Case 1:16-cv-21761-KMM Document 42-1 Entered on FLSD Docket 01/02/2017 Page 1 of 9
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF FLORIDA
`
`CASE NO. 1:16-cv-21761-KMM
`
`
`PRISUA ENGINEERING CORP.,
`
`
`Plaintiff,
`
`
`v.
`
`SAMSUNG ELECTRONICS CO., LTD., et al.,
`
`
`Defendants.
`________________________________________/
`
`
`DECLARATION OF YOLANDA PRIETO, PH.D. IN SUPPORT OF
`PLAINTIFF PRISUA ENGINEERING CORP.’S OPENING
`CLAIM CONSTRUCTION BRIEF
`
`I, Yolanda Prieto, declare:
`
`
`
`
`1.
`
`I am the president of the named plaintiff in the above-captioned action, Prisua
`
`Engineering Corp. (“Prisua”). This declaration is made in support of Prisua’s opening claim
`
`construction brief, filed on even date herewith.
`
`2.
`
`I am the sole inventor of United States Patent No. 8,650,591 (the “‘591 patent”),
`
`titled “Video Enabled Digital Devices for Embedding User Data in Interactive Applications.” In
`
`2014 I formed Prisua to commercialize the invention disclosed and claimed in the ‘591 patent.
`
`Educational Background, Work Experience, Professional Awards and Recognition
`
`3.
`
`I received my Bachelor of Science in Electronics Engineering with an emphasis
`
`on Electronics and RF Circuit Design from the University of Miami in 1976, where I was
`
`awarded a full academic scholarship for my undergraduate studies.
`
`4.
`
`After graduation in 1976, I started my engineering career at Motorola Inc.
`
`(“Motorola”) as a Junior Engineer performing receiver and antenna evaluations. Shortly
`
`
`
`1
`
`
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF FLORIDA
`
`CASE NO. 1:16-cv-21761-KMM
`
`
`PRISUA ENGINEERING CORP.,
`
`
`Plaintiff,
`
`
`v.
`
`SAMSUNG ELECTRONICS CO., LTD., et al.,
`
`
`Defendants.
`________________________________________/
`
`
`DECLARATION OF YOLANDA PRIETO, PH.D. IN SUPPORT OF
`PLAINTIFF PRISUA ENGINEERING CORP.’S OPENING
`CLAIM CONSTRUCTION BRIEF
`
`I, Yolanda Prieto, declare:
`
`
`
`
`1.
`
`I am the president of the named plaintiff in the above-captioned action, Prisua
`
`Engineering Corp. (“Prisua”). This declaration is made in support of Prisua’s opening claim
`
`construction brief, filed on even date herewith.
`
`2.
`
`I am the sole inventor of United States Patent No. 8,650,591 (the “‘591 patent”),
`
`titled “Video Enabled Digital Devices for Embedding User Data in Interactive Applications.” In
`
`2014 I formed Prisua to commercialize the invention disclosed and claimed in the ‘591 patent.
`
`Educational Background, Work Experience, Professional Awards and Recognition
`
`3.
`
`I received my Bachelor of Science in Electronics Engineering with an emphasis
`
`on Electronics and RF Circuit Design from the University of Miami in 1976, where I was
`
`awarded a full academic scholarship for my undergraduate studies.
`
`4.
`
`After graduation in 1976, I started my engineering career at Motorola Inc.
`
`(“Motorola”) as a Junior Engineer performing receiver and antenna evaluations. Shortly
`
`
`
`1
`
`
`
`Case 1:16-cv-21761-KMM Document 42-1 Entered on FLSD Docket 01/02/2017 Page 2 of 9
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`thereafter, I was promoted to a design team that worked on analog discrete RF circuits and front
`
`end circuits for pagers.
`
`5.
`
`While at Motorola, I continued my studies at the University of Miami and in 1978
`
`I completed the degree of Master of Science in Electrical Engineering with an emphasis on
`
`Computer Architectures and Digital Design.
`
`6.
`
`After completing my Master of Science in Electrical Engineering degree, I joined
`
`the Motorola Integrated Circuit (“IC”) design team where I started a 15-year IC design career,
`
`leading to very successful developments in the designs of RF, baseband, audio, and micro-
`
`processor support chips used in domestic and international paging products as well as two-way
`
`radios.
`
`7.
`
`Some of my most memorable design and development work at Motorola
`
`included:
`
`a. Acting as project lead of a Gallium Arsenide (“GaAs”) front end IC. As part
`
`of my lead role, I designed low noise and low power GaAs devices for the
`
`front end IC. I also designed high intercept point GaAs broadband RF
`
`amplifiers and double balanced mixers for the VHF, UHF, and 800/900MHz
`
`bands. This IC successfully shipped with very high yields in various
`
`generations of Motorola’s two-way products.
`
`b. The design of significant sections and improved internal-external speaker
`
`isolation of an audio IC which successfully shipped with very high
`
`performance and high yield in Motorola’s two-way products.
`
`c. The design of external Voltage Controlled Oscillators (VCO) and buffer
`
`circuitry with superior phase noise performance used in the receiver of a two-
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`
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`2
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`Case 1:16-cv-21761-KMM Document 42-1 Entered on FLSD Docket 01/02/2017 Page 3 of 9
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`way product. I was responsible for the complete design, board layout, and
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`implementation of these circuits. I coordinated factory testing and production
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`support leading to successful VCO/buffer shipping.
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`d. I was the designer of a 455KHz IC for an NTT/Docomo (Japan’s leading
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`wireless carrier) pager, leading to successful integration and implementation
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`of several patented circuits, which eliminated the quadrature coil and enabled
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`a DC-coupled limiter circuitry.
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`e. I designed low-power and low-voltage regulator circuits for paging receivers.
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`f. I designed a Programmable Logic Array to numerically decode the volume
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`control setting and display driver for a pager.
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`g. I designed the hardware and software (MC6800 Assembly code) for a code
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`plug programmer.
`
`8.
`
`During this stage of my career I also trained and mentored engineers in the RF
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`discipline.
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`9.
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`In 1992, I was selected as one of a few employees for the Motorola Distinguished
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`Employee Ph.D. Program. Through the program I enrolled at the University of Miami graduate
`
`school and in 1997 received a Ph.D. in Digital Signal Processing with emphasis in Image
`
`Processing and Data Compression.
`
`10.
`
`In 1997, after completing my Ph.D. in Imaging Processing, I became very active
`
`in promoting wireless imaging and video, cooperating worldwide with Motorola teams in
`
`Basingstoke, Geneva, Munich, Tel-Aviv, Phoenix, Austin, and Schaumburg. I created a
`
`multimedia technical team, and worked closely with Motorola multimedia development teams
`
`and research teams worldwide, participating and coordinating internal training and technical
`
`
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`3
`
`
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`Case 1:16-cv-21761-KMM Document 42-1 Entered on FLSD Docket 01/02/2017 Page 4 of 9
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`seminars across the global Motorola engineering teams to increase awareness and promote
`
`knowledge in what was then a developing technology.
`
`11.
`
`Under my technical leadership, the first completely digital wireless image transfer
`
`prototype from image capture to digital display was designed and developed using JPEG and
`
`JPEG2000 compression. This solution was a stepping stone to Motorola’s wireless imaging
`
`products.
`
`12.
`
`Due to my efforts and expertise in various areas in multimedia, particularly in
`
`system-on-chip (“SoC”) architectural implementation and analysis, imaging, video, speech and
`
`audio codecs, pre- and post-processing, I was selected to be the chairperson of the multimedia
`
`subcommittee for the Radio Steering Committee. This committee served as a forum to gather
`
`Motorola’s worldwide experts in multimedia research and development to discuss state-of-the-art
`
`and future developments. I led this committee for approximately six years, until 2004, when I
`
`joined Freescale Semiconductor, Inc., (“Freescale”) after the divestiture of Motorola’s
`
`Semiconductor Products Division, now NXP Semiconductors.
`
`13.
`
`Thereafter I participated, as a principal member, in representing Motorola and
`
`Freescale in the JPEG2000, MPEG and JVT-Experts Standards (H.264 and SVC).
`
`14.
`
`I then led a team of advanced development engineers responsible for the
`
`improved efficiency of speech and audio codecs.
`
`15.
`
`In 2004, the Wireless Integration Technology Center at Motorola, where I was a
`
`Distinguished Member of the Technical Staff, became part of Freescale. I then continued to lead
`
`multimedia solution efforts. In that role, I acted as the technical lead for a group of video codec
`
`researchers and algorithm developers
`
`in
`
`the Applied Research
`
`team developing and
`
`implementing algorithms form MPEG-4, H.264, and SVC, mostly in the areas of motion
`
`
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`4
`
`
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`Case 1:16-cv-21761-KMM Document 42-1 Entered on FLSD Docket 01/02/2017 Page 5 of 9
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`estimation and compensation, rate allocation, de-blocking, and overall implementation efficiency
`
`improvements for these codecs.
`
`16.
`
`I became the technical leader of Freescale’s internal image and video capture
`
`solutions and worked closely with a research and development team designing image sensors,
`
`pre- and post-processing hardware and software implementations such as noise reduction,
`
`contrast enhancement, color space conversion, image rotation, image scaling, de-blocking, etc.
`
`17.
`
` In my technical position at Freescale, I interfaced with other industry participants
`
`(including competitors) that developed audio and video codecs architectures, image signal
`
`processing hardware and software, cameras, displays, security, graphics, and other multimedia
`
`solutions. My interactions with these industry participants gauged possible integration of
`
`competing products into Freescale’s SoCs, or took the form of discussions of industry
`
`multimedia technology roadmap, whose development I was responsible for at Freescale.
`
`18.
`
`Additionally I performed technical evaluations on the intellectual property
`
`portfolios of competitors or industry participants that Freescale considered as potential joint
`
`venture partners or for acquisition.
`
`19.
`
`I was consulted and recognized for my multimedia technical expertise throughout
`
`Freescale. I very often led technical discussions and presentations in multimedia both internally
`
`and with external companies. I also interfaced with universities (e.g., University of Miami and
`
`the University of Bologna, Italy) and research institutes (e.g., IMEC in Belgium) on various
`
`multimedia technology subjects.
`
`20.
`
`Locally, I volunteered to lead and assist undergraduate and graduate students in
`
`their multimedia-related senior projects. Internationally, I served as Freescale’s technical lead
`
`
`
`5
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`
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`Case 1:16-cv-21761-KMM Document 42-1 Entered on FLSD Docket 01/02/2017 Page 6 of 9
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`for a research project on energy conservation targeting LCD drivers, and reconfigurable
`
`multimedia engines.
`
`21.
`
`Additionally I served as multimedia expert in Freescale’s Patent Committee,
`
`where I was responsible for evaluating and recommending internal inventions for potential
`
`patentability and patent prosecution.
`
`22.
`
`During the last 6 years, I have been working as a technology analyst, in a
`
`consulting capacity.
`
`23.
`
`Throughout my professional and educational experience I have been recognized
`
`on a number of occassions for outstanding achievements. These include:
`
`a. Appointed Member of Motorola’s Science Advisory Board Associate, a
`
`highly distinguished membership granted to top worldwide engineers at
`
`Motorola, who through their development and research achievements
`
`significantly contributed
`
`to
`
`the advancement of Motorola’s
`
`technical
`
`leadership.
`
`b. Awarded the Motorola Engineering Award for the Design and Bias
`
`Methodology for GaAs metal–semiconductor field-effect transistor devices
`
`yielding optimal intermodulation performance.
`
`c. Distinguished Member of the Technical Staff at Motorola and Freescale
`
`Semiconductor.
`
`d. Principal Member representing Motorola and Freescale Semiconductor at
`
`JPEG-2000, MPEG and JVT-Experts standards group (video codecs
`
`standards).
`
`
`
`6
`
`
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`Case 1:16-cv-21761-KMM Document 42-1 Entered on FLSD Docket 01/02/2017 Page 7 of 9
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`e. Chair, Motorola’s Multimedia Subcommittee as part of the Radio Architecture
`
`Steering Committee (RASC) (‘98-2004). RASC is a worldwide Motorola
`
`technical steering committee responsible for advancing future and state-of-
`
`the-art technology at Motorola.
`
`f. Awarded Motorola’s Distinguished Employee Ph.D. Program Grant.
`
`g. Silver Quill Fellow Author Award recipient for outstanding contributions to
`
`the publications objectives of the Motorola Communications Enterprise.
`
`h. University of Miami Alumna of Distinction Award.
`
`i. Member of the University of Miami Industry Advisory Board.
`
`j. Member of IEEE.
`
`k. Member, Tau Beta Pi Honor Society and Association of Latin Engineers.
`
`The ‘591 Patent
`
`24.
`
`After leaving Freescale, in late 2009, I took a few months off after so many years
`
`in industry.
`
`25.
`
`During these few months off I attended – along with a journalist friend - some
`
`conferences held in Miami by a group composed mostly of media personalities, including many
`
`Miami Herald (the “Herald”) journalists and personnel.
`
`26.
`
`The idea for the ‘591 patent came to me during one of the conferences I attended
`
`where a former publisher for the Herald, who had since become CEO of the Knight
`
`Foundation, gave a presentation on media content.
`
`27.
`
`As I listened intently to the presentation and subsequent discussion, I noticed that
`
`people, in general, seemed interested in becoming more noticeable, the real protagonists in their
`
`own social circles. This was cemented in my mind by the overwhelming evidence presented
`
`
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`7
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`Case 1:16-cv-21761-KMM Document 42-1 Entered on FLSD Docket 01/02/2017 Page 8 of 9
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`showing how camera phones were becoming not only well accepted, but the tool in
`
`communications and social interactions.
`
`28.
`
`I then began to think about the use of a person’s own media, their faces and
`
`expressions, substituted into their favorite photograph, or TV show or even their favorite video
`
`game.
`
`29.
`
` By substituting themselves into the media content around them, every day
`
`people could interact more robustly with media, build better brand identity, and enhance user
`
`experience, but more importantly they could also feel more at the center of all the stories going
`
`on around them.
`
`30. My image signal processing and wireless video transmission experience led me
`
`then to think more about allowing a smartphone camera user to capture images or a sequence of
`
`images and substitute certain sections of these captured images into some pre-existing or
`
`previously captured image. But the idea certainly was not limited to smart phones. This is
`
`clearly depicted in Fig. 1 of the ‘591 patent, which reveals a number of various embodiments.
`
`31.
`
`There are various technical areas involved in the ‘591 patent. These include
`
`image capture, pre-processing, image display, memory storage, hardware or software processing,
`
`object detection and recognition including face detection, and display data entry. I drew upon
`
`my experience in each of these fields when conceptualizing the invention.
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`8
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`Case 1:16-cv-21761-KMM Document 42-1 Entered on FLSD Docket 01/02/2017 Page 9 of 9
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