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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`
`ZTE (USA) Inc.,
`Samsung Electronics Co., Ltd., and
`Samsung Electronics America, Inc.,
`Petitioner,
`
`v.
`
`Fundamental Innovation Systems International LLC,
`Patent Owner.
`___________________
`
`Case IPR2018-00110
`Patent No. 8,624,550
`___________________
`
`
`
`
`DECLARATION OF DR. KENNETH FERNALD IN SUPPORT OF
`PATENT OWNER'S PRELIMINARY RESPONSE
`
`
`
`
`
`Mail Stop "PATENT BOARD"
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`TABLE OF CONTENTS
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`Page
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`I.
`
`II.
`
`Introduction ............................................................................................ 1
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`USB Enumeration ................................................................................... 5
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`A. Device States ................................................................................ 5
`
`B.
`
`Enumeration Steps ....................................................................... 8
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`III. Use of SE1 in Cited Prior Art ............................................................... 15
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`IV. Dougherty's System Makes Use of Enumeration ................................. 21
`
`A.
`
`B.
`
`C.
`
`The Primary Function of Dougherty's Docking Station Is
`Port Replication .......................................................................... 21
`
`Dougherty's Handshaking Protocol Is Enumeration .................. 23
`
`Petitioners' Contention That Dougherty's Does Not Use
`Enumeration Is Based on Irrelevant Disclosures In
`Dougherty ................................................................................... 29
`
`D. Dougherty's System Requires Enumeration .............................. 30
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`V.
`
`Petitioners' Proposed Modifications to Dougherty .............................. 31
`
`A. Description of First Modification .............................................. 31
`
`B.
`
`C.
`
`Description of Second Combination .......................................... 32
`
`A POSA Would Not Have Made The Proposed
`Modifications ............................................................................. 33
`
`a)
`
`b)
`
`Dougherty's laptop would not be able to
`send SE1 signaling pursuant to normal USB
`communication protocol ........................................ 33
`
`Petitioners' proposals do not properly
`account for unintentionally-generated SE1
`signals .................................................................... 35
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`c)
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`d)
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`e)
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`f)
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`Petitioners' modifications would disable the
`docking station's primary functionality ................. 37
`
`There were other known methods to enable
`docking station charging that would not
`interfere with normal USB communications ......... 40
`
`Petitioners' proposed modifications do not
`work in Dougherty's non-operational
`scenario .................................................................. 42
`
`Petitioners' second proposed modification
`would be inoperable .............................................. 45
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`VI. Petitioners' Rationale For Their Proposed Modifications Is
`Conclusory ............................................................................................ 46
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`I.
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`Introduction
`1. My name is Kenneth Fernald, Ph.D. My qualifications are
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`summarized below and are addressed more fully in my CV attached as
`
`EXHIBIT A.
`
`2.
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`For 30-years I have been involved in the design of integrated
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`circuits. A large portion of my work has involved the design of integrated
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`circuits that involve power management, battery charging and USB control.
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`I have designed USB controllers that have sold in the hundreds of millions of
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`units, and I was intimately involved in this field during the time of the patents
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`at issue in this case.
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`3.
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`I earned my Bachelor of Science and Master of Science degrees in
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`Electrical Engineering from North Carolina State University (NCSU) in 1985
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`and 1987. During this period I worked for the Space Electronics Group
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`developing software for predicting the effects of radiation environments on
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`integrated circuits. I also consulted for the Naval Research Laboratory (NRL).
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`My services to NRL included the design of dosimetry instrumentation and the
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`execution of radiation studies on electronic devices at various facilities around
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`the United States. I joined NASA Langley Research Center in 1987 where I
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`designed motor control instruments and firmware for ground and space station
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`experiments.
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`4.
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`I returned to NCSU in 1988 to earn my Ph.D. in Electrical
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`Engineering. My doctoral research efforts were funded by the National
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`Science Foundation and focused on the development of medical systems
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`utilizing wireless digital telemetry. My work included a thorough investigation
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`of medical telemetry technology and design of a microprocessor-based system
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`for the fast prototyping of implantable medical instruments. I also completed
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`the design and testing of various components of this system, including a
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`bidirectional digital telemetry integrated circuit (IC) and a general-purpose
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`sensor interface and conversion IC. I completed my Ph.D. in 1992, after which
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`I joined Intermedics Inc. in Angleton, Texas.
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`5. My responsibilities at Intermedics included system and circuit
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`design of telemetry, signal-processing, and control ICs for medical devices.
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`Examples include the design of a sensor acquisition, compression, and storage
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`IC for implantable pacemakers and defibrillators. I also worked on advanced
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`wireless digital telemetry technology, control ICs for therapy delivery in
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`defibrillators, and software development for sensor waveform compression and
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`recovery. I left Intermedics in 1998 to join Analog Devices Inc. in Greensboro,
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`NC.
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`6. My work at Analog Devices included the design of advanced ICs
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`for wireless digital communication devices. Specific projects included the
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`design, debug, and testing of a base-band receiver IC for digital satellite
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`systems. This IC performed QPSK demodulation, symbol recovery, and
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`forward-error correction for high-bandwidth wireless video signals. I also
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`performed system design for a CDMA base-band transceiver IC for personal
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`communication devices.
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`7.
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`I rejoined Intermedics in 1998 as the first employee of an IC
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`design group in Austin, Texas. I continued to work on next-generation medical
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`telemetry ICs until Intermedics was acquired by Guidant in 1999. At that time
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`I joined Cygnal Integrated Products, a startup company in Austin, Texas. My
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`responsibilities at Cygnal included the design and development of mixed-signal
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`embedded products for industrial and instrumentation applications. Specific
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`projects included the design of a proprietary communication system for in-
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`system debug, a proprietary clock recovery method for USB devices, and the
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`design of numerous analog and digital circuits and systems. I remained at
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`Cygnal until its acquisition by Silicon Laboratories Inc. in 2003, at which time
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`I joined Zilker Labs, a start-up company in Austin, Texas, as their first VP of
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`Engineering and later became their Chief Technical Officer.
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`8. My responsibilities at Zilker Labs included the development of
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`advanced IC technologies for power management and delivery for board-level
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`electronic systems. Specific duties included architecture design and firmware
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`development for all Zilker Labs products. I left Zilker Labs in 2006 to join
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`Keterex as their first VP of Engineering. My responsibilities at Keterex
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`included management of engineering resources, design and layout of
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`application-specific integrated circuits, and development of software and
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`firmware for Keterex products. I joined Silicon Laboratories in 2010 as a
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`Principal Design Engineer and now hold the title of Fellow. My
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`responsibilities include architecture development and design of 8-bit and 32-bit
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`microcontrollers. Projects have included microcontrollers for metrology,
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`motor control, and low-power and USB applications.
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`9.
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`I hold over 60 patents on technologies such as wireless telemetry
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`for medical devices, low-power analog-to-digital converters, security in
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`embedded systems, clock recovery in communication systems, serial
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`communication protocols, and power management and conversion. I have
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`authored or co-authored over 25 articles, presentations, and seminars on topics
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`including radiation effects in microelectronics, wireless medical devices, low-
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`power circuit design, circuit design for digital communications,
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`microcontrollers and embedded systems, and power management. I am also a
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`co-author of the PMBus™ Power System Management Protocol Specification.
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`10.
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`I have been asked by Fundamental Innovation Systems
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`International LLC to explain the technologies involved in U.S. 8,624,550, the
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`technologies described in the cited references, the knowledge of a person of
`
`ordinary skill in the art at the time of the invention, and other pertinent facts
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`and opinions regarding IPR2018-00110. For the purpose of this declaration, I
`
`apply the same skill level as proposed in the Petition, although I reserve the
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`right to explain why this level is too high. I am being compensated for my
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`work on this case at a fixed, hourly rate, plus reimbursement for expenses. My
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`compensation does not depend on the outcome of this case or any issue in it,
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`and I have no interest in this proceeding.
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`II. USB Enumeration
`A. Device States
`11. When a USB device is plugged into a host's USB port, the host
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`and the device undergo a series of handshakes in order for the host to access
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`the device's functions. This process—which involves "initial exchange of
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`information that enables the host's device driver to communicate with the
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`device"—is called enumeration. Ex. 2003 ["USB Complete"] at 74.
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`12. During the enumeration process, the device moves through a
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`number of states until it reaches the "Configured" state. Shown below is the
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`"Device State Diagram" from the Universal Serial Bus Specification Revision
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`2.0 dated April 27, 2000 ("USB 2.0"), with added annotation. Ex. 1008-0268.
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`This Device State Diagram illustrates the states that the device moves through
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`during the enumeration process. Among these states, "Power," "Default" and
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`"Address" are all considered unconfigured states. Apart from the "Attached"
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`state, the device can transition into the so-called "Suspended" state from any of
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`the "Power," "Default," "Address," or "Configured" states when the device
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`fails to detect any bus activity for 3 milliseconds. Ex. 1008-0269.
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`13.
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`I explain briefly below the states that the devices are in:
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`14. An "Attached" state is the state in which a device is plugged into a
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`hub, but the hub to which the device is connected is not yet powering VBUS.
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`Ex. 1008-0270; Ex. 2003 at 79; Ex. 2006 at 100. Strictly speaking, "Attached"
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`is a pre-enumeration state because the bus enumeration steps described in USB
`
`2.0, Section 9.1.2 only apply to when a USB device is attached to "a powered
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`port." Ex. 1008-0271.
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`15. The device enters the "Powered" state when it receives power
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`from the connected USB port. Ex. 1008-0270; Ex. 2003 at 76, Step 1; Ex.
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`2006 at 96 (Step 1).
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`16. The device enters the "Default" state after it receives a reset
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`command from the bus and completes the reset. Ex. 1008-0270. In this state,
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`the device is addressable at a "default address." Id. The device should not
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`respond to any bus transactions before the Default state. Id.; see also Ex. 2003
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`at 76-77 (steps 2-5); Ex. 2006 at 97 (steps 5-7). Once in the Default state, the
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`host can begin to inquire about the device's natures and capabilities. Id.
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`17.
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` The device enters its "Address" state when the host assigns it a
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`unique address. Ex. 1008-0270. The device "maintains its assigned address
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`while suspended." Id. Before the Address state, the device responds to
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`requests from the host with the default address.
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`18. The device must be configured before its device-specific functions
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`can be used. Ex. 1008-0271. The device is configured once it correctly
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`processes a "SetConfiguration" request from the host containing a non-zero
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`configuration value. Id. Before this occurs, the host issues "GetDescriptor"
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`request(s) to learn of the device's abilities. The host learns additional
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`information about the device "by requesting the one or more configuration
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`descriptors specified in the device descriptor." Ex. 2003 at 78; Ex. 2006 at 98;
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`see also Ex. 1008-00271, -0272.
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`19. As noted before, a device enters the "Suspended" state when it
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`does not see bus activity for 3 ms. Ex. 1008-0269. The device maintains its
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`address and configuration in the "Suspended" state. Ex. 1008-0271.
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`20. Having explained the states that a USB device may be in, I explain
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`in more detail the bus enumeration process that "identif[ies] and manage[s] the
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`device state changes necessary." Ex. 1008-0271.
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`B.
`Enumeration Steps
`21. The enumeration process involves a series of steps. First, when a
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`user plugs the device in to the powered port of a USB hub, the device enters
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`the "powered" state. Ex. 2003 at 76; Ex. 2006 at 96. In this state, the device
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`may receive power from the USB hub—however, it may not draw more than
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`100 mA from VBUS until it is configured. Ex. 1008-0270 to -0271.
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`Furthermore, the USB port to which the device is attached is disabled (Ex.
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`1008-0271), and the USB device cannot respond to any requests from the USB
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`bus until it receives a "reset" command from the bus. Ex. 1008-0270.
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`22. Next, the hub detects the device by "monitor[ing] the voltages on
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`the signal lines of each of its ports." Ex. 2003 at 76; Ex. 2006 at 96. In this
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`step, the USB device sends a high voltage on either the D+ or D- line. Id. The
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`USB hub detects the voltage and determines that the device is either a full-
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`speed device (if D+ is high) or a low-speed device (if D- is high). Ex. 2003 at
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`76, 77; Ex. 2006 at 96, 97 (detecting whether full-speed device supports high
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`speed); Ex. 1008-0271. Upon detecting the device, the hub "continues to
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`provide power but doesn't transmit USB traffic to the device." Ex. 2003 at 76;
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`Ex. 2006 at 96. The hub then reports to the host that one of its ports (and
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`indicates which port) has experienced an event. Id.
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`23. The host learns of the nature of the event, and of the attachment of
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`the new device, by sending a "Get_Port_Status" request. Ex. 2003 at 76; Ex.
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`2006 at 96.
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`24. Then, the host issues a port enable and reset command to the port,
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`which puts the port into the "enabled" state. Ex. 1008-0271; Ex. 2003 at 76;
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`Ex. 2006 at 97. In an enabled state, the host can now signal the connected
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`USB device with control packets.
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`25. After the reset, the USB device enters the "default" state and can
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`still draw no more than 100 mA from the VBUS line. Id. In this stage, the
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`USB device uses the "default address" of 0 to receive control requests. Ex.
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`1008-0271; Ex. 2003 at 77; Ex. 2006 at 97.
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`26. The USB host then reads the device's device descriptor to
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`determine the maximum data payload the USB device can use. Id. Maximum
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`data payload refers to the maximum packet size. Id. Either before or after the
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`USB host requests the device's device descriptor to determine the maximum
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`payload, the host assigns a unique address to the USB device, such that it is in
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`the "Address" state. Ex. 1008-0271; Ex. 2003 at 77-78; Ex. 2006 at 98.
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`27. The host then "sends a Get_Descriptor" request to the new address
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`to learn about the device's abilities. Ex. 2003 at 78; Ex. 2006 at 98. The
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`standard USB descriptors include the following fields (see Ex. 1008-0291 to -
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`0292, Table 9-8):
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`28. The descriptor description above matches that listed in U.S.
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`5,884,086 ("Amoni"), Table II. As noted by Amoni, the descriptors can
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`include information unique to a device, including its nonstandard voltage or
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`current configurations. For example, such information can be encoded by
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`"assign[ing] a vendor specific Device Class . . . and designat[ing] a unique
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`device sub-class assignment with unique encoded voltage and power
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`requirements." Ex. 2004 [Amoni] at 7:16-19. Alternatively, the information
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`can be encoded with "a Product String Index [iProduct] pointing to a string
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`containing voltage and current requirements." Id. at 7:27-29.
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`29. The host continues to learn about the device "by requesting the
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`one or more configuration descriptors specified in the device descriptor." Ex.
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`2003 at 78. The configuration descriptor has the following fields (Ex. 1008-
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`0292 to -0293, Table 9-10). As Amoni noted, the iConfiguration field can also
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`be used to encode a device's nonstandard voltage or current configuration, e.g.,
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`with the index "point[ing] to the location of a text string of UNICODE format"
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`as specified in section 9.6.7 of USB 2.0. Ex. 2004 [Amoni] at 7:37-44.
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`30. The host then reads the "configuration" information from the
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`device, which contains information about the device's capabilities. Ex. 1008-
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`0271; Ex. 2003 at 77; Ex. 2006 at 98-99. Finally, the host assigns a
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`configuration value to the USB device, which puts the device into the
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`"configured" state. Ex. 1008-0272; Ex. 2003 at 79; Ex. 2006 at 99-100.
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`Before this step, since the host does not yet know what additional functionality
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`the device can support, the host will only issue standard device requests, and
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`hence the device will only respond to standard device requests. See Ex. 1008-
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`0278-79 (describing the various standard device requests and noting that "USB
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`devices must respond to standard device requests, even if the device has not yet
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`been assigned an address or has not been configured"); Ex. 2003 at 37
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`(application communications began after enumeration); Ex. 2006 at 41 (same).
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`After it is configured, however, the device can participate in additional USB
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`communications, and draw an amount of power across the VBUS according to
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`its configuration. Ex. 1008-0272; Ex. 2003 at 79; Ex. 2006 at 99-100.
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`31. Either shortly before, or shortly after, the USB device enters the
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`"configured" state, the host assigns and loads a device driver. See Ex. 2003 at
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`78-79; Ex. 2003 at 99. While the USB 2.0 specification does not explicitly
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`describe loading the device driver as being part of the enumeration process (see
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`Ex. 1008-0271 to -0272), the process of loading the device driver is closely
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`related to enumeration and depends on information obtained during the
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`enumeration process, particularly in the Windows operating system. See Ex.
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`2003 at 78-79 ("In selecting a driver, Windows tries to match the Vendor and
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`Product IDs, Release Number, and or class information retrieved from the
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`device with the information stored in the system's INF files."); Ex. 2006 at 99
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`(same); see also Ex. 1008-0311 to 0313 (during device configuration, "[t]he
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`configuring software first reads the device descriptor, then requests the
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`description for each possible configuration. It may use the information
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`provided to load a particular client, such as a device driver, which initially
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`interacts with the device. The configuring software, perhaps with input from
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`that device driver, chooses a configuration for the device."). Thus, regardless
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`of whether loading a driver is explicitly part of enumeration, loading the driver
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`cannot occur in the absence of enumeration.
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`32. Shortly after the enumeration process has been completed, the
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`device has transitioned from being unrecognized by the USB host, to being
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`identified, configured, and ready for operation. This configuration is critical to
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`normal operation of the USB device, because "[a] USB device must be
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`configured before its function(s) may be used." Ex. 1008-0272. The USB
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`device may now also draw power over the VBUS line according to the
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`configuration information set by the USB host. Id.
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`33. When a hub instead of a device is connected to a host, the host
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`also undergoes enumeration with the hub (as well as any devices attached to
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`the hub) using the same procedures as described above. Ex. 2003 at 79-80; Ex.
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`2006 at 100.
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`III. Use of SE1 in Cited Prior Art
`34. Petitioners allege that a POSA "would have known that the SE1
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`condition would be a logical choice for conveying information about a device
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`without interfering with USB signaling." Pet. 51, 11.
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`35.
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`I disagree with Petitioners' conclusions. It is of course possible to
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`use an SE1 signal effectively, as established by the 550 patent. But a POSA
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`would conclude that the attempt to shoehorn it into the Dougherty system is not
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`viable. Indeed, Petitioners' assertions contradict the knowledge of a POSA, as
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`Samsung's expert correctly testified that SE1 signaling interferes with, and
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`indeed terminates, USB communication (Ex. 2005 [Garney] at 260:17-262:10):
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`Q. So if an SE1 condition is detected, what are the two events that
`will occur?
`
`A. What this is saying is if an SE1 is detected by a hub, then it's
`required to disconnect the device, and if an SE1 is detected by an
`attached device it would detect as a reset -- just a minute.· Let me
`read this more carefully.
`
`The SE1 condition has to exist for more than two-1/2
`microseconds, which is the definition of a reset condition.
`
`Q. And when you have 2.5 microseconds of the SE1 condition,
`the hub will disconnect itself from the device, correct?
`
`A. If a hub sees an SE1 condition for more than 2-1/2
`microseconds, it would put the port into a disconnect state.
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`Q: And what does that mean, being in a disconnect state?
`
`A. The things that are attached to that -- to that hub at that port
`would be -- another word that's used is a disabled port.· No more
`signalling -- no more data signalling would be delivered across
`that communication -- across that connection between the hub
`and the attached device or hub that might be connected to it.
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`. . .
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`Q: How long would the device and the hub be disconnected after
`the SE1 signal was received?
`
`A: Until the enumeration is repeated.
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`Q: And if the SE1 signal occurs again?
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`A: I mean, this describes what needs to happen.· Any time the
`hub puts the port into disconnect state, the enumeration would
`have to be repeated.
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`36. Mr. Garney's description above comports with the USB
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`specification's description that a USB hub disable the USB port when SE1
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`signaling is observed to avoid "errors that are very difficult to isolate and
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`correct":
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`Each port is required to have a timer used for detecting disconnect
`when a full-/low-speed device is attached to the port. This timer is
`used to constantly monitor the port's single-ended receivers to
`detect a disconnect event. The reason for constant monitoring is
`that a noise event on the bus can cause the attached device to
`detect a reset condition on the bus after 2.5 µs of SE0 or SE1 on
`the bus. If the hub does not place the port in the disconnect state
`before the device resets, then the device can be at the Default
`Address state with the port enabled. This can cause errors that
`are very difficult to isolate and correct.
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`Ex. 1008-0344, § 11.5.2.2.
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`37. Petitioners cite a number of references that they contend relate to
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`SE1 signaling "without interfering with USB signaling." Pet. 11-14. For
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`example, Petitioners rely on Shiga as the basis for combination with
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`Dougherty. But in Shiga, a SE1 signal is sent by a USB keyboard as a wake-up
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`signal to a host computer when the host computer's power supply is turned off.
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`Ex. 1006. When the power supply is turned off, the D+ and D- lines of the
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`USB keyboard and D+ and D- lines of the USB host "are not connected to
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`each other." Ex. 1006 at 6:8-12. Instead, the D+ and D- lines of the USB
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`keyboard are connected to input terminals of the comparators in the wake-up
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`means 3. Ex. 1006 at 6:12-15, 6:59-65, 7:4-8.
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`38. The wake-up means of Shiga contains only two comparators and
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`an "AND" circuit that takes as input the outputs of the two comparators.
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`Ex.1006 at Fig. 1, 7:9-15. When the output from both the comparators are high
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`(because the voltage on the D+ and D- lines of the USB keyboard exceeded
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`1.5V), the AND circuit output turns on the main power supply. Id. But the
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`wake-up means does not perform USB communications. Accordingly, Shiga
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`does not teach using SE1 signaling under circumstances where USB
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`communication would be possible. Indeed, the data lines of the USB keyboard
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`in Shiga is only reconnected with the data lines of the host after the main
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`power supply is turned on, that is, after the SE1 signaling and processing has
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`taken place. Ex. 1006 at 7:16-31.
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`39. Petitioners also cite to Kerai in support of its contention, asserting
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`that an SE1 signal in Kerai results in a special charging mode. Pet. 13. This is
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`incorrect—Kerai teaches, regarding Figure 3 upon which Petitioners rely:
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`[E]ach logic detector 50 detects the state of a corresponding line
`25,26 and, where the state is found to be high, permits current to
`flow into a corresponding capacitor 51. The output from each
`capacitor 50 supplies the charging terminal 52 which is connected
`to the battery charging circuit 19. Ex. 1012 at 5:47-53.
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`Kerai thus teaches that its battery will draw power from the USB data lines
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`whenever either D+ or D- (line 25 or 26) is held high. This charging mode
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`does not depend on SE1—i.e., the condition where both D+ and D- are held
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`high simultaneously. For instance, Kerai's battery will draw power even when
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`only one of D+ or D- is high at any given time. See Ex. 1012 at 3:30-33
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`(conductors 25 and 26 "carry differential data signals D- and D+").1
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`40. Petitioners also cite to Casebolt and Cypress as supposedly
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`teaching the desirability of SE1 signaling in USB communication. However,
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`in both Casebolt and Cypress, the SE1 signaling state is used in situations
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`where some communications protocol other than USB is desired. For
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`1 Additionally, Kerai recognizes that its scheme may, in fact, interfere
`with USB signaling. For example, Kerai warned that its charging scheme
`could "hav[e] a detrimental effect on the data rate of the [USB] port." Ex.
`1012 at 5:56-59.
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`example, Cypress relates to a peripheral controller that is capable of either
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`USB protocol or PS/2 protocol communications. Ex. 1011 at 6 ("The
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`CY7C637xx features up to 16 general purpose I/O (GPIO) pins to support
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`USB, PS/2 and other applications."). Cypress teaches that its SE1 signaling
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`state occurs under "PS/2 Operation," and only "[w]ith USB disabled." Ex.
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`1011 at 24. Accordingly, Cypress would provide no indication to a POSA that
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`SE1 signaling should be used on a channel where USB is desired.
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`41. Casebolt likewise teaches a peripheral device that is capable of
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`using either the USB or PS/2 protocol. Ex. 1010 at 2:27-41. In Casebolt, SE1
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`indicates that USB communication is not desired—the SE1 state "causes USB
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`functions to be terminated" so that PS/2 communications can begin. Ex. 1010
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`at 7:40-46. Thus, contrary to Petitioners' assertion that a POSA would not
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`understand Casebolt as teaching the use of an SE1 state "without interfering
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`with USB signaling," as Petitioner contends, because the purpose of the SE1
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`state in Casebolt is to terminate USB functionality.
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`42.
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`In summary, the state of the art as summarized by Petitioners
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`shows that SE1 was not used in a system where the host and the device would
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`continue to communicate under normal USB protocols. Nor do those
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`references show that SE1 was contemplated to signal a power supply to supply
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`current without regard to at least one condition associated with current supply
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`or without regard to at least one limit specified in the USB specification as
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`related to current supply. Similarly, none of the references use SE1 to turn off
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`a USB port's VBUS supply when the USB port is connected to a USB device.
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`IV. Dougherty's System Makes Use of Enumeration
`A. The Primary Function of Dougherty's Docking Station Is Port
`Replication
`43. Dougherty teaches an improved "USB based docking station that
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`has the capability of both operating the laptop computer and charging the
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`batteries in the laptop computer while docked without the need to plug in a
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`separate power connection . . . ." Ex. 1005 at 2:45-50. Compared to prior art,
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`Dougherty's USB based docking station does not require a separate power
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`input to the laptop, while still carrying out its primary function—port
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`replication. Id.
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`44. Specifically, Dougherty teaches that a docking station would be
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`desirable because it allows the laptop to "expand the capabilities . . . to include
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`a full size keyboard, a full size monitor, more serial ports, and other
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`functionality typically associated only with desktop computing devices." Ex.
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`1005 at 1:61-67.
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`45. One type of docking station that expands the laptop's capabilities
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`was "commonly referred to as a port replication docking station." Ex. 1005 at
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`2:14-16. Dougherty explains that "port replication" means that "by plugging
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`the laptop into the docking station, more serial and parallel ports are available
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`for connection to printers, scanners, full size display devices, serial or parallel
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`pointing devices and the like." Id. at 2:16-20.
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`46. An instance of a port replication docking station is a USB-based
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`docking station. Id. at 2:24-25. In such an instance, "[a] user connects a
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`laptop, via a USB connection, to a port replication device which generates
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`plurality of communication ports for use as described" for a typical port
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`replication docking station. Id. at 2:25-28.
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`47. One drawback for the traditional USB-based docking station was,
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`however, "the laptop user also plugs the laptop into a separate source of power,
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`or operates the laptop on battery power." Id. at 2:28-32. This gave rise to the
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`desirability to have a docking station that could power the device as well as
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`providing the gener