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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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`____________________
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`Google LLC,
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`Petitioner,
`
`v.
`
`Ikorongo Technology, LLC,
`
`Patent Owner.
`
`U.S. Patent No. RE47,704
`Filing Date: December 19, 2014
`Issue Date: November 5, 2019
`
`____________________
`
`Case No. IPR2021-00058
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`
`
`DECLARATION OF DAVID HILLIARD WILLIAMS IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW
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`IPR2021-00058
`U.S. Patent RE47,704
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`TABLE OF CONTENTS
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`
`I.
`INTRODUCTION ........................................................................................... 1
`II. QUALIFICATIONS ........................................................................................ 3
`III. MATERIALS CONSIDERED ......................................................................10
`IV. LEGAL PRINCIPLES ...................................................................................13
`V.
`LEVEL OF ORDINARY SKILL IN THE ART ...........................................16
`VI. CLAIM CONSTRUCTION ..........................................................................19
`VII. BACKGROUND OF LOCATION-DETERMINING AND
`LOCATION-SHARING TECHNOLOGIES ................................................19
`A.
`The use of software registration, including for data collection
`and sharing purposes was well known prior to the ’704 patent
`priority date. ........................................................................................21
`B. A wide variety of location determination methods and
`technologies were well known at the time of the ’704 patent’s
`earliest priority date, as was the use of such data for tracking
`purposes. ..............................................................................................30
`The ability to share information related to location/location-
`related experiences was known in the art at the time of the ’704
`patent’s earliest priority date. ..............................................................32
`VIII. OVERVIEW OF PRIOR ART ......................................................................56
`A. Overview of Callegari ........................................................................56
`B. Overview of Friedman ........................................................................66
`C. Overview of Eschenbach ....................................................................67
`IX. THE ’704 PATENT .......................................................................................69
`A. Overview of the ’704 Patent ................................................................69
`B.
`The Prosecution History of the ’704 Patent ........................................72
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`C.
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`C.
`The Challenged Claims .......................................................................73
`STATEMENT OF OPINIONS ......................................................................80
`X.
`XI. GROUND 1: CLAIMS 33-41, 43, and 45-48 ARE
`UNPATENTABLE OVER CALLEGARI......................................................80
`A.
`Claim 33 ..............................................................................................81
`B.
`Claim 34 - “wherein enabling the definition of the access rights
`for the one or more other users comprises receiving, via a user
`interface of the location-aware cellular phone device, input that
`defines at least one user of the one or more other users from the
`one or more lists of others that is to have access to the visited
`geographic location data” ..................................................................100
`Claim 35 - “wherein reporting the information indicating the
`visited geographic location data comprises automatically and
`passively reporting the information indicating the visited
`geographic location”..........................................................................105
`Claim 36 - “wherein the definition of the access rights for the
`one or more other users to access the visited geographic
`location data comprises, for each other user of at least a subset
`of the one or more other users, receiving, via a user interface of
`the location-aware cellular phone device, input that defines one
`or more categories of the visited geographic location data to be
`shared with the other user” ................................................................106
`Claim 37 - “wherein the definition of the access rights for the
`one or more other users to access the visited geographic
`location data comprises, for each category of at least a subset of
`a plurality of categories of the visited geographic location data,
`receiving, via a user interface of the location-aware cellular
`phone device, input that defines at least one other user of the
`one or more other users to have access to the category of the
`visited geographic location data” ......................................................110
`Claim 38 - “wherein reporting the information indicating the
`visited geographic location data comprises reporting the
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`C.
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`D.
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`E.
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`F.
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`information indicating the visited geographic location data to
`the registration server” ......................................................................112
`Claim 39 - “wherein the one or more lists of other users
`comprises an Instant Messaging buddy list of a user of the
`location-aware cellular phone device” ..............................................113
`Claim 40 - “wherein the one or more lists of other users
`comprises a contact list maintained by the location-aware
`cellular phone device” .......................................................................114
`Claim 41 - “wherein the one or more lists of other users
`comprises an email contact list maintained by the location-
`aware cellular phone device” ............................................................115
`Claim 43 - “wherein the visited geographic location data further
`defines comments on one or more of the geographic locations
`visited by the location-aware cellular phone device” .......................116
`Claim 45 - “enabling receipt and display of advertising
`information” ......................................................................................117
`Claims 46 and 48 ...............................................................................118
`L.
`M. Claim 47 - “in order to report the information indicating the
`visited geographic location data, the software further instructs
`the controller of the location-aware cellular phone device to
`automatically and passively report the information indicating
`the visited geographic location data” ................................................123
`XII. GROUND 2: CLAIMS 46 AND 47 ARE UNPATENTABLE OVER
`CALLEGARI IN VIEW OF FRIEDMAN ....................................................123
`A.
`Claim 46 ............................................................................................123
`B.
`Claim 47 - “in order to report the information indicating the
`visited geographic location data, the software further instructs
`the controller of the location-aware cellular phone device to
`automatically and passively report the information indicating
`the visited geographic location data” ................................................126
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`C. A Person of Ordinary Skill in the Art Would Have Combined
`Callegari and Friedman ....................................................................127
`XIII. GROUND 3: CLAIMS 33-41, 43, and 45-48 ARE
`UNPATENTABLE OVER CALLEGARI IN VIEW OF
`ESCHENBACH ............................................................................................132
`A.
`Claims 33, 46, and 48 ........................................................................132
`B.
`Claims 34-41, 43, 45, and 47 ............................................................137
`C. A Person of Ordinary Skill in the Art Would Have Combined
`Callegari and Eschenbach ................................................................137
`XIV. GROUND 4: CLAIMS 46 AND 47 ARE UNPATENTABLE OVER
`CALLEGARI IN VIEW OF FRIEDMAN AND ESCHENBACH ................140
`A.
`Claim 46 ............................................................................................141
`B.
`Claim 47 - “in order to report the information indicating the
`visited geographic location data, the software further instructs
`the controller of the location-aware cellular phone device to
`automatically and passively report the information indicating
`the visited geographic location data” ................................................142
`C. A Person of Ordinary Skill in the Art Would Have Combined
`Callegari, Friedman, and Eschenbach ..............................................142
`XV. CONCLUSION ............................................................................................144
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`Exhibit
`Ex-1001
`Ex-1002
`Ex-1003
`Ex-1004
`Ex-1005
`
`Ex-1006
`Ex-1007
`Ex-1008
`Ex-1009
`Ex-1010
`Ex-1011
`Ex-1012
`Ex-1013
`Ex-1014
`Ex-1015
`Ex-1016
`Ex-1017
`Ex-1018
`Ex-1019
`Ex-1020
`Ex-1021
`Ex-1022
`Ex-1023
`Ex-1024
`Ex-1025
`Ex-1026
`Ex-1027
`Ex-1028
`Ex-1029
`Ex-1030
`
`Ex-1031
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`LIST OF EXHIBITS
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`IPR2021-00058
`U.S. Patent RE47,704
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`Description
`U.S. Patent No. RE47,704 (the ’704 patent)
`Prosecution File History of U.S. Patent No. RE47,704
`Declaration of David Hilliard Williams
`Curriculum Vitae of David Hilliard Williams
`U.S. Patent Application Publication No. 2003/0055983 to Callegari
`(“Callegari”)
`U.S. Provisional Patent Application No. 60/277174
`U.S. Provisional Patent Application No. 60/277187
`U.S. Provisional Patent Application No. 60/277200
`U.S. Patent No. 6,714,791 to Friedman (“Friedman”)
`U.S. Patent No. 6,373,429 to Eschenbach (“Eschenbach”)
`U.S. Patent No. 7,080,139
`U.S. Patent No. 6,052,122
`U.S. Patent No. 7,970,390
`U.S. Patent No. 6,466,788
`U.S. Patent App. Pub. No. 2003/0022684A1
`U.S. Patent No. 6,618,593
`U.S. Patent No. 7,739,139
`U.S. Patent No. 8,762,471
`U.S. Patent No. 8,589,247
`U.S. Patent No. 6,240,069
`U.S. Patent No. 7,047,030
`U.S. Patent No. 8,103,729
`U.S. Patent No. 7,953,815
`U.S. Patent No. 6,438,579
`U.S. Patent No. 6,332,127
`U.S. Patent No. 8,295,835
`U.S. Patent No. 6,968,179
`U.S. Patent No. 6,944,447
`U.S. Patent No. 5,493,692
`Goran M. Djuknic & Robert E. Richton, Geolocation and Assisted
`GPS, COMPUT., Feb. 2001, at 123.
`Jim Waldo et al., SUN MICROSYSTEMS LABORATORIES, A Note on
`Distributed Computing (1994).
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`Ex-1032
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`Ex-1033
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`Ex-1034
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`Ex-1035
`Ex-1036
`Ex-1037
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`Ex-1038
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`Ex-1039
`Ex-1040
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`EX-1041
`
`Ex-1042
`
`Ex-1043
`
`Ex-1044
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`Ex-1045
`Ex-1046
`Ex-1047
`Ex-1048
`Ex-1049
`Ex-1050
`Ex-1051
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`IPR2021-00058
`U.S. Patent RE47,704
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`Niranjan G. Shivaratri et al., Load Distributing for Locally
`Distributed Systems, COMPUT., Dec. 1992, at 33.
`Jim Gray, AN APPROACH TO DECENTRALIZED COMPUTER SYSTEMS
`(1985).
`Flaviu Cristian, Understanding Fault-Tolerant Distributed Systems,
`COMMUNICATIONS OF THE ACM, Feb. 1991, at 56.
`U.S. Patent No. 6,799,277
`WO 01/74034
`Microsoft Campus Agreement: How to Get Started (February 9,
`2001), available at
`https://www.uprm.edu/cms/index.php?a=file&fid=126
`Platform Services, OPENWAVE,
`https://web.archive.org/web/20020206231928/http:/www.openwave.
`com/products/platform_services/.
`U.S. Patent No. 7,376,433
`Jay Farrell & Tony Givargis, Differential GPS Reference Station
`Algorithm—Design and Analysis, 8 IEEE TRANSACTIONS ON
`CONTROL SYS. TECH. 519 (2000).
`François J.N. Cosquer & Paulo Veríssimo, The Impact of Group
`Communication Paradigms on Groupware Support, in
`PROCEEDINGS OF THE FIFTH IEEE COMPUTER SOC. WORKSHOP ON
`FUTURE TRENDS OF DISTRIBUTED COMPUTING SYS. 207 (1995).
`M. Kolland et al., Information Sharing in Collaborative
`Environments, in PROCEEDINGS THIRD WORKSHOP ON ENABLING
`TECH.: INFRASTRUCTURE FOR COLLABORATIVE ENTERPRISES 140
`(1994).
`Zygmunt J. Haas & Sanjoy Paul, Limited-lifetime Shared-access in
`Mobile Systems, 3 1995 IEEE INT’L CONF. ON COMM. 1404 (1995).
`Mahadev Satyanarayanan, Accessing Information on Demand at Any
`Location: Mobile Information Access, IEEE PERS. COMM., Feb.
`1996, at 26.
`U.S. Patent No. 8,572,198
`U.S. Patent Application Publication No. 2014/0081753
`U.S. Patent No. 7,133,685
`3GPP Location Standards Release 4.1 (March 2001)
`U.S. Patent No. 7,366,522 (“Thomas”)
`U.S. Patent No. 6,968,179 (“De Vries”)
`U.S. Patent No. 7,433,832 (“Bezos”)
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`Ex-1052
`Ex-1053
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`U.S. Patent Application Publication No. 2002/0095486 (“Bahl”)
`U.S. Patent No. 8,099,667
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`I.
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`IPR2021-00058
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`I, David Hilliard Williams, declare as follows:
`
`INTRODUCTION
`I have been retained on behalf of Google LLC (“Google”) for the
`1.
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`above-captioned inter partes review (IPR) proceeding. I am being compensated for
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`my time in connection with this IPR at my standard hourly consulting rate. I
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`understand that this proceeding involves U.S. Patent No. RE47,704 (“the ’704
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`patent”) titled “Method and Apparatus for Selectively Sharing and Passively
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`Tracking Communication Device Experiences” by Darren P. Briggs, Brady O.
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`Bruce, Michael W. Mitchell, and Emile L. Reed, IV, and that the ’704 patent is
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`currently assigned to Ikorongo Technology, LLC.
`
`2.
`
`I have reviewed and am familiar with the specification of the ’704
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`patent filed on December 19, 2014. I understand that the ’704 patent has been
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`provided as Ex-1001. I will cite to the specification using the following format: Ex-
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`1001, ’704 patent, 1:1-10. This example citation points to the ’704 patent
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`specification at column 1, lines 1-10.
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`3.
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`I have reviewed and am familiar with the file history of the ’704 patent.
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`I understand that the file history has been provided as Ex-1002.
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`4.
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`I understand that the ’704 patent has a filing date of December 19, 2014,
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`but claims priority to the filing date of its parent application, U.S. Patent No.
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`7,080,139, April 24, 2001. I am informed by Google’s counsel that April 24, 2001
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`is the ’704 patent’s earliest possible priority date.
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`5.
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`In preparing this Declaration, I have also reviewed and am familiar with
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`the following prior art used in the Petition for Inter Partes Review of the ’704 patent
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`and/or in my declaration below:
`
`• U.S. Patent Application Publication No. 2003/0055983 to Jeff
`Callegari (Ex-1005), filed on March 19, 2002, issued on March
`20, 2003, and entitled to the priority date of March 19, 2001
`based on Provisional Application Nos. 60/277,174 (Ex-1006),
`60/277,187 (Ex-1007), and 60/277,200 (Ex-1008).
`• U.S. Patent No. 6,714,791 to Jackie Friedman (Ex-1009), filed
`February 23, 2001 and issued March 30, 2004.
`• U.S. Patent No. 6,373,429 to Ralph F. Eschenbach (Ex-1010),
`filed February 6, 2001, and issued April 16, 2002.
`I have been asked to provide my technical review, analysis, insights,
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`6.
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`and opinions regarding the ’704 patent and the above-noted references that form the
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`basis for the grounds of rejection set forth in the Petition for Inter Partes Review of
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`the ’704 patent.
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`II. QUALIFICATIONS
`In formulating my opinions, I have relied upon my training,
`7.
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`knowledge, and experience in the relevant art. A copy of my current curriculum
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`vitae is provided as Ex-1004, and it provides a comprehensive description of my
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`academic and employment history over the last thirty-plus years.
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`8.
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`I have over 30 years of experience in wireless location services,
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`including experience designing, implementing, and managing numerous location-
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`based service (LBS) applications such as mobile social networking, family
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`tracking, and mobile resource management, as well as working in all fields within
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`the location services ecosystem including all forms of location determination
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`technologies, map data, handset technologies, and associated Information
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`Technology systems including identification, authentication, privacy, security, and
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`other related capabilities such as network engineering and operations.
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`9.
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`I am currently the President of the company E911-LBS Consulting,
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`and I have been with the company since 2002. As the President of E911-LBS
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`Consulting, I provide services across the entire wireless value chain, particularly
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`with respect to technology and business strategic planning and product design and
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`development associated with LBS, Global Positioning Satellite (GPS) systems,
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`E911, WiFi-Based and other medium/long-range Real-Time Location Systems
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`(RTLS), Radio Frequency Identification (RFID), Bluetooth, Near Field
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`Communications (NFC), and beacon-based and other short-range
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`communications/location systems, and other location determination and sensing
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`technologies and services.
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`10.
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`I have extensive expertise in all aspects of LBS delivery across the
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`wireless location ecosystem including enabling network, map data, geospatial
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`platform, chipset, data management, device, and location determination
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`infrastructure and integration providers. I am an expert in all related aspects of
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`LBS, including data privacy and security management.
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`11. For example, in the 1995 to 2000 timeframe, as an Associate Partner in
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`the Communications & High Technology Practice of Accenture (one of the world’s
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`leading technology companies), I focused on using wireless location technologies to
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`provide services to the public sector and commercial markets. In particular, from
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`1998 to 2000, I led the development of the LBS product/technology strategy and
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`roadmap for Nextel Communications, Inc. My work with Nextel resulted in some of
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`the earliest LBS applications in the U.S. market and included extensive research into
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`the potential use of various technologies in providing and enabling a wide array of
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`location-based services, including Mobile Resource Management (MRM) worker
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`tracking and vehicle/fleet management applications. This work also including
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`leading the development of the underlying network and Information Technology
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`architectures that would be required to support the LBS applications product strategy
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`and roadmap.
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`12.
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`In 2003, I led the development of part of AT&T Wireless’s E911
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`infrastructure, including the development of systems, processes, and reporting
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`infrastructure to manage and track the deployment of time difference of arrival-
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`based location determination technologies. I managed the testing and Federal
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`Communications Commission (FCC) reporting of network location inaccuracies,
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`with a particular focus on detecting and troubleshooting out-of-norm technology
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`deployment and inaccurate location conditions.
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`13. From 2005 to 2007, I worked with NAVTEQ (now HERE)—the
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`leading provider of map data and services essential to creating LBS applications—
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`to develop the company’s web developer website content and tools. Specifically, I
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`designed and managed the site map and overall content, including the development
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`of comprehensive technical and business web content for all NAVTEQ map product
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`and service lines. Through the developer site, application developers and business
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`managers became intimately familiar with map data, Geographical Information
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`System (GIS) platforms, and location-based services to successfully develop and
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`launch their LBS applications. For example, I developed the content to highlight key
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`types of map data and to provide technical details on how NAVTEQ tools can be
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`used in LBS design for various consumer and business applications.
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`14.
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`I also have extensive LBS application product design and
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`implementation experience, which includes data privacy and security management.
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`For example, from 2007 to 2010, I managed the design, development, and launch of
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`several consumer and business-oriented LBS applications for AT&T Mobility.
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`These LBS application included mobile social networking, family tracking, local
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`search, 411-with-LBS, mobile resource management, and asset tracking. I also
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`developed corporate-wide location data privacy policies and associated system
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`implementation for all LBS customers. My AT&T work also extensively involved
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`various aspects of worker and vehicle/fleet management tracking. In particular, I
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`was the Product Manager for the several of the joint AT&T-Telenav Mobile
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`Resource Management applications, as well as various fleet management solutions.
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`15. These roles and work required extensive knowledge of how the various
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`applications worked, and even required design modifications in order for it to “fit
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`into” AT&T’s network and IT infrastructure, as well as to implement AT&T’s
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`privacy and security policies. The work also included designing/modifying AT&T’s
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`network and IT infrastructure to allow/enable the applications to seamless work with
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`AT&T’s location infrastructure and various IT systems used for functions including
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`Sales, Customer Care, Fulfillment, Billing/Accounts Receivable, and various
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`network and IT operations. Among associated activities, my efforts included closely
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`working with AT&T Legal to develop and implement AT&T’s location privacy
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`policies. These efforts in both data privacy people tracking resulted in a patent: U.S.
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`Patent 8,613,109, titled “Method and Apparatus for Providing Mobile Social
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`Networking Privacy,” that issued on December 17, 2013, of which I was the only
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`non-employee inventor.
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`16.
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`In addition to the Location-Based Services applications, enabling
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`location
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`technologies, wireless communications, and privacy and security
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`experience and expertise described above, I also have many years of Information
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`Technology experience. For example, as a consultant in the Information Technology
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`practices of Deloitte Consulting (originally Touche Ross), Booz Allen & Hamilton,
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`and Andersen Consulting (now Accenture), I served in key technology development
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`and technology leadership roles in numerous projects designing and implementing
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`mainframe, mini-computer, and client-server based computing systems across a
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`wide variety of industries and a wide variety of functions/applications. I also led the
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`design and development of a number of different communications networks
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`associated with those computing systems, including wide- and local-area networks,
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`utilizing both wired and wireless technologies, involving private and public (e.g.
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`Internet-based) communications backbones. This communications system expertise
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`includes underlying expertise in the electrical characteristics of communications
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`signals, extending back to the early 1980s with my Electrical Engineering degree
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`from Purdue University in 1983 and my work as a EE in the design of the Analog-
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`to-Digital Signal Converter unit for the F-15 fighter jet radar system while with
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`Hughes Aircraft Company Radar Systems Division from 1983-1985.
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`17.
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`I have authored multiple books on wireless location, including:
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`• The Definitive Guide to GPS, RFID, Wi-Fi, and Other Wireless
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`Location-Based Services (2005 and 2009 versions);
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`• The Definitive Guide to Wireless E911; and
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`• The Definitive Guide to Mobile Positioning and Location
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`Management (co-author).
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`18.
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`I received a B.S. degree in Electrical Engineering from Purdue
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`University in 1983 with top honors. I received an MBA degree in Information
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`Systems Management from The University of Texas at Austin in 1987, also with
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`top honors.
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`19. My curriculum vitae contains further details on my education,
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`experience, publications, and other qualifications to render an expert option. Ex-
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`1004. My work on this case is being billed at a flat rate of $425 per hour, with
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`reimbursement for actual expenses. My compensation is not contingent upon the
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`outcome of this inter partes review proceeding.
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`IPR2021-00058
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`III. MATERIALS CONSIDERED
`In forming my opinions, I have reviewed the following documents,
`20.
`
`and any other document cited in this declaration:
`
`Description
`U.S. Patent No. RE47,704 (the ’704 patent)
`Prosecution File History of U.S. Patent No. RE47,704
`U.S. Patent Application Publication No. 2003/0055983 to Callegari
`(“Callegari”)
`U.S. Provisional Patent Application No. 60/277174
`U.S. Provisional Patent Application No. 60/277187
`U.S. Provisional Patent Application No. 60/277200
`U.S. Patent No. 6,714,791 to Friedman (“Friedman”)
`U.S. Patent No. 6,373,429 to Eschenbach (“Eschenbach”)
`U.S. Patent No. 7,080,139
`U.S. Patent No. 6,052,122
`U.S. Patent No. 7,970,390
`U.S. Patent No. 6,466,788
`U.S. Patent App. Pub. No. 2003/0022684A1
`U.S. Patent No. 6,618,593
`U.S. Patent No. 7,739,139
`U.S. Patent No. 8,762,471
`U.S. Patent No. 8,589,247
`U.S. Patent No. 6,240,069
`U.S. Patent No. 7,047,030
`U.S. Patent No. 8,103,729
`U.S. Patent No. 7,953,815
`U.S. Patent No. 6,438,579
`U.S. Patent No. 6,332,127
`U.S. Patent No. 8,295,835
`U.S. Patent No. 6,968,179
`U.S. Patent No. 6,944,447
`U.S. Patent No. 5,493,692
`
`10
`
`Exhibit
`Ex-1001
`Ex-1002
`Ex-1005
`
`Ex-1006
`Ex-1007
`Ex-1008
`Ex-1009
`Ex-1010
`Ex-1011
`Ex-1012
`Ex-1013
`Ex-1014
`Ex-1015
`Ex-1016
`Ex-1017
`Ex-1018
`Ex-1019
`Ex-1020
`Ex-1021
`Ex-1022
`Ex-1023
`Ex-1024
`Ex-1025
`Ex-1026
`Ex-1027
`Ex-1028
`Ex-1029
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`

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`IPR2021-00058
`U.S. Patent RE47,704
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`Goran M. Djuknic & Robert E. Richton, Geolocation and Assisted
`GPS, COMPUT., Feb. 2001, at 123.
`Jim Waldo et al., SUN MICROSYSTEMS LABORATORIES, A Note on
`Distributed Computing (1994).
`Niranjan G. Shivaratri et al., Load Distributing for Locally
`Distributed Systems, COMPUT., Dec. 1992, at 33.
`Jim Gray, AN APPROACH TO DECENTRALIZED COMPUTER SYSTEMS
`(1985).
`Flaviu Cristian, Understanding Fault-Tolerant Distributed Systems,
`COMMUNICATIONS OF THE ACM, Feb. 1991, at 56.
`U.S. Patent No. 6,799,277
`WO 01/74034
`Microsoft Campus Agreement: How to Get Started (February 9,
`2001), available at
`https://www.uprm.edu/cms/index.php?a=file&fid=126
`Platform Services, OPENWAVE,
`https://web.archive.org/web/20020206231928/http:/www.openwave.
`com/products/platform_services/.
`U.S. Patent No. 7,376,433
`Jay Farrell & Tony Givargis, Differential GPS Reference Station
`Algorithm—Design and Analysis, 8 IEEE TRANSACTIONS ON
`CONTROL SYS. TECH. 519 (2000).
`François J.N. Cosquer & Paulo Veríssimo, The Impact of Group
`Communication Paradigms on Groupware Support, in
`PROCEEDINGS OF THE FIFTH IEEE COMPUTER SOC. WORKSHOP ON
`FUTURE TRENDS OF DISTRIBUTED COMPUTING SYS. 207 (1995).
`M. Kolland et al., Information Sharing in Collaborative
`Environments, in PROCEEDINGS THIRD WORKSHOP ON ENABLING
`TECH.: INFRASTRUCTURE FOR COLLABORATIVE ENTERPRISES 140
`(1994).
`Zygmunt J. Haas & Sanjoy Paul, Limited-lifetime Shared-access in
`Mobile Systems, 3 1995 IEEE INT’L CONF. ON COMM. 1404 (1995).
`Mahadev Satyanarayanan, Accessing Information on Demand at Any
`Location: Mobile Information Access, IEEE PERS. COMM., Feb.
`1996, at 26.
`U.S. Patent No. 8,572,198
`11
`
`Ex-1030
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`Ex-1031
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`Ex-1032
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`Ex-1033
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`Ex-1034
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`Ex-1035
`Ex-1036
`Ex-1037
`
`Ex-1038
`
`Ex-1039
`Ex-1040
`
`EX-1041
`
`Ex-1042
`
`Ex-1043
`
`Ex-1044
`
`Ex-1045
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`Ex-1046
`Ex-1047
`Ex-1048
`Ex-1049
`Ex-1050
`Ex-1051
`Ex-1052
`Ex-1053
`
`U.S. Patent Application Publication No. 2014/0081753
`U.S. Patent No. 7,133,685
`3GPP Location Standards Release 4.1 (March 2001)
`U.S. Patent No. 7,366,522 (“Thomas”)
`U.S. Patent No. 6,968,179 (“De Vries”)
`U.S. Patent No. 7,433,832 (“Bezos”)
`U.S. Patent Application Publication No. 2002/0095486 (“Bahl”)
`U.S. Patent No. 8,099,667
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`21.
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`I have also relied on my education, experience, research, training, and
`
`knowledge in the relevant art, and my understanding of any applicable legal
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`principles described in this declaration.
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`22. All of the opinions contained in this declaration are based on the
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`documents I reviewed and my knowledge and professional judgment. My opinions
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`have also been guided by my understanding of how a person of ordinary skill in the
`
`art would have understood the claims of the ’704 patent at the time of the alleged
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`invention. For purposes of this declaration, I have been asked to assume that the
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`date of the alleged invention is the earliest claimed priority date: April 21, 2001.
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`23.
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`I reserve the right to supplement and amend any of my opinions in
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`this declaration based on documents, testimony, and other information that
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`becomes available to me after the date of this declaration.
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`IV. LEGAL PRINCIPLES
`24. For purposes of this declaration, I have been asked to opine only on
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`issues regarding obviousness under 35 U.S.C. § 103. I have been informed of the
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`following legal standards, which I have applied in forming my opinions.
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`25.
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`I have been asked to provide my opinions as to whether the cited prior
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`art renders obvious the elements of claims 33-41, 43, and 45-48 of the ’704 patent
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`from the perspective of a person of ordinary skill in the art at the ’704 patent’s
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`priority date in 2001, as described in more detail below.
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`26. For purposes of this declaration, I have been informed and understand
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`certain aspects of the law as it relates to my opinions.
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`27.
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`I have been advised and understand that there are two ways in which
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`prior art may render a patent claim unpatentable. First, the prior art can
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`“anticipate” the claim. Second, the prior art can make the claim “obvious” to a
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`person of ordinary skill in the art. I understand that for an invention claimed in a
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`patent to be patentable, it must not be anticipated and must not be obvious based
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`on what was known before the invention was made.
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`28.
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`I have been advised and understand the information used to evaluate
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`whether an invention was new and not anticipated or obvious when made is
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`generally referred to as “prior art.” I understand that prior art includes patents and
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`printed publications that existed before the earliest filing date of the patent (which I
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`have been informed is called the “effective filing date”). I have been informed and
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`understand that a patent or published patent application is prior art if it was filed
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`before the effective filing date of the claimed invention and that a printed
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`publication is prior art if it was publicly available before the effective filing date.
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`29.
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`I have been advised and understand that a dependent claim is a patent
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`claim that refers back to another patent claim. I have been informed and
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`understand that a dependent claim includes all of the limitations of the claim to
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`which it refers.
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`30.
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`I have been advised and understand that a patent claim may be invalid
`
`as anticipated under 35 U.S.C. § 102 if a prior art reference discloses each element
`
`of the claimed subject matter.
`
`31.
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`I have been advised and understand that a patent claim may be invalid
`
`as obvious under 35 U.S.C. § 103 if the differences between the subject matter
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`claimed and the prior art are such that the claimed subject matter as a whole would
`
`have been obvious to a person of ordinary skill in the art at the time the invention
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`was made. I have also been advised that several factual inquiries underlie a
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`determination of obviousness. These inquiries include (1) the scope and content of
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`the prior art, (2) the level of ordinary skill in the field of the invention, (3) the
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`differences between the claimed invention and the prior art, and (4) any objective
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`evidence of non-obviousness (which I have been informed may also be called
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`“secondary considerations”).
`
`32.
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`I have also been advised and understand that, where a party alleges
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`obviousness based on a combination of refer