DECLARATION OF DR. STEPHEN HEPPE IN SUPPORT OF INTER
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`PARTES REVIEW OF U.S. PATENT 8,013,732
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`Heppe Decl. RE: U.S. Patent 8,013,732
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`Page 1
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`Petitioner Emerson's Exhibit 1004
`Page 1 of 63
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`PARTES REVIEW OF U.S. PATENT 8,013,732
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`Heppe Decl. RE: U.S. Patent 8,013,732
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`Petitioner Emerson's Exhibit 1004
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`TABLE OF CONTENTS
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`INTRODUCTION AND QUALIFICATIONS ....................................................................... 3
`I.
`PERSON OF ORDINARY SKILL IN THE ART (POSITA) ............................................. 7
`II.
`III. CLAIM CONSTRUCTION ................................................................................................. 8
`IV.
`SUMMARY OF PRIOR ART CONSIDERED ................................................................. 11
`V.
`ANALYSIS OF CLAIMS 1-7 ........................................................................................... 27
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`Heppe Decl. RE: U.S. Patent 8,013,732
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`I.
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`INTRODUCTION AND QUALIFICATIONS
`1.
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`I am over 18 years of age. I have personal knowledge of the facts
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`stated in this Declaration and could testify competently to them if asked to do so.
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`2.
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`I obtained a Bachelor’s of Science degree in electrical engineering and
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`computer science at Princeton University in 1977, a Master’s of Science degree in
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`electrical engineering (specializing in communications) from The George
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`Washington University (GWU) in 1982, and a Doctor of Science in electrical
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`engineering (specializing in communications, with minors in operations research
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`and electrophysics) in 1989. I have worked in the fields of radio communication,
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`computer and network communications, packet radio, and ad hoc packet radio
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`networking since 1977. In the late 1980’s, I was the lead communications engineer
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`on a project demonstrating differentially-corrected GPS-based precision approach
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`for a military aircraft. This system relied on the AX.25 packet radio specification
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`for air/ground communications. From 1995 through 2002, I worked on standards
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`as well as hardware and software for an ad hoc (distributed) airborne packet radio
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`system that could exchange GPS position reports and data between aircraft and
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`ground stations. This included augmentations that provided routing and
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`transmission of user data through the airborne stations, allowing transfer of data
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`between aircraft and distant ground stations connected to the Internet or other wide
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`area networks. My detailed CV is provided as Exhibit 1005 to the Petition.
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`Heppe Decl. RE: U.S. Patent 8,013,732
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`3.
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`I have been asked by the Petitioner, Emerson, to provide my opinions
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`about the technical issues addressed below. I am being compensated for my time
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`spent on this matter at my standard hourly compensation rate. I have no financial
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`interest in the outcome of this or any related proceeding. My compensation is not
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`dependent upon the opinions that I am providing in this declaration.
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`4.
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`I have reviewed U.S. Patent 8,013,732 (“the ‘732 patent”), its file
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`history, and the prior art citations noted in my analysis and opinions.
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`5.
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`The ‘732 patent, awarded to Petite and Huff, claims a priority date of
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`October 14, 1998 based on application No. 09/172,554. I understand that the
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`earliest priority date of the challenged claims may be later due to the introduction
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`of new matter in the continuation-in-part applications filed after the October 14,
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`1998 date. While I have provided my opinions based on the October 1998, these
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`opinions are equally applicable as of March, 1999. According to the Abstract of
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`the ‘732 patent, it is directed to a system for monitoring a variety of environmental
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`and/or other conditions within a defined remotely located region, such as, e.g.,
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`utility meters in a defined area. The system is implemented using transmitters
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`integrated into sensors (each) adapted to monitor a particular data input,
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`transceivers dispersed throughout a region, and a gateway to translate and transfer
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`information from the transmitters to a dedicated computer on a network. The
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`system further includes means for identifying and applying an appropriate control
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`signal at a designated actuator.
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`6.
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`Figure 2 of the ‘732 patent, shown below, illustrates a few of the key
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`elements as described in the Abstract. Note that sensors and actuators can both be
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`integrated with a transceiver.
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`7.
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`FIG. 2 illustrates a control system 200 described by the ‘732 patent.
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`One or more sensor/actuators are integrated with transceivers to transmit an RF
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`signal comprising sensed data as well as a transmitter identification code or
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`address. ‘732 at 5:65-6:3; 9:46-50; 15:19-25; FIGs 11, 12. The ‘732 provides
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`examples of sensors and actuators such as a smoke detector, thermostat, or a
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`security system (6:11-14), as well as carbon monoxide and door position sensors
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`(9:55-57). A plurality of stand-alone radio-frequency (RF) transceivers are also
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`dispersed geographically at defined locations and are configured to receive RF
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`transmissions (comprising e.g. sensed data and a transmitter identification
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`code/address), from a remote transceiver, and transmit an outgoing signal
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`comprising the received data and the stand-alone transceiver’s own identification
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`code/address. 3:26-31; 6:15-31; 7:15-20; 10:54-56; FIG 2. While the RF signals
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`can be low-power (6:2-3), they could also be higher-power (6:20-21). A local
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`gateway(s) is (are) configured to receive data transmissions from the various stand-
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`alone or integrated transceivers (i.e., containing sensed data and a transmitter
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`identification address), convert (translate) the transmissions to TCP/IP format, and
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`provide the data to a computer over a WAN. 6:32-47. The computer collects,
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`compiles and stores the data for retrieval upon client demand, and can also identify
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`an appropriate control signal (i.e., for applying at a designated actuator). ‘732
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`patent, Abstract.
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`Heppe Decl. RE: U.S. Patent 8,013,732
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`II.
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`PERSON OF ORDINARY SKILL IN THE ART (POSITA)
`8.
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`The subject matter of the ‘732 patent relates to radio communication,
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`computer communication over local and wide-area networks, protocols for packet
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`data communication and routing, and error control. In my experience, these
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`subjects are normally taught at the graduate level in electrical engineering degree
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`programs, and would consume roughly one year of focused study. It is also
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`certainly possible for diligent engineers to learn these subjects “on the job”,
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`although the competing demands of a typical work environment would generally
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`slow the pace of learning in these specific fields (while possibly offering a more
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`diverse learning experience in a wider variety of specialties). Accordingly, it is my
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`opinion that a person of ordinary skill in the art in the field of the ‘732 patent has,
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`through formal education or practical experience, the equivalent of a Bachelor’s
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`Degree in Electrical Engineering and 2-3 years of experience in the development
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`and design, or technical marketing, of radio communications or computer network
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`systems.
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`9. My analysis and interpretation of the ‘732 patent and the prior art is
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`from the perspective of a person of ordinary skill in the art circa October 1998. As
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`I explained above, this analysis and interpretation, and the opinions that result
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`therefrom, are equally applicable as of March, 1999 unless otherwise stated.
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`III. CLAIM CONSTRUCTION
`10.
`I have been informed that a claim in inter partes review is given the
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`broadest reasonable interpretation (BRI) in light of the specification. In the
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`subsections below, I offer my opinions on some of the terms used in the claims at
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`issue in this inter partes review (IPR). The constructions set forth below are
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`provided for the purposes of this IPR only, and may be different than constructions
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`I would propose in litigation forums using a different standard.
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`A.
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`“sensor”
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`11. The specification teaches a variety of analog and digital sensors with
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`continuous (analog) or binary (digital) outputs. See, e.g., 9:27-38; 10:7-13. The
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`scope of “sensor” does not appear to be limited by the specification, which
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`provides a very broad context for the term: “The system comprises one or more
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`sensors to be read and/or actuators to be controlled remotely.” (3:6-8; emphasis
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`added). The specification provides examples of sensors including those for a
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`thermostat temperature set value, an ambient temperature, and other parameters
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`such as system on/off and operating mode. Id., 10:10:7-16. The specification also
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`teaches sensors for alarm status (9:29-31; 9:46-50) and utility meter operational
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`status and usage (12:40-46). The specification also teaches that a data interface,
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`sensor and actuator can be replaced with a GPS receiver which inputs a data signal
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`containing latitude and longitude coordinates to a data controller (11:1-7). A
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`person of ordinary skill in the art at the time of the inventions (“POSITA”) would
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`interpret this as a teaching that the sensor can be a GPS receiver, and a sensor
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`value or output can be a latitude and longitude. Accordingly, I believe the BRI for
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`“sensor” should be an equipment, program, or device that monitors or
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`measures the state or status of a parameter or condition and provides
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`information concerning the parameter or condition. Parameters and conditions
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`falling within the scope of the term should be understood to include heat, chemical
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`detections, position, location, and operating parameters and conditions including
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`user-generated inputs or data.
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`B.
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` “actuator”
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`12. This term appears initially in the Abstract as a point at which a control
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`signal may be applied. See also, ‘732 at 1:54-61; 3:6-8. For example, the
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`specification teaches an actuator that can apply control signals to a manual
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`temperature control for a temperature set point, a climate mode control switch, and
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`a system on/off switch (‘732 at 10:19-25), or a water supply valve (13:28-33). The
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`specification does not appear to limit the scope of the term “actuator” relative to its
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`plain and ordinary meaning as would be understood by a POSITA circa 1998.
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`Given the related nature of actuators to monitored parameters (10:63-65), it is my
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`opinion that the BRI for actuator should be an equipment, program, or device
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`that controls or affects the state or status of a parameter or condition.
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`C.
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`“gateway”
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`13. The ‘732 patent describes the “gateway” as a translator or converter
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`that converts information in one format on a first network to a second format
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`before further communicating the information. For example, the ‘732 patent states
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`that “[s]tand alone transceiver 221 further processes and transmits the encoded data
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`to local gateway 210 which translates the data packet information into TCP/IP
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`format for transfer across WAN 230 to server 260.” 12:46-49; 13:23-26. The ‘732
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`patent also states that “Local gateway 210 receives the RF data transmission
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`repeated by stand-alone transceiver 221 and converts the RF data transmission into
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`TCP/IP for further transmission across WAN 230 to server 260.” 16:34-38.
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`14. The ‘732 patent also explains that, at the gateway, “[a]nother look up
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`table may be used to associate function codes with the interpretation thereof. For
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`example, a unique code may be associated by a look up table to identify functions
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`such as test, temperature, smoke alarm active, security system breach, etc.” 11:47-
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`51.
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`15.
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`In light of these considerations, “gateway” should be construed as
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`equipment, program and/or device capable of converting and further
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`communicating information.
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`IV. SUMMARY OF PRIOR ART CONSIDERED
`16. Kahn, et al., “Advances in Packet Radio Technology” [Kahn], was
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`published in The Proceedings of the IEEE, Vol. 66, No. 11. The Proceedings of
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`the IEEE is a compendium of articles that are physically bound together and
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`mailed to the IEEE members that subscribe to the “Proceedings.” The Kahn article
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`is dated November 1978. I have been a member of IEEE for many years, and have
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`read IEEE articles and publications throughout my professional career. In my
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`experience, the publication dates listed on articles like Kahn accurately reflect the
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`date that the article was published to the relevant public.
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`17. Kahn provides an overview of the basic concepts of packet radio,
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`including a then-current (1978) description of a particular packet radio network
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`(“PRNET”), a multi-hop, multi-access packet radio network sponsored by the
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`Advanced Research Projects Agency (“ARPA”). Kahn, pp. 1468-69. While the
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`original purpose of the packet radio development effort was for military computer
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`communications, Kahn explains that the concept of a packet radio network is
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`applicable to an extremely wide range of communications applications (1469, col.
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`1). The individual nodes in the network – the packet radios (“PRs”) – comprise a
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`radio unit and a digital unit. The radio unit is a transmitter and receiver. The
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`digital unit comprises a micro-processor and memory for control of the packet
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`radio, buffering of data packets, and storage of software. For example, the
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`microprocessor selects the transmission frequency, data rate, transmit power, and
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`time of transmission. The microprocessor also performs packet processing to route
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`the packet through the network (Kahn, p. 1477), and can be connected to a terminal
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`or “station” that provides additional functionality. See, e.g., Kahn, Fig. 13 and Fig.
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`14. Data received from an attached device (e.g., a terminal) is detected by the
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`digital section, which adds some network routing and control information and
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`passes the packet to the radio section for transmission. Id., p. 1477. The unit of
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`transmission in the network is a packet that includes a number of data bits that
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`include “all the addressing and control information necessary to correctly route it
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`to its destination.” Id., p. 1468, pp. 1478-79.
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`18. The PRNET was normally connected to the ARPANET. Id., p. 1494
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`(the ARPANET later became known as the internet). The connection to the
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`ARPANET was accomplished through a gateway process co-located with the
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`station. Id.
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`19. According to Kahn, “[a] primary objective of a packet radio network
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`is to support real-time interactive communications between computer resources
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`(hosts) connected to the network and user terminals (e.g., terminal-host, host-host,
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`and terminal-terminal interactions).” Kahn, p. 1469, col. 2 and Fig. 9 (see below).
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`While this figure appears to distinguish radio nodes that are “terminals” from
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`“repeaters”, Kahn teaches that there is no such distinction in at least some
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`applications: “For military operation, where a separate backbone network might
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`be infeasible to deploy, each user’s radio might be equipped to support not only his
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`own traffic but that of other designated users… In this case, we do not identify a
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`separate backbone repeater network per se, since it would be indistinguishable
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`from the network of user packet radios.” Id., p. 1477, col. 1. Thus, the “repeaters”
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`in Fig. 9 can also represent nodes associated with a baseband terminal that
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`represent a source or destination of data traffic.
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`20. Cerf and Kirstein, “Issues in Packet-Network Interconnection”
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`[Cerf], was published in Proceedings of the IEEE, Vol. 66, No. 11, November
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`1978 (the same issue as Kahn). Cerf describes early ideas of internetworking -
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`communicating across more than one network - when the two ends of the
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`connection are on different provider’s networks. Cerf p. 1387, col. 1; p. 1388, col.
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`2. Networks included Xerox ETHERNET, LCSNET, packet radios, etc. Id., p.
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`1338, col. 2. Cerf, which Kahn explicitly identified in his paper in relation to the
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`“gateway process” between Kahn’s PRNET and the ARPANET (Kahn at 1494,
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`col. 2, note [34]), describes four different options for creating an “internetwork.”
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`Cerf, pp. 1393 – 99. Each of these options uses a gateway between the networks,
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`but the role of the gateway in each option differs. According to Cerf’s Option 3,
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`“The basic model of network interconnection for the datagram host gateway is that
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`internetwork datagrams will be carried to and from hosts and gateways and
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`between gateways by encapsulation of the datagrams in local network packets.
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`Pouzin describes this process generically as ‘wrapping’ [37].” Id., p. 1397, col. 2.
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`21. Cerf’s Option 4 provides for translating protocols of the networks
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`coupled by the gateway. Cerf at pp. 1398 - 1399. Rather than encapsulating a
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`universal internetworking protocol inside each underlying network’s native
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`protocol (a simple form of protocol translation), this option is one in which the
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`protocols are semantically translated at the same layer. Id. The complexity of the
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`translation depends on the “commonality of concept between the protocols to be
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`translated.” Id., p. 1399, col. 1.
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`22. U.S. Patent No. 6,124,806 to Cunningham et al. (“Cunningham”).
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`Cunningham was filed on September 11, 1998 and issued on September 26, 2000.
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`Cunningham discloses a system that monitors and controls remote devices. A host
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`module receives data from a plurality of sensor interface modules through data
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`collection modules and data repeater modules. 7:19-27, 44:12-41, 44:53-64,
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`47:44-54. The sensor interface modules attach to gas, electric and water meters,
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`and other types of monitored equipment, and include an appropriate hardware
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`sensor for the device being monitored and a transmitter for communicating sensor
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`data to data collection modules using low-power radio-frequency transmissions.
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`6:11-19, 7:30-8:21. The data may be made available to a customer at a separate
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`computer or workstation at the customer’s request. 44:54-64, 46:44-61.
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`23. U.S. Patent No. 5,924,486 to Ehlers et al. (“Ehlers”). Ehlers was
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`filed on October 29, 1997, and issued on July 20, 1999. Ehlers discloses an
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`“environmental condition control system that automatically controls internal
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`environmental conditions to optimize comfort and minimize energy consumption
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`and/or energy cost, based on user-defined parameters.” 2:33-37. This system can
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`be “part of an overall energy management system” and can “report back detailed
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`consumption data as a function of time and format the data in summary fashion to
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`provide, at a minimum, daily averages for any user defined period, monthly totals,
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`as well as track the costs of each energy unit consumed period and provide detailed
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`and average daily cost for any user-defined period as well as monthly totals.”
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`2:46-49; 3:30-36. Indeed, user-selectable data processing is a key advantage of
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`Ehlers: “[n]umerous different environmental condition control, price and energy
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`consumption control and cost prediction functions may be provided by the system
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`of the invention … . The functions may be selected by a user … .” 7:20-26.
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`24. Ehlers’s Fig. 1 is “a block diagram showing the basic hardware
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`components of the system of the invention.” 6:66-67. The devices 50 being
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`controlled by the processor 30 (which may be a “personal computer”, 7:16-18,
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`7:31-32) can include HVAC systems (7:45-52).
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`25. Fig. 3 is a residential embodiment of Fig. 1, and “includes at least the
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`basic general hardware elements shown in FIG. 1” (8:6-8). The “thermostat-like
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`unit … will contain the keypad, temperature sensor, humidity sensor, display,
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`audio transducer, contact closures and a microcontroller.” 30:62-65. The
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`temperature and humidity sensors 8 are shown separately from the keypad 7 and
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`the user output interface 43. Temperature decision & execution 36 is indicated as
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`part of process functions 30, performed by the thermostat-like unit. 31:9-10. The
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`output of Temperature decision & execution 36 passes to Temperature control
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`outputs 44, which “provides control for heating and cooling equipment.” 14:12-
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`13. This control is provided by contacts 51, which “provide control to devices
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`outside the system from functions 41, 42, 44 and 45. These contacts will be rated
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`for controlling relays and low voltage circuits. The contacts may, for example,
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`control the external load devices for energy consumption management and
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`environmental condition control.” 14:46-51.
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`26. Communications link 52 is also provided “to communicate to
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`equipment remote to the system.” 14:17-18. Ehlers describes the communications
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`options very broadly. Communications are available between the user, the
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`supplier, and “other networked entity.” 34:11-14. Examples of communications
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`media include satellite, Ethernet, and phone lines, which can support both input
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`and output communications. 14:59-63. The communications link is useful in that
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`the results provided from process functions “may be provided … to output devices,
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`service providers or external equipment.” 11:11-14. These output devices and a
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`processor performing the process functions 30 can be “physically separated by
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`great distances and connected through [the] communications data link.” 11:14-17.
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`This is confirmed again in Ehlers’s disclosure regarding storage function 22, which
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`may be “remote” from function 21, connected via “communications data link,” and
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`can be a “separate service provider computer system.” 10:66-11:6. Ehlers sums
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`up the advantage of the communications link: “[a]s such, a process can be
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`performed by a remote computer system or by a service provider and sent back to
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`the local system to output functions.” 11:17-20.
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`27. While I have primarily evaluated Ehlers according to Fig. 3, Ehlers
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`also discloses that the “[f]eatures provided by the system of FIG. 4 include all
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`those offered by the systems of FIGS. 2 and 3, plus additional features made
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`possible by the configuration of the FIG. 4 system.” 35:9-13. Fig. 4 is also
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`described as a “more enhanced residential, commercial and industrial form” and it
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`would have been understood by a POSITA that the embodiment of Fig. 3 could be
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`modified to include the features of Fig. 4 without undue experimentation and with
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`a reasonable expectation of success based on Ehlers’ express disclosure that the
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`features of Fig. 4 could be added to Fig. 3.
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`28. Admitted Prior Art (“APA”). In the ‘732 patent, the applicants
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`admitted that it was known to use sensors and actuators to monitor and
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`automatically respond to system parameters to reach desired results. The
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`applicants give examples of automated control systems including manufacturing
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`processes, inventory systems, emergency control systems, heating, ventilation, and
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`air conditioning systems, and fire reporting and damage control systems. ‘732 at
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`1:54-65; 2:27-29. For example, Figure 1 of
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`the ‘732 patent shows a prior art system for
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`monitoring and control. The prior art
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`control system (100) includes a plurality of
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`sensor/actuator pairs 111-117 coupled to
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`local controller 110. Local controller 110
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`formats and applies data signals from the
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`sensors to process control functions. It also
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`returns control signals from the process
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`control functions to the actuators to effectuate changes in the control system. Id.,
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`5:32-41. The control system 100 can also be integrated to a central controller 130
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`using a network such as the public switched telephone network (“PSTN”). Id.,
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`5:42-44.
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`29. Motivation to Combine. There are several reasons why a POSITA
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`would have been motivated to combine the teachings of the various references
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`introduced above. A few of these are introduced here. Further analysis is provided
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`in relation to my analysis of the claims.
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`30. A first combination is Kahn with the admitted prior art (APA)’s
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`“heating, ventilation, and air-conditioning systems” which have thermostat
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`devices. 2:26-31. The applicants note that a well-known problem in the art
`
`with expanding the use of control systems technology to distributed systems
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`“are the costs associated with the sensor-actuator infrastructure required to
`
`monitor and control functions within such systems.” ‘732 at 2:34-37. The
`
`applicants note, in the context of a local network of hard-wired sensors and
`
`actuators, the expense of connecting the sensors and actuators with a local
`
`controller. Id., 2:37-43; 5:48-61. The applicants’ response to this perceived
`
`problem, at least in part, is to propose an RF network for the exchange of
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`data. An RF network does not require the installation of physical wires and
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`Heppe Decl. RE: U.S. Patent 8,013,732
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`Page 20
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`Petitioner Emerson's Exhibit 1004
`Page 20 of 63
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`cables to connect the sensors/actuators with the local controller. The
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`applicants also recognize that an RF system is easily expanded (see, e.g.,
`
`13:11-17; 13:50-55). The applicants also note the benefit of an RF network
`
`in the context of an automotive diagnostics monitoring system (Id., 12:53 –
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`13:6) where a sensor is associated with a mobile user.
`
`31. Kahn combined with the APA solves the same problems noted by
`
`the applicants. The combination avoids the expense associated with
`
`installation of wiring between the sensors/actuators and the local controller,
`
`provides for expansion of the network, and supports mobile users. Kahn
`
`specifically notes the use of packet radio in the mobile environment (Kahn,
`
`1468 - 1469), and the advantage of broadcast radio technology (such as the
`
`PRNET discussed in the article) in terms of network deployment flexibility
`
`and reconfiguration, as compared with most fixed plant installations. Id.,
`
`1469, col. 1. Kahn expected to see “a considerable increase in the usage of
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`civilian terminals and microcomputers ‘on the move’ during the early 1980’s
`
`but, in contrast to the military environment, these applications are expected to
`
`involve relatively simple equipment, reduced capabilities and lower costs.”
`
`Id. Thus, Kahn also recognized that cost is a factor for civilian applications.
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`See also Kahn, p. 1477, col. 1 (routes are assigned by the station to minimize
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`Heppe Decl. RE: U.S. Patent 8,013,732
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`Page 21
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`Petitioner Emerson's Exhibit 1004
`Page 21 of 63
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`PR cost and complexity). Kahn also teaches that deployment of the packet
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`radio net “should be rapid and convenient, requiring little more than
`
`mounting the equipment at the desired location… Once installed, the system
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`should be self-initializing and self-organizing.” Id., 1470, col. 2. This aligns
`
`with the applicants’ awareness that an RF network does not require the
`
`installation of physical wires and cables to connect the sensors/actuators with
`
`the local controller, and that an RF system is easily expanded. Kahn
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`concludes with a projection that low cost radios would emerge within the
`
`next five to ten years (referenced to Kahn’s timeframe of 1978), and that “it
`
`seems likely that packet radio will play a significant future role in computer
`
`communications and the local distribution of information.” Id., 1495, col. 2.
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`Thus, a POSITA in 1998 would have been motivated to combine the
`
`teachings of Kahn with the APA in order to provide for the “local distribution
`
`of information” in the context of a network of sensors and actuators along
`
`with a local controller. Kahn’s discussion of the advantages of broadcast
`
`packet radio networks (e.g., rapid deployment, support for mobile users, the
`
`avoidance of wiring, and the potential for low cost) offers motivation to
`
`combine. Furthermore, a POSITA could have achieved the combination
`
`without undue experimentation and with predictable results. Prior art sensors
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`Heppe Decl. RE: U.S. Patent 8,013,732
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`Page 22
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`Petitioner Emerson's Exhibit 1004
`Page 22 of 63
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`and actuators, intended for “third-party” integration into control systems such
`
`as the HVAC system disclosed in the APA of the ‘732 patent, have well-
`
`defined behaviors and interface specifications to enable such integration with
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`relative ease (i.e., without undue experimentation), and with predictable
`
`results.
`
`32. A POSITA would have also been motivated to combine the
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`teachings of Kahn (with or without those of the APA) with the teachings of
`
`Cunningham. Both Kahn and Cunningham are directed to networks of wireless
`
`transceivers dispersed over a wide area. Kahn, pp. 1477, 79, 81, 88, 89;
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`Cunningham, 6:6-7:27, FIGS. 1, 49. Kahn’s system provides “for the collection
`
`and delivery of measurement data over the radio channel in real-time while an
`
`experiment is being run.” Kahn, p. 1495. Similarly, Cunningham addresses a need
`
`for near real-time information from remote monitoring locations. Cunningham,
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`1:15-39. Understanding these similarities, a POSITA would have been motivated
`
`to use Cunningham’s sensors in Kahn’s system in order to further extend Kahn’s
`
`ability to conduct “the collection and delivery of measurement data.” A POSITA
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`would have also been motivated to combine the teachings of Cunningham’s
`
`sensors with Kahn’s radio communication system to provide additional capabilities
`
`to the Kahn system. This is consistent with Kahn’s disclosure that packet radio
`
`networks are applicable to “an extremely wide range of new and innovative
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`Heppe Decl. RE: U.S. Patent 8,013,732
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`Page 23
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`Petitioner Emerson's Exhibit 1004
`Page 23 of 63
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`computer communication applications.” Kahn, p. 1469. Additionally, the ‘732
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`patent admits that allowing a remote workstation or laptop to access centrally
`
`stored information (for example, through a Web browser) is well known in the art.
`
`Ex. 1001, 7:60-63. A POSITA would have therefore known that providing remote
`
`computers with access to centrally located data, instead of forcing multiple users to
`
`physically visit one computer that hosts that data, is one advantage of a network
`
`and allows the system to more easily provide data to multiple users. Thus, a
`
`POSITA would have been motivated to cause Kahn’s UCLA 360/91 computer to
`
`make its stored data available for retrieval upon demand from a remotely located
`
`device.
`
`33. A POSITA would have also been motivated to combine the
`
`teachings of Kahn and APA with those of Cerf. Kahn refers to Cerf for a
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`description of the gateway process used to interconnect with the ARPANET.
`
`Kahn, p. 1494, col. 2 ([34]). Kahn describes specific operations involving
`
`e.g. remote debugging from the ARPANET, and remote loading of software,
`
`which involve the gateway. Since the ARPANET does not support the link-
`
`layer protocols employed by the PRNET, networking protocols must be
`
`converted or translated. Cerf provides the additional teaching for this aspect
`
`of the system.
`
`Heppe Decl. RE: U.S. Patent 8,013,732
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`Page 24
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`Petitioner Emerson's Exhibit 1004
`Page 24 of 63
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`34. A POSITA would have also been motivated to
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