UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GOOGLE LLC, SAMSUNG ELECTRONICS CO., LTD., SAMSUNG
`ELECTRONICS AMERICA, INC., LG ELECTRONICS INC., and LG
`ELECTRONICS U.S.A., INC.,
`Petitioners,
`v.
`PARUS HOLDINGS, INC.,
`Patent Owner.
`
`Case No. IPR2020-00846 & IPR2020-00847
`U.S. Patent No. 7,076,431 & 9,451,084
`
`DECLARATION OF BENEDICT OCCHIOGROSSO IN SUPPORT OF
`PATENT OWNER’S RESPONSE TO INTER PARTES REVIEW OF U.S.
`PATENT NOS. 7,076,431 & 9,451,084
`
`Parus Exhibit 2059
`Google, et al. v. Parus Holdings, Inc.
`IPR2020-00846
`Page 1 of 105
`
`

`

`VI.
`
`PAGE
`INTRODUCTION ........................................................................................... 1
`I.
`QUALIFICATIONS AND EXPERIENCE ..................................................... 2
`II.
`III. MATERIALS CONSIDERED ...................................................................... 10
`IV.
`PERSON OF ORDINARY SKILL IN THE ART ........................................ 16
`V.
`LEGAL STANDARDS ................................................................................. 17
`A.
`Obviousness ......................................................................................... 17
`B.
`Claim Construction.............................................................................. 19
`C.
`Swearing Behind a Reference ............................................................. 19
`PRIOR ART SPEECH-BASED INFORMATION RETRIEVAL
`SYSTEMS ..................................................................................................... 20
`VII. BACKGROUND AND TECHNOLOGY FOR THE ’431 AND ’084
`PATENTS ...................................................................................................... 21
`A.
`Prior Art Interactive Voice Response Systems Suffered From
`Numerous Drawbacks ......................................................................... 21
`1.
`Typical Prior Art Systems For Accessing Web Sites
`Were Not Sufficiently Portable, Comprehensive, And
`Affordable ................................................................................. 21
`Voice Enabled Options Introduced Additional Problems
`and Drawbacks .......................................................................... 22
`Prior Art “Interactive Voice Response” Systems Suffered
`From A Lack Of Fault Tolerance, Limited Webpage
`Resources, And Generic Search Options And Results ............. 23
`The ’431 and ’084 Patent’s Solutions ................................................. 26
`B.
`VIII. THE SOURCE CODE FOR WEBLEY ASSISTANT.................................. 26
`A.
`’431 Patent ........................................................................................... 27
`1.
`[1.pre] A system for retrieving information from pre-
`selected web sites by uttering speech commands into a
`voice enabled device and providing to users retrieved
`information in an audio form via said voice enabled
`device, said system comprising: ............................................... 28
`
`2.
`
`3.
`
`Case No. IPR2020-00846 & -00847
`U.S. Patent Nos. 7,076,431 & 9,451,084
`TABLE OF CONTENTS
`
`i
`
`Parus Exhibit 2059, Page 2 of 105
`
`

`

`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`8.
`
`9.
`
`10.
`
`Case No. IPR2020-00846 & -00847
`U.S. Patent Nos. 7,076,431 & 9,451,084
`[1.a] a computer, said computer operatively connected to
`the internet; ............................................................................... 29
`[1.b] a voice enabled device operatively connected to
`said computer, said voice enabled device configured to
`receive speech commands from users; ...................................... 29
`[1.c] at least one speaker-independent speech recognition
`device, said speaker-independent speech recognition
`device operatively connected to said computer and to
`said voice enabled device; ........................................................ 30
`[1.d] at least one speech synthesis device, said speech
`synthesis device operatively connected to said computer
`and to said voice enabled device;.............................................. 30
`[1.e] at least one instruction set for identifying said
`information to be retrieved, said instruction set being
`associated with said computer, said instruction set
`comprising: a plurality of pre-selected web site
`addresses, each said web site address identifying a web
`site containing said information to be retrieved; ...................... 31
`[1.f] at least one recognition grammar associated with
`said computer, each said recognition grammar
`corresponding to each said instruction set and
`corresponding to a speech command; said speech
`command comprising an information request selectable
`by the user; ................................................................................ 31
`[1.g] said speaker-independent speech recognition device
`configured to receive from users via said voice enabled
`device said speech command and to select the
`corresponding recognition grammar upon receiving said
`speech command; ...................................................................... 32
`[1.h] said computer configured to retrieve said instruction
`set corresponding to said recognition grammar selected
`by said speaker-independent speech recognition device; ......... 33
`[1.i] said computer further configured to access at least
`one of said plurality of web sites identified by said
`instruction set to obtain said information to be retrieved, ........ 33
`
`i
`
`Parus Exhibit 2059, Page 3 of 105
`
`

`

`11.
`
`12.
`
`13.
`
`14.
`
`15.
`
`16.
`
`17.
`
`18.
`
`Case No. IPR2020-00846 & -00847
`U.S. Patent Nos. 7,076,431 & 9,451,084
`[1.j] said computer configured to first access said first
`web site of said plurality of web sites and, if said
`information to be retrieved is not found at said first web
`site, said computer configured to sequentially access said
`plurality of web sites until said information to be
`retrieved is found or until said plurality of web sites has
`been accessed; ........................................................................... 34
`[1.k] said speech synthesis device configured to produce
`an audio message containing any retrieved information
`from said pre-selected web sites, and said speech
`synthesis device further configured to transmit said audio
`message to said users via said voice enabled device. ............... 35
`[2.] The system of claim 1 wherein said internet is the
`Internet. ..................................................................................... 35
`[4.] The system of claim 1 wherein said voice enabled
`device is a standard telephone, an IP telephone, a cellular
`phone, a PDA, a personal computer, a DVD player, a
`television or other video display device, a CD player, a
`MP3 player, or any other device capable of transmitting
`said audio message. ................................................................... 36
`[5.] The system of claim 1 wherein said speaker-
`independent speech recognition device is configured to
`analyze phonemes to recognize said speech commands........... 36
`[6.] The system of claim 1 wherein said speaker-
`independent speech recognition device is configured to
`recognize naturally spoken speech commands. ........................ 37
`[7.] The system of claim 1 wherein said instruction set
`further comprises a content descriptor associated with
`each said web site address, said content descriptor pre-
`defining a portion of said web site containing said
`information to be retrieved. ....................................................... 37
`[9.] The system of claim 1 wherein said computer is
`further configured to periodically search said internet to
`identify new web sites and to add said new web sites to
`said plurality of web sites. ........................................................ 37
`
`i
`
`Parus Exhibit 2059, Page 4 of 105
`
`

`

`20.
`
`21.
`
`B.
`
`19.
`
`Case No. IPR2020-00846 & -00847
`U.S. Patent Nos. 7,076,431 & 9,451,084
`[10.] The system of claim 1 wherein said instruction set
`further comprises a ranking associated with each said
`web site address, said ranking indicating the order in
`which the plurality of pre-selected web sites are accessed. ...... 38
`[13.] The system in claim 10 wherein said computer is
`configured to access said plurality of web sites in order
`of ranking to retrieve said information requested by said
`user, said computer further configured to first access said
`web site having the highest ranking. ......................................... 38
`[14.] The system of claim 1 further comprising a
`database operatively connected to said computer, said
`database configured to store said information gathered
`from said web sites in response to said information
`requests. ..................................................................................... 39
`’084 Patent ........................................................................................... 39
`1.
`[1pre] 1. A system for acquiring information from one or
`more sources maintaining a listing of web sites by
`receiving speech commands uttered by users into a voice-
`enabled device and for providing information retrieved
`from the web sites to the users in an audio form via the
`voice-enabled device, the system comprising: ......................... 39
`[1.a] at least one computing device, the computing device
`operatively coupled to one or more networks;.......................... 41
`[1.b] at least one speaker-independent speech-recognition
`device, the speaker-independent speech-recognition
`device operatively connected to the computing device
`and configured to receive the speech commands; .................... 41
`[1.c] at least one speech-synthesis device, the speech-
`synthesis device operatively connected to the computing
`device; ....................................................................................... 42
`[1.d] memory operatively associated with the computing
`device with at least one instruction set for identifying the
`information to be retrieved, the instruction set being
`associated with the computing device, the instruction set
`comprising: ................................................................................ 42
`
`2.
`
`3.
`
`4.
`
`5.
`
`i
`
`Parus Exhibit 2059, Page 5 of 105
`
`

`

`6.
`
`7.
`
`8.
`
`9.
`
`10.
`
`Case No. IPR2020-00846 & -00847
`U.S. Patent Nos. 7,076,431 & 9,451,084
`[1.e] a plurality of web site addresses for the listing of
`web sites, each web site address identifying a web site
`containing the information to be retrieved;............................... 43
`[1.f] at least one recognition grammar associated with the
`computing device, each recognition grammar
`corresponding to each instruction set and corresponding
`to a speech command, the speech command comprising
`an information request provided by the user, the speaker-
`independent speech-recognition device configured to
`receive the speech command from the users via the
`voice-enabled device and to select the corresponding
`recognition grammar upon receiving the speech
`command; .................................................................................. 44
`[1.g] the computing device configured to retrieve the
`instruction set corresponding to the recognition grammar
`provided by the speaker-independent speech-recognition
`device; ....................................................................................... 45
`[1.h] the computing device further configured to access at
`least one of the plurality of web sites identified by the
`instruction set to obtain the information to be retrieved,
`wherein the computing device is further configured to
`periodically search via the one or more networks to
`identify new web sites and to add the new web sites to
`the plurality of web sites, the computing device
`configured to access a first web site of the plurality of
`web sites and, if the information to be retrieved is not
`found at the first web site, the computer configured to
`access the plurality of web sites remaining in an order
`defined for accessing the listing of web sites until the
`information to be retrieved is found in at least one of the
`plurality of web sites or until the plurality of web sites
`have been accessed; .................................................................. 45
`[1.i] the speech synthesis device configured to produce
`an audio message containing any retrieved information
`from the plurality of web sites, and .......................................... 47
`
`i
`
`Parus Exhibit 2059, Page 6 of 105
`
`

`

`12.
`
`13.
`
`14.
`
`15.
`
`16.
`
`11.
`
`Case No. IPR2020-00846 & -00847
`U.S. Patent Nos. 7,076,431 & 9,451,084
`[1.j] the speech synthesis device further configured to
`transmit the audio message to the users via the voice-
`enabled device. .......................................................................... 47
`2. The system of claim 1, wherein the one or more
`networks include the Internet. ................................................... 48
`4. The system of claim 1, wherein the voice-enabled
`device is at least one of a standard telephone, an IP
`telephone, a cellular phone, a PDA, a personal computer,
`a DVD player, a television or other video display device,
`a CD player, a MP3 player, and any other device capable
`of transmitting the audio message. ........................................... 48
`5. The system of claim 1, wherein the speaker-
`independent speech recognition device is configured to
`analyze phonemes to recognize the speech commands. ........... 48
`6. The system of claim 1, wherein the speaker-
`independent speech-recognition device is configured to
`recognize naturally spoken speech commands. ........................ 49
`7. The system of claim 1, wherein the instruction set
`further comprises: a content descriptor associated with
`each web site address, the content descriptor pre-defining
`a portion of the web site containing the information to be
`retrieved. ................................................................................... 49
`10. The system of claim 1, wherein the instruction set
`further comprises a pre-defined order of access
`associated with each web site address, the pre-defined
`order of access indicating the order in which the plurality
`of web sites are accessed. .......................................................... 50
`14. The system of claim 1, further comprising: a database
`operatively connected to the computing device, the
`database configured to store the information gathered
`from the web sites in response to the information
`requests. ..................................................................................... 50
`’846 AND ’847 IPR ANALYSIS .................................................................. 51
`A.
`Prior Art ............................................................................................... 51
`1.
`Kovatch ..................................................................................... 51
`
`17.
`
`18.
`
`IX.
`
`i
`
`Parus Exhibit 2059, Page 7 of 105
`
`

`

`B.
`
`C.
`
`D.
`
`2.
`
`Case No. IPR2020-00846 & -00847
`U.S. Patent Nos. 7,076,431 & 9,451,084
`Neal ........................................................................................... 55
`2.
`Petitioner does not establish that Claim 1(j) is taught by the
`combination of Kovatch and Neal or by any other combination. ....... 63
`1.
`Kovatch does not disclose sequentially accessing web
`sites until the information to be retrieved is found. .................. 64
`Neal does not disclose nor teach sequentially accessing
`web sites until the information to be retrieved is found. .......... 64
`Petitioner does not provide a sufficient motivation to combine
`Kovatch, Neal, and DeSimone ............................................................. 69
`1.
`A POSITA would not combine Kovatch with Neal. ................. 70
`2.
`A POSITA would not combine DeSimone with Kovatch
`and Neal .................................................................................... 74
`Petitioner relies on hindsight to cobble together the
`alleged combination .................................................................. 75
`There is written description support for claims 9 and 14 of the
`’431 patent and claim 1 of the ’084 patent .......................................... 76
`1.
`Claim 9 of the ’431 and Claim 1 of the ’084 ............................ 76
`2.
`Claim 14 of the ’431 ................................................................. 80
`
`3.
`
`i
`
`Parus Exhibit 2059, Page 8 of 105
`
`

`

`Case No. IPR2020-00846 & -00847
`U.S. Patent Nos. 7,076,431 & 9,451,084
`I, Benedict Occhiogrosso, hereby declare the following:
`
`I.
`
`INTRODUCTION
`1.
`My name is Benedict Occhiogrosso. I am a citizen of the United States
`
`over 21 years of age, and the co-founder and President of DVI Communications, Inc.
`
`I make this Declaration based on facts and matters within my own knowledge and
`
`on information provided to me by others, and if called as a witness, I could and
`
`would competently testify to the matters set forth herein.
`
`2.
`
`I have been retained as a technical expert witness in this matter by
`
`Counsel for Patent Owner, Parus Holdings, Inc. (“Patent Owner” or “Parus”) to
`
`provide my independent opinions on certain issues requested by Counsel for Patent
`
`Owner relating to the Petitions for Inter Partes Review of United States Patent No.
`
`7,076,431 (the “’431 patent”) and United States Patent No. 9,451,084 (the “’084
`
`patent”). I am being compensated at an hourly rate of $475. My compensation in
`
`this matter is not based on the substance of my opinions or on the outcome of this
`
`matter.
`
`3.
`
`I am providing this Declaration for both the ’431 and ’084 Patents given
`
`the patents have substantially the same specification. Counsel has also informed me
`
`that both the ’431 and ’084 Patents claim the same priority date—specifically,
`
`February 4, 2000—due to both patents claiming priority to the same priority
`
`document. Many of the claimed limitations of the ’084 Patent are substantially
`
`1
`
`Parus Exhibit 2059, Page 9 of 105
`
`

`

`Case No. IPR2020-00846 & -00847
`U.S. Patent Nos. 7,076,431 & 9,451,084
`similar to the ’431 Patent and vice-versa. Many of my citations to the patents are
`
`made with respect to the ’431 Patent for ease of reference. However, because the
`
`specifications of the ’431 and ’084 Patents are substantially similar, any citation to
`
`the specification of the ’431 Patent applies equally to the ’084 Patent, unless
`
`otherwise indicated.
`
`4.
`
`I have been informed by counsel that the claims being challenged in the
`
`accompanying Petition for the ’431 Patent are Claims 1-7, 9-10, and 13-14 (“the
`
`Challenged Claims of the ’431 Patent”); and of the ’084 Patent are Claims 1-7, 10,
`
`and 14 (“the Challenged Claims of the ’084 Patent”).
`
`II. QUALIFICATIONS AND EXPERIENCE
`5.
`I offer the following summary description of my background and
`
`experience, which I believe qualifies me to opine as one skilled in the art of the
`
`relevant technology. I attach my CV as Exhibit A to this Declaration, which is
`
`current as of this date to the best of my knowledge.
`
`6.
`
`I hold a Bachelor of Science Degree in Electrical Engineering as well
`
`as a Master of Science Degree in Electrical Engineering, both from the Polytechnic
`
`Institute of Brooklyn (now part of New York University).
`
`7.
`
`I have authored or co-authored nearly three dozen articles in peer-
`
`reviewed journals, conference proceedings, texts, industry trade publications, and
`
`monographs. These publications span a range of topics including: Integrated Voice–
`
`2
`
`Parus Exhibit 2059, Page 10 of 105
`
`

`

`Case No. IPR2020-00846 & -00847
`U.S. Patent Nos. 7,076,431 & 9,451,084
`Data Communications/Switching, Integrated Packet-Circuit Switching, Voice
`
`Digitization, Packet Voice, Indoor Wireless distribution, Disaster Recovery and
`
`Business Continuity, Data Center Engineering, Switching Processor Architecture,
`
`Telephone and Voice Mail Systems, PBX & LAN switching premises-based systems
`
`and related technologies and Internet of Things (IoT).
`
`8.
`
`I have more than 40 years of telecommunications and information
`
`technology experience. I am the co-founder and President of DVI Communications
`
`Inc., a telecommunications, information technology, and business consulting firm.
`
`Since establishing DVI in 1979, I have planned, designed, implemented, and
`
`managed large-scale projects involving wired and wireless communications
`
`systems, which included transmission of voice and data. Prior to founding DVI and
`
`for several years thereafter, I held a Department of Defense security clearance and
`
`worked on several classified programs within the defense industry, where I
`
`supported the development of several pioneering technologies that have served as
`
`the prototypes for many telecommunications and IT systems later utilized in
`
`commercial practice.
`
`9.
`
`Throughout the course of my professional career, I have worked and
`
`consulted extensively in the fields of information processing, including transaction
`
`processing systems design and development (including centralized and distributed,
`
`encompassing both fault-tolerant and real-time processing), various hardware and
`
`3
`
`Parus Exhibit 2059, Page 11 of 105
`
`

`

`Case No. IPR2020-00846 & -00847
`U.S. Patent Nos. 7,076,431 & 9,451,084
`software platforms (including enterprise client/server incorporating different OS &
`
`DBMS), systems integration, and telecommunications. These telecommunications
`
`systems include wide area and local area networking technology, data, voice, and
`
`video switching systems, and both wired transmission (such as cable and fiber optic)
`
`and wireless transmission (such as UHF/VHF, Microwave, satellite, cellular, and
`
`Wi-Fi, for private networks, Intranets, and the Internet).
`
`10. My technical expertise encompasses several disciplines, such as
`
`transaction processing systems design for various industries and applications, IT
`
`platform engineering, data center, and telecommunications network design. In
`
`addition, I have extensive experience with numerous interfaces and protocols, real-
`
`time synchronization as well as selected applications systems in various industries.
`
`These include financial services (including call centers, trading floors, supporting
`
`consumer, commercial and investment banking), health information systems
`
`(including patient information, clinical and laboratory systems), transportation and
`
`energy utilities (including dispatch, customer service, and trouble reporting),
`
`military aerospace (including Command and Control, position tracking and fusion
`
`centers), and telecommunications switching and operational support systems (order
`
`entry, billing, trouble reporting). Many of these solutions have included Interactive
`
`Voice Response (IVR) systems. I have also provided operational and strategic
`
`planning consultation for client IT enterprise-level systems. Over the course of my
`
`4
`
`Parus Exhibit 2059, Page 12 of 105
`
`

`

`Case No. IPR2020-00846 & -00847
`U.S. Patent Nos. 7,076,431 & 9,451,084
`career, I developed hardware and software, and I have also managed engineering
`
`development teams engaged in product development.
`
`11.
`
`I have extensive expertise in voice-data-video switching, and
`
`transmission systems deployed in networks, including both circuit switching and
`
`packet switching using wireline and wireless distribution methods (including Land
`
`Mobile radio, Satellite, microwave, cellular, and Wi-Fi). In addition, I have
`
`developed various applications systems including voicemail, e-mail, unified
`
`messaging, and audio/video recording for a variety of facility types including call-
`
`contact centers, data centers, trading floors, and mission-critical communications
`
`centers. I have detailed knowledge of Internet Protocol (IP) technology in general,
`
`and also Voice over Internet Protocol (VoIP). I have extensive expertise in voice
`
`digitization, buffering, relay and delay techniques, as well as digital signal
`
`processing of voice signals. At present, my primary responsibilities encompass
`
`strategic planning and systems design of client IT Infrastructures and program
`
`management for major projects undertaken by DVI.
`
`12.
`
`I have also developed
`
`technical expertise with
`
`regard
`
`to
`
`telecommunication applications utilizing speech recognition, including call center
`
`and interactive voice response applications, like the kind described in the Asserted
`
`Patents. I have supported numerous enterprise and institutional clients in the design
`
`of their call centers. My experience in this field includes the use of both speaker-
`
`5
`
`Parus Exhibit 2059, Page 13 of 105
`
`

`

`Case No. IPR2020-00846 & -00847
`U.S. Patent Nos. 7,076,431 & 9,451,084
`independent and speaker-dependent speech recognition algorithms in different
`
`applications utilizing isolated speech recognition and continuous speech recognition.
`
`13.
`
`I have worked on behalf of the Metropolitan Transportation Authority
`
`(MTA) on relay services and assistive technologies. For example, I worked on voice
`
`processing for captioning of live meeting proceedings, which are then made
`
`available for the deaf and hard of hearing. For the MTA, I implemented a system for
`
`captioning live meetings’ proceedings for the deaf and hard of hearing in compliance
`
`with the Americans with Disabilities Act (ADA). The project included logistics,
`
`audio routing, voice processing, video display and captioning to generate a
`
`transcription of a speaker’s voice at a public meeting, and display of the resulting
`
`transcription on television monitors in the boardroom as well as over institutional
`
`broadcast channels and Internet feeds. In-line corrections would be generated and
`
`displayed by the transcriptionist during the proceedings. I have also worked on
`
`captioning or transcription of previously recorded information for compliance and
`
`record-keeping purposes.
`
`14.
`
`For example, with telecommunication services and associated devices
`
`for the switching and transmission of voice and data over POTS lines, digital
`
`transmission facilities (such as T1, E1 and ISDN PRI and BRI), cellular voice and
`
`data and other wireless–based technologies (Line of Sight Microwave, Land Mobile
`
`Radio, Satellite) and IP- and VoIP-based communications, I have deployed various
`
`6
`
`Parus Exhibit 2059, Page 14 of 105
`
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`

`Case No. IPR2020-00846 & -00847
`U.S. Patent Nos. 7,076,431 & 9,451,084
`types of switching and routing systems (supporting numerous voice and data
`
`communications networks) at major institutional clients such as Citicorp NY, City
`
`University of New York, Bear Stearns, Societe Generale, RPCI, and Bertelsmann.
`
`For these projects, among other things, I had to understand the technical
`
`implications, shortcomings, and advantages of deploying different types of
`
`switching systems interconnecting voice and data channels, and the manner in which
`
`various communication protocols transmit voice and data and would use available
`
`bandwidth on different transmission facilities. The transmission facilities included
`
`both terrestrial (wired and wireless) as well as satellite-based communications. I also
`
`had to understand the compatibility issues with various end-user devices and central
`
`network components, both at my client’s locale as well as with the telephone
`
`provider/network provider’s switching systems. This encompassed both signaling
`
`and switching protocols and interfaces to support compatibility and interoperability.
`
`15. With respect to speech recognition technology, I have worked on
`
`numerous projects that incorporated speech recognition technology in interactive
`
`voice response, dictation, and messaging systems. For example, some of my clients
`
`used speech recognition software to convert voice messages into text that could be
`
`sent to the recipient via email or a text message (so-called unified messaging
`
`systems). For numerous clients, I deployed speech recognition technology into
`
`Interactive Voice Response (IVR) systems, improving the user experience as well
`
`7
`
`Parus Exhibit 2059, Page 15 of 105
`
`

`

`Case No. IPR2020-00846 & -00847
`U.S. Patent Nos. 7,076,431 & 9,451,084
`as (in many instances) expediting the process flow for various real-time
`
`inquiry/response and transaction processing applications. For another of my clients,
`
`I worked on refining speech recognition protocols to be used in their
`
`telecommunications system for directory assistance. Other applications included use
`
`of speech recognition for medical transcription as well as record-keeping and
`
`compliance purposes. I have used, applied, and deployed multiple speaker-
`
`dependent and speaker-independent solutions.
`
`16.
`
`I also have extensive experience related to the digitization of voice. For
`
`many of my projects related to call routing and switching, calls can come into the
`
`systems as digital communications or as analog POTS calls. I have frequently
`
`designed and implemented systems that can detect the digital or analog nature of the
`
`incoming voice and when analog, utilize an appropriate sample rate and codec to
`
`convert the analog voice into digital transmission. Under the same umbrella, I have
`
`designed and implemented voice messaging systems that digitally record an analog
`
`voice message in order to record or perform other digital processing on the voice
`
`signal as described above. For example, for DARPA (Defense Advanced Research
`
`Projects Agency), I performed comparisons among various voice digitization
`
`algorithms’ performance in the presence of noise and jamming. As another example,
`
`for both DARPA and Defense Communications Agency (DCA), I conducted studies
`
`comparing circuit, packet and hybrid or integrated (circuit/packet) switching systems
`
`8
`
`Parus Exhibit 2059, Page 16 of 105
`
`

`

`Case No. IPR2020-00846 & -00847
`U.S. Patent Nos. 7,076,431 & 9,451,084
`of voice and data traffic comparing them relative to cost, expandability, complexity,
`
`performance and
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`reliability/survivability. As part of
`
`typical
`
`reliability
`
`considerations, I would deploy manual and automatic recovery processes which
`
`provided fault-tolerant and resilient voice and data networking offering graceful
`
`degradation in the presence of errors or failures. Techniques employed encompassed
`
`error detection/retransmission, vigilant monitoring of correct operation coupled with
`
`switchover to backup, bypass and/or rerouting around failed switching and
`
`transmission facilities and reconnection.
`
`17. As previously outlined, I have supported the deployment of several
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`systems for generating transcriptions of previously recorded and real-time audio. For
`
`example, to support a medical dictation application, I deployed a system that used
`
`speech recognition to generate transcripts, both manual correction and auto text
`
`correction, of medical terms that were used, to correct the medical practitioner’s
`
`dictation. For ADA-compliant broadcast of textual messages for the deaf and hard
`
`of hearing public at MTA meetings, I designed, selected, and deployed remote text
`
`captioning of meetings with remote in-line manual correction of errors in real-time.
`
`I also assessed captioning service accuracy and latency with the goal of improving
`
`service levels.
`
`9
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`Parus Exhibit 2059, Page 17 of 105
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`

`

`Case No. IPR2020-00846 & -00847
`U.S. Patent Nos. 7,076,431 & 9,451,084
`
`III. MATERIALS CONSIDERED
`18.
`In forming the opinions set forth herein, I have considered and relied
`
`upon my education, knowledge in the relevant field, and my experience. I have also
`
`reviewed and considered the materials cited herein, including the following
`
`materials:
`
`Description
`
`Petitioners’ IPR Petition
`U.S. Patent 7,076,431 (“’431 patent”)
`Declaration of Stuart J. Lipoff (“Lipoff”)
`Curriculum Vitae of Stuart J. Lipoff
`U.S. Patent Publication 2001/0047262 (“Kurganov-262”)
`PCT Publication WO2001/050453 (“Kovatch”)
`U.S. Provisional Application 60/174,371 (“Kovatch-
`Provisional”)
`U.S. Patent 6,324,534 (“Neal”)
`U.S. Patent 6,418,433 (“Chakrabarti”)
`U.S. Patent 5,787,470 (“DeSimone”)
`U.S. Patent 5,855,020
`U.S. Patent 6,085,160
`U.S. Patent 6,434,524
`McGraw-Hill Electronics Dictionary (6th ed. 1997)
`(“McGraw-Hill”)
`American Heritage Dictionary of the English Language (3d
`ed. 1996)
`Dictionary of Computing (4th ed. 2002)
`Scheduling Order (Dkt. 85), Parus v. Apple Inc., 6:19-cv-
`00432-ADA (consolidated cases) (W.D. Tex. Jan. 17, 2020)
`
`10
`
`Exhibit No.
`IPR2020-00846
`& 00847
`Paper No. 1
`Exhibit 1001
`Exhibit 1002
`Exhibit 1003
`Exhibit 1004
`Exhibit 1005
`
`Exhibit 1006
`
`Exhibit 1007
`Exhibit 1008
`Exhibit 1009
`Exhibit 1010
`Exhibit 1011
`Exhibit 1012
`Exhibit 1013
`
`Exhibit 1014
`Exhibit 1015
`
`Exhibit 1016
`
`Paru