UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`ONE-E-WAY, INC.,
`Patent Owner.
`
`Case IPR2021-00283
`U.S. Patent 8,131,391 B2
`
`DECLARATION OF JOSEPH C. MCALEXANDER
`IN SUPPORT OF PATENT OWNER’S PRELIMINARY RESPONSE
`TO PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 8,131,391
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`I, Joseph C. McAlexander III, P.E., declare as follows:
`
`1.
`
`I have personal knowledge of the facts set forth herein, and, if called
`
`upon to do so, I could and would testify competently to them.
`
`2.
`
`I have been asked to offer my opinion regarding the Petition for Inter
`
`Partes Review of U.S. Patent No. 8,131,391 in IPR2021-00283, the Petitions for
`
`Inter Partes Review of U.S. Patent No. 10,468,047 in IPR2021-00284 and -00285,
`
`and the Petitions for Inter Partes Review of U.S. Patent No. 10,129,627 in IPR2021-
`
`00286 and -00287, and in particular to compare those patents against prior art
`
`references raised in the respective IPR Petitions, and to consider opinions of
`
`Petitioner’s declarant, Regis J. Bates Jr., offered in support of the IPR Petitions.
`
`3.
`
`I have been retained by Patent Owner One-E-Way, Inc. to provide my
`
`expert opinion. I am being compensated at my customary hourly rate for my time
`
`spent on this opinion. I have no personal interest in the outcome of this or any related
`
`proceeding.
`
`Expert Qualifications
`
`4.
`
`I am a Registered Professional Engineer (#79454). I am President of
`
`McAlexander Sound, Inc., a Professional Engineering Company (F-8163), and the
`
`Managing Director of McAlexander Sound Pte Ltd., both providing professional
`
`consultation in engineering and intellectual property. I am also the President and
`
`CEO of MDFHoldings, Inc., an IP holding company engaged in the field of tracking,
`
`-1-
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`integrating multiple forms of wireless transmission/reception and protocols
`
`including, GPS, Assisted GPS, paging, LANs, RFID, local RF such as Bluetooth,
`
`and using base station technology as appropriate. I hold a Bachelor of Science
`
`degree in Electrical Engineering from North Carolina State University and have over
`
`48 years of experience in microcircuit and semiconductor technologies. I am an
`
`inventor of 31 issued United States patents and a number of foreign patents.
`
`5. My skills and experience are in areas of software development,
`
`management, circuit design and analysis, device fabrication and assembly, testing,
`
`marketing, control system design and analysis, manufacturing operations, and
`
`respective areas of quality, reliability, and defect/failure analysis. Specifically, I
`
`have:
`
`• designed and managed development, testing, simulation, and
`
`evaluation of devices including Dynamic Random Access
`
`Memories
`
`(DRAMs), Static Random Access Memories
`
`(SRAMs), Charge Coupled Devices (CCDs), Shift Registers
`
`(SRs), and functional circuits including I/O buffers for address
`
`and data, decoders, clocks, sense amplifiers, fault tolerant,
`
`parallel-to-serial data paths for video applications, level shifters,
`
`converters, pumps, and logic, as well as wireless communication
`
`systems and MEMs applications;
`
`-2-
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`• managed operations including engineering, training, and quality
`
`assurance for device fabrication, assembly, test, analysis, and
`
`reliability assessment, as well as manufacturing control, each of
`
`which involved both volatile and non-volatile memory;
`
`• designed and performed testing, analysis, and control involving
`
`use of mechanical calibration and measuring equipment,
`
`including optical, scanning e-beam, IR, capacitive, and laser
`
`using phase contrast and Fast Fourier Transform (FFT) for High
`
`Aspect Ratio Inspection (HARI) applications;
`
`• managed the design and installation of audio sound and video
`
`systems for private and commercial enterprises;
`
`• taught courses in solid-state device physics, integrated circuit
`
`design, integrated circuit fabrication, and statistical control;
`
`• provided expert services, investigating both process and design
`
`technologies of various devices (microprocessor and controller,
`
`volatile and non-volatile memory, programmable logic, card, tag,
`
`module, mixed signal, custom, and other), systems (PC and
`
`peripheral, computer, control, laser measurement, switch,
`
`architecture, software, and other), and consumer products
`
`-3-
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`(medical, TV, telephone, VCR, facsimile, copier, lighting, game,
`
`and other);
`
`•
`
`experienced in programming, erasing, and wearout of electrically
`
`programmable and erasable non-volatile memories.
`
`6.
`
`Upon completion of my electrical engineering degree in 1969, I was
`
`commissioned as an officer in the U.S. Army. For 2 years, I managed the air defense
`
`operation for
`
`the New England area, which
`
`included radar and secure
`
`communication channels to aircraft, missile batteries, and U.S. Command. I then
`
`commanded a signal battalion in South Korea for 1 year, designing and orchestrating
`
`at the division level the first of its kind communication power grid mapping study
`
`using AM and FM transmission/reception, among others, and utilizing crypto
`
`security transmission/reception methods.
`
`7.
`
`As part of licensing of my IP circa 2002 – 2004, I negotiated and
`
`executed a number of licensing and design programs to provide GPS tracking and
`
`transmission of information wirelessly, using paging and CDMA. The technologies
`
`included partnerships for skier tracking with Snowtrax, offender tracking with
`
`Stellar Technology Enterprises, pet tracking with The Procter & Gamble Company,
`
`journalist tracking with CNN, asset tracking with TrackDaddy, and family tracking
`
`with Disney, to name a few. I also advised a startup between 2013 and 2018 in peer-
`
`to-peer encrypted cellular communication.
`
`-4-
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`8.
`
`Because of my background, training, and experience, I am qualified as
`
`an expert to opine as set forth herein. A more detailed account of my work
`
`experience and other qualifications is listed in my Curriculum Vitae attached as
`
`Appendix A.
`
`Materials Considered
`
`9.
`
`In the course of developing this declaration, I examined the following
`
`materials:
`
`• U.S. Patent No. 8,131,391 to Woolfork;
`
`• U.S. Patent No. 10,129,627 to Woolfork;
`
`• U.S. Patent No. 10,468,047 to Woolfork;
`
`• The Petitions for Inter Partes Review in IPR2021-00283, -00284, -00285,
`
`-00286, -00287, and exhibits to each respective Petition, including Exhs.
`
`1010 and 1120, the certified English translation of KR Application No. 20-
`
`1998-0018161 (“Ham”); and “Digital Communications: Fundamentals and
`
`Applications” (1988), by Bernard Sklar (“Sklar”), including Exhs. 1003
`
`and 1103; “CDMA Mobile Radio Design” (2000) by John B. Groe, Exhs.
`
`1009 and 1109;
`
`• U.S. Patent No. 6,618,429; and
`
`• U.S. Patent No. 6,091,760.
`
`
`
`-5-
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`Level of Ordinary Skill in the Art
`
`10.
`
`In this analysis, I have been asked to assume the level of ordinary skill
`
`in the art set forth in the Petitions. Thus, I have assumed that a person having
`
`ordinary skill in the art as of December 2001 would have possessed at least a
`
`bachelor’s degree in electrical engineering, and two years of experience in the design
`
`or implementation of wireless communications systems (or equivalent degree or
`
`experience). I am familiar with the level of knowledge meeting this standard.
`
`Additional details regarding that familiarity are contained in my attached Curriculum
`
`Vitae.
`
`Claim Term Constructions
`
`11. For purposes of this declaration, I have been asked to assume the claim
`
`constructions set forth in the Petitions. Thus, I have assumed the following claim
`
`constructions in this analysis:
`
`“reduced
`coding”
`
`Claim Term
`intersymbol
`
`interference
`
`Petitioner’s Requested Construction
`“coding that reduces intersymbol (inter-
`symbol) interference”
`
`independent code
`for
`“configured
`division multiple access
`(CDMA)
`communication operation”
`
`“unique user code”
`
`“configured for code division multiple
`access
`(CDMA)
`communication
`operation performed independent of any
`central control”
`
`“fixed code (bit sequence) specifically
`associated with one user of a device(s)”
`
`-6-
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`Claim Term
`“direct conversion module”
`
`Error Correction Encoding
`
`Petitioner’s Requested Construction
`“module for converting radio frequency
`to baseband or very near baseband in a
`single frequency”
`
`12. Mr. Bates opines that “Ham itself provides express suggestions to use
`
`coding to reduce ISI by teaching the use of ‘error correction encoding on the applied
`
`signal and performs immunity processing so as not to be affected by noise generated
`
`in the communication channel.’ (Ham, p.2).” E.g., IPR2021-00283 Ex. 1002 ¶ 162.
`
`I have reviewed the statement in Ham referenced by Mr. Bates. A person of ordinary
`
`skill in the art would not understand “error correction encoding” referenced in Ham
`
`to refer to encoding to address intersymbol interference, which relates to interference
`
`caused by the signal itself. Interpreted so broadly as to include intersymbol
`
`interference, error correction encoding would include many techniques in both
`
`waveform coding and structured sequencing to address errors arising from any
`
`source of channel impairment. I note that Petitioner’s Sklar reference describes the
`
`use of waveform coding and structured sequencing to address channel impairments
`
`broadly, including switching noise, burst noise, jamming, fading, multipath as well
`
`as interference of numerous types. E.g., IPR2021-00283 Ex. 1003 at 208.
`
`13. The Sklar reference further describes that, under such a broad
`
`interpretation, error correction encoding would include: (1) waveform coding, which
`
`-7-
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`involves transforming a waveform into a better waveform that makes the process of
`
`detection less subject to errors; and (2) structured sequences, which involve
`
`introducing redundancy into a signal, where the redundant bits can then be used for
`
`the detection and correction of errors. Id. A person of ordinary skill would also
`
`understand that waveform coding includes numerous techniques, including M-ary
`
`signaling, and the use of antipodal, orthogonal, biorthogonal and transorthogonal
`
`signals. Id. at 208-19. A person of ordinary skill would further understand that
`
`structured sequence coding covers broad subcategories of coding techniques, such
`
`as linear block coding and convolutional coding, each of which includes multiple
`
`species of coding techniques. Linear block coding includes, for example, the use of
`
`cyclic codes, hamming codes, Golay codes, BCH codes, and Reed-Solomon codes.
`
`Id. at 231-269. Further, convolutional coding includes many coding and decoding
`
`strategies, as well as the use of interleaving to apply convolutional coding techniques
`
`to channels that exhibit certain types of noise or fading. Ex. 2004 (Sklar chapter 6).
`
`Orthogonality and Independent CDMA
`
`14. The Ham reference contains the following disclosure:
`
`In general, a headphone is a design used to provide audio only to a user
`who uses the headphone by receiving an audio signal wirelessly or
`wired; in addition, the code division multiple access method
`(hereinafter referred to as the code division method) is a method of
`sharing a frequency by extending a signal into a frequency band that is
`much wider than the bandwidth of the required amount of information.
`In other words, it shares all frequency and time and maintains
`orthogonality with a unique code assigned to it. In this case, in the
`
`-8-
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`code division method, a signal to be transmitted is extended by
`receiving a unique Pseudo Random (PN) code.
`
`E.g., IPR2021-00283 Ex. 1010 at 2 (emphasis added). A person of ordinary skill in
`
`the art would understand that sharing time (synchronous) and maintaining
`
`orthogonality refer to specific sub-species of CDMA (such as the synchronous,
`
`orthogonal CDMA used in the mid- to late 1990s in IS95), and do not refer to
`
`attributes common to all CDMA. See, e.g., IPR2021-00283 Ex. 1002 ¶ 38, Ex. 1009
`
`at 41-44. For example, CDMA can be asynchronous (transmissions not time-
`
`synchronized) or non-orthogonal (code cross-correlations greater than zero). Thus,
`
`a person of ordinary skill in the art would understand that Ham is disclosing its “code
`
`division method” as being synchronous and maintaining orthogonality. A person of
`
`ordinary skill in the art would also understand that Ham incorporates this specific
`
`“code division method” in its transmission and reception circuits disclosed
`
`thereafter. E.g., IPR2021-00283 Ex. 1010 at 2 (“hereinafter referred to as the code
`
`division method”).
`
`15. One of ordinary skill in the art would understand that Ham’s
`
`unequivocal statement that its code division method “maintains orthogonality” is
`
`consistent with Ham also reporting that “noise and interference are prevented” by its
`
`system. Id. at 3.
`
`16. One of ordinary skill in the art would also understand that maintaining
`
`orthogonality is an indication of centralized control. In particular, in a wireless
`
`-9-
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`communications system in which multiple user devices communicate wirelessly in
`
`the same frequency and time, orthogonality can only be maintained by providing
`
`each user device with a spreading code known to be orthogonal to each spreading
`
`code being used by another user device. In Ham’s system, this would require
`
`centralized control ensuring that all Ham’s assigned PN codes have a cross-
`
`correlation value of zero.
`
`17. A person of ordinary skill would understand that orthogonality can be
`
`implemented in a CDMA system with PN codes as disclosed in Ham. See, e.g., Ex.
`
`2006 (U.S. Patent No. 6,618,429, “System And Method For Generating Signal
`
`Waveforms In A CDMA Cellular Telephone”) at 4:40-44 (“With orthogonal PN
`
`codes, the cross correlation is zero over a predetermined time interval, resulting in
`
`no interference between the orthogonal codes, provided only that the code time
`
`frames are time aligned with each other.”); Ex. 2007 (U.S. Patent No. 6,091,760) at
`
`1:47-54, 2:43-48.
`
`18. A person of ordinary skill in the art would also understand that CDMA
`
`methods in which wireless communications are performed at the same frequency,
`
`and are synchronized in time, have the advantage of being candidate methods for the
`
`use of orthogonal spreading codes. Thus, a person of ordinary skill in the art would
`
`understand that the same-frequency, time-synchronous CDMA method disclosed by
`
`-10-
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`Ham is the type of system in which multi-user interference can be addressed through
`
`the use of spreading codes known to be orthogonal to each other.
`
`PCS
`
`19. Ham discloses the following as one of its design objectives: “Another
`
`object of the present design is to apply a spread spectrum modulation method, which
`
`is a CDMA method, wherein in PCS, which is a personal mobile phone, the
`
`transmission rate is 14.4 kbps, and the frequency band is set from 902 MHz to 928
`
`MHz.” E.g., IPR2021-00283 Ex. 1010 at 2. One of ordinary skill in the art would
`
`recognize that PCS is a wireless cellular-based communications network that
`
`operates using cellular base stations.
`
`Downconversion Architecture In Ham
`
`20.
`
`In its disclosure of a transmission circuit, Ham discloses a signal
`
`“processed to an intermediate frequency through the base band unit 5.” Id. at 3. A
`
`person of ordinary skill in the art would understand Ham’s description of a signal
`
`“processed to an intermediate frequency” as an indication of a non-homodyne
`
`downconversion architecture.
`
`
`
`I declare that all statements made herein of my own knowledge are true and
`
`that all statements made on information and belief are believed to be true; and further
`
`that these statements were made with the knowledge that willful false statements and
`
`-11-
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`the like so made are punishable by fine or imprisonment, or both, under Section 1001
`
`of Title 18 of the United States Code.
`
`
`
`Executed on March 16, 2021.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` ___________________________
`
`Joseph C. McAlexander III, P.E.
`
`-12-
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`APPENDIX A
`
`APPENDIX A
`
`ONE-E-WAY 2001
`
`Apple v. One-E-Way
`IPR2021-00283
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`CURRICULUM VITAE
`
` Joseph C. McAlexander III
`
`PROFESSIONAL SUMMARY
`
`Currently a Registered Professional Engineer (#79454) and recognized as an inventor on 31 US
`and a number of foreign patents, I am President of McAlexander Sound, Inc., and the Managing
`Director of McAlexander Sound Pte Ltd. I have focused my expertise to support a number of
`clients in product, process, and operations analysis and investigation. Forty-eight years of
`experience in microcircuit and semiconductor technologies has developed my skills in areas of
`circuit design and analysis, device fabrication and assembly, testing, marketing, control system
`design and analysis, manufacturing operations and respective areas of quality, reliability, and
`defect / failure analysis. I am also the President and CEO of MDFHoldings, Inc., an IP holding
`company currently engaged in the field of GPS Tracking, and was formerly, among others, a
`Manager with QM Partners, LP, supporting clients in IP management and licensing. I have:
`
`- designed and managed development, testing, and evaluation of devices including Dynamic
`Random Access Memories (DRAMs), Static Random Access Memories (SRAMs), Charge
`Coupled Devices (CCDs), Shift Registers (SRs), and functional circuits including I/O buffers
`for address and data, decoders, clocks, sense amplifiers, fault tolerant, parallel-to-serial data
`paths for video applications, level shifters, converters, pumps, and logic, as well as wireless
`communication systems and MEMs applications;
`
`- managed operations including engineering, training, and quality assurance for device
`fabrication, assembly, test, analysis, and reliability assessment, as well as manufacturing
`control, each of which involved both volatile and non-volatile memory; testing, analysis, and
`control involving use of mechanical calibration and measuring equipment, including optical,
`scanning e-beam, IR, capacitive, and laser using phase contrast and Fast Fourier Transform
`(FFT) for High Aspect Ratio Inspection (HARI) applications; audio and video system design
`and installation;
`
`- taught courses in solid state device physics, integrated circuit design, integrated circuit
`fabrication, and statistical control;
`
`- provided expert services, investigating both process and design technologies of various
`devices (microprocessor and controller, memory, programmable logic, card, tag, module,
`mixed signal, custom, and other), systems (PC and peripheral, computer, control, laser
`measurement, switch, architecture, software, and other), and consumer products (medical,
`TV, telephone, VCR, facsimile, copier, lighting, game, and other);
`
`- provided nuclear radiation hardness testing services for military and space clients; and
`
`- managed the design and installation of audio sound and video systems for private and
`commercial enterprises.
`
`McAlexander Sound, Inc.
`
`CV - Joe McAlexander, 1Q2021
`
`1
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`CURRICULUM VITAE
`
`
`
`
`
`
`
`
`
`
`
`
` Joseph C. McAlexander III
`
`PROFESSIONAL SUMMARY
`
`From 1986-1990, I was Executive Vice President of EPI Technologies, Inc., prior to joining the
`staff at Cochran Consulting, Inc. where I served as senior managing consultant from 1991-2002.
`From 1972 to 1986, I was employed by Texas Instruments Incorporated.
`
`
`McAlexander Sound, Inc.
`
`CV - Joe McAlexander, 1Q2021
`
`2
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`CURRICULUM VITAE
`
` Joseph C. McAlexander III
`
`EXPERIENCE PROFILE
`
`1988-present
`
`McAlexander Sound, Inc. (McASI) - Richardson, TX
`President
`
`o System, Product, and Process investigation, expert witness
`services for protection of intellectual property;
`o Patent portfolio development and valuation;
`o Product liability and insurance claim investigation, expert witness
`services for matters involving such claims;
`o Quality Systems consulting and engineering;
`o Radiation Hardness Testing Technical Representative;
`o Technical Advisor in High Aspect Ratio and Surface Contour
`Measurement using Direct-to-Digital Holography.
`
`2005-present
`
`McAlexander Sound Pte Ltd - Singapore
`Managing Director
`
`o System, Product, and Process investigation, expert witness
`services for protection of intellectual property;
`o Patent portfolio development and valuation;
`o Contract consultation;
`o Not assigned any patents and is not engaged in any IP related
`licensing or litigation activities.
`
`2002-present
`
`MDFHoldings, Inc. – Las Vegas, NV
`CEO
`
`o IP holding and licensing company;
`o Assigned U.S. Patent Nos. 7,340,260 and 7,657,265 and EP 1 557
`058 B1, each related to an object locating system;
`o Has not been and is not engaged in any IP related litigation or
`licensing activities.
`
`2006-2020
`
`QM Partners, L.P. – Texas
`Manager
`
`o Management of development,
`licensing, prosecution and
`exploitation of assigned intellectual property;
`o Not assigned any patents and is not engaged in any IP related
`licensing or litigation activities.
`
`McAlexander Sound, Inc.
`
`CV - Joe McAlexander, 1Q2021
`
`3
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`CURRICULUM VITAE
`
` Joseph C. McAlexander III
`
`EXPERIENCE PROFILE (continued)
`
`2006-2020
`
`Guardian Technologies, LLC – Texas
`Manager
`
`o IP holding and licensing company;
`o Litigated U.S. Patent No. 5,657,076 related
`surveillance 2009-2011 (patent expired 2015);
`o Assigned U.S. Patent No. 8,334,775 related to RFID tracking
`(reassigned 2020 to personal);
`o Not engaged in any IP related licensing or litigation activities.
`
`to security
`
`2006-2020
`
`Appropriate Holdings, LLC – Delaware
`Manager
`
`o IP holding company;
`o Not assigned any patents, has not been and is not engaged in any
`IP related licensing or litigation activities.
`
`1996-2010
`
`RMC Management, LLP - Plano, TX
`Partner
`
`o Asset management.
`
`1991-2002
`
`Cochran Consulting, Inc. (CCI) - Richardson, TX
`Managing Consultant
`
`o System, Product, and Process investigation, expert witness
`services for protection of intellectual property;
`o Design, process, and product reliability;
`o Defect and failure analysis.
`
`1986-Nov'90
`
`EPI Technologies, Inc. - Richardson, TX
`Executive Vice President and Company Officer
`
`o Managed Advanced Technology Div., QA, and
`Engineering, including software program development;
`o Developed strategic, space/energy market growth plans;
`o Negotiated the acquisition of and managed a radiation company;
`o Designed and managed physical analysis, radiation effects, and
`environmental stress laboratories, including optical and e-beam
`measurement;
`o Achieved > 30% annual revenue growth and profitability for each
`laboratory the first 12 months;
`
`McAlexander Sound, Inc.
`
`CV - Joe McAlexander, 1Q2021
`
`4
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`CURRICULUM VITAE
`
`EXPERIENCE PROFILE (continued)
`
`
`
`
`
`
`
`
`
`
`
`
` Joseph C. McAlexander III
`
`o Product and Process investigation services for protection of
`intellectual property.
`
`Texas Instruments, Inc. - Dallas/Houston, TX; Singapore
`
`Quality/Reliability Assurance Manager, TI Dallas Advanced DRAM
`semiconductor wafer fabrication facility
`
`o Developed/implemented on-line, computerized SPC software
`tools for dimensioning analysis and control and pattern recognition;
`o Coordinated people development, design-of-experiments;
`o Managed chemical and physical analysis laboratories;
`o Implemented control systems to assure product, process,
`material, equipment, and facility compliance, including Cost of
`Quality analysis.
`
`1972 – 1986
`
`
`'84 - '86
`
`
`
`
`
`
`
`
`
`
`
`
`
`'82 - '84
`
`Quality/Reliability Assurance and Engineering Manager, TI Singapore
`assembly/test facility
`
`'81 - '82
`
`effective
`an
`operated
`and
`implemented,
`o Developed,
`Quality/Reliability Assurance program for assembly processing
`including optical pattern recognition for equipment registration;
`o Supervised 225 people for 7 day/week operation, including QRA,
`Computer Systems software development, and Training;
`o Trained engineers in Solid State Physics, device fabrication, and
`statistical process control.
`Engineering Operations Manager, TI Houston
`
`o Managed DRAM memory product cost center;
`o Responsible for division test software generation, product
`assembly and test quality / yield, cost reduction and quality
`improvement;
`o Provided technical customer interface for marketing;
`o Coordinated TI Singapore engineering test/assembly.
`
`'79 - '81
`
`Product Engineering Manager, TI Houston
`
`o Responsible for yield improvement, technical customer interface,
`quality improvement, design evaluation, and device characterization
`for DRAM and CCD products;
`o Developed device specifications and test software.
`
`CV - Joe McAlexander, 1Q2021
`
`5
`
`
`
`
`McAlexander Sound, Inc.
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`CURRICULUM VITAE
`
`EXPERIENCE PROFILE (continued)
`
`
`
`
`
`
`
`
`
`
`
`
` Joseph C. McAlexander III
`
`'72 - '79
`
`Design Section Manager / Engineer, TI Houston
`
`
`
`
`1969 - 1972
`
`
`
`
`
`o Responsible for design and development, process compatibility,
`production introduction of Dynamic Ram products;
`o Activities included electrical and physical layout, SPICE model
`simulation, test program generation, and product implementation for
`MOS Dynamic Ram products.
`
`U. S. Army - Coventry, Rhode Island; Seoul, Korea
`Captain, Air Defense Artillery
`
`o Served one year as Communications Officer in Korea;
`o Served two years as Tactical Officer, New England
`Defense.
`
`
`
`
`McAlexander Sound, Inc.
`
`CV - Joe McAlexander, 1Q2021
`
`6
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`CURRICULUM VITAE
`
` Joseph C. McAlexander III
`
`ORGANIZATIONS, PUBLICATIONS, EDUCATION
`
`PROFESSIONAL ORGANIZATIONS AND AWARDS
`
`1 - Institute of Electrical and Electronics Engineers, Inc. (IEEE), Senior Member. Societies:
`Computer, Electron Devices, Solid State Circuits
`2 - Licensing Executives Society (LES)
`3 - National Society of Professional Engineers
`4 - Texas Board of Professional Engineers, Registered License #79454
`5 - Society of Flight Test Engineers
`6 - American Society of Civil Engineers
`7 - 2000/2001 Nationwide Register’s Who’s Who in Executives and Businesses
`8 - 1996/1997 Strathmore's Who's Who Registry of Business Leaders
`
`PUBLICATIONS
`
`1- NUS Proceedings of Engineering Convention '83, Aug '83, pgs. 139-142, The Memory
`Challenge.
`
`2- Archives of Biochemistry and Biophysics, Dec'81, Vol. 212, No. 2, Equilibrium Constants
`under Physiological Conditions for the Reactions of D-3-Phosphoglycerate Dehydrogenase
`and L-Phosphoserine Aminotransferase.
`
`3- International Electron Devices Meeting, Dec '79, pgs. 355-357, Sub 100ns 16K x 1 MOS
`Dynamic RAM Using a Grounded Substrate.
`
`EDUCATION PROFILE
`
`1980 - 1985
`
`Taught Solid State Device Physics, Semiconductor Processing, Circuit
`Design Techniques, and Statistical Quality Control Methods
`
`Effectiveness Training and Japanese Manufacturing Techniques,
`Participative Problem Solving courses
`
`1975 - 1976
`
`1.5 years Graduate Study in Neural Science, the University of Texas
`Graduate School of Biomedical Science
`
`1965 - 1969
`
`BSEE, North Carolina State University
`
`McAlexander Sound, Inc.
`
`CV - Joe McAlexander, 1Q2021
`
`7
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`CURRICULUM VITAE
`
`
`
`
`
`
`4,239,993
`
`
`4,280,070
`
`
`4,288,706
`
`
`4,370,575
`
`
`4,418,293
`
`
`4,533,843
`
`
`4,543,500
`
`
`4,543,501
`
`
`4,748,349
`
`6,172,640 B1
`
`6,236,358 B1
`
`6,421,001 B1
`
`6,441,778 B1
`
`6,480,147 B2
`
`6,518,919 B1
`
`6,771,213 B2
`
`6,859,171 B2
`
` Joseph C. McAlexander III
`
`PATENTS (US-31, Foreign-8)
`
`(1980) High Performance Dynamic Sense Amplifier with
`Active Loads
`
`(1981) Balanced Input Buffer Circuit for Semiconductor
`Memory
`
`(1981) Noise Immunity in Input Buffer Circuit for
`Semiconductor Memory
`
`(1983) High Performance Dynamic Sense Amplifier with
`Active Loads
`
`(1983) High Performance Dynamic Sense Amplifier with
`Multiple Column Outputs
`
`(1985) High Performance Dynamic Sense Amplifier with
`Voltage Boost for Row Address Lines
`
`(1985) High Performance Dynamic Sense Amplifier
`Voltage Boost for Row Address Lines
`
`(1985) High Performance Dynamic Sense Amplifier with
`Dual Channel Grounding Transistor
`
`(1988) High Performance Dynamic Sense Amplifier with
`Voltage Boost for Row Address Lines
`
`(2001) Pet Locator
`
`(2001) Mobile Object Locator
`
`(2002) Object Locator
`
`(2002) Pet Locator
`
`(2002) Portable Position Determining Device
`
`(2003) Mobile Object Locator
`
`(2004) Object Locator
`
`(2005) Mobile Object Locator
`
`
`McAlexander Sound, Inc.
`
`CV - Joe McAlexander, 1Q2021
`
`8
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`CURRICULUM VITAE
`
`PATENTS (continued)
`
`
`7,113,126 B2
`
`7,179,674 B2
`
`7,209,075 B2
`
`7,324,044 B2
`
`7,336,227 B2
`
`7,340,260 B2
`
`
`7,353,706 B2
`
`7,397,097 B2
`
`
`7,564,405 B2
`
`7,657,265 B2
`
`
`7,760,137 B2
`
`7,764,228 B2
`
`7,989,906 B2
`
`8,334,775 B2
`
`
`JP 55-053640 B4
`
`JP 59-044720 B4
`
`DE2935121 C2
`
`
`DE3043651 A1
`
`
`
`
`
`
`
`
`
`
`
`
`
` Joseph C. McAlexander III
`
`(2006) Portable Positioning Determining Device
`
`(2007) Bi-Directional Released-Beam Sensor
`
`(2007) Mobile Object Locator
`
`(2008) Object Locator
`
`(2008) Portable Position Determining Device
`
`(2008) System and Method for Tracking the Location of Multiple
`Mobile Radio Transceiver Units (assigned to MDFHoldings, Inc.)
`
`(2008) Weighted Released-Beam Sensor
`
`(2008) Integrated Released Beam Layer Structure Fabricated in
`Trenches and Manufacturing Method Thereof
`
`(2009) Object Locator
`
`(2010) System and Method for Tracking the Location of Multiple
`Mobile Radio Transceiver Units (assigned to MDFHoldings, Inc.)
`
`(2010) Portable Positioning Determining Device
`
`(2010) Portable Positioning Determining Device
`
`(2011) Bi-Directional released-Beam Sensor
`
`(2012) RFID-Based Asset Security and Tracking System, Apparatus
`and Method (assigned to personal)
`
`(1980) Defect Resistant Semiconductor Memory Cell
`
`(1984) Semiconductor High Speed Read/Write Memory Unit
`
`(1980) Clock Voltage Generator for Semiconductor Memory with
`Reduced Power Dissipation
`
`
`
`(1981) Clock Voltage Generator for Semiconductor Memory with
`Reduced Power Dissipation
`
`
`McAlexander Sound, Inc.
`
`CV - Joe McAlexander, 1Q2021
`
`9
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`CURRICULUM VITAE
`
`PATENTS (continued)
`
`
`GB2032211 B2
`
`EP 1 557 058 B1
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` Joseph C. McAlexander III
`
`(1980) High Performance Dynamic MOS Read/Write Memory
`
`(2011) System and method for tracking the location of multiple
`mobile radio transceiver units (assigned to MDFHoldings, Inc.)
`[States: AT BE BG CH CY CZ DE DK EE ES FI FR GB GR HU
`IE IT LI LU MC NL PT RO SE SI SK TR]
`
`EP 1 676 809 B1
`
`
`
`
`EP 1 676 810 B1
`
`
`
`
`(2010) Weighted released-beam sensor
`[States: DE FR GB IT]
`
`(2010) Bi-directional released-beam sensor
`[States: DE FR GB IT]
`
`
`McAlexander Sound, Inc.
`
`CV - Joe McAlexander, 1Q2021
`
`10
`
`ONE-E-WAY 2001
`Apple v. One-E-Way
`IPR2021-00283
`
`

`

`CURRICULUM VITAE
`
` Joseph C. McAlexander III
`
`CASES
`
`Cases over at least the past 7 years, either active or closed, in which I have signed a Protective
`Order, have testified as an expert either at a trial, hearing, or deposition, or have submitted
`statements / opinions by declaration, affidavit, or report, are:
`
`CASE1
`
`AMS* v. Crane & Seaga
`(*firm: Davidson Berquist
`
`LOCATION
`
`CASE NUMBER
`3:03-CV88-JPB,
`3:08-CV-97-JPB
`and 3:04-CV-
`80,75,48
`(Patents related to vending machines)
`
`ND WVA
`
`YEAR TYPE2
`
`2008-
`2012
`
`P, t, TH
`
`ITT* v. Celco et al.
`DE
`09-190-JJF
`(*firm: Davidson Berquist)
`(Patent related to GPS position determination)
`
`2009 -
`2012
`
`P
`
`TAOS* v. Intersi