UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
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`Google LLC
`Petitioner
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`v.
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`Cywee Group Ltd.
`Patent Owner
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`____________________
`
`Case IPR2018-01257
`Patent No. 8,552,978
`____________________
`
`DECLARATION OF GARY L. BLANK, PH.D.
`September 14, 2018
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`Table of Contents
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`Case IPR2018-01257
`Patent No. 8,552,978
`Declaration of Gary L. Blank, Ph.D.
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`I. INTRODUCTION ............................................................................................. 4
`I. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE ..................... 4
`II. LEVEL OF ORDINARY SKILL IN THE ART AND RELEVANT LEGAL
`STANDARDS ........................................................................................................ 20
`A. Level of Ordinary Skill ............................................................................ 20
`B. Relevant Legal Standards ........................................................................ 22
`III. U.S. PATENT 8,552,978 (THE “‘978 PATENT”) ..................................... 25
`A. Specification and Prosecution History ................................................... 25
`B. Background of the Technology ............................................................... 31
`1. Prior Art Techniques ....................................................................... 31
`2. Quaternion Mathematics for Calculating Orientation ................. 35
`IV. CLAIM CONSTRUCTION .......................................................................... 42
`A. “Comparison” ........................................................................................... 43
`B. “Spatial Pointer Reference Frame” ........................................................ 43
`C. “3D Pointing Device” ............................................................................... 43
`V. REFERENCES RELIED ON BY THE PETITIONER ............................... 44
`A. U.S. Patent 7,089,148 to Bachmann (Bachmann, Exhibit 1004) .......... 44
`B. U.S. Patent Application Publication No. US 2004/0095317 to Zhang
`(Zhang, Exhibit 1005) .............................................................................. 45
`C. U.S. Patent 7,158,118 to Liberty (“Liberty”) .......................................... 47
`VI. BACHMANN DOES NOT QUALIFY AS ANALGOUS ART .................. 48
`VII. NONE OF PETITIONER’S ASSERTED CHALLENGES ESTABLISH
`OBVIOUSNESS .................................................................................................... 49
`A. Claim 10 is Not Obvious over Zhang in View Of Bachmann ............... 51
`1. Zhang in View of Bachmann Does Not Disclose or Suggest “a 3D
`Pointing Device” ............................................................................... 51
`2. There Can Be No Motivation to Combine Zhang and Bachmann 54
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`Patent No. 8,552,978
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`B. Dependent Claim 12 is Not Obvious over Zhang In View Of Bachmann
`.................................................................................................................... 55
`C. Claim 10 is Not Obvious over Liberty in View Of Bachmann ............... 56
`VIII. CONCLUSION ........................................................................................ 56
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`Case IPR2018-01257
`Patent No. 8,552,978
`Declaration of Gary L. Blank, Ph.D.
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`INTRODUCTION
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`I make this Declaration at the request of CyWee Group, Ltd, LLC regarding
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`I.
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`1.
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`my opinions as an independent expert regarding issues raised in the matter of
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`Petition IPR2018-01257 (“Petition”).
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`2.
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`I am being compensated for this work, and my compensation is not
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`dependent on the outcome of this matter.
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`3.
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`In preparation for this Declaration, I studied Exhibits 1001 – 1011 provided
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`by Petitioner as well as the Petition.
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`4.
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`In preparing this Declaration, I relied, in addition to the above Papers and
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`other documents, on my knowledge and experience gained through 50 years as an
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`engineer, professor, and consultant.
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`I.
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`QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
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`5. My Curriculum Vitae is provided as Exhibit 2002. Following is a summary
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`of my education and relevant experience.
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`6.
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`Educational Background
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`As a 15-year old Senior in High School, I applied for scholarships at
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`top Engineering Schools. I was awarded a 4-year scholarship, (all tuition,
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`books, supplies and living expenses) by the Ingersoll Foundation. I received
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`a Bachelor of Science degree in electrical engineering with a minor in
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`mathematics from the Illinois Institute of Technology. I was elected by IIT
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`to be published in “Who’s Who Among Students in American Universities
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`and Colleges 1958-1959”, page 92. I was then awarded a 1-year fellowship
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`(all tuition, books, supplies and living expenses) by the Kaiser Foundation,
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`and received a Master of Science degree in electrical engineering with a
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`minor in mathematics from the University of Idaho, completing and
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`publishing a thesis on Control Systems. I was then awarded a 3-year
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`fellowship (all tuition, books, supplies and living expenses) and received a
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`Ph.D. in electrical engineering with a minor in mathematics from the
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`University of Wisconsin, Madison, completing the requirements at the age
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`of 23 years old. My research work, on the subject of Digital Nonlinear
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`Control Systems, was published and presented at many conferences.
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`7.
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`I have divided my professional experience between academia and industry.
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`Experience in Academia includes:
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`After receiving my Ph.D., I held full-time academic positions at
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`Marquette University (1964-67), Northern Illinois University (“NIU”)
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`(1982-86), and Illinois Institute of Technology (1986-1991). I also held
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`part-time adjunct faculty positions for the University of Florida (1963-64),
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`and the University of California, Los Angeles (1967-81). At NIU, I was
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`involved in the creation of the Electrical Engineering Curriculum (which
` Exhibit 2001 / Page 5 of 59
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`Case IPR2018-01257
`Patent No. 8,552,978
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`was accredited) and the launch of the Department of Electrical Engineering.
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`At all 3 full-time faculty positions I consulted in Industry part-time and was
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`successful in achieving grants from industry to support the research of my
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`graduate students, and placing the students in industrial positions. At NIU, I
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`also obtained the patent for the first velocity controller for brushless dc-
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`motors.
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`Experience in Industry includes:
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`• Honeywell Aero Division – space navigation (secret clearance),
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`• Litton Guidance & Control (Northrop Grumman Systems) – military
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`navigation (secret clearance),
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`• General Motors – gyroscopes (secret clearance),
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`• Ingersoll Milling Machine Co. – auto-industry manufacturing,
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`• Chicago Aerial Industries (Recon Optical) – space lab camera control
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`(secret clearance), and Burroughs Corp. (Unisys) – computer storage.
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`• As an electrical engineering consultant, I have worked for over 30
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`companies:
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`• Parker Hannifin – aircraft navigation control,
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`• L-3 Communications – reconnaissance systems,
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`• Oshkosh Truck – military navigation,
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`• Danfoss Drives – brushless DC motor control,
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`• Allied Healthcare Products, Inc. – respirators and heart-monitoring
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`equipment,
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`• MPC Products Corp. (Woodward Co.) – aircraft control,
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`• Andrew Corporation, - wireless communication hardware and software,
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`• Kohler Co. – manufacture generators,
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`• Recon Optical Inc. – space-lab camera control,
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`• Barber-Colman Co. - control and measurement instruments,
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`• Rockwell-Collins – aviation visual equipment,
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`• Lucent Technologies (AT&T) – communication control equipment,
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`• Woodward Governor Co. – helicopter navigation and control,
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`• Hamilton Sundstrand UTC (United Technology Co. Aerospace Systems)
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`– aerospace navigation,
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`• Ansco Photo Optical – camera systems,
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`• Data Specialties Inc. – computer data storage,
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`• US Dept. of Energy – solar panels, turbines, microgrid, and electric
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`vehicles,
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`• Honeywell – motor control,
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`• Northrop Electromechanical – aircraft navigation and control,
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` Exhibit 2001 / Page 7 of 59
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`• TRE Electromask – optical lithography,
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`• System Technika – robotic control,
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`• Pertec Corp. - hybrid circuits and electronics,
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`• Micropolis Corp. - disk drives,
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`• Xerox Corp- copy machine controls,
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`• EMM Sesco - Integrated circuit manufacturer,
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`• Terminal Data Corp. - high-speed microfilm devices,
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`• Hughes Aircraft – military aircraft control,
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`• Litton Guidance & Control (Northrop Grumman Systems) – military
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`navigation,
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`• Litton Data Systems – PCB Printed Circuit Board design,
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`• Unisys Corp.- computer system design,
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`• Teledyne Systems – aerospace electronics,
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`• General Motors – navigation systems,
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`• A.O. Smith Co. – control systems for gasoline dispensers,
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`8.
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`The Institute of Electrical and Electronics Engineers, Inc. (“IEEE”) is the
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`largest professional, technical organization in the world. There are 200,000
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`members in the USA. I was elected by the members to serve as the IEEE-USA
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`President in 2014.
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` Exhibit 2001 / Page 8 of 59
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`Prior to being elected my involvement in the organization included:
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`Case IPR2018-01257
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`• Starting the IEEE Automatic Control Chapter in Milwaukee.
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`• Started IEEE Student Chapters in various sections and organized student
`conferences.
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`• Started IEEE Consultant Networks in about 20 cities and the first
`overseas Consultants Networks in Canada and Jamaica. There are now
`over 40 IEEE Consultant Networks in the USA and 8 IEEE Consultant
`Networks overseas.
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`• Appointed Chairman of the growing Alliance of IEEE Consultants
`Networks (AICN)
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`• Elected by IEEE-USA members to be their “Member-at-Large” to
`represent their interests on the Board of Directors.
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`• Elected by the Board of IEEE-USA as its Vice-President of Career and
`Member Services. Responsibilities include overseeing the Consultants
`Networks Committee, Employment and Career Services Committee (I
`started this committee to help unemployed members to find jobs), K-12
`STEM Committee, Licensure and Registration of Professional Engineers
`Committee, and Entrepreneurial Activities Committee.
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`I was the first President of IEEE to never have served as one of the six Region
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`Directors of the organization. My election was unanimous amongst the six regions
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`and my margin of votes was overwhelming in each region (approximately two-to-
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`one).
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`My objectives as President for IEEE included:
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` (1) A strong improved financial year with income substantially exceeding
`expenses instead of a recent series of losses or light underspending, by
`utilizing fundamental financial management strategies.
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`(2) A reversal of the consistent negative membership trend of the prior
`several years by increasing member involvement, and the utilization and
`awareness of the IEEE-USA’s products and services.
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`(3) Increasing public visibility, public relations, shaping public policy, and
`building and supporting the careers of the members.
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`(4) Emphasizing the importance and relevance of young professionals,
`women members, and student members, and re-directing many
`existing programs and creating new ones to achieve these goals.
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`The IEEE 2014 End-of-Year report, quoted immediately below, outlined my
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`success in achieving those objectives (appendices A and B referenced by the report
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`have been omitted)::
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`(1) FINANCIAL The operational budget for 2014 was a little less than in
`previous years, just over $5 million for the year. Prior to this, there had
`been a few years where the budgeted expenses exceeded the income, and
`sometimes a small underspending resulted. By carefully watching
`expenses and maximizing income, a new record was established in
`2014 when the underspending was over a half million dollars (left over at
`the end of the year) providing seed money for new career and
`professional programs and services. This extraordinary financial year
`facilitated the purchase of a special expensive asset. This asset will be
`described later in this report.
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`(2) MEMBERSHIP
`Sections and Regions. Four times during the year, President Blank
`personally contacted the chairs of the 170 Sections within all 6 Regions
`about this subject, helping, sharing ideas, and encouraging them. He
`created a 29-minute DVD video “Leading The Way With IEEE-USA”
`emphasizing the dozens of services, products, and discounts available to
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`members. He sent copies to every Section chair to be used to interest
`prospects to become members, to remind current members to renew, and
`to inspire past members to return. By the end of August two Regions
`were well ahead of the previous year and the others were almost there
`too.
`Membership Development President Blank successfully urged the Board
`to elevate the IEEE-USA Membership Development Committee from an
`ad hoc committee to a standing committee. This emphasizes the
`importance of membership development.
`Recognition At the IEEE-USA Annual Meeting in Rhode Island, President
`Blank recognized individuals who made successful membership referrals,
`and also Sections achieving positive net growth, and he invited them to
`share their success stories with an audience composed of IEEE-USA
`volunteer leaders.
`Strategic Discussions President Blank changed the format of the Board of
`Directors meetings. Two hours of the meeting time were planned at each
`meeting, deviating from the customary agenda, to have a strategic
`discussion. Leaving the open meeting room, retiring to a closed room and
`inviting certain experienced members to join the Board members, groups
`met at small tables to discuss topics chosen by President Blank. At the
`end of the two-hour session each table reported on its high points of the
`designated topic. At the first strategic session at the first meeting the
`subject was “IEEE-USA in 2024”. At the other Board meetings, the
`topics for the strategic session were “What can IEEE-USA do to engage
`Young Professionals” and “What changes should IEEE-USA make to
`increase the value of membership”. The answers and ideas collected from
`these strategic discussions are being used to format plans designed to
`enhance membership value and relevance.
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`(3) PUBLIC VISIBILITY
`Outreach Following an IEEE Board Meeting in Rio de Janeiro, Brazil,
`President Blank led a group of Board members on outreach visits to
`engineering universities and companies in Porto Alegre, Brazil. The
`group met with faculty members and company executives.
`Ethics IEEE-USA co-sponsored the first IEEE International Symposium
`on Ethics in Engineering, Science, and Technology. President Blank was
`the keynote speaker on “Ethics”.
`Engineering Management The IEEE International Technology
`Management Conference was held in June in Chicago. President Gary
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`Blank was the keynote speaker on the subject “Management in Science
`and Engineering”.
`Google and Microsoft IEEE-USA President Blank was invited as a guest
`to visit both Google and Microsoft in Seattle.
`Sections Congress Amsterdam President Blank presented a one-hour
`tutorial session on consulting at the IEEE Sections Congress.
`Publications IEEE-USA in ACTION was the quarterly interactive e-zine
`(2010 to 2014) distributed to 200,000+ members, focused on member
`issues, news, products, and services. In 2014, it received an APEX 2014
`Grand Award in the Electronic Media (non-profit) category, one of only
`100 Grand Awards given out of 2075 entries. In 2014 IEEE-USA phased
`out both IEEE-USA in ACTION and IEEE-USA TODAY’S
`ENGINEER and announced that the new flagship publication IEEE-USA
`INSIGHT will be launched late 2014 or early 2015. The new publication
`combines and replaces some of the features of the two previous
`publications, streamlines focus, improves mobile, current web, and e-
`commerce capabilities, responding to new trends in the profession.
`New E-Commerce Store The changes were made in 2014 to allow IEEE-
`USA products to be listed and sold in Xplore. For the first time IEEE-
`USA is actively featuring, promoting, selling, and discounting E-Books,
`now having a broader reach and exposure to IEEE members.
`New IEEE-USA Website In 2014, immediately following the launch
`of IEEE-USA INSIGHT, work was begun on the new website. This will
`continue for some time.
`E-Books In 2014, IEEE-USA added 17 new titles to the E-Book Library,
`distributed 60,000 e-books, free and sold. During this year IEEE-USA
`launched the first four books of IEEE-USA’s Women in Engineering e-
`book series. This series provides a global view of women in science,
`technology, engineering, and mathematics (STEM) fields, as well as first-
`hand accounts of the professional journeys of notable contemporary
`female engineers.
`National Engineers Week 2014 IEEE-USA undertook the responsibility
`of being the lead society sponsor of all engineering and technology
`organizations. IEEE-USA President Gary Blank joined in a live webcast
`at the University of Delaware (UD) to kick off National Engineers Week.
`The webcast included discussion by President Blank, UD President
`Patrick Harker, UD Provost Domenico Grosso, UD College of
`Engineering Dean Ogunnaike, DuPont Chief Engineer and Vice-
`President-Engineering Karen Fletcher.
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`Discover Engineering Family Day A capacity crowd of more than 9200
`visitors participated in the 2014 Discover Engineering Family Day at the
`National Building Museum. It was sponsored jointly by IEEE-USA and
`DuPont. The event featured (among others) former Space Shuttle
`astronaut Dr. Robert Crouch. Promotional coverage was provided by the
`local FOX TV affiliate.
`Hill Event on Minorities in Engineering IEEE-USA co-sponsored a
`STEM Salon on Capitol Hill for “Change the Equation” to help
`familiarize Congress with the results of a recent report “Engineering
`Emergency: African Americans and Hispanics Still Lack Pathways in
`Engineering”.
`U.S. Science and Engineering Festival IEEE-USA President Gary Blank
`joined more than 20 volunteers in staffing the IEEE-USA booth and
`exhibit at the 3rd U.S. Science and Engineering Festival (3 days) held in
`Washington, D.C. in April 2014. The largest STEM event held in the
`United States, this festival drew over 1200 exhibitors, offering hands-on
`experience to a crowd of more than 325,000 students, parents, and
`teachers.
`IEEE-USA and Electric Vehicles IEEE-USA featured a booth at the
`International Conference on Connected Vehicles in Vienna, Austria.
`Participants came from many countries including China. President Gary
`Blank was the keynote speaker.
`Asian American Engineers of the Year Awards In March, President Gary
`Blank was invited to attend and participate in the Asian American
`Engineers of the Year Awards Ceremony in San Francisco, California,
`honoring Asian Americans with outstanding achievements in STEM.
`Award winners of the past 12 years included seven Nobel Laureates, as
`well as many corporate executives, managers, engineers, and researchers.
`Support for Special Anniversaries In 2014, IEEE-USA showed support
`for entities celebrating special anniversaries. President Gary Blank was
`invited, attended and spoke at the following celebrations: IEEE San
`Diego Section’s 75th Anniversary; IEEE Rochester, New York Section’s
`100th Anniversary; IEEE Seattle Section’s 110thAnniversary; UCLA
`Student Chapter’s 50th Anniversary.
`App-E-Feat Competition As a Special Project for 2014, this competition
`challenged students, aged 13-18, and IEEE Student Members, to propose
`or design mobile applications to help solve global problems. App-E-Feat
`fulfills IEEE’s service commitment as a participant in the Clinton Global
`Initiative.
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`IEEE-USA 2014 Salary Survey IEEE-USA completed its 2014 Salary &
`Benefits Survey in May, receiving almost 17, 000 responses (a possible
`record) from Higher Grade Members. The results were published in
`September. In November five specialty reports were released
`highlighting data derived from the survey focusing on salary trends for
`computing, communications, circuits and devices, power and energy, and
`systems and controls.
`IEEE-USA Webinars In 2014, IEEE-USA delivered 20 webinars on
`career and professional topics. In addition to legislative updates, IEEE-
`USA offered such topics as Business Models & Value Propositions,
`Finding the Right People Using Linked-In, The Power of Presentations,
`So you want to be An Entrepreneur, The Software Engineering PE Exam,
`Starting Your Start-Up, Consulting 101 and 102 (by President
`Blank). All webinars have been archived for future viewing.
`IEEE Consultants Networks Managed by IEEE-USA, the Consultants
`Network of all consultants world-wide has grown to a new high of 1845
`members (including President Blank) in 2014. And there has been an
`increase of 48% over last year of the number of consultants publishing
`their resumes in the IEEE-USA on-line Directory to be found by
`potential clients. IEEE-USA published its 2014 Consultants Fee Survey
`Report in November.
`IEEE-USA Consultants Workshops IEEE-USA President Gary Blank,
`along with volunteers and staff, conducted 3 consultants training
`workshops: April 12, Los Angeles/Orange County Networks in Pomona,
`CA; September 13, Central Texas Section Network, in Austin, TX;
`November 15, Canaveral and Melbourne Sections in Cocoa, FL.
`Launched President Blank created and formally launched both IEEE-
`USA’s Employment Networks, designed to provide help for unemployed
`members, and IEEE-USA’s Entrepreneur Networks, intended to help
`members interested in starting independent businesses.
`Entrepreneurial Activities In June 2014, IEEE-USA partnered with the
`Small Business Administration on a webinar, introducing IEEE members
`to SBA’s Online Training Programs. In December, IEEE-USA convened
`its Small Technology Business Symposium, to discuss technology
`entrepreneurs’ needs. This event was held in the U.S. Senate Small
`Business Committee Hearing Room with representatives from the White
`House Office of Science and Technology, the U.S. Trade
`Representative’s Office, the Department of Commerce, the U.S. Patent
`and Trademark Office, the Department of State, the Export/Import Bank,
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`the U.S. Small Business Administration, and the Senate Small Business
`Committee Staff attending.
`STEM National Leadership Conference IEEE-USA participated as a
`supporting organization in the STEM Solutions National Leadership
`Conference, convened by U.S. News and World Report, in April in
`Washington, D.C. The focus of the conference was to discuss ways to
`advance the national STEM agenda.
`Federal Travel Restrictions and STEM Conferences On July 25,
`President Gary Blank represented IEEE-USA and joined other societies
`in a meeting with representatives of federal departments and agencies,
`hosted by the Army Research Laboratory in Adelphi, MD, to discuss the
`impact of federal government restrictions on scientific and technical
`conference attendance.
`Public Policy Priority Issues 1. Intelligent Transportation On October
`20, IEEE-USA submitted a letter to the Department of Transportation,
`signed by President Blank, with comments pertaining to the development
`of federal regulations concerning vehicle-to-vehicle
`communication; 2. Innovation Policy On September 23, IEEE-
`USA submitted comments to the President’s Office of Science and
`Technology, as input to a proposed U.S. Strategy for American
`Innovation, on ways the Administration could help small technology
`companies prosper; 3. Patent Reform On March 14, President Blank
`sent a letter on behalf of IEEE-USA to the Senate, stating IEEE-USA’s
`opposition to the Transparency in Assertion of Patents Act; 4. K-12
`STEM Education On October 16, President Blank, on behalf of IEEE-
`USA, endorsed a Dear Colleague letter from Reps. Kilmer and Buchon of
`the House Science Committee to other members of Congress, calling for
`support of the National Science Foundation’s efforts to develop AP
`Engineering and Computer Science Principles course curricula for use in
`high schools; 5. Skilled Immigration Reform The Comprehensive
`Immigration Act that the Senate ultimately passed contained a number of
`provisions in an IEEE-USA letter from President Blank, including
`language to prevent outsourcing companies from using H1-B visas, and
`to create new green cards for international graduate students. IEEE-USA
`also worked to influence the White House’s executive proposals on
`immigration; 6. Quadrennial Energy Review As a result of a joint effort
`between IEEE-USA and the IEEE Power and Energy Society, a letter
`was submitted by IEEE-USA President Blank with preliminary
`comments to the U.S. Department of Energy as input to the
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`1st Quadrennial Energy Review. The working group followed up with a
`meeting and its final report to the DOE. Melanie Kenderdine, director of
`the Office of Energy Policy and Systems Analysis commended our
`efforts and described our contributions as “very, very helpful”.
`Position Statements In 2014, on behalf of IEEE-USA with the help of
`staff, President Blank released 10 new or updated position statements
`on: Air Force Office of Scientific Research, Cybersecurity, Low Cost
`Access to Space, Space-Borne Synthetic Aperture Radar, Energy
`Efficiency, Small Business Innovation Research, High-Value Job Growth
`through Manufacturing Innovation, Digital Millennium Copyright Act
`Encryption Research, Digital Rights Management, and Disclosure of
`Intellectual Property Assignment Agreements.
`Policy Statements IEEE-USA released 40 policy communications to
`Congress and the Executive Branch on an array of topics in 2014,
`including: federal conferencing and travel spending; relocation of the Air
`Force Office of Scientific Research; federal R&D appropriations for
`FY2014 and FY2015; renewal of the R&D tax credit; funding for
`advancing computing programs; patent reform; reauthorization of
`FY2014 civilian S&T programs; and U.S. spectrum policy.
`Congressional Visits Day The 2014 Science, Engineering and Technology
`Congressional Visits Day, a multi-society event, drew more than 200
`scientists and engineers as advocates for strong federal investments in
`R&D. 38 IEEE-USA members participated in 67 congressional visits.
`Air Force Office of Scientific Research In a letter from President Blank,
`IEEE-USA successfully advocated against an Air Force proposal to
`relocate its Office of Scientific Research. IEEE-USA expressed concern
`about the impact of the move on AFOSR’s ability to sustain its basic
`research mission. Air Force Secretary Deborah Lee James confirmed a
`final decision to not relocate in both a Senate Armed Services Committee
`hearing and in a subsequent response to IEEE-USA.
`State Department Science and Technology Advisor IEEE-USA
`President Gary Blank was invited to the U.S. State Department to
`participate in a meeting to discuss the role of the Science & Technology
`Advisor at State, and the primary considerations for selecting the next
`Advisor.
`Presidential Citation to U.S. Senator and Washington Governor IEEE-
`USA President Gary Blank presented a Presidential Citation to U.S.
`Senator Maria Cantwell, D-Wash., in conjunction with her keynote
`address at the IEEE Seattle Section 110th Anniversary Gala. The citation
` Exhibit 2001 / Page 16 of 59
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`Case IPR2018-01257
`Patent No. 8,552,978
`Declaration of Gary L. Blank, Ph.D.
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`recognized her efforts to create jobs and expand educational
`opportunities in STEM. The Senator later invited President Blank to visit
`her in her office on Capitol Hill. President Blank also presented a
`Citation to Washington Governor Jay Inslee for his efforts in creating
`jobs in STEM.
`Engineering Societies Public Policy Symposium IEEE-USA co-
`sponsored the symposium held in conjunction with the American
`Association of Engineering Convocation. President Gary Blank met with
`and introduced the keynote speaker—the Honorable Daniel Poneman,
`Deputy Secretary of Energy. Poneman highlighted the Department of
`Energy’s priority initiatives including the President’s Climate Action
`Plan.
`The MOVE Project An initiative was introduced at one of the Board
`meetings in early 2014. The cost would be about $60,000 to purchase a
`special vehicle. The IEEE-USA’s Community Outreach Initiative will
`provide a mobile emergency relief program committed to assisting
`victims of natural disasters with short-term communications, computer,
`and power solutions. These temporary emergency relief services will help
`people stay connected and make sure they can access the help they need.
`Services included will cell phone charging, communications support, and
`lighting to disaster victims. When it is not being used for emergency
`services the mobile vehicle will provide a learning opportunity for the
`general public in the area of STEM. The money for the vehicle was not
`available in the operational budget, so the effort met with resistance from
`the Board. President Blank encouraged the Board to table the motion and
`review it later in the year. As the year progressed and the record-setting
`financial savings from IEEE-USA’s annual budget became a reality, the
`IEEE Foundation agreed to fund the project.
`Ignite Ignite is a presentation format in which a speaker has exactly 5
`minutes and must use 20 slides with each slide automatically advancing
`after 15 seconds, forcing the speaker to present his point effectively and
`quickly. President Blank was the first speaker to experiment with this
`technique at the IEEE Sections Congress in Amsterdam. His subject was
`Consultants Networks.
`Patents and Standards During the year IEEE-USA President Blank was
`contacted by phone and email by several members of the Department of
`Justice and by dozens of company executives in the USA and overseas
`about various aspects of patents and standards.
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` Exhibit 2001 / Page 17 of 59
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`Case IPR2018-01257
`Patent No. 8,552,978
`Declaration of Gary L. Blank, Ph.D.
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`IEEE-USA Sponsored Conferences A full schedule (a record high of 15
`conferences) were sponsored and supported by IEEE-USA in 2014.
`See Appendix A.
`YOUNG MEMBERS, WOMEN MEMBERS, AND STUDENT
`MEMBERS
`Young Professional Board Member. The IEEE-USA Board has always
`included a representative from the Young Professionals. According to
`IEEE Rules, only Senior Members are allowed to vote on a Board. Since
`most Young Professionals are not yet Senior Members, the representative
`on the IEEE-USA Board had never been allowed to vote on any issue.
`President Blank personally approached and discussed this subject with
`IEEE Legal Staff, requesting that an exception be made to allow this
`representative to have a vote on this Board at all Board meetings. His
`request was granted and the YP is now a voting member.
`New Direction for Student Professional Awareness Events In 2014,
`there were 60 Events, the highest number on record for any year.
`See Appendix B. On this, its 35th anniversary, there were many
`improvements made. The new program changed its name from SPAC
`(Student Awareness Professional Confere