Filed on behalf of John Mezzalingua Associates, LLC
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________
`
`JOHN MEZZALINGUA ASSOCIATES, LLC,
`Petitioner,
`
`v.
`
`DALI WIRELESS, INC.,
`Patent Owner.
`__________
`
`Case No. To Be Assigned
`Patent 10,334,499 B2
`__________
`
`DECLARATION OF JAMES A. PROCTOR, JR.
`
`JMA V. DALI
`US 10,334,499
`JMA EX1017
`
`

`

`TABLE OF CONTENTS
`
`INTRODUCTION ......................................................................................... 1
`I.
`II. QUALIFICATIONS AND EXPERIENCE ................................................. 2
`III.
`STATEMENT OF LEGAL PRINCIPLES. ................................................ 7
`IV. A PERSON OF ORDINARY SKILL IN THE ART (POSITA) .............14
`V.
`OVERVIEW OF THE ’499 PATENT .......................................................15
`A.
`Summary Of The ’499 Patent ..............................................................15
`VI. CLAIM CONSTRUCTION ........................................................................17
`A.
`“Signal Source” ...................................................................................17
`B.
`“Radio Resource” ................................................................................21
`C.
`“Baseband Unit” ..................................................................................30
`VII. STATE OF THE ART AT THE TIME OF THE INVENTION OF THE
`’499 PATENT ...............................................................................................37
`A.
`Digital Distributed Antenna Systems With Remote Radio Units
`Were Well Known Prior to 2011.........................................................37
`Translating Analog Radio Resources to Digital Baseband (e.g.,
`for Packetized Transport) in a Digital DAS Was Well Known
`Prior to 2011. .......................................................................................47
`Reconfiguration to Send Different Sets of Radio Resources to
`Remote Antenna Units Was Well Known Prior to 2010. ...................50
`VIII. THE CHALLENGED CLAIMS OF THE ’499 PATENT ARE
`UNPATENTABLE. .....................................................................................53
`A.
`Ground 1: Claims 1-5, 8-11, 14-16 and 19 are anticipated by
`Oh. .......................................................................................................53
`1.
`Claim 1. .....................................................................................53
`a.
`Claim 1[pre] – “A system for transporting wireless
`communications” ......................................................................53
`Claim 1[a] – “a baseband unit” .................................................56
`Claim 1[b] – “a plurality of signal sources, including at least a
`first signal source and a second signal source” ........................59
`
`b.
`c.
`
`B.
`
`C.
`
`

`

`d.
`
`e.
`
`f.
`
`g.
`
`h.
`
`i.
`
`j.
`
`2.
`
`3.
`
`4.
`
`Claim 1[c] – “a plurality of remote units, including at least a
`first remote unit and a second remote unit” ..............................62
`Claim 1[d] – “wherein the baseband unit comprises a plurality
`of interfaces to communicatively couple the baseband unit to
`the plurality of signal sources” .................................................63
`Claim 1[e] – “wherein the baseband unit is configured to
`receive a plurality of radio resources from the first signal source
`and the second signal source” ...................................................66
`Claim 1[f] – “wherein the baseband unit is configured to send a
`digital representation of a first set of radio resources to the first
`remote unit at a first point in time, the first set of radio
`resources for transmission at an antenna of the first remote unit”
` ...................................................................................................69
`Claim 1[g] – “wherein the baseband unit is configured to send a
`digital representation of a second set of radio resources to the
`first remote unit at a second point in time, the second set of
`radio resources for transmission at the antenna of the first
`remote unit” ...............................................................................74
`Claim 1[h] – “wherein a number of radio resources in the first
`set of radio resources is different from a number of radio
`resources in the second set of radio resources” ........................75
`Claim 1[i] – “wherein the baseband unit is configured to receive
`digital signals from each of the plurality of remote units” .......76
`Claim 2 – “The system of claim 1 wherein the baseband
`unit is configured to packetize each digital representation
`of a radio resource” ...................................................................77
`Claim 3 – “The system of claim 1 wherein the digital
`representation of the first set of radio resources includes
`destination information identifying the first remote unit
`and the digital representation of the second set of radio
`resources includes destination information identifying the
`first remote unit” .......................................................................77
`Claim 4 – “The system of claim 1 wherein the first set of
`radio resources is a subset of the plurality of radio
`resources and includes at least some radio resources from
`ii
`
`

`

`5.
`
`6.
`a.
`
`b.
`
`c.
`
`d.
`
`e.
`
`f.
`
`g.
`
`7.
`
`the first signal source and at least some radio resources
`from the second signal source.” ................................................79
`Claim 5 – “The system of claim 1 wherein the baseband
`unit and at least one of the plurality of signal sources are
`part of a baseband controller.” ..................................................81
`Claim 8. .....................................................................................85
`Claim 8[pre] – “A baseband controller for use in the transport
`of wireless communications” ....................................................86
`Claim 8 [a] – “a plurality of interfaces to communicatively
`couple a baseband unit to a plurality of signal sources,
`including at least a first signal source and a second signal
`source”.......................................................................................86
`Claim 8 [b] – “at least one interface to communicatively couple
`the baseband unit to a plurality of remote units, including at
`least a first remote unit” ............................................................86
`Claim 8 [c] – “wherein the baseband unit is configured to
`receive a plurality of radio resources from the first signal source
`and the second signal source” ...................................................87
`Claim 8 [d] – “wherein the baseband unit is configured to send
`digital representations of a first set of radio resources to the first
`remote unit at a first point in time, the first set of radio
`resources for transmission at an antenna of the first remote unit”
` ...................................................................................................87
`Claim 8[e] – “wherein the baseband unit is configured to send
`digital representations of a second set of radio resources to the
`first remote unit at a second point in time, the second set of
`radio resources for transmission at the antenna of the first
`remote unit” ...............................................................................88
`Claim 8 [f] – “wherein a number of radio resources in the first
`set of radio resources is different from a number of radio
`resources in the second set of radio resources” ........................88
`Claim 9 – “The baseband controller of claim 8 wherein
`the baseband unit is configured to packetize each digital
`representation of a radio resource” ...........................................88
`
`iii
`
`

`

`8.
`
`9.
`
`b.
`
`Claim 10 – “The baseband controller of claim 8 wherein
`the digital representation of the first set of radio resources
`includes destination information identifying the first
`remote unit and the digital representation of the second
`set of radio resources includes destination information
`identifying the first remote unit” ..............................................88
`Claim 11 – “The baseband controller of claim 8 wherein
`the first set of radio resources is a subset of the plurality
`of radio resources and includes at least some radio
`resources from the first signal source and at least some
`radio resources from the second signal source” .......................89
`10. Claim 14. ...................................................................................89
`a.
`Claim 14[pre] – “A method for providing digital signals in a
`Distributed Antenna System (DAS)” ........................................89
`Claim 14[a] – “receiving at a baseband unit, from a plurality of
`signal sources including at least a first signal source and a
`second signal source, a plurality of radio resources” ...............90
`Claim 14[b] – “transmitting from the baseband unit, at a first
`point in time, a digital representation of a first set of radio
`resources to a first remote unit, the first set of radio resources
`for transmission at an antenna of the first remote unit”............90
`Claim 14[c] – “transmitting from the baseband unit, at a second
`point in time, a digital representation of a second set of radio
`resources to the first remote unit, the second set of radio
`resources for transmission at the antenna of the first remote
`unit” ...........................................................................................90
`Claim 14[d] – “wherein a number of radio resources in the first
`set of radio resources is different from a number of radio
`resources in the second set of radio resources” ........................91
`11. Claim 15 – “The method of claim 14 wherein the digital
`representation of the first set of radio resources includes
`destination information identifying the first remote unit
`and the digital representation of the second set of radio
`resources includes destination information identifying the
`second remote unit” ..................................................................91
`iv
`
`c.
`
`d.
`
`e.
`
`

`

`B.
`
`d.
`
`e.
`
`b.
`c.
`
`12. Claim 16 – “The method of claim 14 wherein the first set
`of radio resources is a subset of the plurality of radio
`resources and includes at least some radio resources from
`the first signal source and at least some radio resources
`from the second signal source” .................................................91
`13. Claim 19 – “The method of claim 14 further comprising
`packetizing, at the baseband unit, at least a subset of the
`plurality of radio resources” ......................................................91
`Ground 2: Claims 1-5, 8-11, 14-16 and 19 are obvious over Oh
`in view of Cannon. ..............................................................................92
`1.
`Claim 1. .....................................................................................92
`a.
`Claim 1[pre] – “A system for transporting wireless
`communications” ......................................................................92
`Claim 1[a] – “a baseband unit” .................................................92
`Claim 1[b] – “a plurality of signal sources, including at least a
`first signal source and a second signal source” ........................94
`Claim 1[c] – “a plurality of remote units, including at least a
`first remote unit and a second remote unit” ..............................94
`Claim 1[d] – “wherein the baseband unit comprises a plurality
`of interfaces to communicatively couple the baseband unit to
`the plurality of signal sources” .................................................95
`Claim 1[e] – “wherein the baseband unit is configured to
`receive a plurality of radio resources from the first signal source
`and the second signal source” ...................................................95
`Claim 1[f] – “wherein the baseband unit is configured to send a
`digital representation of a first set of radio resources to the first
`remote unit at a first point in time, the first set of radio
`resources for transmission at an antenna of the first remote unit”
` ...................................................................................................95
`Claim 1[g] – “wherein the baseband unit is configured to send a
`digital representation of a second set of radio resources to the
`first remote unit at a second point in time, the second set of
`radio resources for transmission at the antenna of the first
`remote unit” ...............................................................................95
`v
`
`f.
`
`g.
`
`h.
`
`

`

`i.
`
`j.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`a.
`
`a.
`
`b.
`
`Claim 1[h] – “wherein a number of radio resources in the first
`set of radio resources is different from a number of radio
`resources in the second set of radio resources” ........................96
`Claim 1[i] – “wherein the baseband unit is configured to receive
`digital signals from each of the plurality of remote units” .......96
`Claim 2 – “The system of claim 1 wherein the baseband
`unit is configured to packetize each digital representation
`of a radio resource” ...................................................................96
`Claim 3 – “The system of claim 1 wherein the digital
`representation of the first set of radio resources includes
`destination information identifying the first remote unit
`and the digital representation of the second set of radio
`resources includes destination information identifying the
`first remote unit” .......................................................................96
`Claim 4 – “The system of claim 1 wherein the first set of
`radio resources is a subset of the plurality of radio
`resources and includes at least some radio resources from
`the first signal source and at least some radio resources
`from the second signal source.” ................................................97
`Claim 5 – “The system of claim 1 wherein the baseband
`unit and at least one of the plurality of signal sources are
`part of a baseband controller.” ..................................................97
`Claim 8 ......................................................................................99
`Claim 8[pre] – “A baseband controller for use in the transport
`of wireless communications” ....................................................99
`Claim 8 [a] – “a plurality of interfaces to communicatively
`couple a baseband unit to a plurality of signal sources,
`including at least a first signal source and a second signal
`source”.......................................................................................99
`Claim 8 [b] – “at least one interface to communicatively couple
`the baseband unit to a plurality of remote units, including at
`least a first remote unit” ..........................................................100
`
`vi
`
`

`

`c.
`
`d.
`
`e.
`
`f.
`
`7.
`
`Claim 8 [c] – “wherein the baseband unit is configured to
`receive a plurality of radio resources from the first signal source
`and the second signal source” .................................................100
`Claim 8 [d] – “wherein the baseband unit is configured to send
`digital representations of a first set of radio resources to the first
`remote unit at a first point in time, the first set of radio
`resources for transmission at an antenna of the first remote unit”
` .................................................................................................100
`Claim 8[e] – “wherein the baseband unit is configured to send
`digital representations of a second set of radio resources to the
`first remote unit at a second point in time, the second set of
`radio resources for transmission at the antenna of the first
`remote unit” .............................................................................101
`Claim 8 [f] – “wherein a number of radio resources in the first
`set of radio resources is different from a number of radio
`resources in the second set of radio resources” ......................101
`Claim 9 – “The baseband controller of claim 8 wherein
`the baseband unit is configured to packetize each digital
`representation of a radio resource” .........................................101
`Claim 10 – “The baseband controller of claim 8 wherein
`the digital representation of the first set of radio resources
`includes destination information identifying the first
`remote unit and the digital representation of the second
`set of radio resources icludes destination information
`identifying the first remote unit” ............................................101
`Claim 11 – “The baseband controller of claim 8 wherein
`the first set of radio resources is a subset of the plurality
`of radio resources and includes at least some radio
`resources from the first signal source and at least some
`radio resources from the second signal source” .....................102
`10. Claim 14. .................................................................................102
`a.
`Claim 14[pre] – “A method for providing digital signals in a
`Distributed Antenna System (DAS)” ......................................102
`
`8.
`
`9.
`
`vii
`
`

`

`c.
`
`d.
`
`b.
`
`Claim 14[a] – “receiving at a baseband unit, from a plurality of
`signal sources including at least a first signal source and a
`second signal source, a plurality of radio resources” .............102
`Claim 14[b] – “transmitting from the baseband unit, at a first
`point in time, a digital representation of a first set of radio
`resources to a first remote unit, the first set of radio resources
`for transmission at an antenna of the first remote unit”..........103
`Claim 14[c] – “transmitting from the baseband unit, at a second
`point in time, a digital representation of a second set of radio
`resources to the first remote unit, the second set of radio
`resources for transmission at the antenna of the first remote
`unit” .........................................................................................103
`Claim 14[d] – “wherein a number of radio resources in the first
`set of radio resources is different from a number of radio
`resources in the second set of radio resources” ......................103
`11. Claim 15 – “The method of claim 14 wherein the digital
`representation of the first set of radio resources includes
`destination information identifying the first remote unit
`and the digital representation of the second set of radio
`resources includes destination information identifying the
`second remote unit” ................................................................103
`12. Claim 16 – “The method of claim 14 wherein the first set
`of radio resources is a subset of the plurality of radio
`resources and includes at least some radio resources from
`the first signal source and at least some radio resources
`from the second signal surce” .................................................104
`13. Claim 19 – “The method of claim 14 further comprising
`packetizing, at the baseband unit, at least a subset of the
`plurality of radio resources” ....................................................104
`Ground 3: Claims 5-8, 12 and 17 are obvious over Oh in view
`of Fischer ...........................................................................................105
`1.
`Claim 5 – “The system of claim 1 wherein the baseband
`unit and at least one of the plurality of signal sources are
`part of a baseband controller.” ................................................105
`
`e.
`
`C.
`
`viii
`
`

`

`2.
`
`3.
`
`4.
`a.
`
`b.
`
`c.
`
`d.
`
`e.
`
`f.
`
`Claim 6 – “The system of claim 1 wherein the baseband
`unit further comprises at least one interface to
`communicatively couple the baseband unit to one or
`more additional baseband units.” ............................................107
`Claim 7 – “The system of claim 6 wherein the one or
`more additional baseband units includes a plurality of
`additional baseband units, and the baseband unit is
`connected to at least a first one of the plurality of
`additional baseband units through a direct connection and
`at least a second one of the plurality of additional
`baseband units through an indirect connection.” ....................110
`Claim 8 ....................................................................................111
`Claim 8[pre] – “A baseband controller for use in the transport
`of wireless communications” ..................................................112
`Claim 8 [a] – “a plurality of interfaces to communicatively
`couple a baseband unit to a plurality of signal sources,
`including at least a first signal source and a second signal
`source”.....................................................................................112
`Claim 8 [b] – “at least one interface to communicatively couple
`the baseband unit to a plurality of remote units, including at
`least a first remote unit” ..........................................................112
`Claim 8 [c] – “wherein the baseband unit is configured to
`receive a plurality of radio resources from the first signal source
`and the second signal source” .................................................112
`Claim 8 [d] – “wherein the baseband unit is configured to send
`digital representations of a first set of radio resources to the first
`remote unit at a first point in time, the first set of radio
`resources for transmission at an antenna of the first remote unit”
` .................................................................................................113
`Claim 8[e] – “wherein the baseband unit is configured to send
`digital representations of a second set of radio resources to the
`first remote unit at a second point in time, the second set of
`radio resources for transmission at the antenna of the first
`remote unit” .............................................................................113
`
`ix
`
`

`

`g.
`
`5.
`
`6.
`
`7.
`
`8.
`
`Claim 8 [f] – “wherein a number of radio resources in the first
`set of radio resources is different from a number of radio
`resources in the second set of radio resources” ......................113
`Claim 12 – “The baseband controller of claim 8 wherein
`the baseband unit further comprises at least one interface
`to communicatively couple the baseband unit to one or
`more additional baseband units” .............................................113
`Claim 13 – “The baseband controller of claim 8 wherein
`the plurality of radio resources include a first composite
`signal from the first signal source and a second
`composite signal from the second signal source, and the
`baseband unit is configured to form the digital
`representation of the first set of radio resources from a
`first subset of the first composite signal and a second
`subset of the second composite signal” ..................................114
`Claim 17 – “The method of claim 14 further comprising
`receiving at the baseband unit, from at least one
`additional baseband unit, a second plurality of radio
`resources” ................................................................................116
`Claim 18 – “The method of claim 14 wherein the
`plurality of radio resources include a first composite
`signal from the first signal source and a second
`composite signal from the second signal source, the
`method further comprising forming, at the baseband unit,
`the digital representation of the first set of radio resources
`from a first subset of the first composite signal and a
`second subset of the second composite signal” ......................116
`
`x
`
`

`

`I.
`
`INTRODUCTION
`
`1.
`
`I, James A. Proctor, Jr., submit this Declaration in support of
`
`Petitioner John Mezzalingua Associates, LLC’s petition for inter partes review
`
`(“IPR”) of claims 1-19 of U.S. Patent No. 10,334,499 B2 (“’499 Patent”)
`
`(EX1001) owned by Dali Wireless, Inc. (“Patent Owner”).
`
`2.
`
`I have been retained by Petitioner as an expert witness in this
`
`proceeding to investigate and opine on certain issues relating to the ’499 Patent,
`
`including whether claims 1-19 of the ’419 Patent would have been obvious to a
`
`person of ordinary skill in the art at the time of invention.
`
`3.
`
`In forming my opinions in this matter, I have reviewed the petition, as
`
`well as the patents, prior art, documents and materials identified in the petition,
`
`including Exhibits EX1001-EX1016 to the petition.
`
`4.
`
`All of the opinions set forth in this Declaration are based on my own
`
`personal knowledge, professional experience, education and judgment in
`
`consideration of the documents, materials and information referenced herein.
`
`5.
`
`I am being compensated for my services as an independent expert in
`
`these proceedings. I expect to be available to provide oral testimony should the
`
`need arise. My compensation is not in any way contingent upon the outcome of
`
`any inter partes review. I have no financial or personal interest in the outcome of
`
`these proceedings, or of any related litigation.
`
`1
`
`

`

`6.
`
`I understand that the Patent Owner is asserting the ’499 Patent against
`
`Petitioner in an on-going patent infringement lawsuit brought by Patent Owner in
`
`Dali Wireless, Inc. v. John Mezzalingua Associates, LLC d/b/a JMA Wireless, C.A.
`
`No. 19-2367-RGA in the District of Delaware.
`
`7.
`
`I reside in Indialantic, Florida, and I am a citizen of the United States
`
`of America.
`
`II. QUALIFICATIONS AND EXPERIENCE
`
`8.
`
`I provide the following overview of my background as it pertains to
`
`my qualifications for providing expert testimony in this matter.
`
`9.
`
`I have worked as an engineer and entrepreneur in the field of wireless
`
`communications for over 22 years, and have been involved with various aspects of
`
`wireless communications for the duration of my career.
`
`10.
`
`I am currently a named inventor on more than 290 issued U.S. patents,
`
`and more than 700 international patent publications in total. A number of these
`
`patents and patent applications are related to the subject matter of the patents
`
`asserted in this matter. A substantial portion of my work has been focused on
`
`wireless communication systems and products.
`
`11. My educational background includes a BSEE (Bachelor of Science,
`
`Electrical Engineering) from the University of Florida (1991) and MSEE (Master
`
`of Science, Electrical Engineering) from the Georgia Institute of Technology
`
`2
`
`

`

`(1992) focusing on digital signal processing.
`
`12.
`
`From 1986 to 1991, while at the University of Florida, I interned with
`
`Harris Corporation in various roles including mechanical design, software
`
`development, and digital design. From 1991 to 1992, while at Georgia Institute of
`
`Technology, I worked at the Georgia Tech Research Institute (GTRI) as a graduate
`
`research assistant, performing software development on classified government
`
`programs.
`
`13.
`
`From 1993 to 1995, while working for Harris Corporation, I designed
`
`various cellular communications systems for voice, data, and tracking/location.
`
`Many of these systems I designed utilized advanced communications technologies,
`
`such as those utilized in the then-developing and future telecommunication
`
`standards (such as IS-95, W-CDMA, and aspects of LTE).
`
`14.
`
`From 1995 to 1998, I worked at Spectrian in advanced development
`
`and technical marketing. At Spectrian, I interfaced with Nortel’s and Qualcomm’s
`
`product management and performed advanced technology development and
`
`systems analysis. In this role, I designed IS-95 CDMA and GSM base station
`
`power amplifiers and control electronics, and received several patents associated
`
`with advanced linearization techniques for the reduction of transmitted distortion.
`
`15.
`
`From 1998 to 2002, I served as the Director of Strategic and
`
`Technical Marketing at Tantivy Communications, a venture capital-funded 3G
`
`3
`
`

`

`cellular data and chip set company. At Tantivy, I helped to architect and
`
`standardize the I-CDMA Spread Spectrum Systems Air Interface Standard
`
`(T1P1.4). I also developed both wireless access terminals and base stations that
`
`complied with the standard. The base stations utilized various IP protocols, and
`
`interfaced with the wire line network utilizing IP over Ethernet. Additionally, I
`
`participated in and provided technical contributions to 3GPP/3GPP2
`
`standardization efforts related to the development of CDMA2000 and 1xEV-DO.
`
`This work resulted in me being a named inventor on more than 150 pending or
`
`issued U.S. patents or applications.
`
`16.
`
`From 2002 to 2007, as co-founder of WiDeFi, Inc., I served in various
`
`roles including President, CEO, CTO, and board member. As the CEO, my
`
`responsibilities included advanced development of platform technologies. I was a
`
`named inventor of wireless technology components, including a frequency
`
`translating TDD repeater, a same frequency repeater architecture for TDD/FDD-
`
`based systems, and physical layer multi-stream MIMO repeater technology.
`
`WiDeFi invented and provided wireless home networking products based on WiFi
`
`and cellular technologies. While at WiDeFi, I was a named inventor on over 25
`
`issued U.S. patents or patent applications.
`
`17.
`
`From 2007 to 2009, I consulted as a principal engineer for Qualcomm
`
`Inc. as part of the acquisition of WiDeFi’s technology. While at Qualcomm, I
`
`4
`
`

`

`worked with its corporate R&D division and developed consumer 3G and 4G
`
`cellular coverage enhancement systems utilizing WiDeFi’s baseband interference
`
`cancellation technologies. My responsibilities included working with international
`
`cellular operators on product requirements, detailed W-CDMA simulations, Long
`
`Term Evolution (“LTE”) systems analysis, and participation in prototype product
`
`realization. I am currently a named inventor on roughly 45 issued U.S. patents or
`
`patent applications assigned to Qualcomm.
`
`18.
`
`From 2010 to the present, I have served as managing director and co-
`
`founder of Proxicom Wireless, LLC, which has developed and continues to
`
`develop cloud-based, mobile social networking and mobile payments technology
`
`based upon the proximity and location of mobile devices. Proxicom currently
`
`holds twelve issued U.S. patents and multiple pending patent applications, of
`
`which I am a named inventor. Significant aspects of Proxicom’s technology
`
`involve a mobile device’s use of short range wireless technologies (802.11, near
`
`field communications, Bluetooth) in combination with cellular data links
`
`(3G/WCDMA or 4G/LTE, for example) to facilitate frictionless interactions via a
`
`wireless networked central cloud server.
`
`19.
`
`Since 2007, I have also been the principal of Proctor Consulting, LLC.
`
`In this role, I have been a consultant relating to wired, wireless, and cellular
`
`communication and technologies, start-up companies and intellectual property. I
`
`5
`
`

`

`have also been involved with numerous patent infringement, patent validity, and
`
`patent analysis assignments for public and private companies in the wired,
`
`wireless, and cellular networking industries.
`
`20. Additionally, I have worked and consulted for both cellular
`
`infrastructure and device focused companies (Spectrian, Qualcomm, Fastback
`
`Networks), and defense contractors (Harris Corporation), where I developed
`
`covert-tracking and location technologies involving CDMA and smart-antenna
`
`technologies.
`
`21.
`
`In various of the above-detailed roles, I have been responsible for the
`
`development of business plans, product development plans, product development
`
`budgets, and product bill of materials estimations. I have been responsible for
`
`numerous product development teams, including schedule and costs of the
`
`development process at various stages of my career. For example, at Tantivy
`
`Communications, I ran a joint development of I-CDMA cellular base stations in
`
`Seoul, Korea that were used in a field trial in that country. Additionally, as
`
`founder and CEO of WiDeFi, Inc., I was responsible for similar such activities, as
`
`required to raise venture capital funding and reporting to the board of directors.
`
`22. A list of my qualifications, publications, as well as a list of issued
`
`patents and additional information regarding my background and qualifications,
`
`can be found in my curriculum vitae attached as Appendix A.
`
`6
`
`

`

`III.
`
`STATEMENT OF LEGAL PRINCIPLES.
`
`23.
`
`24.
`
`I am not an attorney and offer no legal conclusions.
`
`I have been informed and understand that a claim is invalid because of
`
`anticipation under 35 U.S.C. § 102 when every element of the claim is described in
`
`a single prior art reference, such that the elements are arranged as required by the
`
`claim. I have been informed and understand the description of a claim element in a
`
`prior art reference can be express or inherent. For a prior art reference to describe a
`
`cl