`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`SAMSUNG ELECTRONICS AMERICA, INC.
`Petitioner
`
`v.
`
`UNILOC 2017 LLC
`Patent Owner
`____________________
`
`Patent No. 7,136,999
`____________________
`
`DECLARATION OF DR. ZYGMUNT J. HAAS
`
`SAMSUNG EXHIBIT 1002
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`Page 1 of 87
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`Declaration of Dr. Zygmunt J. Haas
`Patent No. 7,136,999
`
`TABLE OF CONTENTS
`
`INTRODUCTION ........................................................................................... 1
`I.
`BACKGROUND AND QUALIFICATIONS ................................................. 1
`II.
`SUMMARY OF OPINIONS ........................................................................... 7
`III.
`IV. PERSON OF ORDINARY SKILL IN THE ART .......................................... 8
`V.
`TECHNICAL BACKGROUND ..................................................................... 9
`VI. OVERVIEW OF THE ’999 PATENT .......................................................... 11
`VII. OVERVIEW OF THE PRIOR ART ............................................................. 14
`A.
`International Patent Application Publication No.
`WO 1998/028929 (“Hokkanen”) (Ex. 1005) ...................................... 14
`U.S. Patent No. 5,812,955 (“Dent”) (Ex. 1006) .................................. 15
`B.
`U.S. Patent No. 5,706,349 (“Aditham”) (Ex. 1007) ............................ 15
`C.
`D. U.S. Patent No. 6,766,373 (“Beadle”) (Ex. 1008) .............................. 16
`VIII. CLAIM CONSTRUCTION .......................................................................... 16
`IX. THE PRIOR ART DISCLOSES OR SUGGESTS ALL OF THE
`FEATURES OF CLAIMS 13 AND 17 OF THE ’999 PATENT ................. 17
`A. Hokkanen in Combination with Dent Discloses or Suggests the
`Features of Claims 13 and 17 .............................................................. 17
`1.
`Claim 13 .................................................................................... 17
`2.
`Claim 17 .................................................................................... 47
`Aditham in Combination with Beadle Discloses or Suggests the
`Features of Claims 13 and 17 .............................................................. 51
`1.
`Claim 13 .................................................................................... 52
`2.
`Claim 17 .................................................................................... 77
`
`B.
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`X.
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`Declaration of Dr. Zygmunt J. Haas
`Patent No. 7,136,999
`CONCLUSION .............................................................................................. 84
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`Declaration of Dr. Zygmunt J. Haas
`Patent No. 7,136,999
`
`I, Dr. Zygmunt J. Haas, declare as follows:
`
`I.
`
`INTRODUCTION
`I have been retained by Samsung Electronics America, Inc.
`1.
`
`(“Petitioner” or “Samsung”) as an independent expert consultant in this proceeding
`
`before the United States Patent and Trademark Office (“PTO”) regarding U.S. Patent
`
`No. 7,136,999 (“the ’999 patent”) (Ex. 1001). I understand this is a proceeding
`
`between Petitioner and Uniloc 2017 LLC (“Patent Owner” or “Uniloc”). I have been
`
`asked to consider whether certain references disclose or suggest the features recited
`
`in claims 13 and 17 (“the challenged claims”) of the ’999 patent. My opinions are
`
`set forth below.
`
`2.
`
`I am being compensated at my rate of $450 per hour for the time that I
`
`spend on this matter. My compensation is in no way contingent on the nature of my
`
`findings, the presentation of my findings in testimony, or the outcome of this or any
`
`other proceeding. I have no other interest in this proceeding.
`
`II. BACKGROUND AND QUALIFICATIONS
`I am an independent consultant. All of my opinions stated in this
`3.
`
`Declaration are based on my own personal knowledge and professional judgment.
`
`In forming my opinions, I have relied on my knowledge and experience, including
`
`
`
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`Declaration of Dr. Zygmunt J. Haas
`Patent No. 7,136,999
`my expertise in the area of network security, and on information referenced in this
`
`Declaration.
`
`4.
`
`I am over 18 years of age and, if I am called upon to do so, I would be
`
`competent to testify as to the matters set forth herein. I understand that a copy of
`
`my current curriculum vitae, which includes a more detailed summary of my
`
`education and professional experience, is provided as Ex. 1003. The following
`
`provides an overview of some of my experience that is relevant to the matters set
`
`forth in this Declaration.
`
`5.
`
`I am a Professor and Distinguished Chair in Computer Science at the
`
`University of Texas in Dallas. I am also Professor Emeritus at the School of
`
`Electrical and Computer Engineering at Cornell University. In addition, I have
`
`provided technical consulting services on intellectual property matters, including
`
`matters involving computer networks and wireless communication technologies.
`
`6.
`
`I received my Bachelor of Science Degree in Electrical Engineering,
`
`summa cum laude, from Technion (IIT), Israel, in 1979, and a Master of Science
`
`Degree in Electrical Engineering, summa cum laude, from Tel-Aviv University,
`
`Israel, in 1985. I subsequently authored the thesis titled “Packet Switching in Fiber-
`
`Optic Networks” as part of earning my Ph.D. in Electrical Engineering from
`
`Stanford University in 1988.
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`2
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`Declaration of Dr. Zygmunt J. Haas
`Patent No. 7,136,999
`I have worked for about 35 years in the field of Electrical Engineering.
`
`7.
`
`The primary focus of my work has been, in general, on communication and
`
`networking systems, with an emphasis on wireless communication networks in the
`
`last 30 years. Throughout my professional career, I have authored and co-authored
`
`numerous technical papers and book chapters related to wireless communication
`
`networks. As shown in my curriculum vitae, which I understand is provided as
`
`Exhibit 1003, I hold over twenty patents in the fields of high-speed networking,
`
`wireless networks, and optical switching, with one additional patent pending.
`
`8.
`
`In my work, among other topics, I have researched wireless networks,
`
`in general, including protocols for routing in ad hoc networks. Specifically, I have
`
`written numerous papers on various schemes for wireless ad hoc networks systems,
`
`including security of ad hoc networks. Some of my works on ad hoc networking
`
`system have received prominent awards. For instance, I have received IEEE
`
`ComSoc AHSN Recognition Award for “outstanding contribution to securing ad hoc
`
`and sensor networks” from the IEEE Communication Society in 2016 as well as
`
`“Best Paper Award” for the paper “Optimal Resource Allocation for UWB Wireless
`
`Ad Hoc Networks” from the IEEE International Symposium on Personal Indoor and
`
`Mobile Radio Communications (PIMRC) in 2005. Furthermore, many of my papers
`
`have been extensively cited by other authors, as indicated by various citation indices.
`
`
`
`3
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`Declaration of Dr. Zygmunt J. Haas
`Patent No. 7,136,999
`For example, my paper on “Securing Ad Hoc Networks,” co-author with a Ph.D.
`
`student at that time, has been cited over 3500 times by other publications according
`
`to the Google Scholar index. I have also taught courses that cover ad hoc network
`
`technologies at the graduate and undergraduate levels. In addition, I have been
`
`invited to many international conferences to deliver keynote speeches on topics
`
`related to ad hoc networks.
`
`9. My employment history following my graduation from Stanford
`
`University began at the Network Research Department of AT&T Bell Laboratories
`
`in 1988.
`
` At AT&T Bell Laboratories, I pursued research on wireless
`
`communications, mobility management, fast protocols, optical networks, and optical
`
`switching. Additionally, while at AT&T Bell Labs, among other topics, I studied
`
`schemes applicable to network security. During my tenure at AT&T, I also worked
`
`for the AT&T Wireless Center of Excellence, where I investigated various aspects
`
`of wireless and mobile networks. As part of my employment at AT&T, I also
`
`worked on multimedia conferencing systems.
`
`10. Since 1995, I have been a Professor at the faculty of the School of
`
`Electrical & Computer Engineering at Cornell University. At Cornell, I headed the
`
`Wireless Networks Lab, a research group with extensive contributions in the area of
`
`wireless communication systems and networks. In 2013, I retired from Cornell with
`
`
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`Declaration of Dr. Zygmunt J. Haas
`Patent No. 7,136,999
`the title of Emeritus Professor and joined the Computer Science Department at the
`
`University of Texas at Dallas with the title of Professor and Distinguished Chair in
`
`Computer Science. At Cornell and at the University of Texas at Dallas, I have taught
`
`dozens of courses related to computer networking and wireless communications. I
`
`have also served on various committees for the benefit of the scientific community.
`
`11.
`
`I am a member of a number of professional societies, including the
`
`Institute of Electrical and Electronic Engineers (IEEE) and the Association for
`
`Computing Machinery (ACM). In 2007, I was elevated to an IEEE Fellow. I have
`
`also been named a Fellow of EAI (European Alliance for Innovation) and a Fellow
`
`of IET (Institution of Engineering and Technology). I have been responsible for
`
`organizing several workshops, and delivering numerous tutorials at major IEEE and
`
`ACM conferences. I served as editor of several publications including the IEEE
`
`Transactions on Networking, the IEEE Transactions on Wireless Communications,
`
`the IEEE Communications Magazine, the Springer “Wireless Networks” journal, the
`
`Elsevier “Ad Hoc Networks” journal, the “Journal of High Speed Networks,” and
`
`the Wiley “Wireless Communications and Mobile Computing” journal. I also served
`
`as a guest editor of IEEE Journal on Selected Areas in Communications issues on
`
`“Gigabit Networks,” “Mobile Computing Networks,” and “Ad-Hoc Networks.”
`
`Finally, I have served as the Chair of the IEEE Technical Committee on Personal
`
`
`
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`Declaration of Dr. Zygmunt J. Haas
`Patent No. 7,136,999
`Communications (TCPC), now known as the IEEE Wireless Communications
`
`Technical Committee.
`
`12.
`
`I have received multiple awards in the field of wireless communications
`
`and networks. I am the recipient of the 2016 IEEE ComSoc AHSN Recognition
`
`Award (“for outstanding contributions to securing ad hoc and sensor networks”). In
`
`2012, I received the IEEE ComSoc WTC Recognition Award, which recognizes
`
`individuals for outstanding technical contributions in the field for their service to the
`
`scientific and engineering communities. Also in 2012, I received the “Best Paper
`
`Award for co-authoring “Collaborating with Correlation for Energy Efficient WSN”
`
`directed at Wireless Sensor Networking. I previously received the “Best Paper
`
`Award” for coauthoring “Optimal Resource Allocation for UWB Wireless Ad Hoc
`
`Networks” directed at personal indoor and mobile radio communications. Finally,
`
`in 2003, I received the “Highly Commended Paper Award” for co-authoring
`
`“Performance Evaluation of the Modified IEEE 802.11 MAC for Multi-Channel
`
`Multi-Hop Ad Hoc Network,” directed at advanced information networking and
`
`applications.
`
`13.
`
`I understand that a copy of my curriculum vitae is marked as Exhibit
`
`1003 and provides additional information regarding my education, technical
`
`experience, and publications.
`
`6
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`Declaration of Dr. Zygmunt J. Haas
`Patent No. 7,136,999
`
`III. SUMMARY OF OPINIONS1
`14. The opinions contained in this Declaration are based on the documents
`
`I reviewed, my professional judgment, as well as my education, experience, and
`
`knowledge, including in the area of regarding network security.
`
`15.
`
`In forming my opinions expressed in this Declaration, I reviewed the
`
`’999 patent (Ex. 1001); the prosecution file history for the ’999 patent (Ex. 1004);
`
`International Patent Application Publication No. WO 1998/028929 to Hokkanen
`
`(“Hokkanen”) (Ex. 1005); U.S. Patent No. 5,812,955 to Dent et al. (“Dent”) (Ex.
`
`1006); U.S. Patent No. 5,706,349 to Aditham et al. (“Aditham”) (Ex. 1007); U.S.
`
`Patent No. 6,766,373 to Beadle et al. (“Beadle”) (Ex. 1008); and any other materials
`
`that I refer to in this Declaration in support of my opinions.
`
`16. My opinions have also been guided by my appreciation of how a person
`
`of ordinary skill in the art, as defined below in Section IV, would have understood
`
`the claims and the specification of the ’999 patent at the time of the alleged
`
`invention, which I have been asked to consider as the mid 2000 timeframe, including
`
`
`1 My citations to non-patent publications are to the original page numbers of the
`
`publication, and my citations to U.S. Patents are to the column:line number or
`
`paragraph number of the patents or published patent applications, as applicable.
`
`
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`Declaration of Dr. Zygmunt J. Haas
`Patent No. 7,136,999
`and up to the June 20, 2000 timeframe (the filing date of U.S. Patent Application
`
`No. 09/597,198), to which I understand the ’999 patent claims priority. My opinions
`
`reflect how a person of ordinary skill in the art, as defined below in Section IV,
`
`would have understood the ’999 patent, the prior art to the patent, and the state of
`
`the art at the time of the alleged invention.
`
`17. As I discuss in detail below, it is my opinion that certain references
`
`disclose or suggest all the features recited in claims 13 and 17 of the ’999 patent.
`
`IV. PERSON OF ORDINARY SKILL IN THE ART
`18. Based on my knowledge and experience, I understand what a person of
`
`ordinary skill in the art would have known at the time of the alleged invention. In
`
`my opinion, based on the materials and information I have reviewed, and based on
`
`my experience in the technical areas relevant to the ’999 patent, a person of ordinary
`
`skill in the art at the time of the alleged invention of the ’999 patent would have had
`
`at least a Bachelor’s degree in computer science, electrical engineering, or a similar
`
`discipline, and at least two years of work experience in the relevant field, e.g.,
`
`network security. More education can substitute for practical experience and vice
`
`versa. My opinions herein are, where appropriate, based on my understandings as
`
`to what a person of ordinary skill in the art would have understood at the time of the
`
`alleged invention. I apply this understanding in my analysis herein.
`
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`Declaration of Dr. Zygmunt J. Haas
`Patent No. 7,136,999
`19. My analysis of the ’999 patent and my opinions in this Declaration are
`
`from the perspective of one of ordinary skill in the art, as I have defined it above,
`
`during the relevant time frame, which I have been asked to assume is the mid 2000
`
`timeframe (including the June 20, 2000, filing date of U.S. Patent Application No.
`
`09/597,198, the application to which I understand the ’999 patent claims priority).
`
`During this time frame, I possessed at least the qualifications of a person of ordinary
`
`skill in the art, as defined above. For example, at this time frame, I had graduated
`
`with a Ph.D. degree and had worked about 7 years in the industry, as well as about
`
`5 years in academia, and had researched topics related to networking, wireless
`
`networks, and network security.
`
`V. TECHNICAL BACKGROUND
`In this section, I discuss the state of the art with respect to certain
`20.
`
`technologies relevant to the subject matter of the ’999 patent. In particular, during
`
`the time preceding June 2000, a person of ordinary skill in the art would have been
`
`aware of various developments in the areas of computer networks and network
`
`security, as I discuss below.
`
`21. Long before June 2000, there were known various computer network
`
`systems and architectures involving multiple computing devices, such as a client and
`
`a server. For example, computer networking concepts and technologies for
`
`
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`Declaration of Dr. Zygmunt J. Haas
`Patent No. 7,136,999
`designing various types of networks, such as wide area network (WAN) and local
`
`area network (LAN), were also well known to a person of ordinary skill in the art at
`
`the time. (See, e.g., Ex. 1007, 3:20–22; Ex. 1008, 1:47–59.) Wireless and mobile
`
`networks of various types, and wireless and mobile network standards, also existed
`
`before June 2000 and were well known.
`
`22. For communication between multiple devices on these networks,
`
`various standards and protocols were developed and implemented well before June
`
`2000. For example, as discussed in Hokkanen and Dent, mobile network standards,
`
`such as Global System for Mobile Communications (GSM), were well known to a
`
`person of ordinary skill in the art long before June 2000. (See, e.g., Ex. 1005, 1:35–
`
`2:9; Ex. 1006, 1:14–19.) Also, as the ’999 patent itself states, the Bluetooth protocol,
`
`which was described in detail in its technical specification, was well known to a
`
`person of ordinary skill in the art before June 2000. (Ex. 1001, 1:11–59.)
`
`23. Also, it was well known long before June 2000 that certain security
`
`measures need to be employed on these network systems to provide security of
`
`operation of such networks, their connected devices, and their communications. For
`
`example, one such security measure is authentication. As discussed in the prior art,
`
`for instance, allowing a device to join a network and start communicating without
`
`verifying its identity would pose a security threat to the network. (See, e.g., Ex.
`
`
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`Patent No. 7,136,999
`1007, 5:13–21; Ex. 1006, 2:10–14.) In fact, security was a major concern well before
`
`the June 2000 timeframe, leading to various standardization efforts in the networking
`
`community.
`
`24. The process of authentication relies on a piece of information that is
`
`unique, exclusive, and known to a claimant device that wishes to communicate on
`
`the network. For instance, in Aditham, the user name, password, universal unique
`
`identifier (UUID), and token would be examples of such information that could be
`
`used for verification of the device identity (i.e., authentication). (See, e.g., Ex. 1007,
`
`Figs. 4, 5.) Various methods of performing authentication were well known long
`
`before June 2000. One such method is the challenge-response scheme employed in,
`
`for example, GSM and Bluetooth, relying on the secret information (e.g., subscriber
`
`identity key, personal identification number (PIN), etc.) that is known to a particular
`
`claimant device, thus allowing authenticating the device. (See, e.g., Ex. 1005, 2:35–
`
`4:22; Ex. 1006, 4:9–19; Ex. 1001, 1:39–53.)
`
`VI. OVERVIEW OF THE ’999 PATENT
`is directed
`25. The ’999 patent
`
`to network security,
`
`including
`
`authenticating electronic devices within a network. (Ex. 1001, 1:5–9, Abstract.) In
`
`particular, the ’999 patent’s purported invention relates to authenticating between
`
`two devices first “on a physically restrained network” and later authenticating the
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`Patent No. 7,136,999
`same two devices on another network using the previously used authentication
`
`information. (Id., 2:3–30.) The’999 patent mentions an “insight”—that “once
`
`devices are authenticated on a restricted network, it is very simple to re-connect the
`
`devices through another, unrestricted network.” (Id., 2:24–27.) Thus, according to
`
`the ’999 patent, an authentication process, such as those used by the Bluetooth
`
`protocol, is used over an initial link between two electronic devices, and the same
`
`authentication protocol would be used again over a later link between the two
`
`electronic devices. (Id., 4:10–50.)
`
`26. The ’999 patent admits
`
`that various communication network
`
`technologies and protocols were known, including wide area networks (WAN) and
`
`Bluetooth. (Id., 1:11–67.) For example, the ’999 patent specifically relies on the
`
`then-known Bluetooth standard upon which the purported invention is implemented.
`
`(See, e.g., id., 1:11–59, 2:28–30, 4:13–16, 4:40–55.) Figure 1 (below) is illustrative
`
`of the purported invention:
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`Declaration of Dr. Zygmunt J. Haas
`Patent No. 7,136,999
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`
`
`(Id., Fig. 1.)
`
`27. As I discuss below, all of the features in the challenged claims of the
`
`’999 patent, including the alleged improvements discussed above, were well known
`
`in the prior art before the alleged invention of the ’999 patent. (See my discussion
`
`below in Sections VII–VIII (discussing the prior art that I have relied upon in this
`
`Declaration); see also my discussion above in Section V (discussing the state of the
`
`art).)
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`Declaration of Dr. Zygmunt J. Haas
`Patent No. 7,136,999
`
`VII. OVERVIEW OF THE PRIOR ART
`International Patent Application Publication No. WO 1998/028929
`A.
`(“Hokkanen”) (Ex. 1005)
`28. Hokkanen relates to “a cellular system comprising base stations and
`
`mobile stations with an interface in between which is a radio interface.” (Ex. 1005,
`
`1:4–5.) Hokkanen also discusses certain the known cordless phone technologies and
`
`their “low security especially when using the traditional analog system.” (Id., 1:16–
`
`32.) However, cordless phone technologies might offer “cheaper prices of the fixed
`
`network.” (Id. 1:28–32). Accordingly, Hokkanen “aims at bringing about a cordless
`
`telephone system which is based on a cellular network” by allowing “standard
`
`terminal equipment of the cellular network [to] be used at home as cordless phones.”
`
`(Id., 5:23–28.)
`
`29. Hokkanen describes a system, in which a mobile phone registered with
`
`a cellular network can be used as a cordless phone in communication with a base
`
`station within a certain area (for example, home) after the mobile phone is registered
`
`with the base station. Hokkanen explains that a mobile phone, or a mobile station
`
`(MS), can be place at a “charging station” of the home base station (HBS), so that
`
`the initial registration of the MS with the HBS can be performed. Hokkanen further
`
`explains that the method used for this registration “may be the same as those used in
`
`the cellular system.” (Id., 8:18–19.) According to Hokkanen, once the registration
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`Patent No. 7,136,999
`is completed, the MS becomes the cordless phone, and when it starts or receives a
`
`call on the telephone network through the HBS, authentication is performed between
`
`the MS and the HBS. (Id., 9:1–2, 10:6–7.)
`
`B. U.S. Patent No. 5,812,955 (“Dent”) (Ex. 1006)
`relates
`to “provid[ing] an
`improved
`30. Dent
`
`radio personal
`
`communications system
`
`including a base station and a radio personal
`
`communications terminal.” (Ex. 1006, 2:22–25.) Dent also states the personal
`
`communications systems it describes would “employ the same security systems and
`
`methods which are employed by the wide area cellular network.” (Id., 2:48–50.)
`
`Dent, for example, describes that the cellular terminal can be “parked in the base
`
`station” for exchange of “[v]erification and encryption signals.” (Id., Abstract.)
`
`C. U.S. Patent No. 5,706,349 (“Aditham”) (Ex. 1007)
`31. Aditham relates to “a method that enables application servers in a
`
`distributed environment to authenticate remote users.” (Ex. 1007, 1:5–9.) Aditham
`
`discusses security issues with known systems and describes a method that seeks to
`
`“provide a security protocol by which application servers can determine the
`
`authenticity of remote users in a distributed computer network environment.” (Id.,
`
`1:41–44.) Aditham describes a “security mechanism” on an application server which
`
`initially authenticates a remote user and issues a token to the authenticated remote
`
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`Patent No. 7,136,999
`user. (Id., 2:3–16.) Later, when a connection is requested by a remote user, the
`
`security mechanism “verifies the token’s origination,” and if it cannot be verified,
`
`“the connection is refused.” (Id., 2:19–27.)
`
`D. U.S. Patent No. 6,766,373 (“Beadle”) (Ex. 1008)
`32. Beadle is directed to a system and method for “dynamically switching
`
`a session connection from a first connection route to another route in response to an
`
`occurrence of specific pre-defined events.” (Ex. 1008, 1:20–22.) According to
`
`Beadle, its method “allow[s] a client browser to switch from one connection route
`
`to another route during a network session without losing session information.” (Id.,
`
`2:43–46.) Thus, Beadle aims to “dynamically improv[e] a client-to-network session
`
`connection and performance” (id., 2:40–42) when “the server is congested” (id., 2:3–
`
`5), “the [network] connection is lost during a session” (id., 2:5–8), or “[n]etwork
`
`input/output (I/O) performance is . . . a problem.” (Id., 2:10–11.)
`
`VIII. CLAIM CONSTRUCTION
`I understand that claim terms are typically given their ordinary and
`33.
`
`customary meanings, as would have been understood by a person of ordinary skill
`
`in the art at the time of the alleged invention, which I understand is mid 2000
`
`(including June 20, 2000, the filing date of the application to which the ’999 patent
`
`claims priority). In considering the meaning of the claims, I understand that one
`
`
`
`16
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`Declaration of Dr. Zygmunt J. Haas
`Patent No. 7,136,999
`must consider the language of the claims, the specification, and the prosecution
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`history of record.
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`34.
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`I have applied the above understanding in my analysis.
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`IX. THE PRIOR ART DISCLOSES OR SUGGESTS ALL OF THE
`FEATURES OF CLAIMS 13 AND 17 OF THE ’999 PATENT
`A. Hokkanen in Combination with Dent Discloses or Suggests the
`Features of Claims 13 and 17
`In my opinion, Hokkanen in combination with Dent discloses or
`
`35.
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`suggests all of the features of claims 13 and 17 of the ’999 patent. Below, I address
`
`claims 13 and 17 and their respective features.
`
`1.
`
`Claim 13
`“A method of authenticating first and second
`a)
`electronic devices, comprising:”
`I have been asked to assume that the preamble of claim 13 is limiting.
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`36.
`
`Under this assumption, it is my opinion that Hokkanen discloses the preamble of
`
`claim 13.
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`37. Hokkanen describes a method of authenticating a “mobile station” (e.g.,
`
`a cellular network phone) and a “home base station.” For example, Hokkanen
`
`describes “[t]urning a cellular network phone (MS) into a cordless phone by placing
`
`the phone in a charging device located in a home base station (HBS) and containing
`
`special communication pins through which the phone and the base station may
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`Declaration of Dr. Zygmunt J. Haas
`Patent No. 7,136,999
`exchange authentication information while the phone is in the charger.” (Ex. 1005,
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`Abstract; see also id., 5:32–6:3 (“The proposed home base station which is
`
`connected to an ordinary telephone connection contains in the manner of a base
`
`station for known cordless phones a charging device where the phone can be
`
`charged. Besides the pins supplying the charging current, it has special
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`communication pins through which the phone and the base station can exchange
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`authentication information while the phone is in the charger. The turning of the
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`cellular network phone into a cordless phone thus begins by placing the phone in the
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`charger.”), 8:3–9 (“The charging station for phone batteries in the home base station,
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`represented by a depression in home base station HBS, may contain, besides
`
`charging current pins, one or more contact pins, whereby when the phone is placed
`
`in the charging station the contact pin will be brought into contact with a
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`corresponding pin in the phone, which will start both deregistration of the phone
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`from the cellular network and registration with the home base station.”).)
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`38. Referring to Figure 4 below, Hokkanen explains that, “[w]hen there is
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`a wireline connection between the home base station and the phone” (e.g., when the
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`mobile station is at the “C” position, such that the contact pins of the MS and HBS
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`are in contact), “any party may generate the authentication and ciphering information
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`provided that the information is agreed upon in advance,” such as “the parameters
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`Declaration of Dr. Zygmunt J. Haas
`Patent No. 7,136,999
`(RAND, SRES, Kc) used for authentication.” (Id., Abstract; see also id., 6:4–13
`
`(“In authentication all information transfer takes place only between base station and
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`phone while the authentication center AuC of the cellular network is entirely outside.
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`Hereby, since there is a wireline connection between the home base station and the
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`phone, it does not matter which party’s authentication means will generate the
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`authentication and ciphering data as long as these are agreed upon in advance. Even
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`the algorithms need not be such which are used in the cellular system. It is enough
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`to agree in advance that when one party sends a certain inquiry, the other party will
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`respond with a certain answer, whereupon both will use an agreed ciphering key in
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`the radio traffic. The authentication is invisible to the user.”), 8:1–9 (“Only when the
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`user connects his phone with a wireline connection directly to the home base station,
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`arrow A -> C, will deregistration of the phone from the cellular network take place.
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`The charging station for phone batteries in the home base station, represented by a
`
`depression in home base station HBS, may contain, besides charging current pins,
`
`one or more contact pins, whereby when the phone is placed in the charging station
`
`the contact pin will be brought into contact with a corresponding pin in the phone,
`
`which will start both deregistration of the phone from the cellular network and
`
`registration with the home base station.”).)
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`Declaration of Dr. Zygmunt J. Haas
`Patent No. 7,136,999
`
`
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`(Id., Fig. 4.)
`
`39. Hokkanen describes two embodiments for authenticating the MS and
`
`HBS. In the first embodiment, “the parameters used in authentication are generated
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`by first means located in the mobile station and the parameters are transferred
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`through a fixed connection to second means which are located in the home base
`
`station and which will store them.” (Id., 6:14–6:21; see also id., 8:10–35, Fig. 5.)
`
`In the second embodiment, “the parameters used in authentication are generated by
`
`second means in the base station and the parameters are transferred through a fixed
`
`connection to such first means in the mobile station which will store them.” (Id.,
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`6:22–25; see also id., 9:24–10:5, Fig. 7.) In both embodiments, “[w]hen the mobile
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`Declaration of Dr. Zygmunt J. Haas
`Patent No. 7,136,999
`station has turned into a cordless phone, authentication is performed in the beginning
`
`of the call formation using parameters which have been calculated in advance and
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`stored in the memory.” (Id., 6:34–36; see also id., 9:1–2, 10:6–7.)
`
`40. As such, Hokkanen discloses the preamble of claim 13. (See also my
`
`discussion below in Sections IX.A.1.b–c (discussing the remaining features of claim
`
`13).)
`
`b)
`
`“upon link set-up over a first link, executing an
`authentication protocol by exchanging authentication
`information between the first and second electronic
`devices
`to
`initially authenticate communication
`between the first and second devices;”
`It is my opinion that Hokkanen in combination with Dent discloses or
`
`41.
`
`suggests these features.
`
`42. First, Hokkanen discloses a “link set-up over a first link.” For example,
`
`in order to “turn[] the cellular network phone into a cordless phone” (MS), the user
`
`must “plac[e] the phone in the charger” of the HBS. (Ex. 1005, 6:1–3; see also id.,
`
`Abstract (“Turning of a cellular network phone (MS) into a cordless phone begins
`
`by placing the phone in a charging device located in a home base station
`
`(HBS) . . . .”), 8:1–9, 10:36–11:5 (“the user to change the mode need only connect
`
`the phone for a moment to the home base station when coming home, to the office
`
`or any other such place”).) By placing the phone in the charger of the HBS, a link
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`
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