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
`
`DECLARATION OF JAMES T. GEIER
`
`Case No. IPR2018-00276
`
`ZTE/SAMSUNG 1009-0001
`IPR2018-00276
`
`

`

`Table of Contents
`
`Introduction ...................................................................................................... 1(cid:3)
`I.(cid:3)
`Background/Qualifications .............................................................................. 1(cid:3)
`II.(cid:3)
`III.(cid:3) Documents and Materials Considered ............................................................. 3(cid:3)
`IV.(cid:3) Legal Principles ............................................................................................... 3(cid:3)
`V.(cid:3)
`Person of Ordinary Skill in the Art .................................................................. 9(cid:3)
`VI.(cid:3)
`’111 patent background ................................................................................... 9(cid:3)
`A.(cid:3)
`Summary ............................................................................................... 9(cid:3)
`B.(cid:3)
`Prosecution history .............................................................................. 10(cid:3)
`C.(cid:3)
`Priority date ......................................................................................... 11(cid:3)
`VII.(cid:3) Technology background & State of the Art .................................................. 11(cid:3)
`A.(cid:3) USB Architecture ................................................................................ 11(cid:3)
`B.(cid:3)
`USB Device Configuration and Detection .......................................... 16(cid:3)
`C.(cid:3)
`USB Current and Voltage Limits ........................................................ 17(cid:3)
`D.(cid:3) USB Signaling States .......................................................................... 18(cid:3)
`E.(cid:3)
`Auxiliary USB Ports ............................................................................ 18(cid:3)
`VIII.(cid:3) Claim Construction ........................................................................................ 20(cid:3)
`IX.(cid:3) Ground 1: Claims 1-3, 6-8, and 16-18 are obvious in light of Theobald and
`Shiga .............................................................................................................. 21(cid:3)
`A.(cid:3)
`Theobald .............................................................................................. 21(cid:3)
`1.(cid:3)
`Resistor embodiment ................................................................ 24(cid:3)
`2.(cid:3)
`Controller embodiment ............................................................. 26(cid:3)
`Shiga .................................................................................................... 29(cid:3)
`B.(cid:3)
`Theobald/Shiga combination ............................................................... 32(cid:3)
`C.(cid:3)
`D.(cid:3) Application of the Theobald/Shiga combination to claims 1-3, 6-7,
`and 16-18 ............................................................................................. 40(cid:3)
`1.(cid:3)
`Claim 1 ...................................................................................... 40(cid:3)
`2.(cid:3)
`Claim 2 ...................................................................................... 47(cid:3)
`3.(cid:3)
`Claim 3 ...................................................................................... 48(cid:3)
`
`Geier Declaration
`
`i
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0002
`IPR2018-00276
`
`

`

`Table of Contents
`(continued)
`
`Claim 6 ...................................................................................... 49(cid:3)
`4.(cid:3)
`Claim 7 ...................................................................................... 50(cid:3)
`5.(cid:3)
`Claim 8 ...................................................................................... 51(cid:3)
`6.(cid:3)
`Claim 16 .................................................................................... 52(cid:3)
`7.(cid:3)
`Claim 17 .................................................................................... 53(cid:3)
`8.(cid:3)
`Claim 18 .................................................................................... 55(cid:3)
`9.(cid:3)
`X.(cid:3) Ground 2: Claim 15 is obvious over Theobald in light of Shiga and Kfoury
` ....................................................................................................................... 56(cid:3)
`A.(cid:3) Kfoury.................................................................................................. 56(cid:3)
`B.(cid:3)
`Theobald/Shiga/Kfoury Combination ................................................. 57(cid:3)
`C.(cid:3)
`Application of the Theobald/Shiga/Kfoury Combination to Claim
`15 ......................................................................................................... 60(cid:3)
`1.(cid:3)
`Claim 15 .................................................................................... 60(cid:3)
`XI.(cid:3) Ground 3: Claims 12 and 14 are obvious over Dougherty in light of Hahn
`and Amoni ..................................................................................................... 63(cid:3)
`A.(cid:3) Dougherty ............................................................................................ 63(cid:3)
`B.(cid:3)
`Hahn .................................................................................................... 67(cid:3)
`C.(cid:3)
`Dougherty/Hahn Combination ............................................................ 69(cid:3)
`1.(cid:3)
`Reasons to Combine Dougherty/Hahn ..................................... 70(cid:3)
`2.(cid:3)
`Reasons to Combine Dougherty/Hahn with the
`Teachings of Amoni .................................................................. 71(cid:3)
`D.(cid:3) Application of the Dougherty/Hahn/Amoni Combination to Claims
`12 and 14 ............................................................................................. 73(cid:3)
`1.(cid:3)
`Claim 12 .................................................................................... 73(cid:3)
`2.(cid:3)
`Claim 14 .................................................................................... 82(cid:3)
`
`Geier Declaration
`
`ii
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0003
`IPR2018-00276
`
`

`

`I.
`
`Introduction
`
`1.
`
`My name is James T. Geier. I submit this declaration on behalf of
`
`ZTE (USA) Inc., Samsung Electronics Co., Ltd., and Samsung Electronics
`
`America, Inc. (“Petitioner”), which I understand are challenging the validity of
`
`claims 1-3, 6-8, 12, and 14-18 (“the challenged claims”) of U.S. Patent No.
`
`7,239,111 B2 (“the 111 patent”) in a petition for inter partes review.
`
`2.
`
`I have been asked to provide an opinion on the validity of the
`
`challenged claims. In my opinion, claims 1-3, 6-8, 12, and 14-18 of the 111 patent
`
`are obvious based on the following grounds:
`
`(cid:120) Ground 1: U.S. Patent No. 5,925,942 (“Theobald”) and U.S. Patent No.
`
`6,625,738 (“Shiga”) render obvious claims 1-3, 6-8, and 16-18 of the
`
`’111 patent.
`
`(cid:120) Ground 2: Theobald, Shiga, and U.S. Patent No. 6,049,192 (“Kfoury”)
`
`render obvious claim 15 of the ’111 patent.
`
`(cid:120) Ground 3: U.S. Patent No. 7,360,004 (“Dougherty”), U.S. Patent No.
`
`5,973,948 (“Hahn”), and U.S. Patent No. 5,884,086 (“Amoni”) render
`
`obvious claims 12 and 14 of the ’111 patent.
`
`II.
`
`Background/Qualifications
`
`3.
`
`Appendix A to this declaration is my curriculum vitae, which sets
`
`forth my qualifications.
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0004
`IPR2018-00276
`
`

`

`4.
`
`I received a B.S. degree in Electrical Engineering from California
`
`State University in 1985. In 1990, I received an M.S. degree in Electrical
`
`Engineering from the Air Force Institute of Technology.
`
`5.
`
`I have 30 years’ experience in the communications industry designing,
`
`analyzing, and implementing communications systems, wireless networks, and
`
`mobile devices. I have authored over a dozen books on mobile and wireless topics,
`
`including Designing and Deploying 802.11 Wireless Networks (Cisco Press),
`
`Implementing 802.1X Security Solutions (Wiley), Wireless Networking Handbook
`
`(New Riders) and Network Re-engineering (McGraw-Hill). I have been an active
`
`participant within standards organizations, such as the IEEE 802.11 Working
`
`Group and the Wi-Fi Alliance. I have served as Chairman of the IEEE Computer
`
`Society, Dayton Section, and various conferences.
`
`6.
`
`I have significant experience with USB, which includes reviewing and
`
`analyzing USB specifications and designing and integrating corresponding USB
`
`interfaces within various applications. Since 1998, I have been analyzing the
`
`operation and limitations of USB in relation to mobile devices that I have
`
`designed. For example, during 1998-1999, I analyzed and tested the integration of
`
`USB into Monarch Marking Systems bar code scanners and printers. Also, during
`
`2008-2009, I integrated USB into a microcontroller-based monitoring and control
`
`system, which involved writing software drivers to interface the microcontroller to
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0005
`IPR2018-00276
`
`

`

`the functionality of a USB port. In addition, I have analyzed how USB impacts the
`
`operation and specifications of many other devices, such as wireless IP phones and
`
`patient heart monitors, which I’ve been part of designing.
`
`III. Documents and Materials Considered
`
`7.
`
`Appendix B to this declaration lists materials that I have considered in
`
`rendering the opinions that I express in this declaration. In forming my opinions, I
`
`have also relied on my experience and education.
`
`IV. Legal Principles
`
`8.
`
`I am not an attorney. I offer no opinions on the law. But counsel has
`
`informed me of legal standards that apply to the issue of patent validity. I have
`
`applied these standards in arriving at my conclusions.
`
`9.
`
`I understand that in an inter partes review the petitioner has the burden
`
`of proving a proposition of unpatentability by a preponderance of the evidence. I
`
`understand this standard is different from the standard that applies in a district
`
`court, where I understand a challenger bears the burden of proving invalidity by
`
`clear and convincing evidence.
`
`10.
`
`I understand that a patent claim is invalid based on anticipation if a
`
`single prior art reference discloses all of the features of that claim, and does so in a
`
`way that enables one of ordinary skill in the art to make and use the invention.
`
`Each of the claim features may be expressly or inherently present in the prior art
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0006
`IPR2018-00276
`
`

`

`reference. I understand that if the prior art necessarily functions in accordance
`
`with, or includes a claim’s feature, then that prior art inherently discloses that
`
`feature. I have relied on this understanding in expressing the opinions set forth
`
`below.
`
`11.
`
`I understand that a prior art reference describes the claimed invention
`
`if it either expressly or inherently describes each and every feature set forth in the
`
`claim; i.e., in determining whether a single item of prior art anticipates a patent
`
`claim, one should take into consideration not only what is expressly disclosed in
`
`that item, but also what is inherently present as a natural result of the practice of
`
`the system or method disclosed in that item.
`
`12.
`
`I understand that to establish inherency, the evidence must make clear
`
`that the missing descriptive matter is necessarily present in the item of prior art and
`
`that it would be so recognized by persons of ordinary skill in the art. I also
`
`understand that prior art use of the claimed patented invention that was accidental,
`
`unrecognized, or unappreciated at the time of filing can still be an invalidating
`
`anticipation.
`
`13.
`
`I understand that although multiple prior art references may not be
`
`combined to show anticipation, additional references may be used to interpret the
`
`allegedly anticipating reference and shed light on what it would have meant to
`
`those skilled in the art at the time of the invention. These additional references
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0007
`IPR2018-00276
`
`

`

`must make it clear that the missing descriptive matter in the patent claim is
`
`necessarily present in the allegedly anticipating reference, and that it would be so
`
`recognized by persons of ordinary skill in the art.
`
`14.
`
`I understand that a patent may not be valid even though the invention
`
`is not identically disclosed or described in the prior art if the differences between
`
`the subject matter sought to be patented and the prior art are such that the subject
`
`matter as a whole would have been obvious to a person having ordinary skill in the
`
`art in the relevant subject matter at the time the invention was made.
`
`15.
`
`To determine if a claim is obvious, the following factors should be
`
`considered: (1) the level of ordinary skill in the art at the time the invention was
`
`made; (2) the scope and content of the prior art; (3) the differences between the
`
`claimed invention and the prior art; and (4) secondary considerations, including
`
`evidence of commercial success, long-felt but unsolved need, unsuccessful
`
`attempts by others, copying of the claimed invention, unexpected and superior
`
`results, acceptance and praise by others, independent invention by others, and the
`
`like.
`
`16.
`
`For example, I understand that the combination of familiar elements
`
`according to known methods is likely to be obvious when it does no more than
`
`yield predictable results. I also understand that an obviousness analysis need not
`
`seek out precise teachings directed to the specific subject matter of the challenged
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0008
`IPR2018-00276
`
`

`

`claim because a court can take account of the inferences and/or creative steps that a
`
`person of ordinary skill in the art would employ.
`
`17.
`
`I understand that the obviousness determination of an invention turns
`
`on whether a hypothetical person with ordinary skill and full knowledge of all the
`
`pertinent prior art, when faced with the problem to which the claimed invention is
`
`addressed, would be led naturally to the solution adopted in the claimed invention
`
`or would naturally view that solution as an available alternative. Facts to be
`
`evaluated in this analysis include:
`
`(cid:120) The scope and contents of the prior art;
`
`(cid:120) Differences between the prior art and the claims at issue;
`
`(cid:120) The level of ordinary skill in the pertinent art; and
`
`(cid:120) Evidence of objective factors suggesting or negating obviousness.
`
`(cid:120) I understand that the following rationales may be used to determine whether
`a piece of prior art can be combined with other prior art or with other
`information within the knowledge of one of ordinary skill in the art:
`
`(cid:120) Combining prior art elements according to known methods to yield
`predictable results;
`
`(cid:120) Simple substitution of one known element for another to obtain predictable
`results;
`
`(cid:120) Use of known techniques to improve similar devices (methods, or products)
`in the same way;
`
`(cid:120) Applying a known technique to a known device (method, or product) ready
`for improvement to yield predictable results;
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0009
`IPR2018-00276
`
`

`

`(cid:120) “Obvious to try” - choosing from a finite number of identified, predictable
`solutions, with a reasonable expectation of success;
`
`(cid:120) Known work in one field of endeavor may prompt variations of it for use in
`either the same field or a different one based on design incentives or other
`market forces if the variations would have been predictable to one of
`ordinary skill in the art; or
`
`(cid:120) Some teaching, suggestion, or motivation in the prior art that would have led
`one of ordinary skill to modify the prior art reference or to combine prior art
`reference teachings to arrive at the claimed invention.
`
`18.
`
`I understand that when a work is available in one field of endeavor,
`
`design incentives and/or other market forces, for example, can prompt variations of
`
`it, either in the same field or a different one. Moreover, if a person of ordinary skill
`
`can implement a predictable variation, I understand that that likely bars its
`
`patentability.
`
`19.
`
`I understand that obviousness must be tested as of the time the
`
`invention was made. I understand that the test for obviousness is what the
`
`combined teachings of the prior art references would have suggested, disclosed, or
`
`taught to one of ordinary skill in the art. In particular, it is my understanding that a
`
`patent claim is invalid based upon obviousness if it does nothing more than
`
`combine familiar elements from one or more prior art references or products
`
`according to known methods to yield predictable results. For example, I understand
`
`that where a technique has been used to improve one device, and a person of
`
`ordinary skill in the art would have recognized that it would improve similar
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0010
`IPR2018-00276
`
`

`

`devices in the same way, using that technique is obvious. I understand that
`
`obviousness can be proved by showing that a combination of elements was
`
`obvious to try, i.e.: that it does no more than yield predictable results; implements a
`
`predictable variation; is no more than the predictable use of prior art elements
`
`according to their established functions; or when there is design need or market
`
`pressure to solve a problem and there are a finite number of identified, predictable
`
`solutions. I have been further informed that when a patent claim simply arranges
`
`old elements with each element performing the same function it had been known to
`
`perform and yields results no more than one would expect from such an
`
`arrangement, the combination is obvious.
`
`20.
`
`I understand that another factor to be considered is common sense.
`
`For example, I understand that common sense teaches that familiar items may have
`
`obvious uses beyond their primary purposes, and, in many cases, a person of
`
`ordinary skill will be able to fit the teachings of multiple patents together like
`
`pieces of a puzzle.
`
`21.
`
`I understand that the Supreme Court articulated additional guidance
`
`for obviousness in its KSR decision. My understanding is that the Supreme Court
`
`said that technical people of ordinary skill look for guidance in other solutions to
`
`problems of a similar nature, and that the obviousness inquiry must track reality,
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0011
`IPR2018-00276
`
`

`

`and not legal fictions. I have relied on these understandings in expressing the
`
`opinions set forth below.
`
`22.
`
`I understand that a new use of an old product or material cannot be
`
`claimed as a new product; the apparatus or system itself is old and cannot be
`
`patented. I further understand that, in general, merely discovering and claiming a
`
`new benefit to an old process cannot render the process newly patentable.
`
`V.
`
`Person of Ordinary Skill in the Art
`
`23.
`
`For purposes of this declaration, I have been asked to apply the
`
`following standard for a person of ordinary skill in the art (POSITA) of the subject
`
`matter of the ’111 patent: the POSITA would have had a master’s degree in
`
`electrical engineering, computer science, or a related field, plus 2-3 years of
`
`experience with Universal Serial Bus (“USB”).
`
`VI.
`
`’111 patent background
`
`A.
`
`24.
`
`Summary
`
`The ’111 patent relates to “[a]n adapter for providing a source of
`
`power to a mobile device through an industry standard port.”1 The ’111 patent has
`
`18 claims.
`
`1 ’111 patent at 2:3-4.
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0012
`IPR2018-00276
`
`

`

`B.
`
`25.
`
`Prosecution history
`
`The ’111 patent issued from U.S. Patent Application No. 11/175,885,
`
`which was filed on July 6, 2005.2
`
`26. On November 20, 2005, the examiner rejected the pending claims
`
`based on U.S. Patent No. 6,130,518 (“Gabehart”).3 In response, the applicant
`
`argued that Gabeheart “does not disclose or suggest the generation of an
`
`identification signal which is configured to indicate to the mobile device that the
`
`power socket is not a USB host or hub.”4
`
`27. On April 4, 2006, the examiner issued another non-final rejection, this
`
`time rejecting the pending claims based on U.S. Patent App. Publication No.
`
`2004/0251878 (“Veselic”).5 In response, the applicant argued that Veselic is not
`
`prior art.6
`
`28. On August 24, 2006, the examiner rejected all pending claims based
`
`upon nonstatutory obviousness-type double patenting over the claims of copending
`
`U.S. App. No. 10/087,629.7 In response, the applicant filed a terminal disclaimer.8
`
`2 ’111 file history at 1.
`3 ’111 file history at 82-86.
`4 ’111 file history at 94-95.
`5 ’111 file history at 97-100.
`6 ’111 file history at 103-104.
`7 ’111 file history at 125-128.
`8 ’111 file history at 133-139.
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0013
`IPR2018-00276
`
`

`

`29.
`
`In response, the examiner issued a notice of allowance,9 leading to the
`
`issuance of the ’111 patent.10 Following the ’111 patent’s issuance, the applicant
`
`requested a certificate of correction to correct “minor and editorial” mistakes.11 On
`
`December 18, 2007, the U.S. Patent Office issued a Certificate of Correction.12
`
`C.
`
`30.
`
`Priority date
`
`The ’111 patent claims priority through a continuation to two
`
`provisional applications: (1) U.S. Provisional Application No. 60/273,021 (“the
`
`’021 provisional”), filed March 1, 2001; and (2) U.S. Provisional Application No.
`
`60/330,486 (“the ’486 provisional”), filed October 23, 2001. My analysis in this
`
`declaration applies even if the claims are entitled to the March 1, 2001 filing date.
`
`VII. Technology background & State of the Art
`
`31. As of March 1, 2001 (the ’111 patent’s claimed priority date),
`
`POSITAs would have had the following background knowledge of the state of the
`
`art.
`
`A.
`
`32.
`
`USB Architecture
`
`POSITAs would have had the following background knowledge about
`
`USB architecture.
`
`9 ’111 file history at 144.
`10 ’111 file history at 162.
`11 ’111 file history at 163.
`12 ’111 file history at 167.
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0014
`IPR2018-00276
`
`

`

`33.
`
`Since its inception in 1995, the USB Implementers Forum, Inc.
`
`(“USB-IF”) has been responsible for the advancement and adoption of USB
`
`technology. As of December 2000, USB-IF had more than 900 member companies
`
`that helped facilitate the development of USB.
`
`34. USB-IF standardized USB technology in the USB specification and
`
`its various revisions. On September 23, 1998, USB-IF released Universal Serial
`
`Bus Specification, Revision 1.1 (“USB 1.1”), which was widely adopted by
`
`industry leaders and consumers. On April 27, 2000, USB-IF released USB
`
`Revision 2.0 (“USB 2.0”).13 Among USB 2.0’s improvements were faster speeds
`
`and additional functionality. Like USB 1.1, USB 2.0 was widely adopted by the
`
`industry.
`
`35. USB 1.1 and 2.0 specified the architecture for a USB system.
`
`Generally, a USB system includes a USB host, one or more USB devices, and a
`
`USB interconnect.14 A USB host (e.g., a laptop computer system) interacts with
`
`USB devices and is responsible for tasks such as (i) detecting the attachment and
`
`removal of USB devices; (ii) managing control and data flow between the host and
`
`USB devices; (iii) collecting status and activity statistics; and (iv) providing power
`
`13 USB 2.0 at 1.
`14 USB 2.0 at 15; USB 1.1 at 15.
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0015
`IPR2018-00276
`
`

`

`to attached USB devices.15 A USB device connects to the USB host, and falls into
`
`one of two categories: (i) a hub, which has the ability to provide additional USB
`
`attachment points, or (ii) a function, which is a device that is able to transmit or
`
`receive data or control information over the USB bus (e.g., a peripheral device,
`
`such as a keyboard, mouse, or mobile phone).16 A USB interconnect is the manner
`
`in which USB devices are connected and communicate with the host.17 The
`
`following figure depicts a typical USB architectural configuration of a USB host,
`
`interconnect, and devices:18
`
`USB 2.0 Figure 4-4.
`
`15 USB 2.0 at 24; USB 1.1 at 24.
`16 USB 2.0 at 22-24; USB 1.1 at 21-24.
`17 USB 2.0 at 15; USB 1.1 at 15.
`18 USB 2.0 at Figure 4-4.
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0016
`IPR2018-00276
`
`

`

`36. USB 1.1 and 2.0 also specified the USB cable structure.19 The USB
`
`cable “consist[ed] of four conductors, two power conductors, and two signal
`
`conductors.”20 The following figure from USB 2.0 depicts the four wires within a
`
`USB cable.21
`
`USB 2.0 Figure 4-2.
`
`VBUS and GND deliver power, and D+ and D- carry signals for communication
`
`between a USB host and the connected device.22
`
`37. USB 1.1 and 2.0 also specified the USB connector structure.23 For
`
`example, USB 1.1 and USB 2.0 specified Series “A” and Series “B” connectors.24
`
`“Table 6-1 provides the standardized contact terminating assignments by numbers
`
`and electrical value for Series ‘A’ and Series ‘B’ connectors.”25
`
`19 USB 2.0 at 86; USB 1.1 at 74.
`20 USB 2.0 at 86; USB 1.1 at 74.
`21 USB 2.0 at Figure 4-2.
`22 USB 2.0 at 17-18; USB 1.1 at 17.
`23 USB 2.0 at 85, 94; USB 1.1 at 73, 82.
`24 USB 2.0 at 85, 94; USB 1.1 at 73, 82.
`25 USB 2.0 at 94; USB 1.1 at 82.
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0017
`IPR2018-00276
`
`

`

`USB 2.0 Figure 4-2.
`
`According to USB 1.1 and USB 2.0, “[a]ll USB devices must have the standard
`
`Series ‘A’ connector.”26 “The ‘B’ connector allows device vendors to provide a
`
`standard detachable cable.”27
`
`USB 2.0 Figure 6-1.
`
`26 USB 2.0 at 85; USB 1.1 at 73.
`27 USB 2.0 at 85; USB 1.1 at 73.
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0018
`IPR2018-00276
`
`

`

`B.
`
`USB Device Configuration and Detection
`
`38. USB 2.0 also specified how the USB host is to configure a USB
`
`device. For example, USB 2.0 stated that “[w]hen a USB device is attached to or
`
`removed from the USB, the host uses a process known as bus enumeration to
`
`identify and manage the device state changes necessary.”28 In its “Bus
`
`Enumeration” section, USB 2.0 specified the bus-enumeration requirements,
`
`including eight actions taken “[w]hen a USB device is attached to a powered
`
`port.”29
`
`39. USB 2.0 also specified how to detect when a low- or high-speed USB
`
`device is attached to a downstream facing port of a host or hub.30 According to
`
`USB 2.0, “[f]ull-speed devices are terminated . . . with the pull-up resistor [Rpu] on
`
`the D+ line.” This termination constitutes a hard-wired connection of a voltage
`
`level to the D+ data line because, as USB 2.0 states, “[t]he voltage source on the
`
`pull-up resistor [Rpu] must be derived or controlled by the power supplied on the
`
`USB cable such that when VBUS is removed, the pull-up resistor does not supply
`
`current on the data line to which it is attached.”31 Similarly, low speed devices are
`
`terminated with a pull-up resistor, but are done so on the D- line (as opposed to the
`
`28 USB 2.0 at 243.
`29 USB 2.0 at 243.
`30 USB 2.0 at 141.
`31 USB 2.0 at 141.
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0019
`IPR2018-00276
`
`

`

`D+ line).32 This hard-wired connection of a voltage level to one or more USB data
`
`lines through a pull-up resistor, Rpu, is illustrated by Figures 7-20 and 7-21 of USB
`
`2.0, below:
`
`USB 2.0 Figures 7-20 and 7-21.
`
`C.
`
`USB Current and Voltage Limits
`
`40. USB 2.0 also imposed certain current and voltage limits on VBUS.
`
`For example, USB 2.0 limited a USB device’s current draw on VBUS to “one unit
`
`load [i.e., 100 mA] or less until configured.”33 USB 2.0 also stated that
`
`“[d]epending on the power capabilities of the port to which the device is attached,
`
`a USB device may be able to draw up to five unit loads [i.e., 500 mA] from VBUS
`
`32 USB 2.0 at 141.
`33 USB 2.0 at 245.
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0020
`IPR2018-00276
`
`

`

`after configuration.”34 As shown below, USB 2.0 also imposed a 5.25 V limit on
`
`the VBUS line.35
`
`USB 2.0 Table 7-7 (in part).
`
`D.
`
`USB Signaling States
`
`41. USB 2.0 also specified different signaling states on the D+ and D-
`
`lines.36 Some of these states (e.g., Differential 0, Differential 1, Data J State, and
`
`Data K State) transmit data while others (e.g., Single-ended 0, Single-Ended 1) are
`
`used as specific signaling conditions.37
`
`E.
`
`42.
`
`Auxiliary USB Ports
`
`POSITAs also understood that power could be delivered to more than
`
`one USB port on a USB adapter or hub. For example, Amoni describes a USB-
`
`connected hub which “provides for the communication of auxiliary (non-standard
`
`USB) voltage and current to downstream hub and peripheral devices . . . over an
`
`34 USB 2.0 at 245.
`35 USB 2.0 at 175, 178.
`36 USB 2.0 at 123.
`37 USB 2.0 at 144-146, Table 7-2.
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0021
`IPR2018-00276
`
`

`

`enhanced USB connection, whereby standard USB signaling is provided along
`
`with the auxiliary power.”38 Amoni’s auxiliary hub 300 “provides for three
`
`auxiliary powered USB ports 303, 305 and 307, although more could be added.”39
`
`Amoni FIG. 3 (annotated).
`
`43. Amoni’s hub 300 “contains its own AC/DC power supply 301, which
`
`is capable of outputting at least one voltage other than 5 volts (i.e., at least one
`
`auxiliary voltage) and can produce a plurality of voltages including the USB
`
`standard +5 volts” to the auxiliary USB ports 303, 305, and 307.40 Through the use
`
`38 Amoni at 2:33-39.
`39 Amoni at 5:11-12.
`40 Amoni at 5:20-27.
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0022
`IPR2018-00276
`
`

`

`of auxiliary USB ports, Amoni’s USB hub 300 may generate a range of power
`
`outputs to connected auxiliary USB devices.41
`
`VIII. Claim Construction
`
`44.
`
`For purposes of this proceeding, in which I understand the standard
`
`for claim construction is the broadest reasonable interpretation (BRI) standard, I
`
`have been asked to apply the interpretations of the claim terms in the table below.
`
`Claim Term
`
`means for receiving energy
`from a power socket
`
`means for regulating the
`received energy from the
`power socket to generate a
`power output
`
`Interpretation that I was asked to apply in this
`proceeding (in which the BRI standard applies)
`Function: receiving energy from a power socket
`
`Corresponding Structure: a plug unit and/or plug
`adapter compatible with a North American power
`socket, a UK power socket, a European power
`socket, or a car power socket; and the equivalents
`thereof.
`
`Function: regulating the received energy from the
`power socket to generate a power output
`
`Corresponding Structure: power converter
`104/304 including at least one of a switching
`converter, a transformer, a DC source, a voltage
`regulator, a linear regulator, or rectifier; and the
`equivalents thereof.
`
`41 Amoni at 5:9-39.
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0023
`IPR2018-00276
`
`

`

`Claim Term
`
`means for generating an
`identification signal that
`indicates to the mobile device
`that the power socket is not a
`USB hub or host
`
`means for coupling the power
`output and identification
`signal to the mobile device
`
`Interpretation that I was asked to apply in this
`proceeding (in which the BRI standard applies)
`Function: generating an identification signal that
`indicates to the mobile device that the power
`socket is not a USB hub or host
`
`Corresponding Structure: identification
`subsystem 108, and equivalents thereof.
`
`Function: coupling the power output and
`identification signal to the mobile device
`
`Corresponding Structure: USB connector 102
`and USB connector 54; and equivalents thereof.
`
`45.
`
`For every other claim term, I have applied the plain meaning of the
`
`term to persons of ordinary skill in the art.
`
`IX. Ground 1: Claims 1-3, 6-8, and 16-18 are obvious in light of Theobald
`and Shiga
`
`A.
`
`46.
`
`Theobald
`
`Theobald discloses the charging system shown below.42
`
`42 Theobald at 2:17.
`
`Geier Declaration
`
`
`
`IPR2018-00276
`ZTE/SAMSUNG 1009-0024
`IPR2018-00276
`
`

`

`Theobald FIG. 1 (annotated).
`
`The charging system 100 includes a base station 101 (yellow) in wireless
`
`communication with