UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`DISH NETWORK L.L.C.,
`Petitioner
`
`v.
`
`BROADBAND ITV, INC.,
`Patent Owner
`
`Case IPR2020-01267
`U.S. Patent No. 10,028,026
`
`DECLARATION OF CLIFTON KAGAWA
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`PROTECTIVE ORDER MATERIAL
`
`BBiTV EX2038
`DISH v. BBiTV
`IPR2020-01267
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`DISH NETWORK L.L.C.,
`Petitioner
`
`v.
`
`BROADBAND ITV, INC.,
`Patent Owner
`
`Case IPR2020-01267
`U.S. Patent No. 10,028,026
`
`DECLARATION OF CLIFTON KAGAWA
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`PROTECTIVE ORDER MATERIAL
`
`BBiTV EX2038
`DISH v. BBiTV
`IPR2020-01267
`
`
`
`Case IPR2020-01267
`U.S. Patent No. 10,028,026
`
`I, Clifton Kagawa, declare and state as follows:
`
`1.
`
`I am Chief Executive Officer and a director and founder of Broadband
`
`iTV, Inc. (“BBiTV”). I reside in Hawaii and have been the CEO of BBiTV since
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`2001.
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`2. My background as a businessman includes having served as a board
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`member and Asia Pacific Chairman and Chief Executive Officer for international
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`public relations firm Hill & Knowlton. I held a similar position with international
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`public relations firm Burson-Marsteller and served on parent company Young &
`
`Rubicam’s advisory board of directors. Prior to working in Asia with these firms, I
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`was majority shareholder of Hawaii-based Communications-Pacific, one of the top
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`50 independent public relations firms in the U.S. at the time of its acquisition by
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`London-based WPP Group. I am and have been active in community organizations
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`including serving on the boards of the Rotary Club of Honolulu, Hawaii Chamber
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`of Commerce, Aloha United Way, the Economic Development Corporation of
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`Honolulu, and Chaminade University.
`
`3.
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`BBiTV was formed in year 2001. BBiTV built its business as an
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`operating company for five years, and later shifted its focus toward IP
`
`development and licensing. Chief Technology Officer Milton Diaz Perez is the
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`inventor of all BBiTV patents and continues in that role. The company has not
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`acquired any of its patents; instead, its entire portfolio of patents stems directly
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`from the leading-edge interactive television platform, Web CMS, and VOD
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`applications that BBiTV, led by Mr. Perez, designed and launched from 2003
`
`through 2006.
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`4.
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`BBiTV’s board of directors consists of myself along with senior
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`experienced professionals such as Mr. Tony Thornley, who formerly served as
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`President and Chief Operating Officer of QUALCOMM Incorporated; who
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`served as President and Chief Executive Officer of Callaway Golf Company;
`
`and who worked for Nortel Networks for 16 years, serving in various financial
`
`and information systems management positions including Vice President of
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`Public Networks, Vice President of Finance NT World Trade, and Corporate
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`Controller Northern Telecom Limited. BBiTV’s business and board of directors
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`are described on our web site: https://www.broadband-itv.com/.
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`5.
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`BBiTV was an early contributor in the development of on-demand
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`and interactive technology for the cable sector. The company began operating in
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`2001 in Hawaii, which was known in the cable industry then as one of the most
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`innovative cable markets due to it being an island market removed from major US
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`metropolitan markets. This has allowed it to become a natural technology test bed.
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`6.
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`BBiTV launched two critical, first-to-market development projects in
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`the US. These included an interactive community channel enabling community
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`members to communicate, as well as to buy and sell goods and services, and a Web
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`platform allowing content producers, businesses, community organizations, and
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`individuals to publish video content directly to the television. BBiTV has also
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`designed systems for television video personals, video greeting cards, talent
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`contests and promotions, and music videos. These projects, among other work and
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`R&D, became the basis for the beginning of BBiTV’s patent portfolio.
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`7.
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`In its time as an operating company, BBiTV launched Promo! in
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`partnership with Oceanic Time Warner Cable (TWC) (now Charter
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`Communications), which to my knowledge was the nation’s first interactive cable
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`channel featuring long form videos on local and national products and services in
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`2003. BBiTV continued its partnership with Oceanic Time Warner Cable and also
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`launched the “TVClassifieds” application in 2005. The company was also a
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`consultant on other Oceanic Time Warner Cable applications in 2005 and 2006.
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`8. Mr. Milton Perez joined BBiTV during April or May of 2003, as a
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`consultant.
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`9. Mr. Perez is an inventor, and he became Chief Technology Officer
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`for BBiTV in September 2003. He has held that position through present day,
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`and continues today as our CTO. His responsibilities have included overseeing
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`the company’s technology development projects, using his over 35 years of
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`experience in software and product development and 25 years developing
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`interactive platforms for the lodging, cable, and web industries. Mr. Perez’s
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`U.S. Patent No. 10,028,026
`past experience includes serving as Senior Vice President of engineering and
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`network, from 1998 to 2002, at StarMedia Network, Inc., the largest operator of
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`community and portal websites in Latin America. StarMedia was acquired, in
`
`part, by Yahoo! and other web media companies. Mr. Perez is also the former
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`Vice President of Engineering at GuestServe, a San Francisco company that
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`developed highly advanced, cost-effective interactive TV systems for cable.
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`GuestServe was acquired by SeaChange, Inc., a leader in digital video servers.
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`Mr. Perez holds a BS in Electrical Engineering and a BA in Art History from
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`Columbia University.
`
`10. At BBiTV, we tasked Mr. Perez with assisting with the company’s
`
`efforts to commercialize a product to sell ads on cable networks. When he joined
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`the company, we had a product, Promo!, which was a VOD-based advertising
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`product built on the Scientific Atlanta XOD platform, and publicly accessible on
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`Time Warner Cable Oceanic (“TWC”) channel 327. He worked on improving the
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`capabilities of the Promo! system, which essentially led to replacing that system
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`and developing a replacement platform.
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`11. As I explain in more detail in this declaration, I was personally
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`involved in the events, and I know and corroborate Mr. Perez’s conception of the
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`inventions described in the ’026 patent by March 30, 2004, which BBiTV then
`
`filed the parent application of on July 30, 2004. In February 2004, Mr. Perez
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`discussed with me certain inventions described in the ’026 patent and the March
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`2004 Draft Application (“March Draft”) (explained below), which were then set
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`forth in the final version of U.S. Patent Application 10/909,192 (“’192
`
`application”), filed on July 30, 2004. EX2062. In February 2004, Mr. Perez also
`
`prepared and explained to me a presentation showing how the hierarchical menu of
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`his invention would work (the “February Presentation”). EX2072. EX2072 is a
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`true and correct copy of a document shown to me by Mr. Perez in February 2004.
`
`12. Mr. Perez did so consistent with and in accordance with the ordinary
`
`business practices of BBiTV at the time when Mr. Perez would discuss new ideas
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`for product development and intellectual property with myself, the CEO of the
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`company. This was done as part of the process for Mr. Perez to obtain approval to
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`proceed with product development and to apply for patent protection. The process
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`included him preparing a presentation showing how the system’s hierarchical EPG
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`and layered templates would work. After Mr. Perez discussed with me subject
`
`matter in the ’026 patent, the March Draft, and the ’192 application, I provided Mr.
`
`Perez with authorization to proceed with product development and the patenting of
`
`his invention. Following my authorization, BBiTV’s patent attorney, Mr. Leighton
`
`Chong, was engaged to file a patent application on Mr. Perez’s invention. I
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`supervised Mr. Perez during this entire time period, and closely monitored the
`
`progress and observed as he worked on developing the inventions described in the
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`’026 patent, working very hard and diligently essentially every day leading up to
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`our filing of BBiTV’s ’192 patent application on July 30, 2004. The timely filing
`
`of the ’192 application was a priority for BBiTV as the patent would assist BBiTV
`
`in obtaining funding for the business to develop products and its business plan was
`
`to be the first to market. EX2178. EX2178 is a true and correct copy of our
`
`business plan that reflected our business plan at the time.
`
`I.
`
`Background Leading To BBiTV Filing Its 7/30/2004 Patent Application
`
`13.
`
`In June of 2003, BBiTV became introduced to Navic Networks, which
`
`offered a platform on Time Warner Cable Oceanic head ends. BBiTV was
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`interested in transitioning our technology onto the Navic platform to permit us to
`
`create custom user interfaces and video controls to replace the poorly performing
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`XOD frontend of Promo! We referred to this among our team internally as the
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`“Version 2.0” product.
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`14. We signed a letter expressing interest in working with Navic in July of
`
`2003, and had meetings with Navic to explore Navic’s capabilities (see, e.g.,
`
`EX2047, reflecting a meeting with Navic in July 2003). EX2047 is a true and
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`correct copy of an email I received on 7/14/2003.
`
`15. With Mr. Perez’s guidance in the development of BBiTV’s system,
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`we also focused on replacing the backend video delivery system with a more
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`streamlined service over the Internet.
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`In September of 2003, Mr. Perez became the CTO of BBiTV full
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`16.
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`time. He was tasked with and worked on projects including developing our new
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`VOD products, applying for patents on the technologies that BBiTV was
`
`developing, and securing funding for the company to develop and market new
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`VOD products.
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`17.
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`In late 2003 and early 2004, he prepared specifications and flow
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`charts for the new products, including those described in EX2050-EX2054.
`
`EX2050 is a true and accurate copy of a draft document shown to me by Mr. Perez
`
`in December 2003. EX2051 is a true and accurate copy of a draft document shown
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`to me by Mr. Perez in December 2003. EX2052 is a true and accurate copy of a
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`draft document shown to me by Mr. Perez in December 2003. EX2053 is a true
`
`and accurate copy of a draft document shown to me by Mr. Perez in January 2004.
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`EX2054 is a true and accurate copy of a draft document shown to me by Mr. Perez
`
`in January 2004.
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`18. BBiTV also, with Milton’s guidance, brought on Ms. Nicole Nestel as
`
`a product manager and Ms. Kim Wall as a graphic designer to assist with creating
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`the design of our products.
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`19. BBiTV signed a developer agreement with Navic on December 7,
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`2003 to work with Navic to implement the VOD capability for BBiTV’s products
`
`on Navic’s platform. See EX2057. EX2057 is a true and correct copy of an email I
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`sent to John Hoctor at Navic Networks on 12/7/2003. Mr. Perez, assisted by Ms.
`
`Wall and Ms. Nestel, would meet with Navic frequently during the course of these
`
`activities, for example by attending a “developer training event” in January 2004.
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`See, e.g., EX2058, 3. I also attended meetings with our BBiTV team and Navic
`
`during this time frame.
`
`20. As Mr. Perez explained to me during this time frame, it was important
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`to also develop a web-based video uploading solution. In connection with this
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`aspect of building our business, he met with vendors—for example, InDemand,
`
`one of the largest providers of ingestion and processing services—in January of
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`2004. See EX2059. EX2059 is a true and correct copy of emails exchanged
`
`between myself and Mr. Perez on 1/27/2004. Mr. Perez explained to me, among
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`other things, that it was not possible for market participants at that time to provide
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`the functionality that he envisioned, and he proposed that BBiTV would have to
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`design and create a web-based content management system (WBCMS) itself.
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`21.
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`I understand from having managed and working closely with Mr.
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`Perez that he conceived of certain inventions described in the ’026 patent in the
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`first quarter of year 2004, and by no later than March 31, 2004. On that date,
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`March 31, 2004, Mr. Leighton Chong, who was BBiTV’s patent attorney at that
`
`time, sent to Mr. Perez and me an early draft of a patent application (EX2061
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`March Draft) that later resulted in U.S. Patent Application 10/909,192 (EX2062,
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`’192 application) filed on July 30, 2004. I understand that the ’192 application
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`issued as U.S. Patent No. 7,590,997 (“’997 patent”).
`
`22.
`
`In March 2004, Mr. Perez was working closely with me; I was his
`
`supervisor, and he disclosed to me certain subject matter described in the ’026
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`patent. As the CTO of BBiTV, he discussed that subject matter with me during the
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`course of discussing product development of the next generation of BBiTV
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`products. He did so during the course of our work together to obtain permission to
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`pursue applying for patents on his inventions which were developed while working
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`at BBiTV.
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`23. Mr. Perez communicated the subject matter of his inventions to
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`BBiTV’s patent attorney, Mr. Leighton Chong, who proceeded to draft the patent
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`application that became the ’192 application. I would discuss the progress and
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`status of these events with Mr. Perez and also with Mr. Chong.
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`24.
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`In early March 2004, on or around March 3, 2004, Mr. Perez, while
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`reporting to me as CEO of BBiTV, met with Mr. Chong to discuss patenting
`
`certain inventions described in the ’026 patent as well as related inventions.
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`EX2063. I reviewed the March Draft and the ’192 application, and these are the
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`inventions that Mr. Perez explained to me; he advised me that he communicated to
`
`our patent attorney, Mr. Chong, at that time. During the course of his work, Mr.
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`Perez regularly reported to me the events and status of obtaining patent protection
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`for these inventions that were an important part of our company’s business.
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`25. While meeting with Mr. Chong, I understood that Mr. Perez created
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`an updated roadmap of the different parts of the VOD system, as shown in
`
`EX2063. Under my supervision as CEO of BBiTV, Mr. Perez as CTO
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`communicated with Mr. Chong throughout March 2004 for us to understand status
`
`and updates on the drafting of BBiTV’s patent specification for patenting of the
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`inventions that Mr. Perez had developed. EX2064; EX2065.
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`26. Mr. Perez prepared a first draft of a patent specification, which
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`contained the major features of the system in a document that I understand is
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`marked for identification with a number, EX2066, titled “Consumer Content patent
`
`outline v2.doc.” I understand that the document has a document creation date of
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`3/24/2004 and date last modified date of 3/26/2004. These dates are consistent with
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`when Mr. Perez sent Mr. Chong the first draft of the patent specification on March
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`29, 2004. EX2068.
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`27. Mr. Perez kept me informed as he worked with Mr. Chong to prepare
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`BBiTV’s patent application and while preparing to seek patent protection for the
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`inventions that he developed while working at BBiTV. Mr. Chong replied on
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`March 30, 2004, noting that the text that Mr. Perez prepared reflects what Mr.
`
`Chong and Mr. Perez wrote out during meetings, and asked for diagrams that Mr.
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`Perez had drawn on a whiteboard. On the next day, March 31, 2004, Mr. Chong
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`sent the March Draft to Mr. Perez and me. EX2060; EX2061. EX2060 is a true and
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`correct copy of an email sent to me by Mr. Chong on 3/31/2004. EX2061 is a true
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`and correct copy of a document attached to EX2060 and received by me on
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`3/31/2004.
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`28. During the time period from March 2004 to July 30, 2004, as I explain
`
`above, Mr. Perez was the Chief Technology Officer of BBiTV and I was the CEO
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`of the company.
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`29. During that time period, Mr. Perez had various responsibilities as the
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`company’s CTO, including development of new products, maintaining current
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`products, and meeting with funders to raise money for further investments in
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`BBiTV. He was required during that time to travel a lot and attend meetings,
`
`seeking to obtain funding for the development and marketing of BBiTV products.
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`Those meetings, most of which I attended, included meeting with venture capital
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`and other firms.
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`30. During May and June 2004, Mr. Perez and I met with numerous
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`investors as part of raising funds for BBiTV’s B Round. For example, during
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`March, we met with Venture Capital groups (“VCs”) on 3/26 and 3/29 in Oahu.
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`EX2073. EX2073 is a true and accurate copy of an email I sent on 3/22/2004. In
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`April, we flew to Boston and had multiple venture capital (“VC”) meetings from
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`4/12-4/16 EX2074-EX2077 . EX2075 is a true and accurate copy of an email I sent
`
`on 3/30/2004. EX2076 is a true and accurate copy of an email I sent on 4/7/2004.
`
`EX2077 is a true and accurate copy of an email I sent on 4/2/2004. We had further
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`VC meetings in San Francisco on 4/21, 4/26, and 4/28. EX2078-EX2081. EX2078
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`is a true and accurate copy of an email I sent on 4/21/2004. EX2079 is a true and
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`accurate copy of an email I sent on 4/26/2004. EX2081 is a true and accurate copy
`
`of an email I received on 4/26/2004. We met with more VCs on a trip to New York
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`from 5/11-5/13 (EX2083-EX2084), and two more on 5/20 and 5/25 EX2085-
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`EX2086. EX2084 is a true and accurate copy of an email I sent on 5/7/2004.
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`EX2085 is a true and accurate copy of an email I received on 5/17/2004. EX2086
`
`is a true and accurate copy of an email I sent on 5/20/2004. In the second and third
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`weeks of June, we also flew to both New York and Boston for more VC meetings.
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`EX2087-EX2089. EX2087 is a true and accurate copy of an email I sent on
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`6/3/2004. EX2088 is a true and accurate copy of an email I sent on 6/10/2004.
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`Further meetings followed in June, such as on 6/22 (EX2090) and 6/25 (EX2091).
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`EX2091 is a true and accurate copy of an email I received on 6/24/2004. During
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`company meetings, we discussed the status of VC conversations. EX2093;
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`EX2094. EX2094 is a true and accurate copy of an email I sent on 5/21/2004.
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`31. Mr. Perez was also responsible for overseeing the development of
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`BBiTV’s product and business planning and technology, including working closely
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`with me as CEO, as well as with Ms. Nicole Nestel and Ms. Kim Wall, in
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`developing our products. He was working hard on both the business and
`
`technology development of BBiTV, as well as devoting as much of his time as
`
`possible to working on BBiTV’s patent application.
`
`32. On March 31, 2004, as I explain above, the first draft of the ’192
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`application, i.e., the March Draft, was sent from Mr. Chong to Mr. Perez and me.
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`EX2060. Mr. Perez discussed with me the progress and hard work he was doing to
`
`prepare BBiTV’s patent application during this time frame up until it was filed on
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`July 30, 2004.
`
`33. From March through June 14, 2004, Mr. Perez worked diligently to
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`review and provide comments on the draft patent application and the related
`
`figures for the ’192 application, while keeping me informed, and I understood that
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`Mr. Chong worked on revising BBiTV’s patent application. EX2102; EX2104;
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`EX105; EX2106; EX2110; EX2111; EX2103, ¶10. During this time period, Mr.
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`Perez would give me regular updates and I understand there was a steady back and
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`forth of communications between BBiTV (via Mr. Perez) and our patent attorney,
`
`Mr. Chong, in the course of preparing the ’192 application.
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`34. There were also meetings with Mr. Chong in the course of preparing
`
`the ’192 application. Mr. Perez lived in California and Mr. Chong lived in Hawaii.
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`Accordingly, we arranged to meet in-person to discuss the disclosure of the ’192
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`application, and a meeting was held on the evening of June 15, 2004 while Mr.
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`Perez was in Hawaii. EX2106.
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`35. After the June 15, 2004 meeting, Mr. Chong and Mr. Perez continued
`
`to diligently revise the ’192 application from June 16-22, 2004.
`
`36. Mr. Chong and Mr. Perez met, for example, on June 22, 2004 to
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`further discuss the ’192 application. EX2107. They met again on June 24, 2004 to
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`further discuss the contents and disclosure of the ’192 application. EX2108.
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`37. After the June 24, 2004 meeting, Mr. Perez continued working on the
`
`drawings for the ’192 application and he kept me informed of the progress of his
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`work and the preparation of BBiTV’s ’192 patent application. EX2109.
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`38. By June 27, 2004, Mr. Perez finished the drawings for Figures 1a and
`
`1b, continuing on the work from the June 24, 2004 meeting with Mr. Chong.
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`EX2110; EX2111.
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`39. As Mr. Perez reported to me at the time, he worked continuously and
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`diligently to draft the figures and prepare BBiTV’s ’192 patent application,
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`completing this work by the end of June 2004 and continuing to communicate with
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`Mr. Chong as well as with myself. EX2110-EX2116; EX2103, ¶10.
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`40. As Mr. Perez reported to me and kept me informed as we were
`
`preparing to file BBiTV’s ’192 patent application during July 2004, Mr. Perez
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`continually worked with Mr. Chong in preparing BBiTV’s patent application while
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`at the same time Mr. Perez had numerous other responsibilities as CTO of our
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`company, as described above.
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`41. Mr. Perez met with Mr. Chong again on July 27, 2004 as we were
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`preparing to finalize and file BBiTV’s ’192 patent application.
`
`42. On July 28, 2004, as BBiTV’s CEO, I gave approval for Mr. Chong to
`
`file BBiTV’s ’192 application and he filed it on July 30, 2004.
`
`43.
`
`I was closely supervising Mr. Perez and the team at BBiTV during the
`
`period from March 31, 2004 through July 30, 2004 when BBiTV’s ’192 patent
`
`application was filed. Mr. Perez was working hard during this time period on his
`
`various responsibilities as CTO of the company and on preparing our patent
`
`application. As his direct supervisor, I knew he was working nearly every day
`
`during that period to attend to his responsibilities.
`
`44.
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`In particular, he worked on developing the inventions that we applied
`
`to patent in the ’192 patent application, continuing to develop these inventions
`
`nearly every day from March 2004 until we filed BBiTV’s ’192 patent application
`
`on July 30, 2004, in addition to his other responsibilities as our CTO including
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`product development and meetings seeking to raise capital for the company’s
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`business.
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`PROTECTIVE ORDER MATERIAL
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`I declare that all statements made herein of my knowledgearetrue, andthat
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`all statements made on information andbelief are believedto be true, and that
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`these statements were made with the knowledgethat willful false statements and
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`the like so made are punishable by fine or imprisonment, or both, under Section
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`1001 of Title 18 of the United States Code.
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`Executed on the 10th day of May 2021.
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` Zontiema
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`Ciifton Kagakya
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`-16-
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`- 16 -
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`PROTECTIVE ORDER MATERIAL
`
`
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