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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.,
`Petitioner,
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`v.
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`OMNI MEDSCI, INC.,
`Patent Owner.
`
`Patent No. 10,517,484
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`IPR2021-00453
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`DECLARATION OF BRIAN ANTHONY, PH. D. REGARDING
`U.S. PATENT NO. 10,517,484
`
`
`
`
`Petitioner Apple Inc.
`Ex. 1003, p. i
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`

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`IPR2021-00453
`
`Declaration of Dr. Anthony
`
`TABLE OF CONTENTS
`
`I.
`
`INTRODUCTION ......................................................................................... 1
`A.
`Engagement ........................................................................................... 1
`B.
`Background and Qualifications ............................................................. 1
`C.
`Compensation ........................................................................................ 5
`D.
`Information Considered ......................................................................... 6
`LEGAL STANDARDS FOR PATENTABILITY ...................................... 6
`II.
`A. Anticipation ........................................................................................... 8
`B.
`Obviousness ........................................................................................... 9
`III. BACKGROUND INFORMATION ABOUT THE ’484 PATENT......... 11
`A.
`The Prosecution History of the ’484 Patent ........................................ 11
`B.
`IPR2019-00916 Involving U.S. Patent No. 9,651,533........................ 13
`C.
`Technical Field .................................................................................... 13
`D.
`Level of Ordinary Skill in the Art ....................................................... 13
`IV. TECHNICAL BACKGROUND ................................................................. 14
`A.
`Photoplethysmography ........................................................................ 14
`B.
`Industry Trends .................................................................................... 22
`V. ANALYSIS OF THE ’484 PATENT ......................................................... 29
`A. Overview of the ’484 Patent ................................................................ 29
`B.
`Construction of Terms Used in the ’484 Patent Claims...................... 30
`VI.
`IDENTIFICATION OF THE PRIOR ART.............................................. 33
`VII. ANALYSIS OF THE PRIOR ART AND ’484 CLAIMS ........................ 34
`A.
`Lisogurski and Carlson Render Obvious Claims 1, 7, 15, and 17 ...... 34
`1. Overview of Lisogurski ................................................................34
`2. Overview of Carlson .....................................................................37
`3. A Person of Ordinary Skill in the Art Would Have Modified
`Lisogurski to Incorporate Elements Shown in Carlson ................38
`
`Petitioner Apple Inc.
`Ex.1003, p. ii
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`IPR2021-00453
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`Declaration of Dr. Anthony
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`semiconductor sources that are light emitting diodes, each of
`the light emitting diodes configured to generate an output
`
`configured to receive a portion of at least one of the output
`
`configured to receive at least a portion of the lens output light
`reflected from the tissue and to generate an output signal
`
`spatially separated detectors, and wherein at least one analog
`to digital converter is coupled to at least one of the spatially
`
`plurality of spatially separated detectors is coupled to an
`amplifier having a gain configured to improve detection
`
`4. Lisogurski and Carlson Describe the Elements of
`Independent Claims 1, 7, and 15 of the ’484 Patent .....................41
`a) Preamble .................................................................................43
`b) “a wearable device adapted to be placed on a wrist or an ear
`of a user” ................................................................................46
`c) “including a light source comprising a plurality of
`optical light having one or more optical wavelengths”..........46
`d) “the wearable device comprising one or more lenses
`optical lights and to direct a lens output light to tissue” ........48
`e) “the wearable device further comprising a detection system
`having a signal-to-noise ratio” ...............................................53
`f) “wherein the detection system is configured to be
`synchronized to the light source” ...........................................55
`g) “wherein the detection system comprises a plurality of
`separated detectors” ................................................................59
`h) “wherein a detector output from the at least one of the
`sensitivity” ..............................................................................61
`i) “a smart phone or tablet comprising a wireless receiver, a
`at least a portion of the output signal” ...................................63
`j) “a cloud configured to receive over the wireless transmission
`to generate processed data and to store the processed data” ..66
`
`wireless transmitter, a display, a microphone, a speaker, one
`or more buttons or knobs, a microprocessor and a touch
`screen, the personal device configured to receive and process
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`link an output status comprising the at least a portion of the
`processed output signal, to process the received output status
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`Petitioner Apple Inc.
`Ex.1003, p. iii
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`IPR2021-00453
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`Declaration of Dr. Anthony
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`signal responsive to light received while the light emitting
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`responsive to light received while at least one of the light
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`noise ratio by differencing the first signal and the second
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`physiological parameters, and the cloud is configured to store a history
`of at least a portion of the one or more physiological parameters over a
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`(i) “wherein the output signal is indicative of one or more of the
`specified period of time” ..........................................................................68
`k) “the wearable device configured to increase the signal-to-
`noise ratio” .............................................................................72
`(i) “by increasing light intensity of at least one of the [plurality
`of] semiconductor sources from an initial light intensity” ......................76
`(ii) “by increasing a pulse rate of at least one of the plurality of
`semiconductor sources from an initial pulse rate” ...................................80
`l) “the detection system further configured to generate a first
`diodes [or semiconductor sources] are off” ...........................90
`m) “[the detection system configured] to generate a second signal
`emitting diodes [or semiconductor sources] is on” ................94
`n) “[the detection system configured to] increase the signal-to-
`signal” .....................................................................................96
`5. Claim 17 ........................................................................................98
`12, and 15-22 ....................................................................................... 98
`1. Overview of Tran ..........................................................................99
`2. A Person of Ordinary Skill in the Art Would Have Modified
`Elements Shown in Tran ...............................................................99
`3. Claims 1, 7, 15, and 17 ................................................................102
`4. Claims 2, 10, and 18 ....................................................................103
`5. Claims 3, 8, and 16 ......................................................................105
`6. Claims 9.......................................................................................106
`7. Claims 11 and 19 .........................................................................107
`8. Claims 4, 12, 21 and 22 ...............................................................108
`9. Claims 20.....................................................................................108
`
`B.
`
`Lisogurski, Carlson, and Tran Render Obvious Claims 1-4, 7-
`
`the combination of Lisogurski and Carlson to Incorporate
`
`Petitioner Apple Inc.
`Ex.1003, p. iv
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`IPR2021-00453
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`Declaration of Dr. Anthony
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`C.
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`D.
`
`Lisogurski, Carlson, Tran, and Isaacson Render Obvious
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`Modified the combined system of Lisogurski, Carlson, and
`
`Claims 5 and 13 ................................................................................. 109
`1. Overview of Isaacson ..................................................................109
`2. A Person of Ordinary Skill In the Art Would Have
`Tran to Incorporate Elements Shown in Isaacson.......................113
`3. Claims 5 and 13 ...........................................................................117
`Obvious Claims 6, 14, and 23 ........................................................... 121
`1. Overview of Valencell-093 .........................................................122
`2. A Person of Ordinary Skill In the Art Would Have
`Shown in Valencell .....................................................................122
`3. Claims 6, 14, and 23 ....................................................................126
`
`Lisogurski, Carlson, Tran, Isaacson, and Valencell Render
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`Modified Lisogurski and Carlson to Incorporate Elements
`
`Petitioner Apple Inc.
`Ex.1003, p. v
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`

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`IPR2021-00453
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`Declaration of Dr. Anthony
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`I.
`
`INTRODUCTION
`A. Engagement
`I have been retained by counsel for Apple Inc. as an expert witness in
`1.
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`the above-captioned proceeding. I have been asked to provide an opinion
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`regarding the patentability of certain claims in U.S. Patent No. 10,517,484
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`(“the ’484 patent”) (Ex.1001). The face of the patent identifies Omni MedSci, Inc.
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`(“Omni”) as the assignee. I have been asked to provide a discussion of the
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`meaning of certain words and phrases in the claims of the ’484 patent, to provide a
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`description of the state of the art of the technology described in the ’484 patent, to
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`analyze the disclosure of the ’484 patent and the applications to which it claims
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`priority, and to analyze various references that I understand are prior art to this
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`patent.
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`B.
`2.
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`Background and Qualifications
`As indicated in my curriculum vitae (“CV”), Ex.1053, I am currently
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`a Principal Research Scientist at the Massachusetts Institute of Technology
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`(“MIT”). My CV includes additional information about my professional history
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`and contains further details on my experience, publications, patents, and other
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`qualifications to render an expert opinion. Below, I highlight some of my
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`experience that is relevant to the technology of the patent at issue.
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`3.
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`I earned a Bachelor of Science in Engineering from Carnegie Mellon
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`University in 1994 and a Master’s degree in Engineering from MIT in 1998. My
`Petitioner Apple Inc.
`Ex.1003, p. 1
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`IPR2021-00453
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`Declaration of Dr. Anthony
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`thesis topic related to anisotropic wave guides and acoustic non-destructive testing.
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`In 2006, I earned my Ph.D. in Engineering from MIT. My research focused on
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`high-performance computation, signal processing, and electro-mechanical system
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`design.
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`4.
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`In 1997, I co-founded Xcitex Inc., a company that specialized in
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`video-acquisition and motion-analysis software. I served as the Chief Technology
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`Officer and directed and managed product development until 2006. Our first demo
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`product was an optical ring for human motion measurement used to capture user
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`hand motion in order to control the user’s interaction with a computer. Many of
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`the structural elements of our optical ring addressed the same system issues as
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`those described and claimed in the patent at issue. For example, our optical ring
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`included multiple light emitting diodes, multiple photodetectors, techniques for
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`modulation and synchronization, noise reduction algorithms, and optical
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`components for light blocking, light redirection, and light capture, and structural
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`components for holding and geometrically arranging the various components. We
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`estimated human hand-motion based on how that motion changed the detected
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`light. In our application we did not try to eliminate motion artifact, we tried to
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`measure it. In developing our ring, we considered well-known problems such as
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`ambient light and noise, which are, unsurprisingly, also mentioned in the patent at
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`issue. Motion Integrated Data Acquisition System (MiDAS) was our flagship
`
`Petitioner Apple Inc.
`Ex.1003, p. 2
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`IPR2021-00453
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`Declaration of Dr. Anthony
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`video and data acquisition product which relied upon precise synchronization of
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`multiple clocks for optical sensor and video acquisition, data acquisition, and
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`external illumination.
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`5.
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`I joined MIT in 2006 and was the Director of the Master of
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`Engineering in Advance Manufacturing and Design Program for over ten years.
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`The degree program covers four main components: Manufacturing Physics,
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`Manufacturing Systems, Product Design, and Business Fundamentals. Many of
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`the courses, projects, and papers my students undertake involve technologies
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`relevant to the patent at issue, for example, sensor devices including non-invasive
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`optical biosensors.
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`6.
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`In 2011, I co-founded MIT’s Medical Electronic Device Realization
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`Center (“MEDRC”) and currently serve as co-director. The MEDRC aims to
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`create and deploy revolutionary medical technologies by collaborating with
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`clinicians, the microelectronics, and medical devices industries. We combine
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`expertise in computation; communications; optical, electrical, and ultrasound
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`sensing technologies; and consumer electronics. We focus on the usability and
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`productivity of medical devices using, for example, image and signal processing
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`combined with intelligent computer systems to enhance practitioners’ diagnostic
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`intuition. Our research portfolio includes low power integrated circuits and
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`systems, big data, micro electro-mechanical systems, bioelectronics, sensors, and
`
`Petitioner Apple Inc.
`Ex.1003, p. 3
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`IPR2021-00453
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`Declaration of Dr. Anthony
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`microfluidics. Specific areas of innovation include wearable, non-invasive and
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`minimally invasive optical biosensor devices, medical imaging, laboratory
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`instrumentation, and the data communication from these devices and instruments
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`to healthcare providers and caregivers. My experience with these devices is
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`directly applicable to the technology in the patent at issue. For example, in one
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`current project related to this work, we use a patient-mounted mobile near infrared
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`(NIR) camera to image and characterize the surface and subsurface structures of
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`the skin.
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`7.
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`I am the Associate Director of MIT.nano, MIT's new 200,000 sq-ft
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`nanofabrication and characterization facility. One of the major research initiatives
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`with MIT.nano focuses on sensors and sensing systems. Our research in sensing
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`science and sensing engineering is targeting innovations in advanced
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`manufacturing, healthcare, environmental remediation, smart infrastructure, and
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`the creation of advanced machines and materials. I also co-founded the Center for
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`Polymer Micro-fabrication at MIT. The Center’s research focuses on polymer-
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`based manufacturing processes and the large-scale commercialization of micro
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`fluidic devices for chemical, biomedical, and photonic applications. My
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`experience under these initiatives is directly applicable to the technology in the
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`patent at issue. We develop optical sensors to noninvasively monitor soft flexible
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`materials during the manufacturing process.
`
`Petitioner Apple Inc.
`Ex.1003, p. 4
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`IPR2021-00453
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`Declaration of Dr. Anthony
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`8.
`
`Furthermore, my research focuses on computational instrumentation,
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`including the development of instrumentation and measurement solutions for
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`manufacturing systems and medical devices. Additionally, my teaching interests
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`include the design and modeling of large-scale systems in a wide variety of
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`decision-making domains and developing optimization algorithms and software for
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`analyzing and designing such systems. I teach or have taught courses in Electrical
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`Engineering, Controls, Optics, and Signal Processing, all pertinent subject matter
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`to the patent at issue.
`
`9.
`
`I have published approximately 85 papers, and have received a
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`number of best paper and distinguished paper awards. I am a co-author of a
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`number of papers that relate to the technology in the patent at issue.
`
`C. Compensation
`I am being compensated for my time at the rate of $500 per hour for
`10.
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`my work in connection with this matter. I am being reimbursed for reasonable and
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`customary expenses associated with my work in this investigation. This
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`compensation is not dependent in any way on the contents of this Declaration, the
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`substance of any further opinions or testimony that I may provide or the ultimate
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`outcome of this matter.
`
`Petitioner Apple Inc.
`Ex.1003, p. 5
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`IPR2021-00453
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`Declaration of Dr. Anthony
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`Information Considered
`D.
`11. My opinions are based on my years of education, research, and
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`experience, as well as my investigation and study of relevant materials. In forming
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`my opinions, I have considered the materials I identify in the attached Exhibit List.
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`12.
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`I may rely upon these materials and/or additional materials to respond
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`to arguments raised by Omni. I may also consider additional documents and
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`information in forming any necessary opinions—including documents that may not
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`yet have been identified by me or provided to me.
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`13. My analysis of the materials produced in this investigation is ongoing,
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`and I will continue to review any new material as it is provided. This report
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`represents only those opinions I have formed to date. I reserve the right to revise,
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`supplement, and/or amend my opinions stated herein based on new information
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`and on my continuing analysis of the materials already provided.
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`II. LEGAL STANDARDS FOR PATENTABILITY
`14. Certain basic legal principles have been explained to me by counsel
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`for Apple. Below, I have recorded these legal standards as they were explained to
`
`me.
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`15.
`
`I understand that for an invention claimed in a patent to be found
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`patentable, it must be, among other things, new and not obvious from what was
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`known before the invention was made.
`
`Petitioner Apple Inc.
`Ex.1003, p. 6
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`IPR2021-00453
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`Declaration of Dr. Anthony
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`16.
`
`I understand the information that is used to evaluate whether an
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`invention is new and not obvious is generally referred to as “prior art” and can
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`include patents and printed publications. I also understand that a patent will be
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`prior art if it was filed before the earliest effective filing date of the claimed
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`invention, while a printed publication will be prior art if it was publicly available
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`before that date. I understand that in this proceeding, the information that may be
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`evaluated to show unpatentability is limited to patents and printed publications.
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`17.
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`I understand that the effective filing date of the claimed invention is
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`the actual filing date of the claims, unless the applicant claims priority to an earlier
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`filed application that supports the claimed subject matter in the manner required by
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`35 U.S.C. § 112. I understand that this section requires the patent’s specification
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`to contain a sufficient written description of the claimed invention to demonstrate
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`that the applicant actually possessed the invention as of the filing date as broadly
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`as it is claimed. In considering whether this written description requirement is met,
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`I understand that I should consider the written description from the viewpoint of a
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`person of ordinary skill in the art. I also understand that I should consider whether
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`this person of ordinary skill would have recognized that the written description
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`describes the full scope of the claimed invention and that the inventor actually
`
`possessed that full scope as of the claimed effective filing date.
`
`Petitioner Apple Inc.
`Ex.1003, p. 7
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`IPR2021-00453
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`Declaration of Dr. Anthony
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`18.
`
`I understand that in this proceeding Apple has the burden of proving
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`that the challenged claims are unpatentable over the prior art by a preponderance of
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`the evidence. I understand that “a preponderance of the evidence” is evidence
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`sufficient to show that a fact is more likely true than it is not.
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`19.
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`I understand that there are two ways in which prior art may render a
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`patent claim unpatentable. First, the prior art can be shown to “anticipate” the
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`claim. Second, the prior art can be shown to have made the claim “obvious” to a
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`person of ordinary skill in the art.
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`A. Anticipation
`I understand that, for a patent claim to be “anticipated” by the prior
`20.
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`art, each and every requirement of the claim must be found, expressly or
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`inherently, in a single prior art reference as recited in the claim.
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`21.
`
`I understand that claim limitations that are not expressly described in
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`a prior art reference may still be there if they are “inherent” to the thing or process
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`being described in the prior art.
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`22.
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`I understand that it can be acceptable to consider evidence other than
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`the information in a particular prior art document to determine if a feature is
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`necessarily present in or inherently described by that document.
`
`Petitioner Apple Inc.
`Ex.1003, p. 8
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`23.
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`I understand that if a reference incorporates other documents by
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`reference, the incorporating reference and the incorporated reference(s) should be
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`treated as a single prior art reference for purposes of analyzing anticipation.
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`24.
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`I understand that to be anticipatory, a reference must not only
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`explicitly or inherently disclose every claimed feature, but those features must also
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`be “arranged as in the claim.” Differences between the prior art reference and a
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`claimed invention, however slight, invoke the question of obviousness, not
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`anticipation.
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`B. Obviousness
`I understand that a claimed invention is not patentable if it would have
`25.
`
`been obvious to a person of ordinary skill in the field of the invention at the time
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`the invention was made. I understand that in determining whether a patent claim is
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`obvious, one must consider the following four factors: (i) the scope and content of
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`the prior art, (ii) the differences between the prior art and the claims at issue, (iii)
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`the knowledge of a person of ordinary skill in the pertinent art; and (iv) objective
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`factors indicating obviousness or non-obviousness, if present (such as commercial
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`success or industry praise).
`
`26.
`
`I understand the objective factors indicating obviousness or non-
`
`obviousness may include: commercial success of products covered by the patent
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`claims; a long-felt need for the invention; failed attempts by others to make the
`
`Petitioner Apple Inc.
`Ex.1003, p. 9
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`IPR2021-00453
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`invention; copying of the invention by others in the field; unexpected results
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`achieved by the invention; praise of the invention by those in the field; the taking
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`of licenses under the patent by others; expressions of surprise by experts and those
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`skilled in the art at the making of the invention; and the patentee proceeded
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`contrary to the accepted wisdom of the prior art. I also understand that any of this
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`evidence must be specifically connected to the invention rather than being
`
`associated with the prior art or with marketing or other efforts to promote an
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`invention. I am not presently aware of any evidence of “objective factors”
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`suggesting the claimed methods are not obvious, and reserve my right to address
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`any such evidence if it is identified in the future.
`
`27.
`
`In addition, I understand that the obviousness inquiry should not be
`
`done in hindsight, but must be done using the perspective of a person of ordinary
`
`skill in the relevant art as of the effective filing date of the patent claim.
`
`28.
`
`I understand that the Supreme Court has rejected a rigid approach to
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`determining the question of obviousness, such as one that requires a challenger to
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`identify a “teaching, suggestion, or motivation to combine” known elements.
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`Instead, a challenger needs to articulate reasoning for combining known elements.
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`Such reasoning can be based on design considerations, market demands, looking to
`
`solutions to related problems in related fields, and on the “ordinary innovation”
`
`and creativity that would be applied by a person of ordinary skill in the art.
`
`Petitioner Apple Inc.
`Ex.1003, p. 10
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`IPR2021-00453
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`29.
`
`I understand that an invention that might be considered an obvious
`
`variation or modification of the prior art may be considered non-obvious if one or
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`more prior art references discourages or leads away from the line of inquiry
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`disclosed in the reference(s). A reference does not “teach away” from an invention
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`simply because the reference suggests that another embodiment of the invention is
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`better or preferred. My understanding of the doctrine of teaching away requires a
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`clear indication that the combination should not be attempted (e.g., because it
`
`would not work or explicit statements saying the combination should not be made).
`
`III. BACKGROUND INFORMATION ABOUT THE ’484 PATENT
`A. The Prosecution History of the ’484 Patent
`I have reviewed the file history of the ’484 patent (Exhibit 1002).
`30.
`
`Before the application was examined, the applicant submitted several Information
`
`disclosure statements (IDS) that included several hundred references. Ex.1002, 1-
`
`360. The examiner allowed the patent after a preliminary amendment that added
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`several limitations to independent claims 1, 7, and 15 along with dependent claims
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`4, 6, 11, 12, 14, 21, and 23. Id., 607-612. On August 19, 2019, the examiner
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`issued a notice of allowance stating that the prior art does not teach several
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`limitations. Id., 631, 634-635. Those limitations were:
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`the wearable device further comprising a detection system
`
`configured to receive at least a portion of the lens output light output
`reflected from the tissue and to generate an output signal having a
`
`Petitioner Apple Inc.
`Ex.1003, p. 11
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`

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`IPR2021-00453
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`Declaration of Dr. Anthony
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`signal-to-noise ratio, wherein the detection system is configured to be
`synchronized to the light source;
`
`a cloud configured to receive over the wireless transmission link an
`output status comprising the at least a portion of the processed output
`signal, to process the received output status to generate processed
`data, and to store the processed data;
`
`wherein the output signal is indicative of one or more of the
`
`physiological parameters, and the cloud is configured to store a
`history of at least a portion of the one or more physiological
`parameters over a specified period of time;
`
`the wearable device configured to increase the signal-to-noise
`
`ratio by increasing light intensity of at least one of the plurality of
`semiconductor sources from an initial light intensity and by increasing
`a pulse rate of at least one of the plurality of semiconductor sources
`from an initial pulse rate; and
`
`the detection system further configured to:
`
`generate a first signal responsive to light received while the light
`emitting diodes are off, generate a second signal responsive to light
`received while at least one of the light emitting diodes is on, and
`increase the signal-to-noise ratio by comparing the first signal and the
`second signal.” Id.
`
`31. On August 23, 2019, the applicant amended claims 1, 7, and 15 as
`
`well as dependent claims 4, 6, 11, 12, 14, 21 and 23. Ex.1002, 1203-1209. On
`
`Petitioner Apple Inc.
`Ex.1003, p. 12
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`IPR2021-00453
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`Declaration of Dr. Anthony
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`October 8, the examiner entered this amendment without explanation. Id., 1214-
`
`1215.
`
`B.
`32.
`
`IPR2019-00916 Involving U.S. Patent No. 9,651,533
`I submitted a declaration in IPR2019-00916 concerning US Patent No.
`
`9,651,533 (the “’533 patent”). Both the ’533 claims and ’484 patents claims share
`
`many of the same limitations. In my previous declaration, and like this one, I
`
`relied on Lisogurski (Ex. 1011) and Carlson (Ex. 1009) to show that the ’533
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`claims were obvious. I understand the PTAB has issued a final written decision
`
`finding that the challenged ’533 claims are unpatentable.
`
`C. Technical Field
`33. The ’484 patent generally relates to optical sensors and devices that
`
`use optical sensors for measurement of physiological signals or biological
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`parameters.
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`D. Level of Ordinary Skill in the Art
`I have been instructed that the claims of a patent are to be reviewed
`34.
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`from the point of view of a hypothetical person of ordinary skill in the art at the
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`time of the filing of the patent.
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`35. Based on my knowledge and experience, it is my opinion that a
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`person of ordinary skill in the art (“skilled person”) at the relevant time frame
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`would have been a person with a good working knowledge of optical sensing
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`techniques and their applications, and some familiarity with optical system design
`Petitioner Apple Inc.
`Ex.1003, p. 13
`
`

`

`IPR2021-00453
`
`Declaration of Dr. Anthony
`
`and signal processing techniques. That knowledge would have been gained via an
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`undergraduate education in engineering (electrical, mechanical, biomedical or
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`optical) or a related field of study, along with relevant experience in studying or
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`developing physiological monitoring devices (e.g., non-invasive optical
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`biosensors) in industry or academia. This description is approximate; varying
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`combinations of education and practical experience also would be sufficient.
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`36.
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` Well before December 2012, my level of skill in the art was at least
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`that of a person of ordinary skill in the art in the field of the ’484 patent, as
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`discussed above. I am qualified to provide opinions concerning what a person of
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`ordinary skill in the art would have known and understood at that time. In
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`preparing this declaration, I have considered the issues from the perspective of a
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`hypothetical person of ordinary skill in the art at the relevant timeframe.
`
`IV. TECHNICAL BACKGROUND
`Photoplethysmography
`A.
`37. The use of optical sensors to detect physiological parameters,
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`including photoplethysmography, has been known for decades. Optical techniques
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`are commonly used in medical monitoring systems such as pulse oximetry systems
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`that measure a person’s pulse rate and blood oxygen saturation. Ex.1019 (BE
`
`Handbook) at 769-76, 1346-55 (discussing oximetry and other applications).
`
`Petitioner Apple Inc.
`Ex.1003, p. 14
`
`

`

`IPR2021-00453
`
`Declaration of Dr. Anthony
`
`38. Photoplethysmography works by directing light into a person’s tissue
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`and measuring the light that is reflected back from or transmitted through the
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`tissue. Ex.1019 (BE Handbook) at 764. Different components of blood or tissue
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`absorb different wavelengths of light. By measuring how much light is absorbed
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`by the tissue and how the absorption changes over time, a device can calculate
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`parameters that are related to the properties of the tissue and blood.
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`39. For example, hemoglobin (the protein molecule in blood that carries
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`oxygen to cells) reflects more red light when it is more oxygenated than when it is
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`deoxygenated; it absorbs more red light when it is deoxygenated. Ex.1019 (BE
`
`Handbook) at 769. Hemoglobin reflects the same amount of infrared (IR) light
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`whether oxygenated or deoxygenated. Ex.1019 (BE Handbook) at 769. If a device
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`measures the absorbed red and IR light multiple times per second, the device can
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`determine several things: (i) the ratio of oxygenated to deoxygenated hemoglobin
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`(oxygen saturation), and (ii) how the volume of blood in the tissue changes,
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`allowing detection of a person’s pulse. Ex.1019 (BE Handbook) at 769, 771.
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`40. Photoplethysmography is an optical technique, and it uses basic
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`optical components or building blocks. The “basic building blocks” of optical
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`sensor systems include lenses, mirrors, reflective surfaces, filters, beam splitters,
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`light sources, fiber optics, light detectors, and other passive components and
`
`Petitioner Apple Inc.
`Ex.1003, p. 15
`
`

`

`IPR2021-00453
`
`Declaration of Dr. Anthony
`
`various active components to convert light signals to electrical signals. Ex.1019
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`(BE Handbook) at 765.
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`
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`Ex.1019 (BE Handbook) at 765. In portable devices, the light sources are typi