UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`DELL INC., EMC CORPORATION, HEWLETT-PACKARD
`ENTERPRISE CO., HP ENTERPRISE SERVICES, LLC, and TERADATA
`OPERATIONS, INC.
`
`Petitioners
`
`v.
`
`REALTIME DATA LLC
`Patent Owner
`____________________
`
`Case IPR2017-00176
`&
`Case IPR2017-00806
`[consolidated]
`Patent No. 7,161,506
`____________________
`
`DECLARATION OF KENNETH A. ZEGER, PH.D., IN SUPPORT OF
`PATENT OWNER’S RESPONSE
`
`Realtime 2004
`Teradata v. Realtime
`IPR2017-00806
`
`

`

`TABLE OF CONTENTS
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`
`
`Introduction ........................................................................................................ 2
`A.
`Engagement ......................................................................................... 2
`B.
`Background and Qualifications ........................................................... 3
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`
`
`I.
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`II. Materials Considered ........................................................................................ 6
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`III. Person Of Skill In The Art ............................................................................... 7
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`IV. Petitioners’ Obviousness Theory As To Claim 104 Limitation C .................. 8
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`V. Petitioners’ Obviousness Theories With Respect To Claim 105 ................... 16
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`VI. Conclusion ..................................................................................................... 21
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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
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`I, Kenneth A. Zeger, Ph.D., a resident of San Diego, California, declare as
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`
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`follows:
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`I.
`
`Introduction
`A. Engagement
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`I have been retained by Patent Owner Realtime Data LLC (“Realtime”
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`or “Patent Owner”) through Zunda LLC to provide my opinions with respect to
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`their Response to the Petitions for Inter Partes Review in IPR2017-00176 and
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`IPR2017-00806 (the “Dell Petition” and “Teradata Petition,” respectively) as to
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`U.S. Patent 7,161,506. Zunda LLC is being compensated for my time at the rate of
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`$690 per hour for time spent on non-deposition tasks and for deposition time. I
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`have no interest in the outcome of this proceeding and the payment of my fees is in
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`no way contingent on my providing any particular opinions.
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`
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`As a part of this engagement, I have also been asked to provide my
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`technical review, analysis, insights, and opinions regarding the Declarations of Dr.
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`Charles D. Creusere (“Creusere Declaration(s),” Ex. 1002 in both proceedings)
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`with respect to challenged claims 104 and 105, as well as the Dell and Teradata
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`Petitions, which rely on the Creusere Declarations.
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`The statements made herein are based on my own knowledge and
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`opinions.
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`Background and Qualifications
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`
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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
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`
`I received a Bachelor’s degree in Electrical Engineering and
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`B.
`
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`Computer Science from the Massachusetts Institute of Technology in 1984.
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`
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`I received a Master of Science degree in Electrical Engineering and
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`Computer Science from the Massachusetts Institute of Technology in 1984.
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`
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`I received a Master of Arts degree in Mathematics from the University
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`of California, Santa Barbara, CA in 1989.
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`
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`I received a Ph.D. degree in Electrical and Computer Engineering
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`from the University of California, Santa Barbara, CA in 1990.
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`I am currently a Full Professor of Electrical and Computer
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`Engineering at the University of California, San Diego (UCSD). I have held this
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`position since 1998, having been promoted from Associated Professor after two
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`years at UCSD. I have been an active member of the UCSD Center for Wireless
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`Communications for 20 years. I teach courses full-time at UCSD in the fields of
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`Electrical and Computer Engineering, and specifically in subfields including
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`communications, information theory, and data compression at the undergraduate
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`and graduate levels. Prior to my employment at UCSD, I taught and conducted
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`research as a faculty member at the University of Illinois, Urbana-Champaign for
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`four years, and at the University of Hawaii for two years.
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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
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` My twenty-plus years of industry experience includes consulting work
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`
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`for the United States Department of Defense as well as for private companies such
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`as Xerox, Nokia, MITRE, ADP, and Hewlett-Packard. The topics upon which I
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`provide consulting expertise include data communications for wireless networks,
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`digital communications, information theory, computer software, and mathematical
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`analyses.
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`
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`I have authored approximately 75 peer-reviewed journal articles, the
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`majority of which are on the topic of communications, information theory, or
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`signal processing. I have also authored over 110 papers at various conferences and
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`symposia over the past thirty-plus years, such as the: IEEE International
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`Conference on Communications; IEEE Radio and Wireless Symposium; Wireless
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`Communications and Networking Conference; IEEE Global Telecommunications
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`Conference; International Symposium on Network Coding; IEEE International
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`Symposium on
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`Information Theory; UCSD Conference on Wireless
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`Communications; International Symposium on Information Theory and Its
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`Applications; Conference on Advances in Communications and Control Systems;
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`IEEE Communication Theory Workshop; Conference on Information Sciences and
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`Systems; Allerton Conference on Communications, Control, and Computing;
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`Information Theory and Its Applications Workshop; Asilomar Conference on
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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
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`Signals, Systems, and Computers. Roughly half of those papers relate to data
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`
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`compression. I also am co-inventor on a US patent disclosing a memory saving
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`technique for image compression.
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`I was elected a Fellow of the IEEE in 2000, an honor bestowed upon
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`only a small percentage of IEEE members. I was awarded the National Science
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`Foundation Presidential Young Investigator Award in 1991, which included
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`$500,000 in research funding. I received this award one year after receiving my
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`Ph.D.
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`
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`I have served as an Associate Editor for the IEEE Transactions on
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`Information Theory and have been an elected member of the IEEE Information
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`Theory Board of Governors for three, three-year terms. I organized and have been
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`on the technical advisory committees of numerous workshops and symposia in the
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`areas of communications and information theory. I regularly review submitted
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`journal manuscripts, government funding requests, conference proposals, student
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`theses, and textbook proposals. I also have given many lectures at conferences,
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`universities, and companies on topics in communications and information theory.
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`I have extensive experience in electronics hardware and computer
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`software, from academic studies, work experience, and supervising students. I
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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
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`personally program computers on an almost daily basis and have fluency in many
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`different computer languages.
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` My curriculum vitae, attached to this declaration as Exhibit A,
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`(“Zeger Curriculum Vitae”), lists my publication record in archival journals,
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`international conferences, and workshops.
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`II. Materials Considered
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`I have been asked to provide a technical review, analysis, insights, and
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`opinions. My technical review, analysis, insights, and opinions are based on almost
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`35 years of education, research, and experience, as well as my study of relevant
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`materials.
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`
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`I have reviewed and am familiar with the ’506 Patent specification
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`and claims. My understanding of the claims is based on the plain and ordinary
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`meaning of the claims as would be understood by a person of ordinary skill in the
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`art, unless the inventor has provided a special meaning for a term. My opinions set
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`forth herein do not rest on a disagreement with Dr. Creusere as to the meaning of
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`any claim term or limitation.
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`
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`I have reviewed and am familiar with the Petitions for Inter Partes
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`Review, Patent Owner Preliminary Responses, and the Board’s Decisions to
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`Institute in these proceedings.
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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
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`I have reviewed the Declarations of Dr. Charles D. Creusere in both
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`proceedings. I have also reviewed the Franaszek, Hsu, and Sebastian references
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`submitted by Petitioners in these proceedings, and am familiar with those
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`references. In addition, I have reviewed Dr. Creusere’s deposition testimony in
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`these proceedings. Based on my review of the materials identified in this paragraph
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`and paragraph 17 above, I did not identify any differences between the Petitions
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`and the Creusere Declarations across the Dell and Teradata proceedings that are
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`material to my opinions herein. The opinions I present here apply equally to both
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`sets of Petitions and Declarations, and were formed on that basis.
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` This declaration represents only opinions I have formed to date. I may
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`consider additional documents as they become available or other documents that
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`are necessary to form my opinions. I reserve the right to revise, supplement, or
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`amend my opinions based on new information and on my continuing analysis.
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`III. Person Of Skill In The Art
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`I am familiar with the concept of the person of ordinary skill in the art
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`(“POSA”), and have reviewed Dr. Creusere and Petitioners’ views on the
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`definition and qualifications of the POSA for purposes of these proceedings. I do
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`not disagree with those views, and have applied the same understandings in
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`forming my opinions set forth herein.
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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
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` Throughout my declaration, even if I discuss my analysis in the
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`
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`present tense, I am always making my determinations based on what a POSA
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`would have known at the time of the invention.
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`IV. Petitioners’ Obviousness Theory As To Claim 104 Limitation C
`
`I understand that at his deposition, Dr. Creusere testified that a POSA
`
`combining Franaszek with Hsu would always use Hsu to identify a data type and
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`three redundancy metrics for each of Franaszek’s data blocks.
`
`Q. Okay. Now, with respect to how Franaszek’s system once
`modified by Hsu would actually make use of Hsu’s data type and
`compression metrics, where in the Franaszek flow process would
`Hsu’s data type and compression metrics analysis occur and -- well,
`just – let’s start there.
`[A.] Well, I mean, a person of ordinary skill in the art, of course,
`would have to -- would have to consider their application what they
`are trying to application [sic]. My own personal feeling on this as a
`person of ordinary skill in the art would be that you would do this in --
`around the same flight in block 4A -- in [Franaszek’s] figure 4A, that
`first block, where it says, at the moment data type available and it
`makes that first split.
`My own opinion is that this is where you would add the Hsu concepts,
`so you -- if you had the data type, then you could use that to guide
`Hsu into making a better situation, into making better or to looking at
`fewer possibilities. If you didn't have the data type, you could then
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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
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`apply Hsu to finding data type and then follow the path to the right
`in figure 4A, where it says, yes, and move -- and move on.
`
`Id. at 131:13-132:15 (emphasis added).
`
` While I do not agree that a POSA would be motivated to combine
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`Franaszek with Hsu at all, I do agree with Dr. Creusere that if a POSA were to
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`make such a combination, the POSA would rely on Hsu’s powerful data type
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`recognition and compressibility analysis approach to identify a data type and three
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`redundancy metrics for each of Franaszek’s data blocks.
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`
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`I understand Dr. Creusere’s explanation of how a POSA would
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`combine Hsu into Franaszek’s Figure 4A to be visually depicted by annotated
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`figure below.
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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
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`I also understand that Dr. Creusere testified that using Hsu’s approach
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`will always yield a result for a block’s data type, and I agree with Dr. Creusere in
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`that particular regard.
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`Q. And in Hsu’s approach, of those four pieces of information that
`the data type and the three redundancy metrics [sic], it will always be
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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
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`the case that at least one, and likely more of those will be identified
`for a given data block, right?
`A. As regards the three redundancy metrics, those are basically
`statistical analysis calculations, and those can always be calculated for
`any data block. As far as the – as the data type information as output
`by Hsu’s new file routine, that, that’s – that will – that should in my,
`in my opinion, as a person of ordinary skill in the art, my best estimate
`is that will always output something. It will always give you
`something. Now exactly what it outputs under certain circumstances,
`I’m not totally sure of.
`Ex. 2003 at 21:13-22:6 (emphasis added).
`
` Based on my review of Dr. Creusere’s testimony, I recognize that Dr.
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`Creusere attempted to qualify the above testimony through additional testimony on
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`re-direct from counsel for Petitioners. Specifically, I am aware that Dr. Creusere
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`testified that Hsu’s approach to data type recognition uses “the UNIX file
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`command,” that “[t]he UNIX file command . . . will return an indication of data for
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`any kind of unrecognized file type,” and that there is therefore “a possibility” that
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`Hsu would in fact fail to determine a data type and simply return “data.” Ex. 2003
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`at 146:15-148:1.
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`
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`I disagree with Dr. Creusere’s testimony and opinions in that regard.
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`To the contrary, it is my opinion that a POSA would understand Hsu to teach an
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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
`
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`approach that will always recognize a data type for each data block, and would not
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`conclude that Hsu’s reference to UNIX file command indicates otherwise.
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` Hsu describes a system that avoids any content independent
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`compression and that instead uses an entirely content-dependent approach. Hsu
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`teaches the identification of a “block type” (i.e., data type) for each data block
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`using a “new-file” procedure. Ex. 1005 at 1103-1104. Hsu’s “new-file” procedure
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`analyzes three 512-byte segments within the block: 512 bytes in the beginning, 512
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`bytes in the middle, and 512 bytes in the end. Ex. 1005 at 1103-1104. During that
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`analysis, Hsu’s method looks for “the pattern of data contained” in each 512 byte
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`segment. Ex. 1005 at 1103-1104. Hsu compares each segment to a collection of
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`known data patterns from Unix and other operating systems. Ex. 1005 at 1103-
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`1104.
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` Correlating with known patterns, Hsu identifies the data type of the
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`block as one of the ten possible classifications shown in Table I, reproduced below.
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`Ex. 1005 at 1103, 1107. In the event that two of the tested segments point to one
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`data type and the third to another, Hsu uses a “majority vote” to reconcile the
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`discrepancy. Ex. 1005 at 1104. Where each of the three segments points to
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`different data types, Hsu uses “the first data type detected.” Ex. 1005 at 1104.
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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
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`Ex. 1005 at 1107.
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` Table I makes clear that Hsu’s list of ten possible data types does not
`
`include “data,” or any other indication of an unrecognized data type. Accordingly,
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`the teachings of Hsu itself foreclose the possibility that its approach will fail to
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`recognize a data type for a data block. Indeed, Hsu specifically explains that its
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`“new-file” approach “compares not only the first 512 bytes of a data set, but also
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`512 bytes in the middle of the set and the 512 bytes at the end (if they exist)” in
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`order to “provide a better indication of the primary data type of a file. . . .” Ex.
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`1005 at 1104 (emphasis original). Hsu also explains that its approach compares
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`those patterns to a larger set of known patterns than previous versions of UNIX.
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`Ex. 1005 at 1104. Both of those teachings would lead a POSA to conclude that Hsu
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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
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`teaches an approach that will not only always recognize and output some data type,
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`but will also be more likely to correctly recognize the data type.
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`I have continuously used UNIX, on an almost weekly basis, since the
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`1980s. Based on my personal experience, I am aware that there were numerous
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`versions of UNIX’s file command during the 1980s and 1990s. Those versions
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`were not necessarily consistent. Moreover, while some POSAs may have been
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`familiar with UNIX and its file command as of the 1995 publication date of Hsu or
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`the 2001 priority date of the ’506 patent, a POSA would almost certainly not have
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`been familiar with how any particular version of UNIX’s file command actually
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`worked. A POSA reading Hsu would neither know which particular version of
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`UNIX’s file command Hsu had utilized, nor would he or she have reason to
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`conclude that Hsu may fail to recognize data types because of its teachings
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`regarding UNIX. And a POSA would appreciate that Hsu does not state that its
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`approach is necessarily identical to any particular version of UNIX’s file
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`command, but rather states that “new-file works in similar fashion.” Ex. 1005 at
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`1104. In addition, I am not aware of evidence that a POSA reading Hsu would
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`have had access to either the source code underlying Hsu’s system or the source
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`code for the specific version of UNIX on which Hsu had relied (if any).
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`Accordingly, a POSA would have no reason to look past Hsu’s own teachings—
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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
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`which demonstrate that Hsu will always identify a data type for each data block—
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`to conclude that Hsu may sometimes fail to identify a data type simply because it
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`was based on some unknown version of UNIX with unknown modifications. Hsu
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`gives neither an explicit nor an implicit suggestion that it will not identify a data
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`type, nor even a clue about how such a (nonexistent, in my opinion) situation
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`would or could be handled. A POSA would not interpret that silence as an
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`indication that Hsu has a problem that it does not address. Rather, the POSA would
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`understand that Hsu simply does not have such a problem.
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` Turning to limitation 104[c], which recites “performing data
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`compression with a single data compression encoder, if a data type of the data
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`block is not identified,” it is my opinion that limitation 104[c] can only be met
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`where a data type of the data block is not identified. Indeed, that is the express
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`language of the limitation.
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` Because a POSA combining Franaszek with Hsu would always use
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`Hsu to identify a block’s data type, Ex. 2003 at 131:13-132:15, and because Hsu
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`will always identify a data type for any data block (as explained above), it follows
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`that the alleged combination of Franaszek and Hsu will always identify a data type
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`for each data block.
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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
`
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`I understand that Petitioners have an alternative theory in which
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`Franaszek would be modified based on Sebastian. Under that theory, Sebastian’s
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`generic filter would be used when Franaszek does not have a data type. That theory
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`does not affect my opinion with respect to limitation 104[c], however, because (as
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`explained above) Hsu would always identify a data type for each block in
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`Franaszek’s system, and thus Sebastian’s generic filter would never be used.
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`V.
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`Petitioners’ Obviousness Theories With Respect To Claim 105
` Like Claim 104, Claim 105 expressly requires analyzing the data to
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`identify one or more data types where the analysis is not “based only on a
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`descriptor” (steps [b] and [e]). Claim 105 further recites, at step [d], “[1] if one or
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`more encoders are associated to said type, compressing said data block with at
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`least one of said one or more encoders, [2] otherwise compressing said data block
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`with a default data compression encoder[.]”
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`
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`I understand that Petitioners’ theory with respect to claim 105 also
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`proposes adapting the descriptor-based system of Franaszek based on the teachings
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`of Hsu. See IPR2017-00176, Pet. at 43-44; IPR2017-00806, Pet. at 46.
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` Based on my review of Franaszek, a POSA would understand
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`Franaszek to teach that Franaszek’s system will always have “one or more
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`encoders [ ] associated to” an identified data type, and that a data block with an
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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
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`identified data type will always be compressed “with at least one of said one or
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`more encoders.”
`
` Since Hsu’s approach would always be used, Ex. 2003 at 131:13-
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`132:15, and will always recognize a data type, it follows that the ensuing
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`combination of Franazek and Hsu will always recognize a data type of a data
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`block, will always have one or more encoders associated with each data block, and
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`will ultimately always compress that data block using those one or more associated
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`encoders. In other words, the combined system of Franaszek and Hsu would never
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`use or perform Franaszek’s step 407.
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`I understand that Petitioners and Dr. Creusere have proposed that a
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`POSA could have modified Franaszek such that—when “a data type has been
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`included in the ‘type’ field, but is not associated with a particular encoder”—
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`Franaszek would use a default encoder, as purportedly taught by Sebastian.
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`IPR2017-00176, Pet. at 42-43; IPR2017-00806, Pet. at 44-45.
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`
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`I am not aware of any evidence that a POSA would have a reason to
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`believe that Franaszek’s system would fail to associate at least one encoder with an
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`identified data type. Rather, based on Franaszek’s teachings, a POSA would
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`conclude based on Franaszek’s teachings that that scenario would not occur within
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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
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`Franaszek’s system. Dr. Creusere testified to the same effect, and appears to agree
`
`with me on this point.
`
`Q. Okay. So your point is simply that Franaszek will have in some
`fashion a list of algorithms that have been predetermined to be the
`appropriate set for a particular data block given the data type
`information that has been provided for that data block?
`A. Yes. Franaszek will have a list of algorithms associated with a
`given type of data, assuming that, assuming that it knows that type of
`data. Franaszek doesn’t address the situation directly, where, where it
`doesn’t know – where there might be type description data. It doesn’t
`know it. But assuming it knows that data, it will have some sort of a
`list associated with that data of possible compression algorithms and it
`will select, it will go through the same process of selecting one of
`those compression algorithms to apply to encode the block.
`Q.
`And to your point just a second ago, Franaszek does not
`contemplate a situation in which it is provided with data type
`information but does not have a list of compression techniques
`associated with that data type. True?
`A.
`From the preferred embodiment of Franaszek, I don’t recall
`any indication that Franaszek contemplates that scenario.
`Ex. 2003 at 14:21-16:1 (emphasis added).
`
` A POSA thus would not have been motivated to modify Franaszek
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`based on the alleged teachings of Sebastian to solve a problem Franaszek did not
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`have.
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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
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`I also understand that Petitioners assert that “Sebastian makes a
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`decision about whether a ‘filter’ is associated with the data type, and if not, it
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`compresses the data using the generic filter.” IPR2017-00176, Pet. at 42; IPR2017-
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`00806, Pet. at 44 (emphasis added).
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`I disagree with that characterization of Sebastian’s teachings, and a
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`POSA would not have understood such a teaching from Sebastian. To the contrary,
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`a POSA would understand that Sebastian teaches that there is always an encoder
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`associated with each of Sebastian’s data types, but that that encoder may not
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`always be installed, which is why a default filter exists. Ex. 1030 at 1:55-60, 4:9-
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`15 (explaining that the generic filter is used when a filter matching the format of
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`the data is not installed). Sebastian does not contain a teaching as to a scenario in
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`which its generic filter will be used when a data type for a data block is not
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`available to it. Indeed, Sebastian does not even contemplate a scenario in which a
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`data type is not available to its system. Dr. Creusere appears to have acknowledged
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`the same during his deposition.
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`So Sebastian does not have any discussion of a scenario in
`Q.
`which the data type for a data block is not available to it and what it
`would do in that scenario. True?
`A. Not to my recollection. Sebastian is a long patent. To be able to
`say that definitively, I would have to through line by line. But to my
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`- 19 -
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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
`
`
`recollection, that is not something that is – that is covered by
`Sebastian.
`Q. And column 4 in that same section you were looking at, and
`throughout Sebastian, the only scenario in which Sebastian teaches
`using its generic filter is when its system does not already have the
`desired or appropriate compression technique for a particular data
`type. True?
`A.
`Sebastian specifically states that if it doesn’t have a filter that
`matches the source’s data format, then it will use a generic filter. So
`that is as far as it goes on the subject. It doesn’t, to my recollection,
`state other scenarios.
`Ex. 2003 at 27:19-28:16 (emphasis added).
`
` Accordingly, I do not believe that Sebastian’s teachings would have
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`motivated a POSA to use a generic encoder where Franaszek had a data type that is
`
`not recognized by its system. While I understand that a POSA is not limited to
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`bodily incorporating one prior art reference into another, it is my opinion that a
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`POSA reading Sebastian would simply not have any basis for arriving at the idea
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`of using Sebastian’s generic filter to compress blocks with unrecognized data
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`types. Again, that is not a scenario Sebastian contemplates, and I have not seen any
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`other teaching or evidence in the Petitions or Dr. Creusere’s declarations to
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`indicate that a POSA would have arrived upon that idea.
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`- 20 -
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`

`

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`IPR2017-00176
`IPR2017-00806
`ZEGER DECLARATION
`
`
`VI. Conclusion
`
`In signing this declaration, I understand that the Declaration will be
`
`filed as evidence in contested cases before the Patent Trial and Appeal Board of
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`the United States Patent and Trademark Office. I acknowledge that I may be
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`subject to cross-examination in these cases and that cross examination will take
`
`place within the United States. If cross examination is required of me, I will appear
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`for cross examination within the United States during the time allotted for cross
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`examination.
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`
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`I declare that all statements made herein of my own knowledge are
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`true and that all statements made on information and belief are believed to be true;
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`and further that these statements were made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
`
`under Section 1001 of Title 18 of the United States Code, and that such willful
`
`false statements may jeopardize the validity of the ʼ506 Patent.
`
`
`
`
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`
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`Executed on September 22, 2017 in San Diego, California.
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`Respectfully submitted,
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`
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`Kenneth A. Zeger, Ph.D.
`- 21 -
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`

`

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`
`
`EXHIBIT A
`EXHIBIT A
`
`

`

`Kenneth A. Zeger
`
`- Professor and consultant -
`
`January 8, 2017
`
`Personal Data
`
`Email: zeger@ZundaLLC.com
`Web: http://ZundaLLC.com (company)
`http://zeger.us (university)
`Citizenship: USA
`
`Academic Degrees
`
`Ph.D (ECE):
`University of California, Santa Barbara (1990)
`M.A. (Mathematics): University of California, Santa Barbara (1989)
`S.M. (EECS):
`Massachusetts Institute of Technology (1984)
`S.B.
`(EECS):
`Massachusetts Institute of Technology (1984)
`
`Faculty Positions
`
`University of California, San Diego
`
`Professor of Electrical Engineering (1998-present)
`-
`- Associate Professor of Electrical Engineering (1996-1998)
`
`University of Illinois, Urbana-Champaign - Associate Professor of Electrical Engineering (1995-1996)
`- Assistant Professor of Electrical Engineering (1992-1995)
`
`University of Hawaii
`
`- Assistant Professor of Electrical Engineering (1990-1992)
`
`Honors and Awards
`
`• IEEE Fellow (2000)
`• NSF Presidential Young Investigator Award (1991)
`• United States Mathematical Olympiad (1980)
`
`Page 1 of 21
`
`CV of K. Zeger
`
`

`

`Consulting Experience
`
`January 8, 2017
`
`Clients:
`
`• Automatic Data Processing Co.
`• Hewlett-Packard Laboratories
`• U.S. Department of Defense
`• MITRE Co.
`• Nokia Telecommunications Inc.
`• Prominent Communications Inc. (Chair of Technical Advisory Board)
`• ViaSat Inc.
`• Xerox Co. Palo Alto Research Center
`• Zeger-Abrams Inc.
`• Zunda LLC (President)
`• Expert Witness in numerous patent infringement and trade secret litigations.
`
`Topics:
`
`• Image, fax, video, vision, television coding.
`• Speech coding and recognition, audio coding, telephony.
`• Electronic hardware devices: cell phones, printers, cameras, TV, computers, dongles, etc.
`• Protocols, networks, Internet, security, GPS.
`• Digital and wireless communications.
`• Error correcting codes.
`• Communication protocols.
`• Software: C, C++, C#, BASIC, Lisp, Fortran, Cobol, Algol, Pascal, Assembler, TMS320, Java,
`DSP, Verilog, HTML, JavaScript, Perl, Visual Basic, VHDL.
`• National security topics.
`
`Page 2 of 21
`
`CV of K. Zeger
`
`

`

`Professional Activities
`
`January 8, 2017
`
`• Board of Governors of IEEE Information Theory Society (1998-2000, 2005-2007, and 2008-
`2010)
`• Associate Editor At-Large of IEEE Transactions on Information Theory (1995-1998).
`• Steering Committee member of Fourth Workshop on Network Coding, Theory, and Applications
`(2007).
`• Co-organizer of: Third Workshop on Network Coding, Theory, and Applications, San Diego
`(2007).
`• Co-organizer of NSF Workshop on Joint Source-Channel Coding, San Diego, California. (1999)
`• Co-organizer of IEEE Information Theory Workshop, San Diego, California. (1998)
`• Co-organizer of Allerton Conference on Communication, Control, and Computing (1995)
`• Co-organizer of IEEE Communication Theory Workshop, Ojai, California. (1990)
`• International Advisory Committee of International Symposium on Spread Spectrum Techniques
`and Applications (ISSTA) (Taichung, Taiwan 2010)
`• Program Committee of Information Theory Workshop (ITW) (Jerusalem, Israel, 2015)
`• Program Committee member of International Symposium on Network Coding (NetCod) (Sydney,
`Australia, 2015)
`• Program Committee member of International Symposium on Network Coding (NetCod) (Bei-
`jing, China, 2011)
`• Program Committee member of Workshop on Network Coding, Theory, and Applications (Net-
`Cod) (Lausanne, Switzerland, 2009)
`• Program Committee member of Workshop on Network Coding, Theory, and Applications (Net-
`Cod) (Hong Kong, 2008)
`• Program Committee member of Workshop on Network Coding, Theory, and Applications (Net-
`Cod) (Boston, 2006)
`• Program Committee member of International Symposium on Information Theory (ISIT) (Toronto,
`Canada 2008)
`• Program Committee member of International Symposium on Information Theory (ISIT) (Ade-
`laide, Australia 2005)
`• Program Committee member of International Conference on Image Processing (ICIP) (Atlanta,
`Georgia, September 2006).
`• Program Committee member of International Conference on Image Processing (ICIP) (Genova,
`Italy, 2005)
`• Program Committee member of International Conference on Image Processing (ICIP) (Singapore
`2004)
`• Program Committee member of International Conference on Image Processing (ICIP) (Barcelona,
`Spain, 2003)
`• Program Committee member of International Symposium on Information Theory and its Appli-
`cations (Monterey, California 2016)
`• Program Committee member of International Symposium on Information Theory and its Appli-
`cations (Melbourne, Australia 2014)
`
`Page 3 of 21
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`CV of K. Zeger
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`

`

`January 8, 2017
`
`• Program Committee member of International Symposium on Information Theory and its Appli-
`catio