`
`UNITED STATES PATENT AND TRADEMARK OFFICE
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`______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`______________
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`UBISOFT, INC. AND SQUARE ENIX, INC.,
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`Petitioners,
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`v.
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`UNILOC USA, INC. AND UNILOC LUXEMBOURG S.A.
`Patent Owners
`
`______________
`
`Case IPR2017-1291
`U.S. Patent 6,728,766
`______________
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`DECLARATION OF DR. VAL DIEULIIS
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`
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`July 25, 2017
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`Ubisoft v. Uniloc, IPR2017-01291
`Uniloc's Exhibit 2001, Page 1
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`TABLE OF CONTENTS
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`1. INTRODUCTION ......................................................................................... 3
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`2. QUALIFICATIONS ...................................................................................... 4
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`3. COMPENSATION, TESTIMONY, AND PUBLICATIONS ..................... 7
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`4. INFORMATION CONSIDERED ................................................................ 8
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`5. DEFENDANTS’ LEGAL POSITION IN DISTRICT COURT .................. 9
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`6. OLSEN’S “SECURITY EQUIVALENCY CHECK”
`DETERMINES WHETHER A USER IS AUTHORIZED TO
`USE AN APPLICATION .............................................................................10
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`IPR2017-01291: Declaration of Dr. Val DiEuliis
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`Page 2 of 12
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`Ubisoft v. Uniloc, IPR2017-01291
`Uniloc's Exhibit 2001, Page 2
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`I, Dr. Val DiEuliis, hereby declare and state as follows:
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`1.
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`1.
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`Introduction
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`My name is Val DiEuliis, and I have been retained by
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`Uniloc, USA, Inc., and Uniloc Luxembourg S.A. (“Uniloc” or the “Patent
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`Owner”). My client Uniloc and its associated counsel, Etheridge Law
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`Group, have asked me to study U.S. Patent No. 6,728,766 (“the ’766
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`patent”), the Petition, and the proffered prior art in this case, in addition
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`to other relevant documents. I document my findings in this declaration.
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`2.
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`I have concluded that U.S. Patent No. 5,758,069 (Olsen;
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`EX1002) does not disclose any distinction between its “security
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`equivalency check” and the function of “determination that the user is
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`authorized to access the selected application program.” And I understand
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`that the Petitioners took the position in the district court proceedings that
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`the claim limitation “license availability” “disclaims” or cannot be met
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`by a reference that only discloses the function of “determination that the
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`user is authorized to access the selected application program.” Therefore,
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`I conclude that Olsen cannot meet the claim limitation “determining the
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`license availability for the selected one of the plurality of application
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`programs for the user based on the maintained license.”
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`IPR2017-01291: Declaration of Dr. Val DiEuliis
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`Page 3 of 12
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`Ubisoft v. Uniloc, IPR2017-01291
`Uniloc's Exhibit 2001, Page 3
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`3.
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`The limited scope of my opinions and analysis in this
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`declaration do not imply that I may not later express other opinions or
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`report other results from other investigations concerning other issues
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`raised by the Petitioners or their experts in this IPR.
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`2.
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`4.
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`Qualifications
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`I am an electrical engineer with over 45 years of experience
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`developing, programming, and analyzing computer algorithms and
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`software. I am experienced with and able to create, read, and interpret
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`firmware and software in C, C++, Java, assembly language, HTML, and
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`other computer programming languages. I have served as an expert
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`witness in multiple cases for which I analyzed computer source code in
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`various languages and testified at ITC hearings and two jury trials
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`concerning my results.
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`5.
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`During my career, I have developed and managed projects
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`for various applications, including sensors, controls, communications,
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`user interfaces, device firmware, handheld devices, medical devices and
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`systems, and test systems for optical and magnetic disk systems.
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`6.
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`I have designed, developed, and implemented hardware and
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`software for digital communication networks, including factory
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`IPR2017-01291: Declaration of Dr. Val DiEuliis
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`Page 4 of 12
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`Ubisoft v. Uniloc, IPR2017-01291
`Uniloc's Exhibit 2001, Page 4
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`networks, document capture and distribution, and communications links
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`for various applications. See DiEuliis CV (e.g., Website Development,
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`Industrial Valve Position Sensor, Condition-Based Maintenance System,
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`Avionics Environmental Monitor, Radio Frequency Billboard Network,
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`Wireless Bar Code System for Hospitals, ISA Board for 4-Port RS422
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`Serial Communications Multiplexer). See also Id. at 3 (Digital Document
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`Storage Technology).
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`7.
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`As a graduate student at the University of Illinois at
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`Urbana-Champaign, I obtained extensive training in the complexity of
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`algorithms; the complexity of databases from an information-theoretic
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`point-of-view; information theory; combinatorics and combinatorial
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`algorithms; and the mathematics and algorithms of error correcting
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`codes, a field closely related to cryptography. In addition, as a part of my
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`graduate research, I created and developed heuristic algorithms and wrote
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`software to synthesize non-linear codes for optimizing the spectra of
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`coded digital communications signals.
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`8.
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`I received the Ph.D. and M.S. degrees in electrical
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`engineering from the University of Illinois at Urbana-Champaign in 1978
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`and 1976, respectively, and the B.S. degree in electrical engineering from
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`the University of Notre Dame in 1972. I am a Registered Professional
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`IPR2017-01291: Declaration of Dr. Val DiEuliis
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`Ubisoft v. Uniloc, IPR2017-01291
`Uniloc's Exhibit 2001, Page 5
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`Engineer (electrical) in the State of Minnesota, and a Life Senior Member
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`of the Institute of Electrical and Electronics Engineers (IEEE).
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`Additionally, I am a co-inventor of two patents.
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`9.
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`I have been an independent engineering consultant, doing
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`business as Electronics Consultants, since 1984. My clients have
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`included 3M, Honeywell, Imation Corporation, and Seagate Technology,
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`among others. Prior to that, I worked as a research engineer for the 3M
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`Company in St. Paul, Minnesota for five years. In addition, before my
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`graduate studies, I worked as an electrical engineer in the U. S. Army
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`with the U.S. Army Security Agency for two years, during which time I
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`held a Top Secret W/Crypto and SI Access security clearance.
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`10.
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`As an adjunct instructor at the University of Saint Thomas in
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`St. Paul, Minnesota, I developed and presented a lecture on classical
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`linear control theory for graduate students; developed and taught a
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`graduate course on computer networks; and taught an undergraduate
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`analog and digital electronics course to mechanical engineering students.
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`11.
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`This and other information about my background is included
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`in my CV, which attached to this declaration as Attachment A.
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`IPR2017-01291: Declaration of Dr. Val DiEuliis
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`Page 6 of 12
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`Ubisoft v. Uniloc, IPR2017-01291
`Uniloc's Exhibit 2001, Page 6
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`3.
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`12.
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`Compensation, Testimony, and Publications
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`I am being paid $440 per hour for the time I spend working
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`on this matter. My compensation is not contingent on my performance,
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`the outcome of this IPR, or any issues involved in or related to this IPR.
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`13.
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`During the past four years, I have testified at trial, hearing,
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`or deposition in the following cases:
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`• Terremark North America, LLC, et al. v. Joao Control &
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`Monitoring LLC.; US PTO Inter Partes Review IPR2015-01466;
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`Joao Control & Monitoring on behalf of Joao Control &
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`Monitoring; 2016. I testified at a deposition.
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`• Kofax, Inc. v. Uniloc USA, Inc., et al.; US PTO Inter Partes
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`Review IPR2015-01207; Uniloc USA on behalf of Uniloc USA;
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`2016. I testified at a deposition.
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`• Sega of America, Inc. et al. v. Uniloc USA et al.; USPTO Inter
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`Partes Review; IPR2014-01453; Uniloc USA on behalf of Uniloc
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`USA, 2015. I testified at a deposition.
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`• Uniloc USA et al. v. Activision Blizzard et al.; United States
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`District Court for the Eastern District of Texas (Tyler); Civil
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`Action No. 6:13-cv-00256-LED; and Uniloc USA v. Electronic
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`Arts, Inc.; Civil Action No. 6:13-cv-259-LED; Nelson Bumgardner
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`Casto and Carter, Scholer, Arnett, Hamada, and Mockler on behalf
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`of Uniloc USA et al.; 2013-2014. I testified at three depositions
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`and a jury trial.
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`IPR2017-01291: Declaration of Dr. Val DiEuliis
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`Page 7 of 12
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`Ubisoft v. Uniloc, IPR2017-01291
`Uniloc's Exhibit 2001, Page 7
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`• In the Matter of Certain Optical Disc Drives, Components thereof,
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`and Products Containing Same; U.S.I.T.C. Investigation No. 337-
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`TA-897; Optical Devices, LLC v. Lenovo et al.; O’Melveny &
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`Myers on behalf of Samsung, Kenyon & Kenyon on behalf of
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`Lenovo, Greenberg Traurig on behalf of LG Electronics,
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`McDermott Will & Emery on behalf of Nintendo and Panasonic,
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`DLA Piper on behalf of Toshiba, and Quinn Emanuel Urquhart &
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`Sullivan on behalf of MediaTek; 2013-2014. I testified at a
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`deposition.
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`• Taser International, Inc. v. Karbon Arms, LLC; United States
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`District Court for the District of Delaware; Civil Action No. 1:11-
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`cv-426-RGA; Smith, Gambrell & Russell, LLP, on behalf of
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`Karbon Arms, 2013. I testified at a deposition.
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`14.
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`4.
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`15.
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`I have had no publications in the past 10 years.
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`Information Considered
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`In order to arrive at my opinions, I have reviewed and
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`considered the materials listed below:
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`• Petition for Inter Partes Review of U.S. Patent No. 6,728,766, and
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`exhibits, Case No. IPR2017-01291, April 24, 2017 [Pet.]
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`• U.S. Patent No. 6,728,766 (“’766”) [EX1001], and its prosecution
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`history [EX1005]
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`• U.S. Patent No. 5,758,069(“Olsen”) [EX1002]
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`IPR2017-01291: Declaration of Dr. Val DiEuliis
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`Page 8 of 12
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`Ubisoft v. Uniloc, IPR2017-01291
`Uniloc's Exhibit 2001, Page 8
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`• Defendants’ Responsive Claim Construction Brief, Uniloc USA,
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`Inc., et al v ADP,LLC, et al, US District Court for the Eastern
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`District of Texas (Marshall Division), Docket #150 [EX2002]
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`5.
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`16.
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`Defendants’ Legal Position in District Court
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`I understand there are certain legal rules, standards, or
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`requirements that I accept for the purpose of my analysis of the opinions
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`and conclusions set forth in this declaration.
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`17.
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`I understand that in related district court proceedings, the
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`Defendants took the position, and represented to the district court, that
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`there is a “disclaimer” during the prosecution of the ’466 patent that
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`“license availability is “distinct from any determination that the user is
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`authorized to access the selected application program”. EX2002 at 23;
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`fn. 11; see also Id. at 26 (“Applicants’ attempt here to distinguish the
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`claimed invention from the prior art constitutes a clear disclaimer of
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`claim scope.”).
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`18.
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`I understand that the above “disclaimer,” which I assume to
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`be true for the purposes of this declaration, means that the claim
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`limitation “license availability” cannot be met by any alleged prior art
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`reference that merely discloses a “determination that the user is
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`authorized to access the selected application program.”
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`IPR2017-01291: Declaration of Dr. Val DiEuliis
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`Page 9 of 12
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`Ubisoft v. Uniloc, IPR2017-01291
`Uniloc's Exhibit 2001, Page 9
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`6.
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`19.
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`Olsen’s “security equivalency check” determines
`whether a user is authorized to use an application
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`The Petitioners argue that the claim limitation “determining
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`the license availability for the selected one of the plurality of application
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`programs for the user based on the maintained license” is met by Olsen’s
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`disclosure of a “‘security equivalency check’ to determine whether the
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`requesting user is among those assigned to the license certificate.”
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`Pet. 16. However, the “security equivalency check” disclosed by Olsen
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`and cited by the Petitioners is a determination that the user is authorized
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`to access the selected application program. As I reported above in § 5, the
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`Petitioners have taken the position that “license availability” is distinct
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`from “authorization.”
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`20.
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`The “security equivalency check” is mentioned only once in
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`Olsen, as in the following:
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`If an assignment exists on the license certificate, it
`performs a security equivalency check to
`determine whether the requesting client 106 is
`among those assigned to the license certificate
`(step 828).
`(EX1002 at 12:14-17; FIG. 8B) (Emphasis added.)
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`IPR2017-01291: Declaration of Dr. Val DiEuliis
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`Page 10 of 12
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`Ubisoft v. Uniloc, IPR2017-01291
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`21.
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`A POSITA would have understood that the passage above
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`explains that the “security equivalency check” merely determines
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`whether the requesting client is authorized, but not whether the license is
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`available.
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`22.
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`The Petitioners point to various passages in Olsen for
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`support, but after having checked their citations, which includes the
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`passage reproduced above in ¶ 20, I find that none of them controvert the
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`fact that the “security equivalency check” determines authorization only.
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`23.
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`After my review of Olsen and the Petition, I did not find
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`anything to suggest that there is any distinction between Olsen’s
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`“security equivalency check” and the function of “determination that the
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`user is authorized to access the selected application program.”
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`24.
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`Therefore, given Petitioners’ position in the district court
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`proceedings that the “disclaimer” regarding the claim limitation “license
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`availability” cannot be met by a reference that only discloses a
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`“determination that the user is authorized to access the selected
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`application program” (see § 5 above), and given my review of Olsen (see
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`¶¶ 20-23 above), Olsen’s “security equivalence check” cannot meet the
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`claim limitation “determining the license availability for the selected one
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`of the plurality of application programs for the user based on the
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`IPR2017-01291: Declaration of Dr. Val DiEuliis
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`Page 11 of 12
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`Ubisoft v. Uniloc, IPR2017-01291
`Uniloc's Exhibit 2001, Page 11
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`maintained license” because there is no distinction between Olsen’s
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`“security equivalency check” and the “determination that the user is
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`authorized to access the selected application program” that Petitioners’
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`represented to the district court is “disclaimed.”
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` I
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` declare that this declaration was executed in Saint Paul,
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`Minnesota on July 25, 2017, that all statements made are, to my
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`knowledge, true, and all statements made on information and belief are
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`believed to be true, and these statements were made knowing that willful
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`false statements so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code.
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`
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`Val DiEuliis
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`IPR2017-01291: Declaration of Dr. Val DiEuliis
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`Page 12 of 12
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`Ubisoft v. Uniloc, IPR2017-01291
`Uniloc's Exhibit 2001, Page 12
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`ATTACHMENT A
`ATTACHMENT A
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`Ubisoft v. Uniloc, IPR2017-01291
`Uniloc's Exhibit 2001, Page 13
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`Ubisoft v. Uniloc, IPR2017-01291
`Uniloc's Exhibit 2001, Page 13
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`Val DiEuliis, Ph.D.
`
`Electronics Consultants
`1033 Fairmount Avenue
`St. Paul, MN 55105
`
`[651] 297-8674
`valdieuliis@electronicsconsultants.com
`www.electronicsconsultants.com
`
` I
`
` am an electrical engineer with over 40 years of experience in the electronics industry. As an independent
`consultant since 1984, I have served a diverse clientele having equally diverse needs. I have worked for
`large corporations, small companies, startup companies, and individual entrepreneurs. I have managed
`projects, studied product and system feasibility, assessed technology, advised executive management,
`mentored young engineers, and provided litigation support to attorneys and their clients. I have developed
`products, systems, and devices for industrial, consumer, commercial, military, and medical applications. I
`have performed research and development in corporate and academic laboratories, and worked with
`testing, sustaining engineering, and manufacturing organizations. I have also taught graduate and
`undergraduate courses in electronics, computer networks, and control theory.
`
` I
`
` have developed software, firmware, and electronic hardware including analog circuits, digital circuits, and
`electronic microcontroller-based devices, for a variety of applications, including light detection, sensing
`industrial valve position using magneto-resistive devices, diagnosing under-the-hood automotive sensors,
`detecting phosphorescence, measuring the height of river water, charging batteries for an orthopedic tool,
`and testing furnace igniters. I've designed servo systems, data detectors, signal processors, and test
`systems for magnetic disk and CD, DVD, Magneto-Optical (MO), and WORM optical disc technologies, and
`I've designed computer peripheral devices for PC, EISA, VME, and proprietary data busses. I have
`evaluated product design and performance and have characterized electronic and electro-mechanical
`components for performance and failure. The table below highlights many of the skills and areas of
`expertise that I've applied to these projects.
`
`
`EXPERTISE
`
` Digital Circuit Design
` Digital Signal Processing (DSP)
` Electro-Mechanical Devices
` Embedded Systems
` FPGA Development
`
`Instruments and Measurements
` Laser Optics
` Low-Power Electronics Design
` Magnetic Disk Technology
`
` 
`
` Algorithms
` Analog Circuit Design
` Assembly Language
` C/C++, Java, Visual Basic, HTML, Pascal,
`Fortran
` Computer System Peripheral Design
` Control Systems
` Data Acquisition
` Data Communications
` Data Storage
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`
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`
`
`Resume of Val DiEuliis, Ph.D.
`Printed: 07/25/17
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`Page 1 of 15
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`Ubisoft v. Uniloc, IPR2017-01291
`Uniloc's Exhibit 2001, Page 14
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`Val DiEuliis, Ph.D.
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`EMPLOYMENT HISTORY
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`1984–Present
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`Electronics Consultants
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`
`
`
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`
`
`Owner/Consultant
`
`For descriptions of selected consulting projects, see Consulting Projects below. A partial,
`representative list of clients is provided in the following:
`
`
`3M
`Carter, Scholer, Arnett, Hamada & Mockler
`Convolve, Inc.
`Greenberg Traurig
`Honeywell
`Imation Corporation
`Kenyon & Kenyon
`Lenovo
`LG Electronics
`Karbon Arms
`McDermott Will & Emery
`McKool Smith
`MediaTek
`
`
`Nelson Bumgardner Casto
`Nintendo
`O’Melveny & Myers
`Panasonic
`Quinn Emanuel Urquhart & Sullivan
`Robins, Kaplan, Miller & Ciresi
`Samsung
`Seagate Technology
`Smith, Gambrell & Russell
`Toshiba
`Uniloc
`Weil Gotshal & Manges
`Wilson Sonsini Goodrich & Rosati
`
`
`1989–2001
`
`
`
`
`University of Saint Thomas
`
`Adjunct Instructor
`
`Developed and taught a course on computer networks.
`Developed and presented a lecture on classical linear control theory.
`Taught an undergraduate analog and digital electronics course comprising lecture and laboratory.
`
`
`1979–1984
`
`3M
`
`
`
`
`
`
`
`Research Specialist
`
`Optical Disk Technology
` Developed a digital audio recording and playback system for use with WORM (write-once-
`read-many) optical disks. I designed the analog front-end circuitry, the phase-locked loop
`timing recovery circuit, the modulation/demodulation circuitry, and the error correcting
`encoding and decoding logic.
` Developed servo systems for focusing and tracking an optical disk on an experimental
`recording and playback system. I characterized the sensors and actuators, performed
`theoretical modeling of the system, and designed the compensation for stabilizing the servos.
`
`Magnetic Disk Drive Development and Manufacturing
` Characterized the servo signals, modeled the positioning actuator, designed the
`compensation, and refined the electronic circuitry for the positioning servo in an 8”
`Winchester disk drive product.
` Characterized and designed portions of the read channel for the disk drive.
` Solved problems in the manufacturing plant, developed assembly and test procedures, and
`created manufacturing documentation.
`
`
`CV of Val DiEuliis, Ph.D.
`Printed: 07/25/17
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`Page 2 of 15
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`Ubisoft v. Uniloc, IPR2017-01291
`Uniloc's Exhibit 2001, Page 15
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`
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`1972–1974
`
`
`
`
`
`
`
`
`2003–Present
`
`
`
`Val DiEuliis, Ph.D.
`
`Digital Document Storage Technology
` Surveyed a large insurance company’s operations, wrote the functional specification, and
`designed the architecture for a digital document capture, storage, and retrieval system.
` Designed and developed the main processor board with a Motorola 68000 microprocessor.
`This design, which incorporated programmable logic, included a dual-access, time-
`multiplexed RAM buffer memory.
` Designed and developed a peripheral board that interfaced to a computer-output-microfiche
`(COM) machine.
`
`U.S. Army
`
`Specialist 4
`
`I was an electrical engineer while stationed at an Army Security Agency maintenance depot. I
`performed RF measurements on radio frequency receiving systems, assessed systems and
`instrumentation, and designed an on-line antenna integrity test system for a field operations site.
`
`CONSULTING PROJECTS
`
`Litigation Support
`
`I have provided litigation support services to attorneys and their clients:
` Testified in patent infringement cases concerning CD and DVD optical disk technology,
`software and algorithms, two-dimensional bar codes and systems, vibrating conveyor
`systems, CMOS integrated circuits, hard disk drive technology, wireless medical sensors,
`portable entertainment devices, and stun guns.
` Testified in depositions, International Trade Commission hearings, a jury trial, a Markman
`hearing, and a hearing concerning an injunction resulting from a patent litigation.
` Produced declarations and testified in depositions for Inter Partes Reviews
` Analyzed analog and digital circuits and systems.
` Analyzed microprocessor and digital signal processor source code, Verilog source code,
`controller chip specifications, and products.
` Analyzed hardware and software source code for servo control systems, microprocessor and
`microcontroller-based devices, image analysis, and mathematical algorithms
` Produced expert reports, declarations, and witness statements.
` Performed infringement and validity analyses.
` Consulted on prior art, patent validity and infringement contentions, and claim construction.
` Developed a technology tutorial and presented it in court.
`
`
`2006–Present
`
`Patent Analysis
`
`
`
`
`
`
`I have reviewed and analyzed patents for their technical and investment value:
` Analog and digital circuits and systems
` Data storage devices
` Magnetic and optical storage technology, systems, and devices
` Control systems
` Electronic devices
`
`
`
`
`CV of Val DiEuliis, Ph.D.
`Printed: 07/25/17
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`
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`Page 3 of 15
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`Ubisoft v. Uniloc, IPR2017-01291
`Uniloc's Exhibit 2001, Page 16
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`
`2009-Present
`
`Website Development
`
`Val DiEuliis, Ph.D.
`
`
`
`
`2012
`
`
`
`
`2010
`
`
`
`
`2010
`
`
`
`
`2008-2009
`
`
`
`
`2008
`
`
`
`
`
`
`An architect hired me to create two websites for his nationwide training courses for architects
`seeking LEED accreditation and training in managing an architecture practice. I designed,
`developed, and published his sites, which includes course and biographical information, upcoming
`dates and locations, and an ecommerce page for prospective buyers.
`
`Component Characterization – An Inductor for a Wireless Battery Charger
`
`A new company with a novel product for human vision correction asked me to test and characterize
`a component used to pick up the magnetic field in its non-contact battery charger circuit. The
`contract manufacturer of the electronics did not specify the component and a second source for it
`could be found. I tested the part (an inductor), created a SPICE model for it based on my test data,
`and identified its type, size, shape, wire gauge, and wire material based my microscope inspection.
`I delivered a detailed report that specified the component so that it may be purchased from multiple
`vendors.
`
`Integrated Circuit Replacement for a Medical Device
`
`A medical device company manufactures two printed circuit boards that incorporate two
`components—an FPGA and a Flash memory chip—that have been discontinued by their suppliers.
`I was hired to upgrade these printed circuit boards to replace the obsolete components. I identified
`pin-for-pin replacements for each part, purchased the parts, produced the FPGA’s programming
`information, and updated my client’s documentation.
`
`Design Review for an Automatic Fragrance Dispenser
`
`A home products company hired me to analyze a prototype battery-powered automated fragrance
`dispenser for compliance with safety requirements. Specifically, my client wanted to know whether
`a fuse was required in their circuit. I analyzed the UL 283 specification with respect to my client’s
`product, tested the prototype for heat dissipation, and determined the design required no fuse and
`appears to be compliant with UL requirements.
`
`Programmable Precision Current Source
`
`A company that manufactures industrial control valves hired me to develop a special purpose
`instrument—a precision programmable current source—for use in testing valve positioners in its
`manufacturing process. This is a handheld device with a custom user interface panel with an LED
`display and user pushbuttons for current selection.
` Designed a PIC microcontroller circuit and developed the printed circuit board
` Designed and developed the user interface panel and the packaging (enclosure)
` Designed and developed the microcontroller firmware
`
`Helicopter Camera Mount Controls
`
`A company that develops and installs customized modifications to helicopters and other vehicles
`hired me to design a control system for a retractable mast that supports an infrared surveillance
`FLIR camera for a helicopter.
`
`Identified MIL-SPEC relays suitable for aviation
` Designed a dual-redundant control system with cockpit indicators and control switches.
`
`
`
`
`CV of Val DiEuliis, Ph.D.
`Printed: 07/25/17
`
`
`
`Page 4 of 15
`
`Ubisoft v. Uniloc, IPR2017-01291
`Uniloc's Exhibit 2001, Page 17
`
`

`

`
`
` 2006–2007
`
`Circuit Failure Analysis
`
`Val DiEuliis, Ph.D.
`
`
`
`
`2000–2002
`
`
`
`
`1998–2002
`
`
`
`
`1997–2001
`
`
`
`
`
`
`An engineer hired me to analyze a circuit failure that had occurred by the thousands in a new
`product.
` Analyzed the design of the circuit
`
`Inspected and tested several failed circuit boards
` Researched power resistor failures
` Produced a report of my findings and opinions concerning the failure
`
`Detector of Phosphorescent Emissions
`
`A materials scientist at a large company hired me to design an electronic device to detect and
`identify phosphorescent materials.
` Developed a MATLAB mathematical model of the illumination, phosphorescent emission, and
`photodetector.
` Designed and developed the hardware and firmware for a small, battery-powered PIC
`microcontroller-based detector of the phosphorescent materials. This detector included a
`bright LED illuminator and a super-high gain, low noise photo-detector circuit. The electronics
`fit into a slim, hand-held package that easily fit into a shirt pocket or a small purse.
` Researched and developed advanced algorithms for identifying the phosphorescent
`materials.
`
`Sky-Ride at the Minnesota State Fairgrounds
`
`The owner of the Sky-Ride cable car at the Minnesota State Fairgrounds hired me to design and
`install controls, work with safety inspectors, and improve his maintenance procedures.
`
`Industrial Valve Position Sensor
`
`A manufacturer of industrial control valves hired me to develop the electronics for a rotary position
`sensor and a HART modem.
` Co-developed the concept of a position sensor using two magneto-resistive sensor chips and
`a microcontroller, and evaluated its feasibility.
` Developed a mathematical model using Visual Basic to aid in selecting design parameters
`such as magnet size, magnet spacing, and analog-to-digital converter resolution.
` Developed an automated prototype tester to aid in the design and manufacture of the device.
` Designed and tested the analog front-end and signal conditioning circuitry for the production
`units, and developed a hybrid circuit board for the magneto-resistive sensor chips.
` Wrote key sections of the C language sensor software to incorporate efficient straight-line
`code in critical areas and a table lookup of the position result.
` Designed, developed, and manufactured a modem for the HART (Highway Addressable
`Remote Transducer) communications network, which is a 1200 Baud FSK link on a 4-20 mA
`current loop circuit.
` Researched and tested communication transformers, and designed a transformer-coupled
`interface to the HART circuitry that met the HART specification’s terminal impedance
`requirements.
`
`
`
`
`CV of Val DiEuliis, Ph.D.
`Printed: 07/25/17
`
`
`
`Page 5 of 15
`
`Ubisoft v. Uniloc, IPR2017-01291
`Uniloc's Exhibit 2001, Page 18
`
`

`

`
`
`1998–2000
`
`Servo for a Magnetic Head Tester
`
`Val DiEuliis, Ph.D.
`
`
`
`
`1999
`
`
`
`
`1998
`
`
`
`
`1997
`
`
`
`A magnetic disk drive manufacturer hired me to develop a head-positioning servo for the
`company's production head test systems.
` Developed requirements and specifications, designed the architecture, and identified the
`major components for the servo system.
` Developed the hardware, including a servo position demodulator, analog front-end circuitry,
`and digital logic using VHDL descriptions for Xilinx field-programmable gate arrays (FPGA).
` Created and implemented algorithms for tracking the servo header information across the
`surface of the disk.
` Analyzed disk surface testing results to demonstrate how the new servo improved the
`magnetic head test when compared to prior tester systems.
` Characterized and modeled system components and control algorithms using MATLAB and
`SimuLink.
`
`Power Inverter PCB Reverse Engineering
`
`A manufacturer of power inverters hired me to create a schematic and bill of materials of an
`existing circuit board.
`
`Book Demagnetizer Design
`
`A large company that developed products for libraries hired me to perform a preliminary design
`study for a device that would automatically scan a magnet to demagnetize the security strip in a
`book before a patron left the library. I developed an aluminum structure that met the weight and
`strength requirements, and identified an inexpensive, small stepping motor to move the magnet.
`
`Condition-Based Maintenance System
`
`A large company’s research center hired me to develop the functional requirements for a condition-
`based maintenance (CBM) system to predict failure probabilities for large motors, gearboxes, and
`other equipment on U. S. Navy ships. I analyzed the original proposal to the Navy, worked with the
`project team to develop a set of requirements, and designed a system architecture based on the
`requirements.
`
`
`1992–1997
`
`Optical Disk Technology
`
`
`
`
`
`
`A division of a large company hired me to develop a tester for a new generation of rewritable
`magneto-optical (MO) disks.
` Developed the laser optics, mechanics, focus and tracking servos, optical signal detection,
`instrumentation, and software for a MO disk test system.
` Created and automated test procedures to evaluate media performance, tested disks,
`analyzed test data, and presented the results to my client's management and their OEM
`customers.
` Designed and built an optical and electronic module for High Density CD disks, a precursor to
`DVD disks.
` Tested both optical disks and a recording system designed for flying-head near-field MO
`recording and playback.
`
`
`
`
`CV of Val DiEuliis, Ph.D.
`Printed: 07/25/17
`
`
`
`Page 6 of 15
`
`Ubisoft v. Uniloc, IPR2017-01291
`Uniloc's Exhibit 2001, Page 19
`
`

`

`
`
`1996
`
`
`
`
`1992
`
`
`
`
`1991–1992
`
`
`
`
`1990–1992
`
`
`
`Val DiEuliis, Ph.D.
`
`Avionics Environmental Monitor
`
`A large company’s research center hired me to design and build an electronic device to monitor the
`shock, vibration, and temperature in a compartment of an avionics bay in a U. S. Air Force B-1
`bomber.
` Designed and developed a low power circuit board to collect the data and transfer it to the
`memory on a commercial-off-the-shelf (COTS) processor. The device included a 3-axis
`accelerometer, temperature sensors, and a PIC microcontroller.
` Created a packaging scheme that met the customer’s detailed volume and shape
`requirements.
` Wrote the firmware that collects, analyzes, and stores the data; and interfaces with the user
`through a RS232 port.
`
`Radio Frequency Billboard Network
`
`A national billboard company hired me to investigate the technology of a startup company that had
`developed a system to monitor the lighting on billboards and report the status to a central offi