`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.,
`Petitioner,
`v.
`PARUS HOLDINGS, INC.,
`Patent Owner.
`
`Case No. IPR2020-00686 & IPR2020-00687
`U.S. Patent No. 7,076,431 & 9,451,084
`
`DECLARATION OF BENEDICT OCCHIOGROSSO IN SUPPORT OF
`PATENT OWNER’S SUR-REPLY TO PETITIONER’S REPLY TO
`PATENT OWNER’S RESPONSE TO INTER PARTES REVIEW OF U.S.
`PATENT NOS. 7,076,431 & 9,451,084
`
`Parus Exhibit 2027
`Apple Inc. v. Parus Holdings, Inc.
`IPR2020-00686
`Page 1 of 5
`
`
`
`Case No. IPR2020-00686 & -00687
`U.S. Patent Nos. 7,076,431 & 9,451,084
`TABLE OF CONTENTS
`
`PAGE
`INTRODUCTION ........................................................................................... 1
`OPINIONS ....................................................................................................... 1
`
`I.
`II.
`
`i
`
`Parus Exhibit 2027, Page 2 of 5
`
`
`
`Case No. IPR2020-00686 & -00687
`U.S. Patent Nos. 7,076,431 & 9,451,084
`I, Benedict Occhiogrosso, hereby declare the following:
`
`I.
`
`INTRODUCTION
`1.
`I have been asked to respond to new opinions that Dr. Terveen offered
`
`in his supplemental declaration. (Ex. 1040). This supplemental declaration directly
`
`rebuts these new opinions. All of my opinions expressed in my original declaration
`
`(Ex. 2025) remain the same. References to opinions of the ’431 Patent below are
`
`intended as equally applicable to the ’084 Patent.
`
`II. OPINIONS
`2.
`Ladd does not disclose speech recognition that converts speech to text
`
`and then compares the converted text to vocabulary or grammar in order to recognize
`
`the speech inputs as Dr. Terveen now contends. (Ex. 1040, ¶¶ 2-9). Instead, Ladd
`
`discloses speech recognition that compares recorded audio speech inputs with
`
`speech patterns.
`
`3.
`
`For example, Ladd indicates that the automatic speech recognition
`
`(“ASR”) unit “identifies a selected speech pattern of the inputs, [and] the ASR
`
`unit 254 sends an output signal to implement the specific function associated with
`
`the recognized voice pattern.” (Ex. 1004, 9:36-39 (emphasis added)). Ladd further
`
`indicates that the detection unit “records the audio inputs from the user and
`
`compares the audio inputs to the vocabulary or grammar stored in the database
`
`server unit.” (Ex. 1004, 10:12-15 (emphasis added)). These disclosures from Ladd,
`
`1
`
`Parus Exhibit 2027, Page 3 of 5
`
`
`
`Case No. IPR2020-00686 & -00687
`U.S. Patent Nos. 7,076,431 & 9,451,084
`which Dr. Terveen identify as describing speech recognition in Ladd, demonstrate
`
`to me that Ladd discloses speech recognition that directly compares audio inputs,
`
`not text, to a vocabulary or grammar in order to identify a selected speech pattern of
`
`the inputs.
`
`2
`
`Parus Exhibit 2027, Page 4 of 5
`
`
`
`Case No. IPR2020-00686 & -00687
`U.S. Patent Nos. 7,076,431 & 9,451,084
`
`I declare that all statements made herein of my knowledge are true, and that
`
`all statements made on information and belief are believed to be true, and that
`
`these statements were made with the knowledge that willful false statements and
`
`the like so made are punishable by fine or imprisonment, or both, under Section
`
`1001 of Title 18 of the United States Code.
`
`3
`
`Parus Exhibit 2027, Page 5 of 5
`
`
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