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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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`COREPHOTONICS, LTD.,
`Patent Owner.
`____________
`
`Case No. IPR2020-00860, IPR2020-00487
`____________
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`DECLARATION OF ERAN KALI
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`APPLE V. COREPHOTONICS
`PROTECTIVE ORDER MATERIAL
`IPR2020-00861
`Exhibit 2013
`Page 1
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`
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`I, Eran Kali, do hereby declare as follows:
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`1.
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`I am a co-founder of and the Vice President of Sales and Licens-
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`ing for Corephotonics, Ltd. (“Corephotonics”), the Patent Owner in these pro-
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`ceedings.
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`2.
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`I make this declaration on the basis of personal knowledge, and
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`if called and sworn as a witness, I could and would testify as set forth herein.
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`3.
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`I am familiar with Corephotonics’ business and with the matters
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`discussed in this declaration.
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`Corephotonics’ Business
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`4.
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`I co-founded Corephotonics in 2012 to develop the next genera-
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`tion of mobile phone cameras.
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`5.
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`In 2012, Corephotonics developed an innovative dual-aperture
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`camera system that uses two fixed-focal length lenses, one being a wide-angle
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`lens, and the other being a miniature telephoto lens. Through the use of imag-
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`ing data from two cameras to produce a single image, Corephotonics’ tech-
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`nology offered enormous improvements over conventional camera systems
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`for smartphones in both optical resolution and image zoom performance. At
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`the time, single-aperture camera systems were typical, and zoom functionality
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`1
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`APPLE V. COREPHOTONICS
`PROTECTIVE ORDER MATERIAL
`IPR2020-00861
`Exhibit 2013
`Page 2
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`on phones with single-aperture cameras was achieved by digitally manipulat-
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`ing the image data captured by the camera to generate a “zoomed” photo.
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`6.
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`A significant drawback to the conventional technique was that
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`the “zoomed” photo had poor image resolution (because, essentially, the
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`smartphone’s processor and software was just magnifying a portion of a cap-
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`tured image to approximate the effect of a zoomed-in image). With Corepho-
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`tonics’ dual-camera system, the second telephoto camera provides much
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`higher optical resolution than the first wide angle camera, and the imaging
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`data from the telephoto camera can be combined with imaging data from the
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`wide angle camera to create an effectively greater level of zoom without de-
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`grading image quality.
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`7.
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`Corephotonics also developed an image processing techniques
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`for video that minimized the transition jump (e.g., in recorded video or in a
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`camera viewfinder) in a video stream when the video switched between one
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`camera and another during zooming up or down. Corephotonics also devel-
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`oped, for still images, an image fusion technique that combined image data
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`from two cameras to create an improved, higher quality, and higher resolution
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`image than would otherwise be possible with one camera.
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`2
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`APPLE V. COREPHOTONICS
`PROTECTIVE ORDER MATERIAL
`IPR2020-00861
`Exhibit 2013
`Page 3
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`8.
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`Corephotonics now employs 80 staff, the majority of whom are
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`engineers, scientists, and technologists, who continue to develop Corephoton-
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`ics’ innovative camera technologies for mobile devices and explore new ap-
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`plications for its technologies.
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`9.
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`Currently, Corephotonics’s core technologies can be divided into
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`six categories: (1) tele camera optics; (2) folded camera optics; (3) folded
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`camera actuation and optical image stabilization; (4) image fusion between
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`multiple imagers; (5) depth mapping, (6) smooth camera transition; and (7)
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`collapsible compact cameras allowing large sensors with compact form in
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`smartphones. (not public). Public information about these technologies is
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`available on Corephotonics’s website, at https://corephotonics.com/inven-
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`tions/ (accessed Jan. 27, 2021):
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`3
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`APPLE V. COREPHOTONICS
`PROTECTIVE ORDER MATERIAL
`IPR2020-00861
`Exhibit 2013
`Page 4
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`10. Corephotonics has filed for and received numerous patents for its
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`advanced lens designs, multi-camera systems, and optical image processing
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`techniques. Over 190 granted or allowed (in at least 8 countries) and over 160
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`additional filed. Corephotonics today continues to develop multi-aperture
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`camera and image processing technologies and has filed for and obtained pa-
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`tents on those technologies as well.
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`Corephotonics’ Technology Widely-Recognized as
`Innovative and Valuable
`11. Part of Corephotonics’ business involves the licensing of its tech-
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`nology to customers in mobile device/smart phone space. Since 2014, Core-
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`photonics has successfully licensed its technology to numerous smartphone
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`OEMs and component manufacturers.
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`12.
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`13.
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`APPLE V. COREPHOTONICS
`PROTECTIVE ORDER MATERIAL
`IPR2020-00861
`Exhibit 2013
`Page 5
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`14.
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`15.
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`16.
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`Apple’s Efforts to License Corephotonics’ Technology
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`5
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`APPLE V. COREPHOTONICS
`PROTECTIVE ORDER MATERIAL
`IPR2020-00861
`Exhibit 2013
`Page 6
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`
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`17. Apple Inc., whom I understand is the Petitioner in this proceed-
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`ing, had a years-long relationship with Corephotonics which started in early
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`2012. This included a prolonged chapter of intense technology exchanges dur-
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`ing 2013-2014 and at least two cycles of explicit licensing negotiation in 2014
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`and again in 2016. Corephotonics spent years demonstrating its technologies
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`to Apple and discussing potential business arrangements.
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`18. As part of that years-long process, Corephotonics provided
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`highly confidential technical information and device samples to Apple, in-
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`cluding, for example, “black box” simulation programs for testing and ana-
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`lyzing Corephotonics’ lens performance and imaging algorithms. An
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`elaborate suite of tests was mutually composed by Apple and Corephotonics
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`specifically to test Corephotonics’ image fusion and smooth transition algo-
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`rithms and techniques. Apple was initially skeptical of the compliance of such
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`techniques to smartphone usability
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` but
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`ultimately used smooth transition in all zoom dual camera iPhones fromi-
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`Phone 7+ to most recent iPhone 11 models.
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`19. Between 2012 and 2017, Apple and Corephotonics had numer-
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`ous meetings, calls, and communications to discuss Corephotonics’s
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`6
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`APPLE V. COREPHOTONICS
`PROTECTIVE ORDER MATERIAL
`IPR2020-00861
`Exhibit 2013
`Page 7
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`technologies. I provide below a small sample of the communications Apple
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`and Corephotonics had.
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`20.
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`21.
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`In June 2014, in advance of a meeting with Apple engineers and
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`executives, Corephotonics provided a confidential presentation to Apple pro-
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`posing to Apple to license its “fusion technology along with additional com-
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`ponents related to zoom.” A true and correct copy of that presentation is
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`attached as Exhibit 2006. At this early stage “fusion technology” was a blan-
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`ket term for the dual camera imaging software including smooth transition
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`which was deeply evaluated by Apple by this stage.
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`22.
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`7
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`APPLE V. COREPHOTONICS
`PROTECTIVE ORDER MATERIAL
`IPR2020-00861
`Exhibit 2013
`Page 8
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`23.
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`24.
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`26. Talks between Apple and Corephotonics essentially broke down
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`in late 2016. When Apple announced its iPhone 7 line of phones in the Fall of
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`2016, among the key features of those phones (which the previous iPhone
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`generation did not have) was the use of a dual-camera system. We were
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`8
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`APPLE V. COREPHOTONICS
`PROTECTIVE ORDER MATERIAL
`IPR2020-00861
`Exhibit 2013
`Page 9
`
`
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`disappointed to Apple’s developer notes for the iPhone 7 series touting what
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`was, essentially, the smooth transition technology that Corephotonics had
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`been showing to Apple for years: “The Dual camera's defining feature is its
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`ability to smoothly transition between wide and tele cameras, acting like a
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`single lens camera with optical zoom at 2x.” https://developer.apple.com/fo-
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`rums/thread/63347 (emphasis added).
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`27.
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`In signing this declaration, I understand that the declaration will
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`be filed as evidence in proceedings before the Patent Trial and Appeal Board
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`of the United States Patent and Trademark Office. I acknowledge that I may
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`be subject to cross-examination in the case and that cross-examination will
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`take place within the United States. If cross-examination is required of me, I
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`will appear for cross-examination within the United States during the time
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`allotted for cross-examination.
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`28.
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`I declare under penalty of perjury under the laws of the United
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`States of America that the foregoing is true and correct and that all statements
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`made herein of my knowledge are true and that all statements made on infor-
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`mation and belief are believed to be true; and further, that these statements
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`were made with knowledge that willful false statements and the like so made
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`are punishable by fine or imprisonment, or both, under 18 U.S.C. § 1001.
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`9
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`APPLE V. COREPHOTONICS
`PROTECTIVE ORDER MATERIAL
`IPR2020-00861
`Exhibit 2013
`Page 10
`
`
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`DATED:
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`January 28, 2021
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`/s/ Eran Kali
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`10
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`APPLE V. COREPHOTONICS
`PROTECTIVE ORDER MATERIAL
`IPR2020-00861
`Exhibit 2013
`Page 11
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