throbber
UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`UNIFIED PATENTS INC.
`Petitioner
`
`v.
`
`FALL LINE PATENTS, LLC
`Patent Owner
`
`CASE IPR2018-00043
`PATENT 9,454,748
`
`DECLARATION OF DR. JOHN C. HALE UNDER 37 C.F.R. § 1.68
`
`IN OPPOSITION TO DECISION GRANTING INTER PARTES REVIEW OF
`
`U.S. PATENT NO. 9,454,748 (CLAIMS 16-19 AND 21-22)
`
`1
`
`FALL LINE PATENTS EX2006
`
`

`

`TABLE OF CONTENTS
`TABLE OF CONTENTS
`
`I.
`
`II.
`II.
`
`III.
`III.
`
`IV.
`IV.
`
`V.
`
`VI.
`VI.
`
`3
`INTRODUCTION
`INTRODUCTION ................................................................................ 3
`
`3
`QUALIFICATIONS AND COMPENSATION
`QUALIFICATIONS AND COMPENSATION ............................................. 3
`
`5
`BACKGROUND
`BACKGROUND .................................................................................. 5
`
`PERSON OF ORDINARY SKILL
`7
`PERSON OF ORDINARY SKILL ...................................................... 7
`
`DISCUSSION OF THE '748 PATENT
`7
`DISCUSSION OF THE ‘748 PATENT ............................................... 7
`
`10
`CLAIM CONSTRUCTION
`CLAIM CONSTRUCTION .............................................................. 10
`
`VII.
`VII.
`
`DISCUSSION OF PRIOR ART
`10
`DISCUSSION OF PRIOR ART ....................................................... 10
`
`VIII.
`VIII.
`
`DISCUSSION OF THE HTML "HIDDEN QUESTION" TAG 19
`DISCUSSION OF THE HTML “HIDDEN QUESTION” TAG ...... 19
`
`IX.
`IX.
`
`22
`CONCLUSIONS
`CONCLUSIONS ............................................................................... 22
`
`2
`2
`
`FALL LINE PATENTS EX2006
`FALL LINE PATENTS EX2006
`
`

`

`I, Dr. John C. Hale, hereby declare the following:
`
`I. INTRODUCTION
`
`1.
`
`I have been retained by counsel for Fall Line Patents, LLC ("Patent Owner,"
`
`hereinafter), the owner of the subject matter of the above-identified patent, i.e.,
`
`U.S. Patent 9,454,748 (the " '748 patent"), to offer testimony with respect to the
`
`subject matter at issue herein (the "IPR" hereinafter).
`
`II. QUALIFICATIONS AND COMPENSATION
`
`2. My curriculum vitae documenting the details of my professional experience,
`
`publications, and related information is attached hereto as Exhibit "A" and
`
`incorporated herein.
`
`3. By way of summary, I am a tenured professor and the Tandy Endowed Chair
`
`in Bioinformatics and Computation Biology of the Tandy School of Computer
`
`Science at the University of Tulsa, Tulsa, Oklahoma.
`
`4.
`
`I have been a professor of Computer Science at The University of Tulsa
`
`since 1999. Before that I was a professor in the School of Electrical Engineering
`
`and Computer Science at Washington State University (1997-1999). I graduated
`
`with my PhD in Computer Science from The University of Tulsa in 1997, having
`
`previously earned BS and MS degrees in Computer Science from that same
`
`institution.
`
`3
`
`FALL LINE PATENTS EX2006
`
`

`

`5.
`
`I have authored over 90 scholarly articles in the area of computer science,
`
`including those on topics in the fields of cyber security, bioinformatics, artificial
`
`intelligence and applied formal methods. In addition, I have delivered testimony to
`
`Congress on three separate occasions.
`
`6.
`
`Also, I am an inventor with respect to two issued U.S. patents:
`
`a. U.S. Patent No. 6,732,180, J. Hale and G. Manes, "A Method to
`
`Inhibit the Identification and Retrieval of Proprietary Media via
`
`Automated Search Engines Utilized in Association with Computer
`
`Compatible Communications Networks," issued May 4, 2004.
`
`b. U.S. Patent No. 9,471,789, P. Hawrylak, M. Papa, J. Hale,
`
`"Compliance Method for a Cyber Physical System," issued October
`
`18, 2016, and foreign counterparts.
`
`7.
`
`I am being compensated at the rate of $225 per hour plus reimbursement for
`
`expenses for my work on this Petition for Inter Partes Review. This is my standard
`
`hourly rate for consulting work of this nature. My compensation does not depend
`
`on the conclusions that I reach or on the outcome of this review.
`
`8.
`
`I previously submitted a declaration in opposition to the reexamination of
`
`claims 1-14 of U.S. Patent 7,822,816 which is a parent of the '748 patent.
`
`4
`
`FALL LINE PATENTS EX2006
`
`

`

`9.
`
`Based on my education, training, and experience, I am familiar with the
`
`technology which is the subject of the '748 Patent, the cited references, and general
`
`U.S. Patent Office practices and procedures.
`
`III. BACKGROUND
`
`10. I have been asked to provide my opinions with respect to certain matters
`
`associated with claims 16-19 and 21-22 (the "Challenged Claims") of the '748
`
`Patent.
`
`11. In preparing this Declaration, I have reviewed the following documents,
`
`among others:
`
`(a) The "Petition for Inter Partes Review of U. S. Patent 9,454,748
`
`Challenging Claims 16-19 And 21-22 Under 35 U. S. C. § 312 And
`
`37 C. F. R. § 42.104" (the "Petition"), filed by Unified Patents, Inc.
`
`("Petitioner);
`
`(b) U. S. Patent 9,454,748 (the '748 Patent, EX1001), including its
`
`written description, figures, and claims;
`
`(c) the file history of the '748 Patent (EX1002);
`
`(d) the declaration of Dr. A. L. Narashimha Reddy, expert witness for
`
`Petitioner (EX1005);
`
`(e) U.S. Patent 6,154,745 to Kari et al. ("Kari") (EX1006);
`
`5
`
`FALL LINE PATENTS EX2006
`
`

`

`(f) Excerpts of "HTML 4 Unleashed" by Darnell et al. ("Darnell")
`
`(EX1007);
`
`(g) U.S. Patent 6,380,928 to Todd ("Todd") (EX1008);
`
`(h) U.S. Patent 6,381,603 to Chan et al. ("Chan") (EX1010);
`
`(i)
`
`U.S. Patent 6,222,483 to Twitchell et al. ("Twitchell") (EX1014);
`
`(j) U.S. Patent 5,043,736 to Darnell et al. ("Darnell '736") (EX1015);
`
`(k) "Service Manual: RAE/RAK-1 Series Cellular Phone/Personal Digital
`
`Assistant," Nokia_9000i_Service_Manual.pdf, EX2007, obtained
`
`from
`
`https://wvvvv.manualslib.com/download/830641/Nokia-9000i.html;
`
`(1)
`
`Excerpt from "HTML — The Complete Reference" by Powell. 3rd Ed.,
`
`pages 427-428 ("Powell") (EX2008);
`
`(m) DECISION re Institution of Inter Partes Review 35 U. S. C. § 314(a)
`
`and 37 C. F. R. § 42.108(b), IPR2018-0004, Paper 6 (the "Decision")
`
`and
`
`(n) Any other documents not listed above but referenced in the text that
`
`follows.
`
`12. I have been asked to offer my opinion with respect to the technology
`
`associated with, and obviousness of, certain of the claims of the '748 patent in
`
`view of prior art references provided by the Petitioner.
`
`6
`
`FALL LINE PATENTS EX2006
`
`

`

`IV. PERSON OF ORDINARY SKILL
`
`13. Petitioner has suggested that a hypothetical person of ordinary skill in the art
`
`relevant to the priority date of the '748 patent would have a "bachelor's degree in
`
`computer science, computer engineering, electrical engineering, or a related
`
`subject, or equivalent industry or trade school experience in programming software
`
`applications." Petition at page 6, (Paper 1). That definition will be accepted for
`
`purposes of this declaration.
`
`14. Based on my education, training, and professional experience in the field of
`
`the claimed invention, and teaching, I am familiar with the level of the abilities of a
`
`person of ordinary skill in the art at the time of the claimed invention. It is my
`
`understanding that earliest priority date of the '748 patent is August 19, 2002, and
`
`that the Patent Office has accepted Patentee's showing of a conception date and
`
`diligent reduction to practice of the claimed invention at least as early as January 1,
`
`2002.
`
`V. DISCUSSION OF THE '748 PATENT
`
`15. This patent relates to a method of collecting data using handheld devices and
`
`transmitting the data to a central server where it can be accessed and used.
`
`16. Prior art methods of collecting data in this fashion from handheld devices
`
`required coding and compiling a device specific program that presented the
`
`7
`
`FALL LINE PATENTS EX2006
`
`

`

`questionnaire to the user. The resulting executable program would then be usable
`
`by only one kind of device.
`
`17. However, the '748 patent overcomes this problem by tokenizing the
`
`questionnaire before it is transmitted to the handheld device. That is, the instant
`
`system assigns device independent "tokens" to the elements of a questionnaire.
`
`See EX1001 at 8:15-17 ("This series of questions or statements will have been
`
`constructed on computer 22 and reduced to tokenized form for transmission to the
`
`handheld 28.") (italics added); See also, EX1001 at 8:40-43 (describing how
`
`tokens are "assigned" to questions).
`
`18. The questionnaire and its tokens must be device independent (EX1001 at
`
`Col. 7, lines 47-58.):
`
`As a part of the inventive system each remote device, preferably a
`handheld computer, is provided with an operating instruction system
`("OIS") which overlays its native operating system. Once equipped
`with the OIS, a remote device can be programmed according to
`methods described hereinafter. Any program developed under the
`inventive system will run on any handheld computer equipped with
`the OIS and files on one such handheld will transfer freely to any
`other handheld or any computer connected to the inventive system.
`
`19. In other words, this patent contemplates that there will be an application
`
`layer (the "OIS") that overlays the operating system on each different type of
`
`remote device so that the same tokenized questionnaire can be executed without
`
`change on each such device. The OIS makes possible the device independence of
`
`the tokenized questionnaire.
`
`8
`
`FALL LINE PATENTS EX2006
`
`

`

`20. At least some of the tokens of each questionnaire must be executable. That
`
`is, they must correspond, for example, to a "logical, mathematical, or branching
`
`operation". (EX1001, Col. 8, lines 56-64.)
`
`21. The '748 patent also discloses an embodiment where the handheld device is
`
`able to determine its current location. One embodiment utilizes automatic entry of
`
`the GPS coordinates into the questionnaire in response to a question that requests
`
`location information that is part of the transmitted questionnaire. This variation is
`
`discussed, for example, in EX1001 at col. 10, lines 55-58. The '748 patent
`
`contemplates that the GPS receiver might be used to automatically collect the
`
`location of the handheld device and include that information in the questionnaire.
`
`22. The '748 patent also discloses an embodiment where the handheld device is
`
`able to determine its current location. One embodiment utilizes automatic entry of
`
`the GPS coordinates into the questionnaire in response to a question that requests
`
`location information that is part of the transmitted questionnaire. This variation is
`
`discussed, for example, in EX1001 at col. 10, lines 55-58. The '748 patent
`
`contemplates that the GPS receiver might be used to automatically collect the
`
`location of the handheld device and include that information in the questionnaire.
`
`23. The term "loosely networked" is used in the '748 patent to describe a
`
`networked computer system wherein devices on the network are tolerant of
`
`9
`
`FALL LINE PATENTS EX2006
`
`

`

`intermittent network connections and, in fact, tolerant of the type of network
`
`connection available.
`
`VI. CLAIM CONSTRUCTION
`
`24. I understand that in its Decision Board adopted the following construction
`
`for the term "token": "a distinguishable unit of a program, such as an index, an
`
`instruction, or a command that can represent something else such as a question,
`
`answer, or operation". Decision at p. 17.
`
`25. I understand that the Board has also construed "GPS integral thereto" as
`
`"Global Positioning System equipment integral thereto." Decision at p. 13.
`
`26. I understand that the Board has also construed "originating computer /
`
`recipient computer / central computer" in its Decision at p. 18 as encompassing "a
`
`computer having the ability to perform functions associated with an originating
`
`computer, a recipient computer, and/or a central computer."
`
`27. For purposes of this Declaration only, these constructions will be adopted
`
`herein.
`
`VII. DISCUSSION OF THE PRIOR ART
`
`28. I have reviewed the Kari patent and understand that the specification of that
`
`patent suggests that a Nokia 9000 Communicator cellular telephone could be used
`
`as a "search terminal" in connection with his invention. Kari, EX1006, col. 3,
`
`lines 11-26.
`
`10
`
`FALL LINE PATENTS EX2006
`
`

`

`29. Based on my research, the Nokia 9000 had a relatively primitive browser.
`
`Technical documents from Nokia indicate that the browser was HTTP 1.0 and
`
`HTML 2.0 compliant. Nokia Service Manual, RAE/RAK-1 Series Cellular Phone
`
`/ Personal Digital Assistant, EX2007. Table 3 from that reference is reproduced
`
`below (Id, at page 1-8):
`
`Table 3. 0th
`
`communication protocols/formats supported
`
`Application
`Email
`
`Protocol
` SMTP, IMAI'4. MIME1
`
`All Internet apps
`
`TCP/IP
`
`Notes
`
`WWW
`
`Terminal
`
`PC Connectivity
`Module n f n-
`nection
`Ext. serial iif
`
`H
`
`1.0. HTML 2.0
`
`JPEG. GIF
`
`VT1OU
`
`RS232, IrDA
`RBUS
`
`MBUS
`
`30. Based on the contents of this document I have determined that the Nokia
`
`9000 device was not HTML 4 compliant contrary to the assumption of Petitioner's
`
`expert. See, Reddy Declaration ¶91, p. 35 (EX1005).
`
`31. Additionally, the previous reference and the table reproduced above make it
`
`clear that the Nokia 9000 device did not have Bluetooth which Reddy seems to
`
`believe as set out in EX1005 at ¶86 ("...either GPS equipment is incorporated, or
`
`integral to, Kari's search terminal, or the GPS equipment is connected in some way
`
`11
`
`FALL LINE PATENTS EX2006
`
`

`

`to the search terminal (e.g., using a serial connection, or a Bluetooth wireless
`
`connection)". Emphasis added.
`
`32. Even assuming that the Nokia Device was HTML 4 compliant, there was no
`
`facility in HTML or a standard browser for reading GPS location information from
`
`a GPS receiver.
`
`33. In 2001, GPS location information would have been available to an
`
`application only through a hardware connection linking the data processing device
`
`to a GPS receiver. With respect to the Nokia 9000, that connection would most
`
`likely have taken the form of a serial link (e.g., an RS232 connection). If a
`
`personal computer was the search terminal, Kari suggests using a PCMCIA card.
`
`34. Neither the HTML 2 nor the HTML 4 standard provided any mechanism for
`
`reading a serial port / interface or bus connected device. That option was just not
`
`available in a standard HTML 2 or 4 browser.
`
`35. Further, neither the HTML 2 nor the HTML 4 standard even provided any
`
`mechanism for importing or reading data into a form from an external source,
`
`where the external source includes reading information from a file stored on hard
`
`disk or elsewhere.
`
`36. Assuming for purposes of argument that an HTML 2 or an HTML 4
`
`document imports or reads location data from an external source; that could only
`
`12
`
`FALL LINE PATENTS EX2006
`
`

`

`be done through the use of device specific software external to the standard
`
`browser.
`
`37. If an application embedding an HTML form acquires GPS location
`
`information; that can only be done via device specific — not device independent —
`
`coding which means the HTML form could not comprise only device independent
`
`tags, commands, or tokens.
`
`38. Further, it is my opinion that in the flow chart contained in Fig. 3A and 3B
`
`of Kari (included below), steps 308 and 309 in Fig. 3A could not be performed by
`
`an HTML 2 or 4 browser, and none of the steps 311-316 in Fig. 3B could be
`
`performed by the same sort of browser.
`
`13
`
`FALL LINE PATENTS EX2006
`
`

`

`301
`
`302
`
`DATA
`CONNECTION
`
`303
`
`CHOOSE DESIRED
`SERVICE
`
`304
`
`DISPLAY SELECTED
`QUERY FORM
`
`FILL IN QUERY
`FORM +SUBMIT
`
`READ DATA
`
`305
`
`306-
`
`307
`
`NO
`
`3081
`
`READ I NI FILE
`
`309 -,,,
`
`ADD LOCATION INFO
`AND ROUTE INFO
`
`310
`
`COMPOSE
`QUERY MESSAGE
`
`FIG.3A
`
`FIG.3A
`FIG.3B
`FIG.3
`
`14
`
`FALL LINE PATENTS EX2006
`
`

`

`312 TRY TO RE—ESTABUSH
`CONNECTION
`
`RESPONSE
`RECEIVED?
`
`CONNECTION
`TIME OUT?
`
`COMPOSE
`ERROR MESSAGE
`
`FIG.3B
`
`39. Forms that are displayed by HTML 2 or 4 browsers could not read an INI
`
`file (308), add location and route information to the contents of the INI file (309),
`
`set a time flag (311), try to re-establish connection (312), branch and take different
`
`actions depending on whether or not communications had been re-established
`
`(313-316).
`
`40. If an HTML form required interaction with the server (e.g., if a "SEND"
`
`button were selected by the user) and a network connection was unavailable, the
`
`15
`
`FALL LINE PATENTS EX2006
`
`

`

`browser would print an error message indicating that the network was not available
`
`and continue to the next line of HTML. There was no capability in HTML 2 or 4
`
`to sense the absence of network availability and take alternative action.
`
`41. There was no capability in standard HTML 2 or 4 to sense a network outage
`
`and take alternative action, e.g., loop and retest until the network connection was
`
`available again as is required in Kari 's Fig. 3B, boxes 312, 313, and 315, supra.
`
`42. In my opinion, HTML 2 and HTML 4 browsers could not have been used by
`
`Kari to serve as a replacement for the OIS application layer taught and claimed in
`
`the '748 patent for least for the reasons set out above.
`
`43. Thus, assuming for purposes of argument that it is desired to implement any
`
`of steps 308, 309, 311, 312, and 313-316 via a standard browser, then any such
`
`implemented step must be performed by a separate machine-specific program,
`
`which machine-specific program would not be comprised of "device independent
`
`tokens".
`
`44. As such, Kari could not implement his "advantageous embodiment" of Figs.
`
`3A and 3B (col. 6, line 63 to col. 8, line 16) in either a HTML 2 or HTML 4
`
`browser in a device independent manner.
`
`45. In my opinion, a POSITA in possession of the teachings of Kari would not
`
`look to Darnell for any purpose at least because Darnell teaches a different version
`
`16
`
`FALL LINE PATENTS EX2006
`
`

`

`of HTML than was supported on Kari 's handheld computer / Nokia 9000
`
`Communicator.
`
`46. With respect to Todd (EX1009), I have reviewed the disclosure of that patent
`
`in detail and Petitioner's expert opinion of various aspects of that reference. It is
`
`my opinion that its operating logic as illustrated in Figures 5 through 12 of Todd
`
`could not have been implemented in HTML 2 or HTML 4. Nor would Todd
`
`provide any teaching that would help a POSITA implement the teachings of Kari.
`
`47. More particularly, the software in Todd requires access to system level
`
`parameters that standard HTML browsers would not have access to. Hardware
`
`parameters such as battery voltage, battery temperature, checking the serial port
`
`(Figure 8), were not available to HTML 2 or 4 browsers.
`
`48. Further, Petitioner's expert indicates at ¶128 that "Todd describes that "the
`
`answer(s) is stored in EEPROM...and the device determines whether to transmit
`
`the answer(s)..." and that transmitting occurs "if set to do so and the conditions for
`
`transmission are met." (Todd at 10: 15-18, 9: 67-10: 1 (EX1009))".
`
`49. The passage from Todd noted above is then deemed "analogous" to Karl 's
`
`description of a response of a "response" not being received, i.e., blocks 312, 313,
`
`and 315 of Kari 's Fig. 3B.
`
`50. Petitioner's expert then concludes at ¶129 that "a POSITA would have
`
`found it obvious to incorporate the storing of survey responses as taught by Todd
`
`17
`
`FALL LINE PATENTS EX2006
`
`

`

`into the system of Kari to remove the need for the user to re-enter query message
`
`information while a connection is being set up."
`
`51. Of course, as discussed above in ¶45, Kari could not implement this
`
`functionality in a device independent fashion because neither HTML 2 nor HTML
`
`4 had any provision for waiting "while a connection is being set up", nor was there
`
`any provision in a standard browser to call a system level routine to accomplish
`
`this same task.
`
`52. Thus, Todd's teachings could not be implemented in a device independent
`
`manner using a standard HTML 2 or 4 browser and a POSITA aware of Kari and
`
`looking to Todd would not find any teaching that could be implemented in Kari 's
`
`handheld device.
`
`53. With respect to Chan (EX1010), I have reviewed the disclosure of that
`
`patent in detail and Petitioner's expert opinion of various aspects of that reference.
`
`54. Petitioner's expert opines that a POSITA would have been motivated to
`
`combine Chan's handheld computer which included a GPS receiver and the
`
`methods of Kari to teach Patentee's "handheld computing device with a GPS
`
`integral thereto". Reddy's Declaration EX1005 at ¶ 89-90.
`
`55. Chan does not mention "HTML" or "browser". Chan further does not
`
`mention device independence or device indifference.
`
`18
`
`FALL LINE PATENTS EX2006
`
`

`

`56. Assuming for purposes of argument that Kari were to utilize Chan's "hand
`
`held" computer (EX1010, col. 3, lines 15-18, contains the only reference in Chan
`
`to "hand held computer"), Chan does not overcome the central problems of Kari,
`
`e.g., there is no teaching or suggestion in Chan of how to use an HTML browser to
`
`read a device such as a GPS receiver in a device independent fashion, nor does
`
`Chan teach or suggest how one could use an HTML 2 or 4 browser to determine
`
`that a network connection was not available and hold its transmission of data to a
`
`remote server until such time as the network connection was reestablished.
`
`VIII. DISCUSSION OF THE HTML "HIDDEN QUESTION" TAG
`
`57. I have reviewed Dr. Reddy's Declaration (EX1007), including statements
`
`(e.g., in ¶96, ¶101, and 137) as they relate to the use of "hidden questions" as a
`
`method for providing GPS information to an HTML 2 or 4 document.
`
`58. Dr. Reddy says at ¶96 that "a hidden question could be used for location
`
`information, as taught by Darnell ..., for example, if the query form of Kari were
`
`to automatically collect GPS location information. (Darnell at 241 (EX1007))."
`
`59. To the extent that Dr. Reddy is saying that hidden questions could be used to
`
`acquire GPS location information from a GPS receiver, that statement is
`
`categorically wrong for at least the following reasons.
`
`60. An HTML hidden question is a special input element in an HTML form that
`
`is not rendered in the browser and can have in it a prepopulated data value supplied
`
`19
`
`FALL LINE PATENTS EX2006
`
`

`

`by the server. The data value may either be generated by the server de novo and
`
`transmitted to the browser or it could have been data captured by the server from
`
`previous browsing activity.
`
`61. The figure below from EX2008, page, 428, illustrates this point graphically:
`
`Client
`
`New form
`page comes
`back with
`hidden data
`
`Step 1
`
`Order Form
`PeM
`
`Qiy Uu
`
`1-Edden
`
`Nazi
`
`Step 2
`
`Figure 11-4. Using hidden_ form fields to pteserve state
`
`62. In this figure, an HTML page that is resident on a client computer accepts
`
`customer information in one web page and transmits it to the server (Step 1) so that
`
`it can be sent back again to be held on the actual order web page as a hidden form
`
`field until the order is completed. Then, the combined customer information and
`
`order is transmitted back to the server for fulfillment (Step 2).
`
`20
`
`FALL LINE PATENTS EX2006
`
`

`

`63. Thus, the data value that pre-populates the hidden question must come
`
`directly from the server, i.e., if the data value originated on the client end in order
`
`to be loaded into a hidden question that quantity would first have to be transmitted
`
`from the client to the server.
`
`64. Obviously, using a hidden question to load a foiiii with a value would fail if
`
`a connection to the server was not available.
`
`65. Dr. Reddy also states the following with respect to hidden questions (1[101)
`
`... however, if the application program reads automatically the
`information on the location, a hidden question may be used to instruct
`the application program to read the information on the location.
`Hidden questions are described in further detail above with reference
`to Darnell.
`
`66. A "hidden question" could not be used by either an HTML 2 or 4 form to
`
`read GPS information from a device, nor could it be used to "instruct" the browser
`
`to read such information.
`
`67. Forms that were compliant with the HTML standard were not able to
`
`"instruct" a separate device specific application program to read GPS information
`
`so that may be included in a blank form as Dr. Reddy suggests in ¶101 of EX1005.
`
`68. Note that if there was no network connection between Kari 's handheld and
`
`the server, the hidden question function would fail since a hidden question requires
`
`transmission from (and possibly to-and-from) the server, if there is no connection
`
`to the server the hidden question item cannot be prepopulated.
`
`21
`
`FALL LINE PATENTS EX2006
`
`

`

`IX. CONCLUSION
`
`I hereby declare that all statements made herein of my own knowledge are
`
`true and that all statements were made with the knowledge that willful false
`
`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 application or any patent issued
`
`thereon.
`
`Dated: June 26, 2018
`
`Respectfully submitted,
`
`22
`
`FALL LINE PATENTS EX2006
`
`

`

`APPENDIX A
`APPENDIX A
`
`23
`23
`
`FALL LINE PATENTS EX2006
`FALL LINE PATENTS EX2006
`
`

`

`JOHN C. HALE
`Tandy Endowed Chair in Bioinformatics and Computational Biology
`Professor, Tandy School of Computer Science
`The University of Tulsa
`800 S Tucker Drive
`Tulsa, Oklahoma 74104-3189
`email: john-haledutulsa.edu
`
`Objective
`To develop and educate students while conducting research in the areas of computer security,
`computational biology, medical informatics, neuroinformatics, and applied formal methods.
`
`Education
`Ph.D. (CS), University of Tulsa, Tulsa, Oklahoma, 1997
`M.S. (CS), University of Tulsa, Tulsa, Oklahoma, 1992
`B.S. (CS), University of Tulsa, Tulsa, Oklahoma, 1990
`
`Areas of Specialization
`Computer security, computational biology, object systems, neuroinformatics, medical informatics,
`formal methods, networks, data mining, computer graphics.
`
`Professional Experience
`Lead Research Scholar, Institute of Bioinformatics and Computational Biology
`University of Tulsa, Tulsa, Oklahoma 2007—present
`Professor, Department of Computer Science
`University of Tulsa, Tulsa, Oklahoma 2008—present
`Director, Institute for Information Security
`University of Tulsa, Tulsa, Oklahoma 1999-2009
`Associate Professor, Department of Computer Science
`University of Tulsa, Tulsa, Oklahoma 2003-2008
`Assistant Professor, Department of Computer Science
`University of Tulsa, Tulsa, Oklahoma 1999-2003
`Teaching at The University of Tulsa:
`Instructor, CS 1001, Introduction to Computer Science, 2003, 2004, 2006
`Instructor, CS 2033, Computer Architecture, Organization and Assembler, 2000 - present
`Instructor, CS 4063/6423, Computer Architecture, 2000 - 2009
`Instructor, CS 4373/6373, High Performance Computing, 2014 - present
`Instructor, CS 4863, Introduction to Category Theory, 2006
`Instructor, CS 4863, Visualization, 2007
`Instructor, CS 4863, Internet Privacy, 2015
`Instructor, CS 5183/7183, Information System Security Engineering, 2005 - present
`Instructor, CS 5193/7193, Risk Management for Information Systems, 2008
`Instructor, CS 5403/7403, Secure Electronic Commerce, 1999 - 2014
`Instructor, CS 5443/7443, Information System Assurance, 2001 - 2003
`Instructor, CS 5463/7463, Enterprise Security Management, 2002 - 2013
`Instructor, CS 7863, Neuroinformatics, 2008, 2014
`Instructor, CS 7863, Medical Informatics, 2011 - 2015
`Instructor, CS 7863, Computational Biology, 2007, 2015, 2017
`Assistant Professor, School of Electrical Engineering and Computer Science
`Washington State University, Pullman, Washington 1997-1999
`Teaching at Washington State University:
`Instructor, CptS 483, Computer Security, 1998
`Instructor, CptS 452, Compiler Design, 1997 & 1998
`Instructor, CptS 518, Programming Language Theory, 1998
`
`Miscellaneous
`Citizenship: U.S. Citizen
`Ethnic status: Native American/Caucasian
`
`FALL LINE PATENTS EX2006
`
`

`

`Books
`
`• [1] Research Advances in Database and Information Systems Security, V. Atluri and J. Hale (Eds.),
`Kluwer Academic Publishing, Boston, Massachusetts, 2000.
`
`Journal Articles
`
`• [2] L. Kong, G. Bauer, and J. Hale , Robust Wireless Signal Indoor Localization, in Concurrency
`and Computation: Practice and Experience, vol. 27, no. 11, pp. 2839 - 2850, 2015.
`
`• [3] J. Staggs, M. Mol, M. Fisher, B. Brummel and J. Hale, A Perceptual Taxonomy of Contextual
`Cues for Cyber Trust, in Journal of the Proceedings of the Colloquium for Information System Security
`Educators (CISSE), pp. 151 - 158, 2014.
`
`• [4] M. Matlock, N. Schimke, L. Kong, S. Macke, and J. Hale, Systematic Redaction for Neuroimage
`Data, International Journal of Computational Models and Algorithms in Medicine, Soon Ae Chun,
`Jaideep Vaidya (Eds.), IGI Global, Hershey, PA, vol. 3, no. 2, pp. 63-75, 2012.
`
`• [5] P. Hawrylak, N. Schimke, J. Hale, and M. Papa, Security Risks Associated with Radio Frequency
`Identification in Medical Environments. Journal of Medical Systems, Springer, vol. 36, is. 6, pp.
`3491-3505, 2012.
`
`• [6] G. Manes, J. Johnson, A. Barclay, M. Harvey, E. Downing and J. Hale, Issues and Techniques
`for Redacting PDF Files. Journal of Digital Forensic Practice, vol. 2, no. 3, pp. 113-116, 2008.
`
`• [7] D. Marks and J. Hale, Security Service Packages: Partitioning the Security Space, Journal of
`Information Privacy Security, vol. 2, no. 4, pp. 30-44, 2006.
`
`• [8] J. Hale and P. Brush', Guest Editorial - The Shifting Sands of Secur(e/ity) Management, Journal
`of Network and Systems Management, vol. 47, no, 3, Springer Netherlands, 2005.
`
`• [9] J. Hale, T. Landry and C. Wood, Susceptibility audits: A tool for safeguarding information
`assets, Business Horizons, vol. 12, no. 3, Elsevier, pp. 59-66, May - June 2004.
`
`• [10] J. Hale and P. Brusil, Guest Editorial - Secur(e/ity) Management: Two Sides of the Same Coin,
`Journal of Network and Systems Management, vol. 12, no. 1, Springer Netherlands, 2004.
`
`• [11] J. Hale, M. Papa and S. Shenoi, Programmable access control, Journal of Computer Security,
`vol. 11, no. 3, IOS Press, Amsterdam, The Netherlands, pp. 331-351, 2003.
`
`• [12] M. Papa, 0. Bremer, J. Hale and S. Shenoi, Formal analysis of E-commerce protocols, IEICE
`Transactions on Information and Systems, Special Issue on Autonomous Decentralized Systems and
`Systems' Assurance, vol. E84-D, no. 10, Oxford University Press, Oxford, U.K., pp. 1313-1323,
`October, 2001.
`
`• [13] J. Hale, J. Threat and S. Shenoi, A ticket-based access control architecture for object systems,
`Journal of Computer Security, vol. 8, pp. 43-65, 2000.
`
`• [14] J. Hale and S. Shenoi, Analyzing FD inference in relational databases, Data and Knowledge
`Engineering, vol. 18, pp. 167-183, 1996.
`
`Book Chapters
`
`• [15] D. Hill, J. Walker and J. Hale, Privacy Considerations for Health Information Exchanges, in
`Medical Data Privacy Handbook, A. Gkoulalas-Divanis and G. Loukides (Eds.), Springer Interna-
`tional, Chain, Switzerland, pp. 289-311, 2015.
`
`• [16] P. Hawrylak and J. Hale, Data Privacy Issues with RFID in Healthcare, in Medical Data Privacy
`Handbook, A. Gkoulalas-Divanis and G. Loukides (Eds.), Springer International, Cham, Switzerland,
`pp. 549-567, 2015.
`
`FALL LINE PATENTS EX2006
`
`

`

`• [17] N. Schimke and J. Hale, Privacy Considerations and Techniques for Neuroimages, in Medical
`Data Privacy Handbook, A. Gkoulalas-Divanis and G. Loukides (Eds.), Springer International, Cham,
`Switzerland, pp. 527-547, 2015.
`
`• [18] B. Brummel, J. Hale and M. Mol, Training Cyber Security Personnel, in The Psychosocial
`Dynamics of Cyber Security Work, S. Zaccaro, R. Dalal, and L. Tetrick (Eds.), Routledge, Boca
`Raton, FL, 2015.
`
`• [19] P. Hawrylak and J. Hale, The Use of Body Area Networks and Radio Frequency Identification
`in Healthcare, Encyclopedia of Information Science and Technology, Third Edition, IGI Global, pp.
`6318 - 6326, 2015.
`
`• [20] P. Hawrylak, S. Reed, M. Butler and J. Hale, The Access of Things: Spatial Access Control,
`in Handbook of Research on Progressive Trends in Wireless Communications and Networking, M.A.
`Matin (Ed.), IGI Global, Hershey, PA, pp. 189-207, 2014.
`
`• [21] P. Hawrylak, C. Hartney, M. Haney, J. Hamm and J. Hale, Techniques to model and derive
`a cyber attacker's intelligence, Efficiency and Scalability Methods for Computational Intellect, IGI
`Global, pp.. 162 - 180, 2013.
`
`• [22] P. Hawrylak, C. Hartney, M. Papa and J. Hale, Using Hybrid Attack Graphs to Model and An-
`alyze Attacks against the Critical Information Infrastructure, in Critical Information Infrastructure
`Protection and Resilience in the ICT Sector , S. Bologna, P. Theron (Eds.), IGI Global, Hershey,
`PA, pp. 173-197, 2013.
`
`• [23] N. Schimke, J. Hale, P. Hawrylak and M. Papa, RFID and E-Health: Technology, Imple-
`mentation, and Security Issues, in Telemedicine and E-Health Services, Policies and Applications:
`Advancements and Developments, Joel J. P. C. Rodrigues, Isabel de la Torre, and Beatriz Sainz de
`A

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket