UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`HUAWEI DEVICE CO., LTD., LG ELECTRONICS, INC., AND ZTE (USA)
`INC.
`PETITIONER
`
`V.
`
`PAPST LICENSING GMBH & CO., KG
`PATENT OWNER
`______________________
`
`CASE IPR2017-00448
`
`U.S. PATENT NO. 6,895,449
`
`______________________
`
`DECLARATION OF DR. KENNETH FERNALD UNDER 37 C.F.R. § 42.53
`
`Papst Licensing GmbH & Co., KG.
`Petitioner – Huawei, LG and ZTE
`Patent Owner - Papst Licensing GmbH & Co., KG.
`IPR2017-00448
`EXH. 2001
`
`1
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`

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`I.
`
`TABLE OF CONTENTS
`
`
`I.
`
`II.
`
`III.
`
`IV.
`
`V.
`
`TABLE OF CONTENTS ................................................................................................... II
`
`INTRODUCTION ............................................................................................................. 1
`
`QUALIFICATIONS .......................................................................................................... 1
`
`COMPENSATION AND PRIOR TESTIMONY .............................................................. 5
`
`INFORMATION CONSIDERED ..................................................................................... 5
`
`VI.
`
`RELEVANT LEGAL STANDARDS ............................................................................... 6
`
`A. Written Description Requirements ........................................................................ 6
`
`VII.
`
`PERSON OF ORDINARY SKILL IN THE ART ............................................................. 6
`
`VIII. SUMMARY OF THE ‘449 PATENT ............................................................................... 7
`
`IX.
`
`ANALYSIS AND OPINIONS .......................................................................................... 8
`
`A.
`
`B.
`
`The ‘755 Application Supports the Claimed “Multi-purpose Interface” ............... 8
`
`The ‘755 Application Supports the “Inquiry” and “Inquiring” Claim
`Elements ............................................................................................................... 12
`
`X.
`
`CONCLUDING REMARKS ........................................................................................... 16
`
`XI.
`
`EXHIBIT A: CURRICULUM VITAE OF DR. KENNETH W. FERNALD ................. 17
`
`XII. EXHIBIT B: MATERIALS CONSIDERED................................................................... 23
`
`
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`
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`ii
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`2
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`

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`II.
`
`INTRODUCTION
`
`1. My name is Kenneth Fernald, Ph.D. I have been retained by counsel for
`
`Papst Licensing GmbH & Co., KG as an expert witness in the above-captioned
`
`proceeding.
`
`2.
`
`I understand that Huawei Device Co., Ltd., LG Electronics, Inc., and
`
`ZTE (USA) (“Petitioner”) have alleged claims 1-10, 12-13, and 15-18 of U.S. Pa-
`
`tent No. 6,895,449 (“the ‘449 Patent”) are unpatentable over the prior art cited in
`
`the above-captioned inter partes review.
`
`3.
`
`I have been asked to provide an opinion regarding the sufficiency of the
`
`March 1997 German application (“the ‘755 application”) in supporting certain
`
`claimed features of the ‘449 Patent.
`
`III. QUALIFICATIONS
`
`4. My qualifications are summarized here and are addressed more fully in
`
`my CV attached as EXHIBIT A. I earned my Bachelor of Science and Master of
`
`Science degrees in Electrical Engineering from North Carolina State University
`
`(NCSU) in 1985 and 1987. During this period, I worked for the Space Electronics
`
`Group developing software for predicting the effects of radiation environments on
`
`integrated circuits. I also consulted for the Naval Research Laboratory (NRL). My
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`services to NRL included the design of dosimetry instrumentation and the execu-
`
`tion of radiation studies on electronic devices at various facilities around the
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`1
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`3
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`United States. I joined NASA Langley Research Center in 1987 where I designed
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`motor control instruments and firmware for ground and space station experiments.
`
`5.
`
`I returned to NCSU in 1988 to earn my Ph.D. in Electrical Engineering.
`
`My doctoral research efforts were funded by the National Science Foundation and
`
`focused on the development of medical systems utilizing wireless digital telemetry.
`
`My work included a thorough investigation of medical telemetry technology and
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`design of a microprocessor-based system for the fast prototyping of implantable
`
`medical instruments. I also completed the design and testing of various compo-
`
`nents of this system, including a bidirectional digital telemetry integrated circuit
`
`(IC) and a general-purpose sensor interface and conversion IC. I completed my
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`Ph.D. in 1992, after which I joined Intermedics Inc. in Angleton, Texas.
`
`6. My responsibilities at Intermedics included system and circuit design of
`
`telemetry, signal-processing, and control ICs for medical devices. Examples in-
`
`clude the design of a sensor acquisition, compression, and storage IC for implanta-
`
`ble pacemakers and defibrillators. I also worked on advanced wireless digital te-
`
`lemetry technology, control ICs for therapy delivery in defibrillators, and software
`
`development for sensor waveform compression and recovery. I left Intermedics in
`
`1998 to join Analog Devices Inc. in Greensboro, NC.
`
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`2
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`4
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`7. My work at Analog Devices included the design of advanced ICs for
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`wireless digital communication devices. Specific projects included the design, de-
`
`bug, and testing of a base-band receiver IC for digital satellite systems. This IC
`
`performed QPSK demodulation, symbol recovery, and forward-error correction for
`
`high-bandwidth wireless video signals. I also performed system design for a
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`CDMA base-band transceiver IC for personal communication devices.
`
`8.
`
`I rejoined Intermedics in 1998 as the first employee of an IC design
`
`group in Austin, Texas. I continued to work on next-generation medical telemetry
`
`ICs until Intermedics was acquired by Guidant in 1999. At that time I joined Cyg-
`
`nal Integrated Products, a startup company in Austin, Texas. My responsibilities at
`
`Cygnal included the design and development of mixed-signal embedded products
`
`for industrial and instrumentation applications. Specific projects included the de-
`
`sign of a proprietary communication system for in-system debug, a proprietary
`
`clock recovery method for USB devices, and the design of numerous analog and
`
`digital circuits and systems. I remained at Cygnal until its acquisition by Silicon
`
`Laboratories Inc. in 2003, at which time I joined Zilker Labs, a start-up company
`
`in Austin, Texas, as their first VP of Engineering and later became their Chief
`
`Technical Officer.
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`9. My responsibilities at Zilker Labs included the development of advanced
`
`IC technologies for power management and delivery for board-level electronic sys-
`
`tems. Specific duties included architecture design and firmware development for
`
`all Zilker Labs products. I left Zilker Labs in 2006 to join Keterex as their first VP
`
`of Engineering. My responsibilities at Keterex included management of engineer-
`
`ing resources, design and layout of application-specific integrated circuits, and de-
`
`velopment of software and firmware for Keterex products. I joined Silicon Labor-
`
`atories in 2010 as a Principal Design Engineer and now hold the title of Distin-
`
`guished Engineer. My responsibilities include architecture development and de-
`
`sign of 8-bit and 32-bit microcontrollers. Projects have included microcontrollers
`
`for metrology, motor control, and low-power and USB applications.
`
`10. I hold over 55 patents on technologies such as wireless telemetry for
`
`medical devices, low-power analog-to-digital converters, security in embedded
`
`systems, clock recovery in communication systems, serial communication proto-
`
`cols, and power management and conversion. I have authored or co-authored over
`
`20 articles, presentations, and seminars on topics including radiation effects in mi-
`
`croelectronics, wireless medical devices, low-power circuit design, circuit design
`
`for digital communications, microcontrollers and embedded systems, and power
`
`management. I am also a co-author of the PMBus™ Power System Management
`
`Protocol Specification.
`
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`IV. COMPENSATION AND PRIOR TESTIMONY
`
`11. I am being compensated at a rate of $350 per hour for my work in this
`
`matter. I am being reimbursed for reasonable and customary expenses associated
`
`with my work in this investigation. My compensation is not contingent on the out-
`
`come of this matter or the specifics of my testimony.
`
`12. Within the last five years, I have testified by deposition in the following
`
`cases (with underline indicating the represented party):
`
`• Papst Licensing GmbH & Co., KG v. Apple, Case 6:15-cv-1095, deposed
`December 1, 2016.
`
`• InfoBionic, Inc. v. Braemar Manufacturing, LLC, Cases IPR2015-01679
`and IPR2015-01688, deposed July 26, 2016.
`
`• Luminara Worldwide, LLC v. Liown Electronics Co. Ltd., et al., Civil No.
`14-cv-03103 (SRN/FLN), deposed March 30, 2016.
`
`• Dane Technologies, Inc. v. Gatekeeper Systems, Inc., Civil No. 12-cv-
`2730-ADM-AJB, deposed April 21-22, 2015 and August 2014.
`
`
`
`V.
`
`INFORMATION CONSIDERED
`
`13. My opinions are based on my years of education, research, and experi-
`
`ence, as well as my investigation and study of relevant materials. In forming my
`
`opinions, I have considered the materials I identify in this report and those in-
`
`cluded in EXHIBIT B of this report.
`
`14. This report represents only those opinions I have formed to date. I re-
`
`serve the right to revise, supplement, and/or amend my opinions stated herein
`
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`5
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`7
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`based on any new information and on my continuing analysis of the materials al-
`
`ready provided.
`
`VI. RELEVANT LEGAL STANDARDS
`
`A. Written Description Requirements
`
`15. My analysis discussed in this declaration relates to the sufficiency of the
`
`written description of the ‘755 application. I have been advised that the test for
`
`sufficiency of the written description is whether the disclosure reasonably conveys
`
`to those skilled in the art that the Inventor had “possession” of the claimed subject
`
`matter. I understand that “possession” must be demonstrated by the material
`
`within the four corners of the ‘755 application. In other words, the ‘755 applica-
`
`tion must describe an invention understandable to a person of ordinary skill in the
`
`art and show that the Inventor actually possessed what is claimed.
`
`VII. PERSON OF ORDINARY SKILL IN THE ART
`
`16. I understand the invention date of ‘449 Patent to be March 4, 1997, based
`
`on the ‘755 application date listed on the face of the ‘449 Patent. A person of ordi-
`
`nary skill in the art (“POSITA”) is a hypothetical person of ordinary creativity hav-
`
`ing “the capability of understanding the scientific and engineering principles appli-
`
`cable to the pertinent art.” Ex parte Hiyamizu, 10 USPQ2d 1393, 1394 (B.P.A.I.
`
`1988). After reviewing the technology of the ‘449 Patent, I consider the relevant
`
`
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`6
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`8
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`

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`art to be, generally speaking, “the transfer of data and in particular to interface de-
`
`vices for communication between a computer or host device and a data transmit/re-
`
`ceive device from which data is to be acquired or with which two-way communica-
`
`tion is to take place.” Exhibit 1001 (‘449 Patent) at 1:13-17. I consider examples
`
`of a person of ordinary skill in the art, as of March 4, 1997, to include a person
`
`with at least a bachelor’s degree in a related field such as computer engineering or
`
`electrical engineering and at least three years of experience in the design, develop-
`
`ment, and/or testing of hardware and software components involved with data trans-
`
`fer or in embedded devices and their interfaces with host systems. Alternatively, a
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`POSITA may have five or more years of experience in these technologies, without a
`
`bachelor’s degree.
`
`VIII. SUMMARY OF THE ‘449 PATENT
`
`17. The ‘449 Patent generally describes apparatus and methods for achieving
`
`high data transfer rates for data acquisition systems to a host computer, without re-
`
`quiring an end user to install specialized software for each host computer system.
`
`See, e.g., Exhibit 1001 (‘449 Patent) at 3:27-31.
`
`18. At the time of the invention, there were an increasing number and variety
`
`of data acquisition systems with the ability to capture high volumes of information,
`
`and an increasing demand to transfer that information to commercially available,
`
`
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`7
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`9
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`general purpose computers. Id. at 1:21-55. However, due to the hierarchical na-
`
`ture of computer system software, device-specific drivers generally provide higher
`
`data transfer rates, while more general-purpose drivers support a wider variety of
`
`devices at the cost of lower performance. Id. at 1:21-2:14. This is true today, as
`
`well as at the time of the invention. The invention of the ‘449 Patent allows a data
`
`acquisition system to identify itself as a type of device normally found in host
`
`computers in order to leverage the capabilities of drivers for such devices. Id. at
`
`4:10-36. Accordingly, by using the invention, users could obtain high data transfer
`
`performance without loading specific software that may otherwise be required to
`
`support a given data acquisition device on a given host computer system. Id. at
`
`1:18-55, 3:27-63, 7:43-50, 8:30-48.
`
`IX. ANALYSIS AND OPINIONS
`
`19. It is my understanding that Petitioner contends the ‘449 Patent is not enti-
`
`tled to priority benefit of the ‘755 application because that application allegedly
`
`does not provide sufficient written description for the challenged claims. Paper 1
`
`(Petition) at 10. In the following sections I discuss my analysis and opinions for
`
`each of the claimed features for which Petitioner contends lacks support by the
`
`‘755 application.
`
`A. The ‘755 Application Supports the Claimed “Multi-purpose Inter-
`face”
`
`20. Petitioner contends:
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`8
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`10
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`

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`… the German priority application did not disclose using
`driver programs in connection with a “multi-purpose in-
`terface,” which would be necessary for such an interface
`to be used with a host computer.
`
`Petition at 11-12.
`
`21. It is unclear whether Petitioner contends the “German priority applica-
`
`tion,” i.e., the ‘755 application, fails to disclose a multi-purpose interface. Regard-
`
`less, and based on the disclosure of the ‘755 application, it is my opinion that a
`
`person of ordinary skill in the art would understand the Inventor to be in posses-
`
`sion of an invention including a multi-purpose interface.
`
`22. A single-purpose interface is an interface designed to connect to one spe-
`
`cific type of device. For example, a classic floppy drive controller is one such sin-
`
`gle-purpose interface. A host computer simply assumes that a floppy disk drive
`
`(“FDD”) is attached to its floppy disk drive controller. Exhibit 1001 (‘449 Patent)
`
`at 3:13-16. As such, a single-purpose interface generally requires no means of de-
`
`termining what type of device is attached – the host simply assumes any attached
`
`device is of the expected type. The ‘755 application makes it clear that such a sin-
`
`gle-purpose interface is undesirable, stating “it is desirable that an interface be so
`
`flexible that the interface can be used to connect very different kinds of electrical
`
`or electronic systems to a host device.” Exhibit 1120 (‘755 application) at 3 (un-
`
`derline added).
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`11
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`23. As an alternative to a single-purpose interface, the ‘755 application de-
`
`scribes using a host “input/output interface” which supports the ability of the host
`
`to determine what type of device is attached. See, e.g., Exhibit 1120 (‘755 applica-
`
`tion) at 1 (“… when receiving an inquiry from the host device through the first
`
`connecting device as to the type of device that is connected to said host device…”),
`
`and at 4 (“When the host device system … is booted, … typical BIOS routines is-
`
`sue an instruction, which is known by those skilled in the art as the ‘INQUIRY’ in-
`
`struction, to each input/output interface that is present in the host device. The [pe-
`
`ripheral] will generate a signal … This signal signals to the host device that, for ex-
`
`ample, a hard disk drive is connected at the respective interface, to which the IN-
`
`QUIRY instruction was sent.”). A person skilled in the art would understand an
`
`input/output interface which supports multiple device types, and as a consequence
`
`has the ability to determine what device type is attached, as a multi-purpose inter-
`
`face.
`
`24. Further, the ‘755 application describes at least two well-known multi-
`
`purpose interfaces, the Small Computer System Interface (“SCSI”) and the En-
`
`hanced Parallel Port interface (“EPP”), also known as the IEEE 1284 interface.
`
`See, e.g., Exhibit 1120 (‘755 application) at 6 and 7. The SCSI interface described
`
`in the ‘755 application is a multi-purpose interface which can connect to a variety
`
`of devices. The SCSI standard states “SCSI-2 includes command sets for magnetic
`
`
`
`10
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`12
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`

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`and optical disks, tapes, printers, processors, CDROMs, scanners, medium chang-
`
`ers, and communications devices.” Exhibit 2005 (ANSI INCITS 131-1994
`
`[S2013]) at Abstract. The SCSI standard further describes the ability to determine
`
`which type of device is attached, stating “[t]he formalized sequence of requests
`
`identify the type of attached SCSI-2 device, the characteristic of the device, and all
`
`the changeable parameters supported by the device.” Exhibit 2005 (ANSI INCITS
`
`131-1994 [S2013]) at 6 (underline added). Further, the SCSI standard states:
`
`The INQUIRY command may be used by a system to de-
`termine the configuration of the SCSI bus. Target devices
`respond with information that includes their type and
`standard level and may include the vendor’s identifica-
`tion, model number and other useful information.
`
`Exhibit 2005 (ANSI INCITS 131-1994 [S2013]) at 85 (underline
`
`added).
`
`25. In addition, the EPP interface described in the ‘755 application is also a
`
`multi-purpose interface which can connect to a variety of devices and has the abil-
`
`ity to detect what type of device is attached. The IEEE 1284-1994 standard de-
`
`scribes the EPP interface as providing “bidirectional parallel communications be-
`
`tween hosts and printers or other peripherals.” Exhibit 2004 (IEEE Std 1284-1994)
`
`at Abstract (underline added). This standard further describes, in part, the purpose
`
`of the EPP interface as follows:
`
`This standard was developed to provide an open path for
`communications between computers and more intelligent
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`11
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`13
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`printers and peripherals. The availability of a standard bi-
`directional protocol will encourage the development of
`new peripherals that return significant data, as well as
`basic status, to the host.
`
`Exhibit 2004 (IEEE Std 1284-1994) at 1 (underline added). The EPP
`
`standard further describes the ability to determine what type of device is at-
`
`tached:
`
`Prior to the first peripheral-to-host transfer, the host does
`not know the type of device to which it is attached, or
`how to communicate with it. The device identification
`option allows the host to request ID information from the
`peripheral using one of the IEEE 1284 reverse data trans-
`fer modes (Nibble, Byte, or ECP). The peripheral identi-
`fies itself by sending a sequence of bytes to the host indi-
`cating its device type, device family, and language capa-
`bilities.
`
`Exhibit 2004 (IEEE Std 1284-1994) at 17 (underline added). As explained
`
`above, the ‘755 application describes a variety of multi-purpose interfaces and ex-
`
`pressly utilizes features common to multi-purpose interfaces, such as the ability to
`
`request the identity of the attached device, to achieve the goals of the invention.
`
`As such, it is my opinion that the ‘755 application demonstrates the Inventor pos-
`
`sessed an invention including a multi-purpose interface, as understood by a person
`
`of ordinary skill in the art.
`
`B.
`
`The ‘755 Application Supports the “Inquiry” and “Inquiring” Claim
`Elements
`
`26. Petitioner contends:
`
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`12
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`14
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`

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`… the claims of the ’449 Patent are not entitled to a pri-
`ority date earlier than the March 3, 1998 filing date of the
`international application PCT/EP98/01187 (Exs. 1116,
`1121) because German priority document does not con-
`vey with reasonable clarity to a POSITA that, as of the
`filing date sought, the inventor was in possession of the
`invention of at least the “inquiry from the host device as
`to the type of a device attached at the multi-purpose in-
`terface of the host device” recited in claims 1 and 17 and
`the “inquiring by the host device at the interface device
`as to the type of device to which the multi-purpose inter-
`face of the host device is attached” recited in claim 18.
`
`Petition at 15 (underline added).
`
`27. However, Petitioner effectively admits that the ‘755 application supports
`
`the required elements. For example, Petitioner states:
`
`A POSITA would have understood that the “inquiry from
`the host device . . .” recited in claims 1 and 17 and the
`“inquiring by the host device . . .” recited in claim 18
`would have been a particular signal that is provided by
`the driver or program of the multi-purpose interface. Ex.
`1103, ¶45. For example, if the multi-purpose interface is
`SCSI, such as disclosed in the ‘449 Patent, the SCSI
`Standard discloses the SCSI INQUIRY command. Ex.
`1114, at 85, Table 31; id. At 96. The peripheral target de-
`vice can, for example, a magnetic disk, a printer device,
`or a CD-ROM device. Id. at 98, Table 47; Ex. 1101, at
`4:63-5:18; Ex. 1102, at 16; Ex. 1103, ¶46.
`
`Paper 1 (Petition) at 14 (underline added).
`
`28. In fact, the ‘755 application also discloses a SCSI interface, which Peti-
`
`tioner admits is both a “multi-purpose interface” and discloses “the SCSI IN-
`
`QUIRY command.” See, e.g., Exhibit 1120 (‘755 application) at 6 and 7.
`
`
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`13
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`15
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`29. In addition, and as discussed above, the ‘755 application further supports
`
`the “inquiry” and “inquiring” elements, i.e., the ability of the host to determine
`
`what type of device is attached. See, e.g., Exhibit 1120 (‘755 application) at 1 (“…
`
`when receiving an inquiry from the host device through the first connecting device
`
`as to the type of device that is connected to said host device…”), and at 4 (“When
`
`the host device system … is booted, … typical BIOS routines issue an instruction,
`
`which is known by those skilled in the art as the ‘INQUIRY’ instruction, to each
`
`input/output interface that is present in the host device. The [peripheral] will gener-
`
`ate a signal … This signal signals to the host device that, for example, a hard disk
`
`drive is connected at the respective interface, to which the INQUIRY instruction
`
`was sent.”).
`
`30. Petitioner’s position is founded on the incorrect premise that 1) the “in-
`
`quiry” and “inquiring” claims require a driver or program specific to the multi-pur-
`
`pose interface (see, e.g., Paper 1 (Petition) at 13), and 2) “[a] POSITA would un-
`
`derstand that the ‘INQUIRY’ instruction is not an instruction that could be issued
`
`by a ‘BIOS routine’.” Paper 1 (Petition) at 14. However, the ‘755 application con-
`
`tradicts Petitioner’s position, e.g. it explicitly discloses that the BIOS can issue the
`
`“INQUIRY” command. For example, the ‘755 application discloses “[w]hen the
`
`host device system … is booted, … normal BIOS routines output a command to
`
`
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`14
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`16
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`each input/output interface … recognized among experts as an ‘INQUIRY’ com-
`
`mand.” Exhibit 1120 at 4 (underline added). The ‘755 application continues by
`
`explaining that the peripheral responds to this INQUIRY command and “signals to
`
`the host device that, for example, a hard disk drive is connected at the respective
`
`interface, to which the INQUIRY instruction was sent.” Id. Thus, a POSITA
`
`would clearly understand that the INQUIRY instruction is an instruction that could
`
`be issued by a BIOS routine, thereby negating Petitioner’s premise.
`
`31. In fact, in some embodiments described in the ‘755 application, a multi-
`
`purpose driver is clearly located in the BIOS to allow the host computer to boot
`
`from the inventive peripheral device. For example, the ‘755 application discloses:
`
`When the host device system … is booted, … normal
`BIOS routines output a command to each input/output in-
`terface … recognized among experts as an ‘INQUIRY’
`command. … the digital signal processor 13 informs the
`host device that the host device is communicating with a
`hard disk drive. If the host device receives the response
`that a drive is present, then it will now send the request to
`the interface device 10 to read the boot sequence, which
`in the case of actual hard disks is usually found in the
`first sectors of the disk. The digital signal processor 13,
`the operating system of which is stored in the memory
`unit 14, will respond to this instruction by sending to the
`host device a virtual boot sequence, which in the case of
`actual drives includes the type, the starting position and
`the length of the file allocation table (FAT), the number
`of sectors, etc., as known to those skilled in the art.
`
`Exhibit 1120 at 4 (underline added).
`
`
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`15
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`32. A POSITA would understand that since the ENQUIRY command is is-
`
`sued before the boot seguence is loaded, i.e._, before the main operating system and
`
`nonuBIOS driver programs are loaded, the disclosed operation of the mule-purpose
`
`interface in such embodiments cannot depend on a non-B108 driver program since
`
`such programs are not executable until after the main operating system has been
`
`loaded using the boot sequence provided by the peripheral. Simply put, the BIOS
`
`routines are generally the only routines available to boot a host computer system
`
`and hence the BIOS must contain all drivers needed during the boot process.
`
`X.
`
`CONCLUDING REMARKS
`
`ate/l?
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`port if additional evidence or information pertinent to my opinions becomes availa~
`
`33. For the purpose of preparing this report, I have reviewed all the materials
`
`and conducted analyses that I believe are appropriate given the evidence available
`
`at this time.
`
`I understand that I will have the right to supplement or amend this re—
`
`ble, and I plan to do so if necessary.
`
`DATED:
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`18
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`XI. EXHIBIT A: CURRICULUM VITAE OF DR. KENNETH W. FERNALD
`
`DEGREES
`Ph.D., Electrical Engineering, North Carolina State University, 1992
`Dissertation: "A Microprocessor-Based System for the Fast Prototyping of Implantable Instru-
`ments for Biomedical Research Applications"
`M.S., Electrical Engineering, North Carolina State University, 1987
`Thesis: "Simulation of Circuit Response to Proton Environments"
`B.S., Electrical Engineering, North Carolina State University, 1985
`
`CONTINUED EDUCATION
`• Analog Bipolar Cell Design, 1997
`• Spread-Spectrum Wireless, IS-95 and Third Generation CDMA Digital Cellular Com-
`munications, 1997
`• RF Design for Personal Communication Systems, 1995
`• Switched Capacitor Circuit Design, 1994
`• Low-Power CMOS Circuit Design, 1993
`• Cardiac Pacing Technology, 1992
`• Digital Signal Processing, 1988
`• Adaptive Filter Design, 1987
`
`EXPERT WITNESS WORK (last five years)
`• Papst Licensing GmbH & Co., KG v. Apple, Case 6:15-cv-1095, deposed Decem-
`ber 1, 2016.
`• InfoBionic, Inc. v. Braemar Manufacturing, LLC, Cases IPR2015-01679 and
`IPR2015-01688, deposed July 26, 2016.
`• Luminara Worldwide, LLC v. Liown Electronics Co. Ltd., et al., Civil No. 14-cv-
`03103 (SRN/FLN), deposed March 30, 2016.
`• Dane Technologies, Inc. v. Gatekeeper Systems, Inc., Civil No. 12-cv-2730-ADM-
`AJB, deposed April 21-22, 2015 and August 2014.
`
`
`EXPERIENCE
`Consulting (Part-time)
`Provide technical analysis and design services to various clients. Projects include:
`• IP analysis on topics such as circuit and system design, embedded systems, wired and
`wireless networking, firmware and software, consumer electronic platforms, etc.
`• Design, fabrication, and testing of a high-speed USB isolator
`• Software and firmware development for a USB-to-SPI/SMBus Serial Adapter
`• Analysis and architecture design for a high-density, nano-device memory platform
`• Analysis for a massively dense 3D integrated memory
`• Design of a radiation-tolerant, nano-device memory IC
`
`
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`17
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`19
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`

`

`
`Distinguished Engineer, Silicon Laboratories, Inc.
`April 2010 to Present
`Lead the design of 8-bit and 32-bit microcontroller integrated circuits. Responsible for
`IC architecture, peripheral design, and project management. Personally designed an all-
`digital PLL, USB and USART peripherals, timing and memory logic, low-power charge-
`pumps, and other analog, mixed-signal and digital circuits and systems.
`
`Vice-President, Engineering, Keterex, Inc.
`August 2006 to April 2010
`Led the design of mixed-signal integrated circuits and systems. Personally designed a
`mixed-signal audio playback IC, a 500V ballast controller and half-bridge driver, a small-
`footprint boost controller for DDR memory platforms, and an ultra low-power signal pro-
`cessing IC. Personally developed firmware (in C) and scripting/IDE software (in C and
`Java) for serial communications and audio processing.
`
`CTO / Vice-President, Engineering, Zilker Labs, Inc.
`December 2003 to August 2006
`Led the design of innovative digital power-management products. Established the IC de-
`sign team and infrastructure. Co-authored the PMBus Specification. Personally per-
`formed product definition, IC architecture and RTL design, and firmware development.
`
`Principal Design Engineer, Cygnal Integrated Products, Inc.
`March 1999 to December 2003
`System and circuit design for mixed-signal microcontroller products. Served as the archi-
`tect and team leader for several products, all of which sampled 1st silicon. Individual de-
`sign efforts included linear regulators, supply monitors, crystal and precision RC oscilla-
`tors, voltage references, a USB clock recovery system, a proprietary serial debug inter-
`face, a µP instruction cache, a micropower real-time clock, and digital interface, control,
`and timing peripherals. Designed the platform and firmware for host-to-device commu-
`nications and debugging.
`
`Senior IC Design Engineer, Analog Devices, Inc.
`June 1995 to June 1998
`Team Leader for development of a CDMA/AMPS Voiceband/Baseband Codec ASIC.
`Tasks included specification, interface design, top-level integration/simulation and cus-
`tomer interface. Lead Design Engineer for development of a DBS digital receiver ASIC.
`Tasks included ADC, DAC, oscillator, and PLL design, IC evaluation, and technical
`management of contractor activities.
`
`Principal Design Engineer, Intermedics, Inc.
`May 1992 to June 1995, June 1998 to March 1999
`
`
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`18
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`20
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`Specification, design, layout supervision, debug, and test development for high-reliability
`micropower mixed-signal CMOS ICs for implantable applications. Projects included
`wireless telemetry ICs, a waveform compression and storage IC, a flyback charging and
`shock delivery controller, ADCs, switched-capacitor filters, DC-to-DC converters, and
`reference generators.
`
`Assistant Researcher, Analog Circuits Group, NC State University
`August 1988 to May 1992
`Original research and development of an intelligent implantable wireless telemetry instru-
`ment for biomedical applications, including the design, layout, and testing of mixed-sig-
`nal CMOS ICs to provide data acquisition and wireless bidirectional digital telemetry
`functions.
`
`Systems Engineer, NASA Langley Research Center
`June 1987 to August 1988
`Designed a microprocessor-based motion controller for linear DC actuators, including
`system software and firmware development.
`
`Assistant Researcher, Space Electronics Group, NC State University
`August 1985 to May 1987
`Original research and development of a software platform (in C) for modeling the effects
`of radiation on semiconductors.
`
`Research Engineer, Naval Research Laboratory
`Summer 1986
`Designed and constructed a electronic dosimetry system for use in radiation effects ex-
`periments. Performed radiation experiments on integrated circuits at several accelerator
`facilities. Consulted on radiation effects in digital memories.
`
`SELECT ISSUED PATENTS (over 55 patents issued)
`5,522,866: Method and apparatus for improving the resolution of pulse position modula-
`tion communications between an implantable medical device and an external
`medical device
`5,548,795: Hybrid analog-to-digital convertor for low power applications, such as use in
`a