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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.,
`Petitioner,
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`v.
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`OMNI MEDSCI, INC.,
`Patent Owner.
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`Patent No. 10,188,299
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`IPR2020-00175
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`DECLARATION OF BRIAN ANTHONY, PH. D. REGARDING
`U.S. PATENT NO. 10,188,299
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`
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`Petitioner Apple Inc.
`Ex. 1003, p. i
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`IPR2020-00175
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`Declaration of Dr. Anthony
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`TABLE OF CONTENTS
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`I.
`
`INTRODUCTION ...................................................................................... 1
`A.
`Engagement ........................................................................................ 1
`B.
`Background and Qualifications ........................................................... 1
`C.
`Compensation ..................................................................................... 5
`D.
`Information Considered ...................................................................... 6
`LEGAL STANDARDS FOR PATENTABILITY ..................................... 6
`II.
`A. Anticipation ........................................................................................ 8
`B.
`Obviousness ........................................................................................ 9
`III. BACKGROUND INFORMATION ABOUT THE ’299 PATENT ........ 11
`A.
`Effective Filing Date of the ’299 Patent ............................................ 11
`B.
`The Prosecution History of the ’299 Patent ....................................... 12
`C.
`Technical Field ................................................................................. 14
`D.
`Level of Ordinary Skill in the Art ..................................................... 14
`IV. TECHNICAL BACKGROUND .............................................................. 15
`A.
`Photoplethysmography ..................................................................... 15
`B.
`Industry Trends ................................................................................. 23
`V. ANALYSIS OF THE ’299 PATENT ....................................................... 30
`A. Overview of the ’299 Patent ............................................................. 30
`B.
`Construction of Terms Used in the ’299 Patent Claims ..................... 31
`VI.
`IDENTIFICATION OF THE PRIOR ART ............................................ 32
`VII. ANALYSIS OF THE PRIOR ART AND ’299 CLAIMS ........................ 33
`A.
`Lisogurski and Carlson Render Obvious Claims 7 and 11-13 ........... 33
`1. Overview of Lisogurski ..............................................................33
`2. Overview of Carlson ...................................................................36
`3. A Person of Ordinary Skill in the Art Would Have Modified
`Lisogurski to Incorporate Elements Shown in Carlson ................37
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`Petitioner Apple Inc.
`Ex.1003, p. ii
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`that are light emitting diodes, each of the light emitting diodes
`configured to generate an output optical beam having one or
`more optical wavelengths, wherein at least a portion of the
`one or more optical wavelengths is a near-infrared wavelength
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`output optical beams and to deliver a lens output beam to
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`the lens output beam reflected from the tissue and to generate
`an output signal having a signal-to-noise ratio, wherein the
`detection system is configured to be synchronized to the light
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`4. Lisogurski and Carlson Describe the Elements of Claim 7
`of the ’299 Patent ........................................................................40
`a) Preamble ..............................................................................42
`b) a light source comprising a plurality of semiconductor sources
`between 700 nanometers and 2500 nanometers” ..................43
`c) “a lens configured to receive a portion of at least one of the
`tissue” ..................................................................................45
`d) “a detection system configured to receive at least a portion of
`source” .................................................................................51
`e) “a personal device…” ...........................................................57
`(i) “a personal device comprising a wireless receiver, a wireless
`57
`(ii) “a personal device… wherein the personal device is
`transmitted over a wireless transmission link” .......................................59
`f) “a remote device…” .............................................................61
`(i) “a remote device configured to receive over the wireless
`processed data and to store the processed data” .....................................61
`(ii) “wherein the output signal is indicative of one or more of the
`over a specified period of time” .............................................................63
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`transmitter, a display, a microphone, a speaker, one or more buttons or
`knobs, a microprocessor and a touch screen, the personal device
`configured to receive and process at least a portion of the output signal”
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`configured to store and display the processed output signal, and wherein
`at least a portion of the processed output signal is configured to be
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`transmission link an output status comprising the at least a portion of the
`processed output signal, to process the received output status to generate
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`physiological parameters, and the remote device is configured to store a
`history of at least a portion of the one or more physiological parameters
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`Petitioner Apple Inc.
`Ex.1003, p. iii
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`signal responsive to light while the light emitting diodes are
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`responsive to light received while at least one of the light
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`noise ratio by differencing the first signal and the second
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`g) “the system configured to increase the signal-to-noise ratio”66
`(iii) “by increasing light intensity of at least one of the plurality
`of semiconductor sources from an initial light intensity” .......................70
`(iv) “by increasing a pulse rate of at least one of the plurality of
`semiconductor sources from an initial pulse rate” .................................74
`h) “the detection system further configured to generate a first
`off” .......................................................................................80
`i) “[the detection system configured] to generate a second signal
`emitting diodes is on” ...........................................................83
`j) “[the detection system configured to] increase the signal-to-
`signal” ..................................................................................85
`5. Claim 11 .....................................................................................87
`6. Claim 12 .....................................................................................87
`7. Claim 13 .....................................................................................91
`12-13 ................................................................................................ 92
`1. Overview of Mannheimer ...........................................................92
`2. A Person of Ordinary Skill In the Art Would Have
`Shown in Mannheimer ................................................................93
`3. Claim 12 .....................................................................................95
`a) A detector located at “different distances” from each LED ..96
`b) A detector “generat[ing]” both the claimed “third” and
`“fourth” signals ....................................................................98
`4. Claim 13 ................................................................................... 100
`Render Obvious Claims 10 and 14 .................................................. 101
`1. Overview of Park ...................................................................... 101
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`Lisogurski, Carlson, and Mannheimer Render Obvious Claims
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`B.
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`C.
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`Modified Lisogurski and Carlson to Incorporate Elements
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`Lisogurski, Carlson, and Park (with or without) Mannheimer
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`Petitioner Apple Inc.
`Ex.1003, p. iv
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`Modified Lisogurski and Carlson to Incorporate Elements
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`2. A Person of Ordinary Skill In the Art Would Have
`Shown in Park ........................................................................... 103
`3. Claims 10 and 14 ...................................................................... 107
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`Petitioner Apple Inc.
`Ex.1003, p. v
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`IPR2020-00175
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`Declaration of Dr. Anthony
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`I.
`
`INTRODUCTION
`A. Engagement
`I have been retained by counsel for Apple Inc. as an expert witness in
`1.
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`the above-captioned proceeding. I have been asked to provide an opinion
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`regarding the patentability of certain claims in U.S. Patent No. 10,188,299
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`(“the ’299 patent”) (Ex.1001). The face of the patent identifies Omni MedSci, Inc.
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`(“Omni”) as the assignee. I have been asked to provide a discussion of the
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`meaning of certain words and phrases in the claims of the ’299 patent, to provide a
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`description of the state of the art of the technology described in the ’299 patent, to
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`analyze the disclosure of the ’299 patent and the applications to which it claims
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`priority, and to analyze various references that I understand are prior art to this
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`patent.
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`B.
`2.
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`Background and Qualifications
`As indicated in my curriculum vitae (“CV”), Ex.1053, I am currently
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`a Principal Research Scientist at the Massachusetts Institute of Technology
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`(“MIT”). My CV includes additional information about my professional history
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`and contains further details on my experience, publications, patents, and other
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`qualifications to render an expert opinion. Below, I highlight some of my
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`experience that is relevant to the technology of the patent at issue.
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`3.
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`I earned a Bachelor of Science in Engineering from Carnegie Mellon
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`University in 1994 and a Master’s degree in Engineering from MIT in 1998. My
`Petitioner Apple Inc.
`Ex.1003, p. 1
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`thesis topic related to anisotropic wave guides and acoustic non-destructive testing.
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`In 2006, I earned my Ph.D. in Engineering from MIT. My research focused on
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`high-performance computation, signal processing, and electro-mechanical system
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`design.
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`4.
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`In 1997, I co-founded Xcitex Inc., a company that specialized in
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`video-acquisition and motion-analysis software. I served as the Chief Technology
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`Officer and directed and managed product development until 2006. Our first demo
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`product was an optical ring for human motion measurement used to capture user
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`hand motion in order to control the user’s interaction with a computer. Many of
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`the structural elements of our optical ring addressed the same system issues as
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`those described and claimed in the patent at issue. For example, our optical ring
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`included multiple light emitting diodes, multiple photodetectors, techniques for
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`modulation and synchronization, noise reduction algorithms, and optical
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`components for light blocking, light redirection, and light capture, and structural
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`components for holding and geometrically arranging the various components. We
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`estimated human hand-motion based on how that motion changed the detected
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`light. In our application we did not try to eliminate motion artifact, we tried to
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`measure it. In developing our ring, we considered well-known problems such as
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`ambient light and noise, which are, unsurprisingly, also mentioned in the patent at
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`issue. Motion Integrated Data Acquisition System (MiDAS) was our flagship
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`Petitioner Apple Inc.
`Ex.1003, p. 2
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`video and data acquisition product which relied upon precise synchronization of
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`multiple clocks for optical sensor and video acquisition, data acquisition, and
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`external illumination.
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`5.
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`I joined MIT in 2006 and was the Director of the Master of
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`Engineering in Advance Manufacturing and Design Program for over ten years.
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`The degree program covers four main components: Manufacturing Physics,
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`Manufacturing Systems, Product Design, and Business Fundamentals. Many of
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`the courses, projects, and papers my students undertake involve technologies
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`relevant to the patent at issue, for example, sensor devices including non-invasive
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`optical biosensors.
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`6.
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`In 2011, I co-founded MIT’s Medical Electronic Device Realization
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`Center (“MEDRC”) and currently serve as co-director. The MEDRC aims to
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`create and deploy revolutionary medical technologies by collaborating with
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`clinicians, the microelectronics, and medical devices industries. We combine
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`expertise in computation; communications; optical, electrical, and ultrasound
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`sensing technologies; and consumer electronics. We focus on the usability and
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`productivity of medical devices using, for example, image and signal processing
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`combined with intelligent computer systems to enhance practitioners’ diagnostic
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`intuition. Our research portfolio includes low power integrated circuits and
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`systems, big data, micro electro-mechanical systems, bioelectronics, sensors, and
`
`Petitioner Apple Inc.
`Ex.1003, p. 3
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`microfluidics. Specific areas of innovation include wearable, non-invasive and
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`minimally invasive optical biosensor devices, medical imaging, laboratory
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`instrumentation, and the data communication from these devices and instruments
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`to healthcare providers and caregivers. My experience with these devices is
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`directly applicable to the technology in the patent at issue. For example, in one
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`current project related to this work, we use a patient-mounted mobile near infrared
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`(NIR) camera to image and characterize the surface and subsurface structures of
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`the skin.
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`7.
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`I am the Associate Director of MIT.nano, MIT's new 200,000 sq-ft
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`nanofabrication and characterization facility. One of the major research initiatives
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`with MIT.nano focuses on sensors and sensing systems. Our research in sensing
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`science and sensing engineering is targeting innovations in advanced
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`manufacturing, healthcare, environmental remediation, smart infrastructure, and
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`the creation of advanced machines and materials. I also co-founded the Center for
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`Polymer Micro-fabrication at MIT. The Center’s research focuses on polymer-
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`based manufacturing processes and the large-scale commercialization of micro
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`fluidic devices for chemical, biomedical, and photonic applications. My
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`experience under these initiatives is directly applicable to the technology in the
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`patent at issue. We develop optical sensors to noninvasively monitor soft flexible
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`materials during the manufacturing process.
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`Petitioner Apple Inc.
`Ex.1003, p. 4
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`8.
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`Furthermore, my research focuses on computational instrumentation,
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`including the development of instrumentation and measurement solutions for
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`manufacturing systems and medical devices. Additionally, my teaching interests
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`include the design and modeling of large-scale systems in a wide variety of
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`decision-making domains and developing optimization algorithms and software for
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`analyzing and designing such systems. I teach or have taught courses in Electrical
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`Engineering, Controls, Optics, and Signal Processing, all pertinent subject matter
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`to the patent at issue.
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`9.
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`I have published approximately 85 papers, and have received a
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`number of best paper and distinguished paper awards. I am a co-author of a
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`number of papers that relate to the technology in the patent at issue.
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`C. Compensation
`I am being compensated for my time at the rate of $500 per hour for
`10.
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`my work in connection with this matter. I am being reimbursed for reasonable and
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`customary expenses associated with my work in this investigation. This
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`compensation is not dependent in any way on the contents of this Declaration, the
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`substance of any further opinions or testimony that I may provide or the ultimate
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`outcome of this matter.
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`Petitioner Apple Inc.
`Ex.1003, p. 5
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`Information Considered
`D.
`11. My opinions are based on my years of education, research, and
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`experience, as well as my investigation and study of relevant materials. In forming
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`my opinions, I have considered the materials I identify in the attached Exhibit List.
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`12.
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`I may rely upon these materials and/or additional materials to respond
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`to arguments raised by Omni. I may also consider additional documents and
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`information in forming any necessary opinions—including documents that may not
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`yet have been identified by me or provided to me.
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`13. My analysis of the materials produced in this investigation is ongoing,
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`and I will continue to review any new material as it is provided. This report
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`represents only those opinions I have formed to date. I reserve the right to revise,
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`supplement, and/or amend my opinions stated herein based on new information
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`and on my continuing analysis of the materials already provided.
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`II. LEGAL STANDARDS FOR PATENTABILITY
`14. Certain basic legal principles have been explained to me by counsel
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`for Apple. Below, I have recorded these legal standards as they were explained to
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`me.
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`15.
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`I understand that for an invention claimed in a patent to be found
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`patentable, it must be, among other things, new and not obvious from what was
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`known before the invention was made.
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`Petitioner Apple Inc.
`Ex.1003, p. 6
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`16.
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`I understand the information that is used to evaluate whether an
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`invention is new and not obvious is generally referred to as “prior art” and can
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`include patents and printed publications. I also understand that a patent will be
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`prior art if it was filed before the earliest effective filing date of the claimed
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`invention, while a printed publication will be prior art if it was publicly available
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`before that date. I understand that in this proceeding, the information that may be
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`evaluated to show unpatentability is limited to patents and printed publications.
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`17.
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`I understand that the effective filing date of the claimed invention is
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`the actual filing date of the claims, unless the applicant claims priority to an earlier
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`filed application that supports the claimed subject matter in the manner required by
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`35 U.S.C. § 112. I understand that this section requires the patent’s specification
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`to contain a sufficient written description of the claimed invention to demonstrate
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`that the applicant actually possessed the invention as of the filing date as broadly
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`as it is claimed. In considering whether this written description requirement is met,
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`I understand that I should consider the written description from the viewpoint of a
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`person of ordinary skill in the art. I also understand that I should consider whether
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`this person of ordinary skill would have recognized that the written description
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`describes the full scope of the claimed invention and that the inventor actually
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`possessed that full scope as of the claimed effective filing date.
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`Petitioner Apple Inc.
`Ex.1003, p. 7
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`18.
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`I understand that in this proceeding Apple has the burden of proving
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`that the challenged claims are unpatentable over the prior art by a preponderance of
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`the evidence. I understand that “a preponderance of the evidence” is evidence
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`sufficient to show that a fact is more likely true than it is not.
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`19.
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`I understand that there are two ways in which prior art may render a
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`patent claim unpatentable. First, the prior art can be shown to “anticipate” the
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`claim. Second, the prior art can be shown to have made the claim “obvious” to a
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`person of ordinary skill in the art.
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`A. Anticipation
`I understand that, for a patent claim to be “anticipated” by the prior
`20.
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`art, each and every requirement of the claim must be found, expressly or
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`inherently, in a single prior art reference as recited in the claim.
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`21.
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`I understand that claim limitations that are not expressly described in
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`a prior art reference may still be there if they are “inherent” to the thing or process
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`being described in the prior art.
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`22.
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`I understand that it can be acceptable to consider evidence other than
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`the information in a particular prior art document to determine if a feature is
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`necessarily present in or inherently described by that document.
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`Petitioner Apple Inc.
`Ex.1003, p. 8
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`23.
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`I understand that if a reference incorporates other documents by
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`reference, the incorporating reference and the incorporated reference(s) should be
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`treated as a single prior art reference for purposes of analyzing anticipation.
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`24.
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`I understand that to be anticipatory, a reference must not only
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`explicitly or inherently disclose every claimed feature, but those features must also
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`be “arranged as in the claim.” Differences between the prior art reference and a
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`claimed invention, however slight, invoke the question of obviousness, not
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`anticipation.
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`B. Obviousness
`I understand that a claimed invention is not patentable if it would have
`25.
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`been obvious to a person of ordinary skill in the field of the invention at the time
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`the invention was made. I understand that in determining whether a patent claim is
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`obvious, one must consider the following four factors: (i) the scope and content of
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`the prior art, (ii) the differences between the prior art and the claims at issue, (iii)
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`the knowledge of a person of ordinary skill in the pertinent art; and (iv) objective
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`factors indicating obviousness or non-obviousness, if present (such as commercial
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`success or industry praise).
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`26.
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`I understand the objective factors indicating obviousness or non-
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`obviousness may include: commercial success of products covered by the patent
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`claims; a long-felt need for the invention; failed attempts by others to make the
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`Petitioner Apple Inc.
`Ex.1003, p. 9
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`invention; copying of the invention by others in the field; unexpected results
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`achieved by the invention; praise of the invention by those in the field; the taking
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`of licenses under the patent by others; expressions of surprise by experts and those
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`skilled in the art at the making of the invention; and the patentee proceeded
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`contrary to the accepted wisdom of the prior art. I also understand that any of this
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`evidence must be specifically connected to the invention rather than being
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`associated with the prior art or with marketing or other efforts to promote an
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`invention. I am not presently aware of any evidence of “objective factors”
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`suggesting the claimed methods are not obvious, and reserve my right to address
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`any such evidence if it is identified in the future.
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`27.
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`In addition, I understand that the obviousness inquiry should not be
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`done in hindsight, but must be done using the perspective of a person of ordinary
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`skill in the relevant art as of the effective filing date of the patent claim.
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`28.
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`I understand that the Supreme Court has rejected a rigid approach to
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`determining the question of obviousness, such as one that requires a challenger to
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`identify a “teaching, suggestion, or motivation to combine” known elements.
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`Instead, a challenger needs to articulate reasoning for combining known elements.
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`Such reasoning can be based on design considerations, market demands, looking to
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`solutions to related problems in related fields, and on the “ordinary innovation”
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`and creativity that would be applied by a person of ordinary skill in the art.
`
`Petitioner Apple Inc.
`Ex.1003, p. 10
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`29.
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`I understand that an invention that might be considered an obvious
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`variation or modification of the prior art may be considered non-obvious if one or
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`more prior art references discourages or leads away from the line of inquiry
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`disclosed in the reference(s). A reference does not “teach away” from an invention
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`simply because the reference suggests that another embodiment of the invention is
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`better or preferred. My understanding of the doctrine of teaching away requires a
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`clear indication that the combination should not be attempted (e.g., because it
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`would not work or explicit statements saying the combination should not be made).
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`III. BACKGROUND INFORMATION ABOUT THE ’299 PATENT
`A. Effective Filing Date of the ’299 Patent
`30. The ’299 patent is titled “System Configured for Measuring
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`Physiological Parameters.” Ex.1001, Face. It issued from U.S. Application No.
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`15/860,065, which was a continuation of U.S. Patent No. 9,651,533 (filed October
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`6, 2015), which was a continuation of U.S. Patent No. 9,164,032 (filed December
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`17, 2013). The ’299 patent claims benefit to U.S. Provisional Application No.
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`61/747,487 (filed December 31, 2012) (“’487 provisional application”). Id.
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`31.
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`I have reviewed the ’487 provisional application and do not believe
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`that they support the claims of the ’299 patent in the manner required by 35 U.S.C.
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`§ 112. The ’487 Provisional does not describe a measurement device that
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`communicates with a personal device, where the personal device wirelessly
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`Petitioner Apple Inc.
`Ex.1003, p. 11
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`transmits data to a remote device for further processing as required by independent
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`claim 7. The provisional describes a detection system that can send data to “a
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`computational system, comprising computers or other processing equipment,” but
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`there is no disclosure that the computing system can send data it has processed to a
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`remote system for additional processing. Ex.1015, [0066], [0074] (describing a
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`computer system 1811). The provisional also describes a camera that can
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`wirelessly interface with a computer, table, or smartphone, but there is no
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`disclosure of those devices sending the camera data to a remote device. Ex.1015,
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`[0068]. It is therefore my opinion that the provisional application does not
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`demonstrate that the inventor was in possession of a device with these elements of
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`the claims.
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`B.
`32.
`
`The Prosecution History of the ’299 Patent
`I have reviewed the file history of the ’299 patent (Exhibit 1002).
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`Before the application was examined, the applicant submitted several Information
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`disclosure statements (IDS) that included several hundred references. Ex.1002, 1-
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`80. The examiner allowed the patent after a preliminary amendment that added
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`several limitations to independent claims 1, 6, and 12. Id., 234-238. Among those
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`amendments, the applicant added limitations regarding the claimed “personal” and
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`“remote” devices. Ex.1002, 234. On May 14, 2018, the examiner issued a notice
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`Petitioner Apple Inc.
`Ex.1003, p. 12
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`of allowance stating that the prior art does not teach several limitations including
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`the claimed “detection system” and “remote device.” Id., 250-252.
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`33. The examiner later issued several corrected notices of allowability
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`(“NOA”) maintaining the same rationale on May 18 (Id., 490-492). After the
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`corrected notice of allowability, applicant filed IDS that included additional prior
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`art on July 19, 2018. Ex.1002, 506-507. On August 31, the examiner issued a first
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`corrected NOA. Id., 520-521. Later, the applicant again filed an IDS with
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`additional prior art on September 11. Id., 555-565. On September 17, the
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`examiner issued another corrected NOA. Id., 584-585. The references submitted
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`with these two IDS included Lisogurski (Ex.1011), Carlson (Ex.1009),
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`Mannheimer (Ex.1008), and Park (Ex.1010). Ex.1002, 506, 507, 555, 557. The
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`examiner provided no additional reasons for allowance over the new prior art.
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`34. On October 21, the applicant amended claims 6 and 9 (issued as
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`claims 7 and 10, respectively) and added claims 25-28 (issued as claims 11-14).
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`Ex.1002, 610-611, 614-615. On November 9, 2018, the examiner issued another
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`notice of allowability and repeated a similar rationale for allowing the claims. Id.,
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`632-633.
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`Petitioner Apple Inc.
`Ex.1003, p. 13
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`IPR2020-00175
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`Declaration of Dr. Anthony
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`C. Technical Field
`35. The ’299 patent generally relates to optical sensors and devices that
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`use optical sensors for measurement of physiological signals or biological
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`parameters.
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`D. Level of Ordinary Skill in the Art
`I have been instructed that the claims of a patent are to be reviewed
`36.
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`from the point of view of a hypothetical person of ordinary skill in the art at the
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`time of the filing of the patent.
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`37. Based on my knowledge and experience, it is my opinion that a
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`person of ordinary skill in the art (“skilled person”) at the relevant time frame
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`would have been a person with a good working knowledge of optical sensing
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`techniques and their applications, and some familiarity with optical system design
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`and signal processing techniques. That knowledge would have been gained via an
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`undergraduate education in engineering (electrical, mechanical, biomedical or
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`optical) or a related field of study, along with relevant experience in studying or
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`developing physiological monitoring devices (e.g., non-invasive optical
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`biosensors) in industry or academia. This description is approximate; varying
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`combinations of education and practical experience also would be sufficient.
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`38. Well before December 2012, my level of skill in the art was at least
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`that of a person of ordinary skill in the art in the field of the ’299 patent, as
`
`Petitioner Apple Inc.
`Ex.1003, p. 14
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`

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`IPR2020-00175
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`Declaration of Dr. Anthony
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`discussed above. I am qualified to provide opinions concerning what a person of
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`ordinary skill in the art would have known and understood at that time. In
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`preparing this declaration, I have considered the issues from the perspective of a
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`hypothetical person of ordinary skill in the art at the relevant timeframe.
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`IV. TECHNICAL BACKGROUND
`Photoplethysmography
`A.
`39. The use of optical sensors to detect physiological parameters,
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`including photoplethysmography, has been known for decades. Optical techniques
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`are commonly used in medical monitoring systems such as pulse oximetry systems
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`that measure a person’s pulse rate and blood oxygen saturation. Ex.1019 (BE
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`Handbook) at 769-76, 1346-55 (discussing oximetry and other applications).
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`40. Photoplethysmography works by directing light into a person’s tissue
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`and measuring the light that is reflected back from or transmitted through the
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`tissue. Ex.1019 (BE Handbook) at 764. Different components of blood or tissue
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`absorb different wavelengths of light. By measuring how much light is absorbed
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`by the tissue and how the absorption changes over time, a device can calculate
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`parameters that are related to the properties of the tissue.
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`41. For example, hemoglobin (the protein molecule in blood that carries
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`oxygen to cells) reflects more red light when it is more oxygenated than when it is
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`deoxygenated; it absorbs more red light when it is deoxygenated. Ex.1019 (BE
`
`Petitioner Apple Inc.
`Ex.1003, p. 15
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`

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`IPR2020-00175
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`Declaration of Dr. Anthony
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`Handbook) at 769. Hemoglobin reflects the same amount of infrared (IR) light
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`whether oxygenated or deoxygenated. Ex.1019 (BE Handbook) at 769. If a device
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`measures the absorbed red and IR light multiple times per second, the device can
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`determine several things: (i) the ratio of oxygenated to deoxygenated hemoglobin
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`(oxygen saturation), and (ii) how the volume of blood in the tissue changes,
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`allowing detection of a person’s pulse. Ex.1019 (BE Handbook) at 769, 771.
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`42. Photoplethysmography is an optical technique, and it uses basic
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`optical components or building blocks. The “basic building blocks” of optical
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`sensor systems include lenses, mirrors, reflective surfaces, filters, beam splitters,
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`light sources, fiber optics, light detectors, and other passive components and
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`various active components to convert light signals to electrical signals. Ex.1019
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`(BE Handbook) at 765.
`
`Petitioner Apple Inc.
`Ex.1003, p. 16
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`

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`IPR2020-00175
`
`Declaration of Dr. Anthony
`
`
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`Ex.1019 (BE Handbook) at 765. In portable devices, the light sources are typically
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`light emitting diodes (LEDs) because they are small and have low power
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`requirements. Ex.1019 (BE Handbo