IPR2021-01004
`U.S. Patent No. 9,918,196
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`GOOGLE LLC,
`
`Petitioner,
`
`v.
`TRAXCELL TECHNOLOGIES, LLC,
`
`Patent Owner.
`
`U.S. Patent No. 9,918,196
`Filing Date: September 27, 2017
`Issue Date: March 13, 2018
`
`____________________
`
`Case No. IPR2021-01004
`
`DECLARATION OF WILLIAM MICHALSON, PH.D.
`
`

`

`IPR2021-01004
`U.S. Patent 9,918,196
`
`TABLE OF CONTENTS
`
`I.
`INTRODUCTION .........................................................................................11
`QUALIFICATIONS ......................................................................................12
`II.
`III. MATERIALS CONSIDERED ......................................................................17
`IV.
`LEGAL PRINCIPLES ...................................................................................18
`V.
`THE ’196 PATENT .......................................................................................20
`VI.
`LEVEL OF ORDINARY SKILL IN THE ART ...........................................21
`VII. CLAIM CONSTRUCTION ..........................................................................23
`VIII. SUMMARY OF OPINIONS .........................................................................23
`IX. GROUND 1: CLAIMS 1, 4, 5, 7, 8, 10, 11, 15, 18-20, 22, 24 AND 25
`ARE UNPATENTABLE OVER HANCOCK IN VIEW OF KARP .............24
`A. U.S. Patent No. 6,202,023 (Hancock) .................................................24
`B. U.S. Patent No. 6,591,242 (Karp) .......................................................25
`C.
`Independent Claims .............................................................................26
`1.
`Claim 1 ......................................................................................26
`a.
`Element [1pre]- A method of providing navigation
`assistance to a user of a communications device,
`the method comprising: ..................................................26
`Element [1a] - receiving, by a directional
`assistance service, an Internet query initiated at the
`communications device and directed via the
`Internet to initiate a request for navigational
`assistance to a destination; ..............................................27
`Element [1b] - responsive to receiving the Internet
`query, determining whether or not the
`communications device is a mobile wireless
`communications device; .................................................31
`1
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`b.
`
`c.
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`IPR2021-01004
`U.S. Patent 9,918,196
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`d.
`
`e.
`
`f.
`
`Element [1c] - responsive to determining that the
`communications device is the mobile wireless
`communications device, the directional assistance
`service determining and using a present location of
`the mobile wireless communications device as a
`location of the communications device; .........................40
`Element [1d] - responsive to determining that the
`communications device is not the mobile wireless
`communications device, obtaining a fixed location
`associated with the communications device to
`determine the location of the communications
`device; and ......................................................................44
`Element [1e] - the directional assistance service
`providing navigation information to the
`communications device in response to the Internet
`query, wherein the navigation provides directions
`for proceeding from the location of the
`communications device to a location of the
`destination. ......................................................................47
`Claim 15 ....................................................................................48
`a.
`Element [15 pre] - A mobile wireless
`communications network, comprising: ..........................49
`Element [15a] - multiple radio-frequency
`transceivers and associated multiple antennas to
`which the associated radio-frequency transceivers
`are coupled, wherein the multiple radio-frequency
`transceivers are configured for radio-frequency
`communication with one or more mobile wireless
`communications devices; and .........................................49
`Element [15b] - a directional assistance network
`coupled to the multiple radio-frequency
`transceivers .....................................................................52
`Elements [15c]-[15g] ......................................................53
`
`d.
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`2.
`
`b.
`
`c.
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`2
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`IPR2021-01004
`U.S. Patent 9,918,196
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`D.
`
`2.
`
`3.
`
`Dependent Claims ...............................................................................55
`1.
`Claim 4 - The method of claim 1, wherein the obtaining
`the fixed location associated with the communications
`device comprises retrieving the fixed location from a
`database. ....................................................................................55
`Claim 5 - The method of claim 4, wherein the retrieving
`the fixed location from the database comprises querying
`a public service telephone network (PSTN). ............................56
`Claim 7 - The method of claim 1, further comprising
`receiving a user input of a destination address at the
`communications device, wherein the received Internet
`query includes the destination address, and wherein the
`directional assistance service determines the location of
`the destination from the destination address. ............................57
`Claim 8 - The method of claim 1, further comprising
`receiving a user input of a name of a business at the
`communications device, wherein the received Internet
`query includes the name of the business, and wherein the
`directional assistance service determines the location of
`the destination from the name of the business. .........................59
`Claim 10 - The method of claim 1, further comprising:
`the directional assistance service prompting the user of
`the communications device to provide an option for
`selection of suggested nearby businesses as the
`destination; responsive to the user selecting the option
`for selection of the suggested nearby businesses, the
`directional assistance service suggesting one or more
`nearby businesses; and responsive to a user input
`selecting a selected one of the suggested nearby
`businesses, sending the Internet query including an
`identifier of the selected one of the suggested nearby
`businesses. .................................................................................60
`Claim 11 - The method of claim 10, further comprising:
`the directional assistance service prompting the user of
`the communications device to provide an option for
`3
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`6.
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`4.
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`5.
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`

`

`X.
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`IPR2021-01004
`U.S. Patent 9,918,196
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`selection of a category of business for the suggested
`nearby businesses; responsive to the user selecting the
`option for selection of the category of business, sending a
`prompt for the user to specify the category of business;
`and responsive to the user specifying the category of
`business, the directional assistance service suggesting the
`one or more nearby businesses matching the category of
`business. ....................................................................................63
`Claims 18-19, 20, 22, and 24-25 ...............................................65
`7.
`GROUND 2: CLAIMS 2-3, 16-17, AND 29-30 ARE
`UNPATENTABLE OVER HANCOCK IN VIEW OF KARP AND
`RAYBURN ......................................................................................................68
`A. U.S. Patent No. 6,937,869 (Rayburn) .................................................68
`B.
`Dependent Claims ...............................................................................69
`1.
`Claim 2 - The method of claim 1, wherein the
`determining and using the present location of the mobile
`wireless communications device comprises querying an
`external user location database of a network of the
`mobile wireless communications device to determine the
`location of the communications device. ...................................69
`a.
`A POSA would have been motivated to combine
`Rayburn’s database with Hancock’s system. .................71
`Claim 3 - The method of claim 1, wherein the
`determining and using the present location of the mobile
`wireless communications device comprises: the
`directional assistance service initiating locating the
`mobile wireless communications device by sending a
`query to a switch or base station controller of a wireless
`network; and building an internal database storing the
`present location of the mobile wireless communications
`device with results of the query and using the stored
`location as the location of the communications device. ...........72
`Claims 16-17 .............................................................................76
`
`2.
`
`3.
`
`4
`
`

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`IPR2021-01004
`U.S. Patent 9,918,196
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`C.
`
`Independent Claims .............................................................................78
`1.
`Claim 29 ....................................................................................78
`2.
`Claim 30 ....................................................................................81
`XI. GROUND 3: CLAIMS 6, 9, 13, 21, 23, AND 27 ARE
`UNPATENTABLE OVER HANCOCK IN VIEW OF KARP AND
`TAKAKI ..........................................................................................................86
`A. U.S. Patent No. 6,029,069 (Takaki) ....................................................86
`B.
`Claim 6 - The method of claim 1, further comprising receiving
`a user input of a destination telephone number at the
`communications device, wherein the received Internet query
`includes the destination phone number, and wherein the
`directional assistance service determines the location of the
`destination from the destination phone number. .................................86
`1.
`A POSA would have been motivated to combine Takaki
`with Hancock and Karp to further Hancock’s goal of
`providing an easy-to-use location determination feature. .........87
`Claim 9 ................................................................................................88
`C.
`Claim 13 ..............................................................................................90
`D.
`Claims 21, 23, and 27 ..........................................................................92
`E.
`XII. GROUND 4: CLAIMS 12 AND 26 ARE UNPATENTABLE OVER
`HANCOCK IN VIEW OF KARP AND ENZMANN .....................................96
`A.
`U.S. Patent No. 7,130,630 (Enzmann) ................................................96
`B.
`Claim 12 - The method of claim 1, further comprising: the
`directional assistance service prompting the user of the
`communications device to provide an option for selection of
`tracking another communications device that is another mobile
`wireless communications device; and responsive to the user
`selecting the option for tracking the another mobile wireless
`communications device, the directional assistance service
`
`5
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`IPR2021-01004
`U.S. Patent 9,918,196
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`sending the Internet query with an identifier of the another
`mobile wireless communications device. ............................................96
`1.
`A POSA would have been motivated to use Enzmann’s
`third-party tracking in Hancock’s system to allow
`supervision of others. ..............................................................100
`Claim 26 ............................................................................................101
`C.
`XIII. GROUND 5: CLAIMS 14 AND 28 ARE UNPATENTABLE OVER
`HANCOCK IN VIEW OF KARP, TAKAKI, AND ENZMANN ..................102
`A.
`Claim 14 ............................................................................................102
`B.
`Claim 28 ............................................................................................103
`XIV. GROUND 6: CLAIMS 1, 4, 5, 7, 8, 10-12 15, 18-20, 22, AND 24-26 ARE
`UNPATENTABLE OVER BEHR IN VIEW OF KARP.............................104
`A.
`U.S. Patent No. 6,107,944 (Behr) .....................................................104
`B.
`Independent Claims ...........................................................................105
`1.
`Claim 1 ....................................................................................105
`a.
`Element [1pre] - A method of providing navigation
`assistance to a user of a communications device,
`the method comprising: ................................................105
`Element [1a] - receiving, by a directional
`assistance service, an Internet query initiated at the
`communications device and directed via the
`Internet to initiate a request for navigational
`assistance to a destination; ............................................106
`Element [1b] - responsive to receiving the Internet
`query, determining whether or not the
`communications device is a mobile wireless
`communications device; ...............................................109
`Element [1c] - responsive to determining that the
`communications device is the mobile wireless
`
`d.
`
`b.
`
`c.
`
`6
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`IPR2021-01004
`U.S. Patent 9,918,196
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`e.
`
`f.
`
`communications device, the directional assistance
`service determining and using a present location of
`the mobile wireless communications device as a
`location of the communications device; .......................116
`Element [1d] - responsive to determining that the
`communications device is not the mobile wireless
`communications device, obtaining a fixed location
`associated with the communications device to
`determine the location of the communications
`device; and ....................................................................118
`Element [1e] - the directional assistance service
`providing navigation information to the
`communications device in response to the Internet
`query, wherein the navigation provides directions
`for proceeding from the location of the
`communications device to a location of the
`destination. ....................................................................120
`Claim 15 ..................................................................................122
`a.
`Element [15 pre] - A mobile wireless
`communications network, comprising: ........................122
`Element [15a] - multiple radio-frequency
`transceivers and associated multiple antennas to
`which the associated radio-frequency transceivers
`are coupled, wherein the multiple radio-frequency
`transceivers are configured for radio-frequency
`communication with one or more mobile wireless
`communications devices; and .......................................123
`Element [15b] - a directional assistance network
`coupled to the multiple radio-frequency
`transceivers ...................................................................126
`Elements [15c]-[15g] ....................................................126
`d.
`Dependent Claims .............................................................................128
`
`2.
`
`b.
`
`c.
`
`C.
`
`7
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`1.
`
`2.
`
`3.
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`4.
`
`5.
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`6.
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`IPR2021-01004
`U.S. Patent 9,918,196
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`Claim 4 - The method of claim 1, wherein the obtaining
`the fixed location associated with the communications
`device comprises retrieving the fixed location from a
`database. ..................................................................................128
`Claim 5 - The method of claim 4, wherein the retrieving
`the fixed location from the database comprises querying
`a public service telephone network (PSTN). ..........................128
`Claim 7 - The method of claim 1, further comprising
`receiving a user input of a destination address at the
`communications device, wherein the received Internet
`query includes the destination address, and wherein the
`directional assistance service determines the location of
`the destination from the destination address. ..........................129
`Claim 8 - The method of claim 1, further comprising
`receiving a user input of a name of a business at the
`communications device, wherein the received Internet
`query includes the name of the business, and wherein the
`directional assistance service determines the location of
`the destination from the name of the business. .......................130
`Claim 10 - The method of claim 1, further comprising:
`the directional assistance service prompting the user of
`the communications device to provide an option for
`selection of suggested nearby businesses as the
`destination; responsive to the user selecting the option
`for selection of the suggested nearby businesses, the
`directional assistance service suggesting one or more
`nearby businesses; and responsive to a user input
`selecting a selected one of the suggested nearby
`businesses, sending the Internet query including an
`identifier of the selected one of the suggested nearby
`businesses. ...............................................................................131
`Claim 11 - The method of claim 10, further comprising:
`the directional assistance service prompting the user of
`the communications device to provide an option for
`selection of a category of business for the suggested
`
`8
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`IPR2021-01004
`U.S. Patent 9,918,196
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`7.
`
`nearby businesses; responsive to the user selecting the
`option for selection of the category of business, sending a
`prompt for the user to specify the category of business;
`and responsive to the user specifying the category of
`business, the directional assistance service suggesting the
`one or more nearby businesses matching the category of
`business. ..................................................................................132
`Claim 12 - The method of claim 1, further comprising:
`the directional assistance service prompting the user of
`the communications device to provide an option for
`selection of tracking another communications device that
`is another mobile wireless communications device; and
`responsive to the user selecting the option for tracking
`the another mobile wireless communications device, the
`directional assistance service sending the Internet query
`with an identifier of the another mobile wireless
`communications device. ..........................................................133
`Claims 18-20, 22, 24-26 ..........................................................134
`8.
`XV. GROUND 7: CLAIMS 2, 3, 6, 9, 13, 14, 16, 17, 21, 23, and 27-30
`ARE UNPATENTABLE OVER BEHR IN VIEW OF KARP AND
`RAYBURN ....................................................................................................139
`A.
`Dependent Claims .............................................................................139
`1.
`Claim 2 The method of claim 1, wherein the determining
`and using the present location of the mobile wireless
`communications device comprises querying an external
`user location database of a network of the mobile
`wireless communications device to determine the
`location of the communications device. .................................139
`a.
`A POSA would have been motivated to combine
`Rayburn’s database with Behr’s system. ......................140
`Claim 3 - The method of claim 1, wherein the
`determining and using the present location of the mobile
`wireless communications device comprises: the
`directional assistance service initiating locating the
`9
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`2.
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`

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`IPR2021-01004
`U.S. Patent 9,918,196
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`3.
`
`mobile wireless communications device by sending a
`query to a switch or base station controller of a wireless
`network; and building an internal database storing the
`present location of the mobile wireless communications
`device with results of the query and using the stored
`location as the location of the communications device. .........142
`Claim 6 - The method of claim 1, further comprising
`receiving a user input of a destination telephone number
`at the communications device, wherein the received
`Internet query includes the destination phone number,
`and wherein the directional assistance service determines
`the location of the destination from the destination phone
`number. ...................................................................................146
`a.
`A POSA would have been motivated to combine
`Rayburn’s telephone number query with Behr’s
`system to further Behr’s goal of providing a
`versatile location determination feature. ......................146
`Claim 9 ....................................................................................147
`4.
`Claim 13 ..................................................................................149
`5.
`Claim 14 ..................................................................................151
`6.
`Claims 16-17, 21, 23, and 27-28 .......................................................153
`Independent Claims ...........................................................................158
`1.
`Claim 29 ..................................................................................158
`2.
`Claim 30 ..................................................................................161
`XVI. CONCLUSION ............................................................................................165
`
`B.
`C.
`
`10
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`IPR2021-01004
`U.S. Patent 9,918,196
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`I.
`
`INTRODUCTION
`1.
`My name is William Michalson, Ph.D. I am currently a member of the
`
`faculty of the Robotics Engineering Department at the Worcester Polytechnic
`
`Institute in Massachusetts. I also have appointments as a Professor in the
`
`Departments of Electrical and Computer Engineering, Mechanical Engineering,
`
`and Computer Science. I have been retained as an independent expert by Google
`
`LLC. (“Google”) in this proceeding.
`
`2.
`
`I have been asked to provide my opinion as to whether claims 1-30 of
`
`United States Patent No. 9,918,196 are valid. This report sets forth my opinions
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`and the bases of my opinions.
`
`3.
`
`All of the opinions stated herein are based on my own personal
`
`knowledge and professional judgment and my analysis of the materials and
`
`information I considered in preparing this report. The materials I reviewed in
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`connection with preparing this report are listed below. I make the following
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`statements based on my own personal knowledge and, if called as a witness, I
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`could and would testify to the following. 4. I am being paid for my work in this
`
`litigation at the rate of $525.00 per hour, plus reimbursement of reasonable
`
`expenses. My compensation does not depend on the outcome of this proceeding,
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`and I have no financial interest in that outcome.
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`IPR2021-01004
`U.S. Patent 9,918,196
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`II. QUALIFICATIONS
`4. My qualifications for forming the opinions set forth in this report are
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`summarized here and are addressed more fully in my resume, which is attached
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`hereto as Exhibit 1004.
`
`5.
`
`I received my Ph.D. in Electrical Engineering from the Worcester
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`Polytechnic Institute in 1989, my Master of Science in Electrical Engineering from
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`the Worcester Polytechnic Institute in 1985, and my Bachelor of Science in
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`Electrical Engineering from Syracuse University in 1981.
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`6.
`
`I was employed as an engineer at Raytheon Company from 1981 until
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`1991. During this period, I worked on a variety of projects that involved both
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`hardware and software design and debugging. These projects involved developing
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`computer systems and software for a variety of applications, including the
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`following: air traffic display systems, signal and data processing systems, and
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`communications systems. During this time period, I was involved in hardware and
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`software development that included experience working with satellite, airborne,
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`and ground-based systems for navigation and communications. From 1985 until
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`1988, I received a fellowship from Raytheon to pursue my Ph.D. degree, and I
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`worked part-time during this period. I returned to Raytheon full-time from 1988
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`until 1991.
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`
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`IPR2021-01004
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`7.
`
`I have been a full-time faculty member at the Worcester Polytechnic
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`Institute in Massachusetts since 1991 and I currently hold the rank of Professor in
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`the Department of Robotics Engineering. My emphasis at the Worcester
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`Polytechnic Institute is on teaching and conducting research on navigation,
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`communications, and computer system design.
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`8.
`
`I hold nine patents in the fields of audio signal processing, indoor
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`geolocation devices, and handheld GPS (Global Positioning System) mapping
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`devices. I have authored or co-authored over 100 original articles in the fields of
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`communications networks, precision location systems and GPS, including more
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`than 15 journal papers and 90 conference papers. I have also authored a book
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`chapter relating to optical interconnect networks for massively parallel computers.
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`9.
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`First licensed as a radio amateur in 1974, I have been involved with
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`the design, analysis, implementation and repair of radio communication devices
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`since that time. In approximately 1976 I obtained my commercial radiotelephone
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`license which allowed me to repair two-way radio equipment, such as public
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`safety, marine and aviation radios, as well as act as the engineer-in-charge of
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`commercial broadcast transmitters. In approximately 1979 I obtained a commercial
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`radiotelegraph license. In addition, I have been involved with the design, analysis,
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`implementation and repair of digital systems since 1979, starting as a computer
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`hobbyist and, prior to graduation, working in a psychology laboratory at Syracuse
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`IPR2021-01004
`U.S. Patent 9,918,196
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`University where I was responsible for interfacing human and animal sensors to a
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`CP/M-based microcomputer for recording data and controlling experiments.
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`10.
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`I began my professional career as an engineer in the field of computer
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`architecture and computer systems since I began employment at Raytheon in 1981.
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`In this capacity I worked on hardware and software design for computer systems
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`and digital signal processing system for applications such as air traffic control,
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`missile guidance and spaceborne data processing. At the Worcester Polytechnic
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`Institute I have taught classes relating to computer architecture and design, and
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`classes relating to embedded system designs, advanced system architectures, and
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`real-time system designs, which relate to the design of computer systems,
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`including real-time operating systems and programming. I currently teach classes
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`relating to Electrical Engineering Design and Robot Navigation. I have worked
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`extensively in software programming, including during my employment at
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`Raytheon and in a variety of projects relating to navigation and communications
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`systems at the Worcester Polytechnic Institute.
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`11. GPS and GPS-related technologies have dominated the bulk of my
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`research since 1992. I have been involved in numerous academic, consulting, and
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`litigation projects involving navigation, communications and computer
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`technologies. Examples of my academic projects include a container tracking
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`system in 2003 that explored the application of tracking and communications
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`IPR2021-01004
`U.S. Patent 9,918,196
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`technologies to track shipping containers, an automotive-based system in 2000 that
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`combined GPS and map data in an automotive environment, a remote hazard
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`detection system in 1996 that combined GPS and radio communications to
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`remotely identify hazards to the radio technologies to determine the precise path of
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`vehicles operating off-road during forest operations. As a consultant, I have
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`worked with the combination of GPS and radio communications in the context of
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`space shuttle docking operations, transfer of traffic information to GPS devices in a
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`vehicle, combinations of GPS and cellular communications for the tracking of
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`individuals, and map-based handheld tracking devices. engineer operating a freight
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`train, and a differential GPS system in 1995 that combined GPS and radio
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`technologies to determine the precise path of vehicles operating off-road during
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`forest operations. As a consultant, I have worked with the combination of GPS and
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`radio communications in the context of space shuttle docking operations, transfer
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`of traffic information to GPS devices in a vehicle, combinations of GPS and
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`cellular communications for the tracking of individuals, and map-based handheld
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`tracking devices.
`
`12. My resume identifies the cases in which I have testified as an expert
`
`by deposition or at trial during the last four years.
`
`13.
`
`In writing this report, I have considered my own knowledge and
`
`experience, including my work experience in the fields of electrical engineering,
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`IPR2021-01004
`U.S. Patent 9,918,196
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`computer engineering, navigation and communications; my experience in teaching
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`those subjects; and my experience in working with others involved in those fields.
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`I have also considered the materials identified below.
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`14. Although for the sake of brevity this report refers to selected portions
`
`of the cited references, it should be understood that one of ordinary skill in the art
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`would view the references cited herein in their entirety, and potentially in
`
`combination with other references cited herein or cited within the references
`
`themselves. The references used in this report, therefore, should be viewed as
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`being incorporated herein in their entirety.
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`15.
`
`I am prepared to use any or all of the above-referenced materials,
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`other materials that may be produced during the course of this proceeding, and
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`supplemental charts, models, schematics, computer/animations, and other
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`demonstratives and representations based on those materials to support my
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`testimony.
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`16.
`
`It may be necessary for me to supplement this report based on
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`material that subsequently comes to light in this case, and I reserve the right to do
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`so. I may be asked to present demonstrative evidence at trial, and I reserve the right
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`to do so.
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`17.
`
`
`
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`IPR2021-01004
`U.S. Patent 9,918,196
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`It may be necessary for me to revise or supplement this report, or
`
`submit a supplemental or responsive report, as a result of any supplemental or
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`responsive report of Plaintiff, and I reserve the right to do so.
`
`III. MATERIALS CONSIDERED
`In forming my opinions, I have reviewed the following documents,
`18.
`
`and any other document cited in this declaration:
`
`Exhibit
`
`Description
`
`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
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`Ex-1022
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`Ex-1023
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`
`
`U.S. Patent No. 9,918,196 (“the ’196 patent”)
`Prosecution File History of U.S. Patent No. 9,918,196
`U.S. Patent No. 6,202,023 (“Hancock”)
`U.S. Patent No. 6,591,242 (“Karp”)
`U.S. Patent No. 6,029,069 (“Takaki”)
`U.S. Patent No. 7,130,630 (“Enzmann”)
`U.S. Patent No. 6,107,944 (“Behr”)
`U.S. Patent No. 6,937,869 (“Rayburn”)
`U.S. Patent Application Publication 2003/0060211
`U.S. Patent No. 6,766,174
`U.S. Patent No. 6,167,441
`U.S. Patent No. 7,512,098
`U.S. Patent No. 6,236,365
`U.S. Patent Application Publication No. 2002/0168986
`U.S. Patent No. 7,127,493
`U.S. Patent No. 6,839,552
`U.S. Patent No. 6,154,727
`Federal Communications Commission Record, 9 FCC Rcd. No. 22,
`FCC 94-237 (Oct. 19, 1994).
`Neil J. Boucher, The Cellular Radio Handbook: A Reference for
`Cellular System Operation (June 1990)
`Marcovici, Jean-Claude, “The electronic directory service.” User-
`Oriented Content-Based Text and Image Handling (1988).
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`IPR2021-01004
`U.S. Patent 9,918,196
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`Ex-1024
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`Henrick Dam, et al., Performance Evaluation of Adaptive Antenna
`Base Stations in Commercial GSM Network, IEEE (1999).
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`19.
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`I have also relied on my education, experience, research, training, and
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`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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`20. 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
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`art would have understood the claims of the ’196 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: October 23, 2001.
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`21.
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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
`22.
`It is my understanding that there are two ways that prior art references
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`can render a patent claim unpatentable: anticipation and obviousness. Counsel has
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`informed me that the petitioner has the burden in an IPR to show unpatentability
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`by a preponderance of the evidence.
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`IPR2021-01004
`U.S. Patent 9,918,196
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`I also understand that there is a set process as follows: a) the claims of
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`23.
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`a patent are