UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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`SONY CORPORATION and
`POLYCOM, INC.
`Petitioners
`v.
`REALTIME ADAPTIVE STREAMING, LLC
`Patent Owner
`____________
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`Case No. IPR2018-01413
`Patent 9,769,477
`____________
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`DECLARATION OF DR. CHANDRAJIT BAJAJ
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`Table of Contents
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`I. BACKGROUND AND QUALIFICATIONS ............................................... 3
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`II. LEGAL FRAMEWORK ............................................................................ 10
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`III. OPINION ..................................................................................................... 16
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`A. LEVEL OF SKILL OF A PERSON HAVING ORDINARY SKILL IN THE ART .......... 16
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`B. CLAIM CONSTRUCTION ............................................................................... 18
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`C. BACKGROUND OF THE TECHNOLOGY ........................................................... 18
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`1. Data Compression .................................................................................. 19
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`2. Video Compression Standards ................................................................ 21
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`3. Video Compression ................................................................................. 26
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`4. Storage Optimization .............................................................................. 33
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`5. Video Decompression ............................................................................. 35
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`D. OBVIOUS TO COMBINE PAULS AND BROOKS ................................................. 40
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`IV. CONCLUSION ............................................................................................ 51
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`I, Chandrajit Bajaj, hereby declare the following:
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`I.
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`BACKGROUND AND QUALIFICATIONS
`1. My name is Chandrajit Bajaj and I am over 21 years of age and
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`otherwise competent to make this Declaration. I make this Declaration based on facts
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`and matters within my own knowledge and on information provided to me by others,
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`and, if called as a witness, I could and would competently testify to the matters set
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`forth herein.
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`2.
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`I have summarized in this section my educational background, career
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`history, and other relevant qualifications. My curriculum vitae (“CV”) is attached
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`hereto as Exhibit 1006 and provides an accurate identification of my background
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`and experience.
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`3.
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`I am currently employed as a Professor of Computer Science at the
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`University of Texas at Austin (“UT Austin”). I currently hold the Computational
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`Applied Mathematics endowed Chair in Visualization. I am also the Director of the
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`Computational Visualization Center at UT Austin, which has been funded by the
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`National Institutes of Health, the National Science Foundation, the Department of
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`Energy, and the Department of Defense. The center personnel include fifteen
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`researchers, scientists, post-graduate students, and staff.
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`4.
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`I have a Bachelor of Technology degree in Electrical Engineering,
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`which I obtained from the Indian Institute of Technology in Delhi (IITD) in 1980. I
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`also have a Master of Science degree and a Doctorate in Computer Science from
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`Cornell University in 1983 and 1984 respectively.
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`5.
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`Prior to my employment at the University of Texas, I was an assistant
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`professor, then associate professor, and finally professor of Computer Sciences at
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`Purdue University (Purdue) from 1984 until I resigned in 1997 and transferred to UT
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`Austin. During this time, I was also the Director of Image Analysis and
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`Visualization Center at Purdue University. I was a visiting associate professor of
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`Computer Science at Cornell University from 1990–1991. I have also been invited
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`for collaborative visits by several academic institutions and have presented
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`numerous keynote presentations worldwide. I have been an editorial member of the
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`SIAM Journal on Imaging Sciences, and the ACM Transactions on Graphics, and
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`continue my editorial role for ACM Computing Surveys and the International
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`Journal of Computational Geometry and Applications.
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`6.
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`I have spent the better part of my career, both at Purdue and UT Austin,
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`researching, designing, teaching and using computer systems to model, simulate,
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`and visualize natural and synthetic objects, combining computational image and
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`geometric processing. I am knowledgeable about and have much experience in both
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`hardware and software, including algorithms, used for capturing, analyzing and
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`displaying interactive imagery.
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`7.
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`In the 1970s, while majoring in Electrical Engineering at Indian
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`Institute of Technology with a minor in Computer Sciences, I was intimately
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`involved in the design and fabrication of microprocessor-controlled circuits as well
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`as the development of microprocessor controller software. In the 1980s, while at
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`Cornell University, my past experiences led to research in image and geometry
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`processing and optimization and the development of robot motion planning
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`software. In the early 1990s, I created 3D collaborative multimedia software
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`environments which were fully navigable for multi-person computer gaming and
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`simulation. In 1994, I co-authored a technical paper entitled “Shastra: Multimedia
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`Collaborative Design Environment.” The need for increasing computer graphics
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`display realism without sacrificing interactivity led me also to explore image
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`processing techniques such as texture mapping with data compression, such as
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`described in my publications “Compression-Based 3D Texture Mapping for Real-
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`Time Rendering,” and “3D RGB Image Compression for Interactive Applications.”
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`During this time I was also intimately involved with the development of a new
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`synthetic-natural hybrid data compression MPEG (Motion Pictures Expert Group)
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`standard. During this time I also applied and received a joint patent “Encoding
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`Images of 3-D Objects with Improved Rendering Time and Transmission Process,”
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`August 2002, US Patent 6438266.
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`8.
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`In the early to mid-2000s, and now at University of Texas (UT) at
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`Austin, I began to create, using novel hardware and software, spatially-realistic 3D
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`graphical environments for a combination of different types of acquired and
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`reconstructed imagery within which a user may explore, query, and learn. My
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`publications included “Volumetric Video Compression and Interactive Playback”
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`and “SIMD Optimization of Linear Expressions for Programmable Graphics in
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`Hardware.” During this time at UT Austin, I was involved in developing hardware
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`and software
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`technology
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`that allowed multiple computers with multiple
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`programmable graphics cards (GPUs) to simultaneously and synchronously display
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`to large multi-screen immersive displays. We called this the UT Meta-Buffer
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`solution. One of the publications that resulted from this is titled “Active
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`Visualization in a Multidisplay Immersive Environment.” Much of my past and
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`current work involves issues relating to interactive computer multimedia, including
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`interactive 3D video and real-time retrieval of texture image data for use in rendering
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`applications in computer graphics and virtual environments. Over the course of my
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`career, I have participated in the design and use of several computer systems
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`including handhelds, laptops, graphics workstations to PC/Linux clusters, as well as
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`very large memory supercomputers for capturing, modeling and displaying virtual
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`and scientific phenomena. My experience with computer modeling and displaying
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`computer graphics imagery encompasses many fields, such as interactive games,
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`molecular, biomedical and industrial diagnostics, oil and gas exploration, geology,
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`cosmology, and military industries.
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`9. Currently at UT Austin, I hold faculty appointments with, and supervise
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`M.S. and Ph.D. students from several UT departments, including, electrical
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`engineering, biomedical engineering, and mathematics. I currently serve on the
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`editorial boards for the International Journal of Computational Geometry and
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`Applications, and the ACM Computing Surveys. Much of my recent work involves
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`issues relating to interactive image and video data sciences, 3D modeling, bio-
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`informatics, computer graphics, and computational visualization. Examples of my
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`publications, including peer-reviewed publications, are listed in my CV.
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`10. As set forth in my CV, I have authored approximately 159 peer-
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`reviewed journal articles, 33 book chapters (which were also peer reviewed), and
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`146 peer-reviewed conference publications.
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`11.
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`I have written and edited four books, on topics ranging from image
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`processing, geometric modeling and visualization techniques, to algebraic geometry
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`and its applications. I have given 181 invited-speaker keynote presentations. I am a
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`Fellow of the American Association for the Advancement of Science, a Fellow of
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`the Institute of Electrical and Electronics Engineers (IEEE), a Fellow of the Society
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`of Industrial and Applied Mathematics (SIAM), and also a Fellow of the Association
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`of Computing Machinery (also known as ACM), which is the world’s largest
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`education and scientific computing society. ACM Fellow is ACM’s most
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`prestigious member grade and recognizes the top 1% of ACM members for their
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`outstanding accomplishments in computing and information technology and/or
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`outstanding service to ACM and the larger computing community.
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`12. As part of my work in connection with this proceeding, I have reviewed
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`the corresponding IPR Petition and the following materials, which were included as
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`exhibits filed in connection therewith. The prior art exhibits listed below (e.g., Exs.
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`1004-05, 1007-36), some of which are discussed in more detail herein, informed my
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`understanding of what would have been known to a person having ordinary skill in
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`the art (“POSITA”) at the time.
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`Citation
`Exhibit No.
`Exhibit 1001 U.S. Patent No. 9,769,477 (“’477 Patent”)
`Exhibit 1002
`File History of U.S. Patent No. 9,769,477 (“’477 File History”)
`Exhibit 1004 U.S. Patent No. 6,920,150 to Pauls et al. (“Pauls”)
`Exhibit 1005 U.S. Patent No. 7,143,432 to Brooks et al. (“Brooks”)
`Exhibit 1006 Curriculum Vitae of Dr. Chandrajit Bajaj
`Exhibit 1007 U.S. Patent No. 6,031,937 to Graffagnino (“Graffagnino”)
`Shi et al. Image and Video Compression for Multimedia Engineering,
`Exhibit 1008
`CRC Press (2000) (“Shi”)
`Exhibit 1009 U.S. Patent No. 6,327,304 to Miller et al. (“Miller”)
`Exhibit 1010 Dovstam, Video Coding in H.26L, Master of Science Thesis, Royal
`Institute of Technology (2000) (“Dovstam”)
`Exhibit 1011 Girod et al. Comparison of the H.263 and H.261 Video Compression
`Standards, SPIE Proceedings Vol. CR60 (1995) (“Girod”)
`Westwater et al., Real-Time Video Compression Techniques and
`Algorithms, Florida Atlantic University, Kluwer Academic Publishers
`(1997) (“Westwater”)
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`Exhibit 1012
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`Exhibit 1016
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`for Data Compression,
`Exhibit 1013 Witten et al., Arithmetic Coding
`Communications of the ACM (June 1987) (“Witten”)
`ITU-T H.263, Video coding for low bit rate communication (1998)
`Exhibit 1014
`(“H.263 Standard”)
`Exhibit 1015 U.S. Patent No. 6,885,643 to Teramoto et al. (“Teramoto”)
`ITU-T H.262, Information technology – Generic coding of moving
`information: Video (“MPEG-2
`pictures and associated audio
`Standard”)
`ISO/IEC 14496-1, Information Technology – Generic coding of audio-
`Exhibit 1017
`visual objects, Part 1: Systems (“MPEG-4 Standard”)
`Exhibit 1018
`Provisional Application cited in Brooks
`Exhibit 1019 U.S. Patent No. 5,276,898 to Kiel et al. (“Kiel”)
`Exhibit 1020 U.S. Patent No. 5,473,376 to Auyeung (“Auyeung”)
`Exhibit 1021 U.S. Patent No. 5,563,961 to Rynderman et al. (“Rynderman”)
`Exhibit 1022 U.S. Patent No. 5,675,789 to Ishii et al. (“Ishii”)
`Exhibit 1023 U.S. Patent No. 5,812,789 to Diaz et al. (“Diaz”)
`Exhibit 1024 U.S. Patent No. 6,021,198 to Anigbogu et al. (“Anigbogu”)
`Exhibit 1025 U.S. Patent No. 6,091,777 to Guetz et al. (“Guetz”)
`Exhibit 1026 U.S. Patent No. 6,172,987 to Razazian et al. (“Razazian”)
`Exhibit 1027 U.S. Patent No. 6,181,711 to Zhang et al. (“Zhang ‘711”)
`Exhibit 1028 U.S. Patent No. 6,185,625 to Tso et al. (“Tso ‘625”)
`Exhibit 1029 U.S. Patent No. 6,216,157 to Vishwanath et al. (“Vishwanath”)
`Exhibit 1030 U.S. Patent No. 6,229,850 to Linzer et al. (“Linzer”)
`Exhibit 1031 U.S. Patent No. 6,421,733 to Tso et al. (“Tso ‘733”)
`Exhibit 1032 U.S. Patent No. 7,003,171 to Takeo (“Takeo”)
`Exhibit 1033 U.S. Patent No. 7,039,116 to Zhang et al. (“Zhang ‘116”)
`Exhibit 1034 WO 01/63772 A1 to Ternovskiy et al. (“Ternovskiy”)
`Gao et al., A Programmable Router Architecture Supporting Control
`Plane Extensibility, IEEE Communications Magazine, March 2000
`(“Gao”)
`Exhibit 1036 Hoang, Fast and Efficient Algorithms for Text and Video
`Compression, May 1997
`Exhibit 1037 U.S. Patent No. 5,374,916 to Chu (“Chu”)
`Exhibit 1038 U.S. Patent No. 5,734,744 to Wittenstein (“Wittenstein”)
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`Exhibit 1035
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`II. LEGAL FRAMEWORK
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`13.
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`I am a technical expert and do not offer any legal opinions. However,
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`counsel has informed me as to certain legal principles regarding patentability and
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`related matters under United States patent law, which I have applied in performing
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`my analysis and arriving at my technical opinions in this matter.
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`14.
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`I understand that a person cannot obtain a patent on an invention if the
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`differences between the invention and the prior art are such that the subject matter
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`as a whole would have been obvious at the time the invention was made to a person
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`having ordinary skill in the art (“POSITA”). Unless otherwise indicated below, when
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`I use the term POSITA, the timeframe of my use of that term should be assumed to
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`be at the time of the invention claimed in the ’477 Patent, which is February 13,
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`2001. I have been informed that a conclusion of obviousness may be founded upon
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`more than a single item of prior art. I have been further informed that obviousness
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`is determined by evaluating the following factors: (1) the scope and content of the
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`prior art, (2) the differences between the prior art and the claim at issue, (3) the level
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`of ordinary skill in the pertinent art, and (4) secondary considerations of non-
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`obviousness. In addition, the obviousness inquiry should not be done in hindsight.
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`Instead, the obviousness inquiry should be done through the eyes of a POSITA at
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`the time of the alleged invention.
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`15.
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`In considering whether certain prior art renders a particular patent claim
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`obvious, counsel has informed me that I can consider the scope and content of the
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`prior art, including the fact that one of skill in the art would regularly look to the
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`disclosures in patents, trade publications, journal articles, conference papers,
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`industry standards, product
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`literature and documentation,
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`texts describing
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`competitive technologies, requests for comment published by standard setting
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`organizations, and materials from industry conferences, as examples. I have been
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`informed that for a prior art reference to be proper for use in an obviousness analysis,
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`the reference must be “analogous art” to the claimed invention. I have been informed
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`that a reference is analogous art to the claimed invention if: (1) the reference is from
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`the same field of endeavor as the claimed invention (even if it addresses a different
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`problem); or (2) the reference is reasonably pertinent to the problem faced by the
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`inventor (even if it is not in the same field of endeavor as the claimed invention). A
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`reference is “reasonably pertinent” to the problem if it would logically have
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`commended itself to an inventor's attention in considering his problem. In
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`determining whether a reference is reasonably pertinent, one should consider the
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`problem faced by the inventor, as reflected either explicitly or implicitly, in the
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`specification.
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`16.
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`I understand that, in order to establish that a claimed invention was
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`obvious based on a combination of prior art elements, a clear articulation of the
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`reason(s) why a claimed invention would have been obvious must be provided.
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`Specifically, I am informed that, under the U.S. Supreme Court’s KSR decision, a
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`combination of multiple items of prior art renders a patent claim obvious when there
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`was an apparent reason for one of ordinary skill in the art, at the time of the invention,
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`to combine the prior art, which can include, but is not limited to, any of the following
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`rationales:
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`• Combining prior art methods according to known methods to yield predictable
`results;
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`• Substituting one known element for another to obtain predictable results;
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`• Using a known technique to improve a similar device in the same way;
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`• Applying a known technique to a known device ready for improvement to
`yield predictable results;
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`• Obvious to try—trying a finite number of identified, predictable potential
`solutions, with a reasonable expectation of success;
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`• Identifying that 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 are predictable to one of
`ordinary skill in the art; and/or
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`• Identifying an explicit 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 the prior art references to arrive at the claimed invention.
`17.
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`I understand that the existence of an explicit teaching, suggestion, or
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`motivation to combine known elements of the prior art is a sufficient, but not a
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`necessary, condition to a finding of obviousness. This so-called “teaching-
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`suggestion-motivation” test is not the exclusive test and is not to be applied rigidly
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`in an obviousness analysis. In determining whether the subject matter of a patent
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`claim is obvious, neither the particular motivation nor the avowed purpose of the
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`patentee controls. Instead, the important consideration is the objective reach of the
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`claim. In other words, if the claim extends to what is obvious, then the claim is
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`invalid. I am further informed that the obviousness analysis often necessitates
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`consideration of the interrelated teachings of multiple patents, the effects of demands
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`known to the technological community or present in the marketplace, and the
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`background knowledge possessed by a person having ordinary skill in the art. All of
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`these issues may be considered to determine whether there was an apparent reason
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`to combine the known elements in the fashion claimed by the patent.
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`18.
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`I also understand that in conducting an obviousness analysis, a precise
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`teaching directed to the specific subject matter of the challenged claim need not be
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`sought out because it is appropriate to take account of the inferences and creative
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`steps that a POSITA would employ. The prior art considered can be directed to any
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`need or problem known in the field of endeavor at the time of invention and can
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`provide a reason for combining the elements of the prior art in the manner claimed.
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`In other words, the prior art need not be directed towards solving the same specific
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`problem as the problem addressed by the patent. Further, the individual prior art
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`references themselves need not all be directed towards solving the same problem. I
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`am informed that, under the KSR obviousness standard, common sense is important
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`and should be considered. Common sense teaches that familiar items may have
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`obvious uses beyond their primary purposes.
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`19.
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`I also understand that the fact that a particular combination of prior art
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`elements was “obvious to try” may indicate that the combination was obvious even
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`if no one attempted the combination. If the combination was obvious to try
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`(regardless of whether it was actually tried) or leads to anticipated success, then it is
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`likely the result of ordinary skill and common sense rather than innovation. I am
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`further informed that in many fields it may be that there is little discussion of obvious
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`techniques or combinations, and it often may be the case that market demand, rather
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`than scientific literature or knowledge, will drive the design of an invention. I am
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`informed that an invention that is a combination of prior art must do more than yield
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`predictable results to be non-obvious.
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`20.
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`I understand that for a patent claim to be obvious, the claim must be
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`obvious to a POSITA at the time of the alleged invention. I understand that the
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`factors to consider in determining the level of ordinary skill in the art include (1) the
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`educational level and experience of people working in the field at the time the
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`invention was made, (2) the types of problems faced in the art and the solutions
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`found to those problems, and (3) the sophistication of the technology in the field.
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`21.
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`I understand that it is improper to combine references where the
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`references teach away from their combination. I understand that a reference may be
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`said to teach away when a POSITA, upon reading the reference, would be
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`discouraged from following the path set out in the reference, or would be led in a
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`direction divergent from the path that was taken by the patent applicant. In general,
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`a reference will teach away if it suggests that the line of development flowing from
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`the reference’s disclosure is unlikely to be productive of the result sought by the
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`patentee. I am informed that a reference teaches away, for example, if (1) the
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`combination would produce a seemingly inoperative device, or (2) the references
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`leave the impression that the product would not have the property sought by the
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`patentee. I also am informed, however, that a reference does not teach away if it
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`merely expresses a general preference for an alternative invention but does not
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`criticize, discredit, or otherwise discourage investigation into the invention claimed.
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`22.
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`I understand that even if a prima facie case of obviousness is
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`established, the final determination of obviousness must also consider “secondary
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`considerations” if presented. In most instances, the patentee raises these secondary
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`considerations of non-obviousness. In that context, the patentee argues an invention
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`would not have been obvious in view of these considerations, which include: (a)
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`commercial success of a product due to the merits of the claimed invention; (b) a
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`long-felt, but unsatisfied need for the invention; (c) failure of others to find the
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`solution provided by the claimed invention; (d) deliberate copying of the invention
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`by others; (e) unexpected results achieved by the invention; (f) praise of the
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`invention by others skilled in the art; (g) lack of independent simultaneous invention
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`within a comparatively short space of time; and/or (h) teaching away from the
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`invention in the prior art.
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`23.
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` I further understand that secondary considerations evidence is only
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`relevant if the offering party establishes a connection, or nexus, between the
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`evidence and the claimed invention. The nexus cannot be based on prior art features.
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`The establishment of a nexus is a question of fact. While I understand that the Patent
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`Owner here has not offered any secondary considerations at this time, I will
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`supplement my opinions in the event that the Patent Owner raises secondary
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`considerations during the course of this proceeding.
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`III. OPINION
`A. Level of Skill of a Person Having Ordinary Skill in the Art
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`24.
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`I was asked to provide my opinion as to the level of skill of a person
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`having ordinary skill in the art (“POSITA”) for the ’477 Patent at the time the
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`application for the patent was filed. Here, counsel has informed me to assume that
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`the relevant timeframe is February 13, 2001, which is the filing date of the earliest
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`application to which the ’477 Patent claims priority. In determining the
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`characteristics of a hypothetical person of ordinary skill in the art of the ’477 Patent
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`at the time of the claimed invention, I was told to consider several factors, including
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`the type of problems encountered in the art, the solutions to those problems, the
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`rapidity with which innovations are made in the field, the sophistication of the
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`technology, and the education level of active workers in the field. I also placed
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`myself back in the time frame of the claimed invention and considered the colleagues
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`with whom I had worked at that time.
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`25.
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`In my opinion, a person having ordinary skill in the art of the ’477
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`Patent at the time of its filing would have been a person having the equivalent of (1)
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`at least an undergraduate degree in computer science, computer engineering,
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`electrical engineering, or a similar technical field; (2) a working knowledge of
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`compression techniques for various types of media; and (3) two or more years of
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`experience (or with a graduate degree in the above-stated fields, one or more years
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`of experience) in analysis, design, or development related to media compression,
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`with additional education substituting for experience and vice versa. Such a person
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`of ordinary skill in the art would have been capable of understanding the ’477 Patent
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`and the prior art references discussed herein.
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`26. Based on my education, training, and professional experience in the
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`field of the claimed invention, I am familiar with the level and abilities of a person
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`of ordinary skill in the art at the time of the claimed invention. Additionally, I met
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`at least these minimum qualifications to be a person having ordinary skill in the art
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`as of the time of the claimed invention of the ’477 Patent.
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`B. Claim Construction
`27.
`I have been informed by counsel and understand that the first step in a
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`patentability analysis involves construing the claims, as necessary, to determine their
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`scope. The construed claim language is then compared to the disclosures of the prior
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`art. For purposes of this proceeding, I do not offer any opinions as to how a POSITA
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`would understand various terms in the claims of the ’477 Patent.
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`28.
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`In performing my analysis described herein, I have applied the claim
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`construction set forth in the Petition. For those terms that have not expressly been
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`construed, I have applied the meaning of the claim terms of the ’477 Patent that is
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`generally consistent with the terms’ ordinary and customary meaning, as a POSITA
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`would have understood them at the time of the invention.
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`C. Background of the Technology
`29.
`I was asked to summarize the background of the prior art from the
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`standpoint of the knowledge of a POSITA prior to February 13, 2001. There are
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`numerous patents, publications, and systems that are relevant to the media
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`compression technologies described and claimed in the ’477 Patent, and the specific
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`references discussed herein are just examples of what would have been known to a
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`POSITA. Many of the functionalities described and claimed in the ’477 Patent relate
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`to well-known hardware and software programming techniques for media
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`compression at the time of the application for the ’477 Patent.
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`1.
`Data Compression
`30. Compression is a scheme for reducing the amount of information
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`required to represent data and can be performed on all types of data including text,
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`speech/voice, audio, and video data. See Graffagnino (Ex. 1007) at 1:11-12. Data is
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`compressed for various reasons. For example, data is often compressed to reduce the
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`size, increasing storage efficiency. See id. at 1:12-14. Additionally, data may be
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`compressed prior to transmission to reduce the amount of time required to transmit
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`data. See id. at 1:14-17. There are several categories of compression techniques that
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`can be used to compress data and in some instances these techniques can be used
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`sequentially to produce greater compression. See generally Shi (Ex. 1008); see also
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`Miller (Ex. 1009) at 1:47-49, 3:17-26.
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`31.
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`In lossless compression, the information content of the original data and
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`the compressed data is exactly the same, and thus it is reversible. See Shi (Ex. 1008)
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`at 29; see also Miller (Ex. 1009) at 1:37-44. Conversely, with lossy compression the
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`compressed data will contain less information than the original and is irreversible.
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`See Miller (Ex. 1009) at 1:44-49. Lossy compression removes irrelevant
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`information, such as information that the intended recipient cannot perceive, and
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`thus produces larger compression ratios (i.e., smaller files). Lossy compression
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`algorithms include most video compression techniques, such as MPEG with
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`encoding standards called MPEG-1, MPEG-2, MPEG-4 and the ITU-IT video
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`encoding standards called H.261, H.263, H.264. See, e.g., Shi (Ex. 1008) at 333, 403,
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`429; Graffagnino (Ex. 1007) at 1:55-57; Miller (Ex. 1009) at 45-49.
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`32. Symmetry refers to the ratio of the computational complexity of
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`compression to that of decompression. Graffagnino (Ex. 1007) at 2:6-7. An
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`asymmetrical compression algorithm exhibits a significant time difference for
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`compression and decompression, while a symmetrical algorithm takes the same
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`amount of time to compress and decompress data. See id. JPEG compression is
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`widely considered a symmetric compression algorithm. See Graffagnino (Ex. 1007)
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`at 4:39-43. Asymmetrical compression algorithms include Lempel-Ziv and most
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`video compression algorithms such as MPEG. See id.
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`33. Compression efficiency can be measured by the compression ratio of
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`the compressed data. Graffagnino (Ex. 1007) at 1:20-24. Compression ratio refers
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`to the ratio of number of bits of uncompressed data to the number of bits of
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`compressed data. Id. The higher the compression ratio, the smaller the file size and
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`as discussed above, smaller files are desirable because of the increased storage
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`efficiency and speedier transmission times. However, compression to a very small
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`size often also requires more complex techniques. The costs associated with using
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`more complicated techniques include increased computing power required to
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`perform the calculations and longer time and slower speed in compressing the data
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`itself (i.e., decreased compression rate). Various trade-offs can be used to balance a
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`desired compression ratio with the compression rate and then transmit data rate. For
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`example, by reducing the quality of the data the data may be compressed more
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`quickly and to a smaller size and faster transmit data rate. In the case of compressing
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`video data, a balance between compression ratio and image quality is generally
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`desired in order to optimize storage, while maintaining a sufficient image quality for
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`optimal compression and transmission rate to a remote user.
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`34. Different types of compression techniques are better suited for certain
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`types of data. For example, only lossless compression can be used to transmit
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`computer program files as a lossy tech