh University. He also has received a Masters Degree in Electrical Engineering from
`Northeastern University, and a MBA degree from Suffolk University.
`
`Mr. Lipoff is a fellow of the IEEE Consumer Electronics, Communications, Computer, Circuits,
`and Vehicular Technology groups. He is a member of the IEEE Consumer Electronics Society
`National Administration Committee, and was the Boston Chapter Chairman of the IEEE
`Vehicular Technology Society. He served as 1996-7 President of the IEEE Consumer Electronics
`Society and as Chairman of the Consumer Electronics Society Technical Activities and Standards
`Committee; he currently is VP of Publications for The IEEE Consumer Electronics Society. He
`has also chaired the search committee for Sony supported Mazura Ibuka Award in consumer
`electronics and is a current committee member. As Vice President and Standards Group
`Chairman of the Association of Computer Users, he served as the ACU representative to The
`ANSI X3 Standards group. For the Federal Communications Commission's Citizens advisory
`committee on CB radio (PURAC), he served as Chairman of the task group on user rule
`compliance. He has been elected to membership in the Society of Cable Television Engineers
`(SCTE), The Association of Computing Machinery (ACM) , and The Society of Motion Picture
`and Television Engineers (SMPTE).
`
`Stuart Lipoff holds a FCC General Radiotelephone License and a Certificate in Data Processing
`(CDP) from the ACM supported Institute for the Certification of Computing Professionals
`(ICCP). He is a registered professional engineer (by examination) in The Commonwealth of
`Massachusetts.
`
`Mr. Lipoff holds seven USA patents and has published articles in Electronics Design,
`Microwaves, EDN, The Proceedings of the Frequency Control Symposium, Optical Spectra, and
`numerous IEEE publications. He has presented papers at many IEEE and other meetings. In the
`
`VIZIO, Inc. Exhibit 1024
`1 of 12
`
`

`
`Stuart J. Lipoff
`
`fall of 2000, he served as general program chair for The IEEE Vehicular Technology Conference
`on advanced wireless communications technology. He has organized sessions at The
`International Conference on Consumer Electronics and was the 1984 program chairman. He
`conducted an eight week IEEE sponsored short course on Fiber Optics Systems Design. In 1984,
`he was awarded IEEE's Centennial Medal and in 2000 IEEE's Millennium Metal.
`
`He has served as a member of the USA advisory board to the National Science Museum of Israel
`and has presented a short course on international product development strategies as a faculty
`member of Technion Institute of Management in Israel. He is also a member of the board of
`directors of The Massachusetts Future Problem Solving Program.
`
`Mr Lipoff is internationally recognized as an authority and opinion leader in new economy
`related businesses and technology. Citations supporting his recognition can be found on his web
`site at http://www.ipaction.com .
`
`Some examples of projects he has performed in the video and broadband telecommunications
`sector include:
`
`(cid:149)
`
`(cid:149)
`
`(cid:149)
`
`(cid:149)
`
`• Leadership of the project which developed the series of DOCSIS specifications for high
`speed residential cable modems. The scope of work included developing a roadmap and
`strategic framework for evolving the business from simple high speed internet services to
`multimedia broadband services combining voice, data, and secure electronic content delivery.
`This project was performed under contract to the MCNS consortium of cable TV operators
`representing 85% of the subscriber base in North America and has since been adopted by the
`United Nations as a global telecommunications standard.
`• For Next Generation Network Architecture llc (NGNA llc) consortium of Comcast, Cox, and
`Time-Warner; he managed the project that produced a five year planning horizon vision for
`the services and technology the cable industry will seek to deploy. The services and vision
`were then mapped to overall architectures impacting network elements in the back office,
`head-end, outside plant, and customer premises and documented in next generation network
`recommendations. The project involved coordination with over fifty senior technical staff in
`the three cable MSO sponsors as well as interactions with over 100 suppliers of systems,
`software, and products to the cable industry. The recommendations and findings were wide
`ranging including, for example: software defined downloadable conditional access (CA)
`systems, migration of the outside plant from low to mid split, bridging from network CA to
`in-home network digital rights management systems (DRM), and migration from 1way to
`2way digital TV.
`• For The National Association of Broadcasters (NAB) he managed a project to engage NAB
`members in the development of new applications and services for over-the-air radio and
`television broadcasting. The project included developing a list and priority recommendations
`for research projects for consideration of funding by NAB which would explore the most
`promising candidate research projects.
`• For the cable operator consortium SpectrumCo he supported exploration of alternative
`means to provide competitive public network wireless services to existing cable and new
`
`VIZIO, Inc. Exhibit 1024
`2 of 12
`
`

`
`Stuart J. Lipoff
`
`customers. The project involves exploring 3rd and 4th generation wireless air-interface
`technologies and developing models that integrate capital expenditures forecasts with
`operating profits to develop financial performance perspectives of alternatives. A unique
`aspect of this project includes developing technology forecasts and estimates of subscriber
`equipment capable of supporting video and multimedia content delivery to handsets.
`
`• For COMCAST Cablevision of Philadelphia, he assisted in the development of a family of
`advanced two-way, residential digital services, including: development of system/service
`concepts and specification/selection of a range of equipment to provide this service. Detailed
`operating and balance sheet financial models of were developed to measure financial
`attractiveness of alternatives and use as a tool to select specific strategies.
`• For a division of Westinghouse in cooperation with Kansai Electric (Japan), he developed
`detailed business plans for the launch of cable TV and associated broadband services. The
`project involved demand studies to assess adoption and desires of consumers followed by
`recommendations on marketing, operating, and technology strategies.
`• For the Westinghouse Teleprompter Cable Company, he studied the market for a fiberoptic
`based institutional data network in Pittsburgh and developed the business and financial
`models to examine the financial attractiveness of offering these services.
`
`• For Times Mirror Cable TV, he developed business plans for the upgrade of selected systems
`to 2way capability and exploration of alternative telephony and other advanced services to be
`provided. I worked with the client to develop risk/reward perspectives for specific service
`options and develop a roadmap in order of most attractive priorities.
`• Analysis and recommendations in a study funded by CableLabs which led to today's hybrid-
`fiber coax architecture widely deployed worldwide for delivering broadband multimedia
`services to the home. The project involved developing forecasts of technology trends in
`parallel with projecting the business applications. Detailed proforma financial models were
`developed to make the cost/benefit of deploying this technology visible to the cable industry,
`and strategies were developed and recommended to the industry.
`• On behalf of a leading law firm representing TV-Com International, he supported the client as
`a damages expert in patent litigation related to digital conditional access and encryption
`technology employed to protect video entertainment delivered over cable television networks.
`This project required the develop of sophisticated financial models which demonstrated the
`value of the patents by computing the impact the technology had on the overall enterprise
`value of the defendant.
`• On behalf of a leading law firm representing IPPV Enterprises, he supported the client as
`damages expert in patent litigation related to secure key exchange and key management as
`employed by the defendant- Echostar. As above, this project required the develop of
`sophisticated financial models which demonstrated the value of the patents by computing the
`impact the technology had on the overall enterprise value of the defendant
`• Leadership of a project jointly funded by The National Association of Broadcasters and
`Maximum Service TV Association to analyze options to accelerate the adoption of digital TV
`
`VIZIO, Inc. Exhibit 1024
`3 of 12
`
`

`
`Stuart J. Lipoff
`
`technology by consumers. His recommendations were provided to the FCC and were the
`basis for the August 2002 report and order the FCC issued to mandate a roll-out schedule for
`digital TV receivers.
`
`(cid:149) • For Bell South he contributed to a major operations improvement project involving developing
`forecasts of the future competitive environment, customer needs, a strategy to compete, and
`new business models. These forecasts were then applied to develop business redesign
`recommendations and a list of new services offerings.
`(cid:149) • For Magnavox Cable TV (a division of N.A. Philips) he performed comparative cost and
`technical analysis of fiber optics versus conventional coax systems. This analysis was
`followed by the development of strategies and sales support materials to pitch the new HFC
`systems to cable TV operators.
`(cid:149) • I performed additional work for The Cable Television Laboratories in which he studied the
`application of remote and distributed antennas supporting microcellular PCS on hybrid fiber-
`coax cable TV systems. A key issue explored was the requirement for the fiber optic portion
`of the plant to carry the PCS carriers in analog form and deal with the wide dynamic range
`demands for inbound signals.
`(cid:149) • For a consortium of the major cable TV operators consisting of Comcast, Time Warner, Cox,
`and Rogers; he developed models for prediction of reliability of alternative HFC architectures
`and their suitability to provide local exchange voice services competitive with ILECs. The
`project required understanding the reliability specifications employed in conventional local
`exchange carrier telephone plant and the contributions between hardware, power, and
`workmanship failures. Each of three alternative fiber optic architectures for cable delivered
`voice telephony were studied and modeled to develop reliability predictions and
`recommendations were made as to which aspects of the three alternatives were the best
`choice for cable delivered voice telephony.
`(cid:149) • For GTE Systems he prepared a presentation on developing commercial opportunities for
`wide-bandwidth ATM switching. The scope of applications included: metro area network
`LAN interconnect, broadcast studio digital video routing and switching, and distributed
`switching for digital wireless personal communications networks. The goal of the project was
`to explore cable TV and other commercial applications for their military systems broadband
`switching technology.
`(cid:149) • For Bellcore (now Telcordia division of SAIC), he evaluated the R&D portfolio of their
`Applied Research Group. The main components of this portfolio were DWDM technologies
`for long haul interLATA communications as well as optical multiplexing components for
`passive optical network applications in cable TV and advanced broadband residential
`services. I provided R&D planning assistance on the allocation of funding and priorities to
`the R&D efforts and identified opportunities for securing intellectual property rights to
`critical R&D efforts.
`(cid:149) • For the ViaSat Division of Modern Times Group (Sweden) he developed business plans for
`the launch of a new service that bundled discounted long distance telephone services with
`direct to home satellite TV services and other interactive services including gambling via the
`set-top box.
`
`VIZIO, Inc. Exhibit 1024
`4 of 12
`
`

`
`Stuart J. Lipoff
`
`• For Magnavox Cable TV, he supported the development of a set-top-box cable converter
`with a microcomputer based user interface and conditional access system. The product was
`sold in both the USA and Canada.
`
`• For Southern New England Telephone (SNET), he supported the launch of a video dial tone
`service. He contribution to the project included engineering and cost analysis of system
`alternatives as well as assisting with the preparing of RFPs for set-top-boxes and other
`network elements.
`
`VIZIO, Inc. Exhibit 1024
`5 of 12
`
`

`
`Stuart J. Lipoff
`Litigation Support Projects as a Disclosed Expert
`Current as of September 2016
`
`• Provided declaration and on invalidity, retained by TCT Mobile Inc in the case
`captioned below:
`The United States Patent and Trademark Office
`Case: Unassigned (Patent Number 8,274,991)
`Before The Patent Trial and Appeal Board
`Petitioner: TCT Mobile (US) Inc and TCT Mobile Inc
`Patent Owner: Wireless Protocol Innovations, Inc
`
`• Provided declaration and on invalidity, retained by TCT Mobile Inc in the case
`captioned below:
`The United States Patent and Trademark Office
`Case: Unassigned (Patent Number 8,565,256)
`Before The Patent Trial and Appeal Board
`Petitioner: TCT Mobile (US) Inc and TCT Mobile Inc
`Patent Owner: Wireless Protocol Innovations, Inc
`
`• Provided declaration and on invalidity, retained by Techtronics Industries Co, LTD in
`the case captioned below:
`The United States Patent and Trademark Office
`Case: Unassigned (Patent Number 7,224,75)
`Before The Patent Trial and Appeal Board
`Petitioner: Techtronics Industries Co, LTD
`Patent Owner: Chamberlain Group, Inc.
`
`• Provided declaration and deposition testimony on invalidity, retained by Securus
`Technologlies, Inc in the case captioned below:
`The United States Patent and Trademark Office
`Case: IPR2016-01411
`Before The Patent Trial and Appeal Board
`Petitioner: Securus Technologies, Inc
`Patent Owner: Global Tel*Link Corporation
`
`• Provided declaration and deposition testimony on invalidity, retained by Securus
`Technologlies, Inc in the case captioned below:
`The United States Patent and Trademark Office
`Case: IPR2016-00269
`Before The Patent Trial and Appeal Board
`Petitioner: Securus Technologies, Inc
`Patent Owner: Global Tel*Link Corporation
`
`Page 1
`
`VIZIO, Inc. Exhibit 1024
`6 of 12
`
`

`
`Stuart J. Lipoff
`Litigation Support Projects as a Disclosed Expert
`Current as of September 2016
`
`• Provided declaration and deposition testimony on invalidity, retained by Securus
`Technologlies, Inc in the case captioned below:
`The United States Patent and Trademark Office
`Case: PGR2015-00013
`Before The Patent Trial and Appeal Board
`Petitioner: Global Tel*Link Corporation
`Patent Owner: Securus Technologies, Inc
`
`• Provided declaration and deposition testimony on invalidity, retained by Securus
`Technologlies, Inc in the case captioned below:
`The United States Patent and Trademark Office
`Case: PGR2015-00014
`Before The Patent Trial and Appeal Board
`Petitioner: Global Tel*Link Corporation
`Patent Owner: Securus Technologies, Inc
`
`• Provided declaration and deposition testimony on invalidity, retained by Arris Group
`and Cox Communications in the case captioned below:
`The United States Patent and Trademark Office
`Case: IPR2014-00746
`Before The Patent Trial and Appeal Board
`Petitioner: Arris Group, Inc
`Patent Owner: C-Cation Technologies, LLC
`
`• Provided expert report and testified at ITC hearing as technical expert, retained by
`Samsung in the case captioned below:
`The United States International Trade Commission
`Investigation No. 337-TA-882
`In the Matter of CERTAIN DIGITAL MEDIA DEVICES, INCLUDING
`TELEVISIONS, BLU-RAY DISC PLAYERS, HOME THEATER SYSTEMS,
`TABLETS AND MOBILE PHONES, COMPONENTS THEREOF AND
`ASSOCIATED SOFTWARE
`Complainants: Black Hills Media, LLC
`Respondents: Samsung Electronics Co. Ltd.
`
`• Provided expert reports and deposition testimony on invalidity and rebuttal to
`infringement, retained by Comcast et al as a technical expert in the case captioned below:
`The United States District Court, Eastern District of Texas, Marshall Division
`
`Page 2
`
`VIZIO, Inc. Exhibit 1024
`7 of 12
`
`

`
`Stuart J. Lipoff
`Litigation Support Projects as a Disclosed Expert
`Current as of September 2016
`
`Civil Action No. 2:11-CV-30 (DF)
`In the Matter of United States Patent Number 5,563,883
`Plaintiffs: C-Cation Technologies, LLC
`Defendants: Comcast Corporation, Charter Communications, Inc., cequel
`Communications, LLC dba Suddenlink Communications, Cable One, Inc.,
`Almega Cable Inc., Longview Cable Television Company, Inc., and Kilgore
`Video, Inc
`
`• Provided expert reports on invalidity and rebuttal to infringement, retained by Apple in
`the case captioned below:
`The United States District Court, Eastern District of Texas, Tyler Division
`Civil Action No. 6:10-cv-74-LED-JDL
`In the Matter of Certain Digital Set-Top Boxes Components Thereof
`Plaintiffs: Smartphone Technologies LLC
`Defendants: LG Electronics Inc, LG Electronics USA, Inc, Apple Inc, and AT&T
`Mobility LLC
`
`• Provided expert report and presented tutorial at ITC hearing as technical expert,
`retained by Apple in the case captioned below:
`The United States International Trade Commission
`Investigation No. 337-TA-808
`In the Matter of Certain Electronic Devices with Communication Capabilities,
`Components Thereof, and Related Software
`Complainants: HTC Corporation
`Respondents: Apple Inc
`
`• Provided expert report and testified at ITC hearing as technical expert, retained by
`Cablevision in the case captioned below:
`The United States International Trade Commission
`Investigation No. 337-TA-712
`In the Matter of Certain Digital Set-Top Boxes Components Thereof
`Complainants: Verizon Services Corporation and Verizon Communications Inc.
`Respondents: Cablevision Systems Corporation
`
`Provided declarations as a technical expert, retained by Comcast in the case captioned
`below:
`
`The United States District Court for the Eastern District of Viginia, Norfolk
`Division
`Civil Action No. 2:11 CV 103 RAJ/TEM
`
`Page 3
`
`VIZIO, Inc. Exhibit 1024
`8 of 12
`
`

`
`Stuart J. Lipoff
`Litigation Support Projects as a Disclosed Expert
`Current as of September 2016
`
`Plaintiffs: Bear Creek Technologies, Inc
`Defendants: Comcast Corporation et al
`
`• Provided declarations and expert report as technical expert, retained by Active Video in
`the case captioned below:
`The United States District Court for The Eastern District of Virginia, Norfolk
`Division
`Civil Action No. 2:10-cv-248 RAJ/FBS
`Plaintiffs: Active Video Networks Inc
`Defendants: Verizon Communications Inc., Verizon Services Corp.
`Verizon Virginia Inc. and Verizon South Inc.
`
`• Provided expert report and deposition testimony as a technical and industry expert,
`retained by eleven member joint defense group in the case captioned below:
`The United States District Court for The District of Maryland, Southern Division
`Civil Action No.8:07-cv-03012-AW (D.Md.)
`Plaintiffs: Technology Patents LLC
`Defendants: Deutsche Telekom AG et al: AT&T Mobility LLC, Microsoft
`Corporation, Yahoo! Inc., Sprint Nextel Corporation, Motorola, Inc., Palm, Inc.,
`Samsung Electronics Co., LTD., Samsung Telecommunications America LLP,
`LG Electronics Mobilecomm U.S.A., Inc., Helio, LLC, Clickatell (PTY) LTD.,
`Cellco Partnership (d/b/a Verizon Wireless), and T-Mobile USA, Inc.)
`
`• Provided declarations as a technical expert, retained by BigBand Networks in the case
`captioned below:
`The United States District Court for The District of Delaware
`Civil Action No. 07-351 (JJF)
`Plaintiffs: BigBand Networks, Inc.
`Defendants: Imagine Communications, Inc.
`
`• Provided declarations as a technical expert, retained by Romek Figa in the case
`captioned below:
`The United States District Court for The District of Massachusetts
`Civil Action No. 08-cv-10304-NG
`Plaintiffs: Romek Figa d/b/a Abraham & Son
`Defendants: Apple Inc
`
`• Provided declarations as a technical and industry expert, retained by ODS Technologies
`in the case captioned below:
`The United States District Court Central District of California, Western Division
`Civil Action No. CV 07-03265 DDP (RCx)
`
`Page 4
`
`VIZIO, Inc. Exhibit 1024
`9 of 12
`
`

`
`Stuart J. Lipoff
`Litigation Support Projects as a Disclosed Expert
`Current as of September 2016
`
`Plaintiffs: ODS Technologies, L.P., d/b/a TVG Network, and ODS Properties, Inc
`Defendants: Magna Entertainment Corporation; HRTV, LLC., ; and Xpressbet,
`Inc
`
`• Provided expert report and declarations as a technical and industry expert, retained by
`Motorola in the case captioned below:
`The United States District Court for the District of Delaware
`Civil Action No. 07-752-GMS
`Plaintiffs and Counter-Defendants: Motorola, Inc., ET AL
`Defendants and Counter-Plaintiffs: Rembrandt Technologies, LP, ET AL
`
`• Provided expert report and deposition testimony as a technical and industry expert,
`retained by Amino Communications in the case captioned below:
`The United States District Court, Central District of California
`Civil Action No. CV-07-1829
`Plaintiffs: Amino Communications, LLC
`Defendants: Guest-Tek Interactive Entertainment, LTD, Guest-Tek Inc, and
`DOES 1 through 10
`
`• Provided expert report and deposition testimony as a liability industry expert, retained
`by JTMD and Ascion in the case captioned below:
`The United States District Court, District of Massachusetts
`Civil Action No. 07-CV-10207-RGS
`Plaintiffs: L& P Property Management Company and Legget & Platt Incorporated
`Defendant: JTMD, LLC d/b/a Reverie, and Ascion, LLC
`
`• Provided deposition testimony as an liability expert, retained by National
`Semiconductor in the case captioned below:
`The Superior Court of California, County of Santa Clara
`Civil Action No. 1 -02-CV8 1 0872
`Plaintiff: Itech Group, Inc.
`Defendant: National Semiconductor Corporation
`
`• Provided expert report, deposition, and trial testimony as a liability technical expert,
`retained by Charter Communications in the case captioned below:
`The United States District Court, Eastern District of Texas, Marshall Division
`Civil Action No. 2-05-CV-436
`Plaintiff: Hybrid Patents Incorporated
`Defendant: Charter Communications, Inc.
`
`• Provided expert report and deposition testimony as a liability industry expert, retained
`by Lutron in the case captioned below:
`The United States District Court, District of Utah
`Case No. 2:03-CV-00488TC
`
`Page 5
`
`VIZIO, Inc. Exhibit 1024
`10 of 12
`
`

`
`Stuart J. Lipoff
`Litigation Support Projects as a Disclosed Expert
`Current as of September 2016
`
`Plaintiff-Counter defendant: Vantage Controls, Inc.
`Defendant-Counter plaintiff: Lutron Electronics Co., Inc.
`
`• Provided expert report and trial and deposition testimony as a liability industry expert,
`retained by Telewizja Polska in the case captioned below:
`The United States District Court, Illinois, Eastern Division
`Civil Action No. 02-C-3293
`Plaintiffs: Telewizja Polska USA
`Defendant: EchoStar SateIlite
`• Provided expert report and deposition testimony as a liability technical expert, retained
`by Broadcom in the case captioned below:
`The United States District Court, Eastern District of Texas, Sherman Division
`Civil Action No. 4:03CV159
`Plaintiffs: Broadcom Corporation
`Defendant: Microtune (Texas), L.P.
`
`• Provided expert report, deposition testimony and trial testimony as a damages expert,
`retained by IPPV and MAAST in the case captioned below:
`The United States District Court For the District of Delaware
`Civil Action No. 99-577-RRM
`Plaintiffs: IPPV Enterprises, LLC and MAAST, Inc.
`Defendant: EchoStar Communications Corp
`
`• Provide expert report and deposition testimony as a damages expert, retained by the
`TVJCOM in the case captioned below:
`The United States District Court For the Middle District of Florida.
`Case No. 3:OO-CV-1045-5-2 1 A
`Plaintiffs: TVJCOM International, Inc.
`Defendants: Mediaone of Greater Florida, Inc., Canal Plus Technologies, S.A.,
`Canal Plus U.S. Technologies, Inc., and Societe Europeene de Controle D'Acces
`
`• Provided expert report and deposition testimony as a liability expert, retained by Sony
`in the case captioned below:
`The United States District Court for the Eastern District of New York
`Civil Action No. 92-01 28-ARR (Consolidated), Civil Action No. 91 -5056-ARR
`Plaintiffs: Loral Fairchild Corporation
`Defendants: Sony Company of Japan, LTD.
`
`• Provided expert report and deposition testimony as a liability expert, retained by
`General Instrument in the case captioned below:
`The United States District Court for the Eastern District of Pennsylvania
`General Instrument Corporation v. Scientific-Atlanta, Inc.
`Civil Action No. 91 -6923
`Plaintiffs: General Instrument Corporation
`
`Page 6
`
`VIZIO, Inc. Exhibit 1024
`11 of 12
`
`

`
`Stuart J. Lipoff
`Litigation Support Projects as a Disclosed Expert
`Current as of September 2016
`
`Defendants: Scientific-Atlanta, Inc.
`
`Page 7
`
`VIZIO, Inc. Exhibit 1024
`12 of 12

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