Ex. 1003
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––––––
`
`SAMSUNG ELECTRONICS AMERICA, INC,
`Petitioner
`
`v.
`
`PROXENSE, LLC
`Patent Owner
`––––––––––––––
`
`IPR2021-01448
`Patent 10,698,989
`––––––––––––––
`
`DECLARATION OF ANDREW WOLFE IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW
`
`

`

`
`
`TABLE OF CONTENTS
`
`Ex. 1003
`
`Page
`
`DECLARATION OF ANDREW WOLFE IN SUPPORT OF .......................1
`
`PETITION FOR INTER PARTES REVIEW ...................................................1
`
`I.
`
`II.
`
`INTRODUCTION .................................................................................1
`
`EDUCATION AND WORK EXPERIENCE .......................................1
`
`III. COMPENSATION ................................................................................7
`
`IV. LEGAL PRINCIPLES ...........................................................................7
`
`V.
`
`LEVEL OF SKILL IN THE ART .........................................................8
`
`VI. OVERVIEW OF THE ’989 PATENT ..................................................9
`
`VII. PROSECUTION OF THE ’989 PATENT ............................................9
`
`VIII. CLAIM CONSTRUCTION ............................................................... 11
`
`IX. CITED ART ....................................................................................... 11
`
`A.
`
`B.
`
`C.
`
`D.
`
`E.
`
`F.
`
`G.
`
`H.
`
`I.
`
`Scott (WO1999056429) ........................................................... 11
`
`Russell (US20040044627) ....................................................... 12
`
`Lapsley (US2001/0000535) ..................................................... 13
`
`Robinson (US2003/0177102) .................................................. 13
`
`Rhoads (US2004/0153649) ...................................................... 14
`
`Berardi (US 7239226) .............................................................. 14
`
`Rosen (US6175921) ................................................................. 15
`
`Shreve (US2004/0153649) ....................................................... 15
`
`Kinoshita (US2003/0055792) .................................................. 16
`
`X. GROUND 1: CLAIMS 1-9 ARE RENDERED OBVIOUS BY
`SCOTT AND LAPSLEY. .................................................................. 16
`
`A.
`
`Claim 1 ..................................................................................... 16
`
`1.
`
`2.
`
`[1pre]: A method comprising: ...................................... 16
`
`[1A]: receiving, at a smartphone, an identification
`(ID) code from a third-party trusted authority, the
`ID code uniquely identifying the smartphone
`among a plurality of smartphones; ................................ 17
`
`
`
`i
`
`

`

`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`8.
`
`9.
`
`10.
`
`
`
`Ex. 1003
`
`[1B]: persistently storing biometric data and the ID
`code on the smartphone, ................................................ 18
`
`[1C]: wherein the biometric data is one selected
`from a group consisting of facial recognition, a
`fingerprint scan, and a retinal scan of a legitimate
`user; ................................................................................ 19
`
`[1D]: receiving, at the smartphone, scan data from
`a biometric scan using the smartphone; ......................... 20
`
`[1E]: comparing, using the smartphone, the scan
`data to the biometric data; .............................................. 21
`
`[1F]: determining whether the scan data matches
`the biometric data; and ................................................... 21
`
`[1G]: responsive to a determination that the scan
`data matches the biometric data, wirelessly
`sending, from the smartphone, the ID code for
`comparison by the third-party trusted authority
`against one or more previously registered ID codes
`maintained by the third-party trusted authority, ............ 21
`
`(1) Motivation to Combine........................................ 24
`
`[1H]: a transaction being completed responsive to
`the third-party trusted authority successfully
`authenticating the ID code, ............................................ 25
`
`[1I]: wherein the transaction being completed
`includes accessing one or more from a group
`consisting of a casino machine, a keyless lock, an
`ATM machine, a web site, a file and a financial
`account. .......................................................................... 26
`
`B.
`
`Claim 2: “[t]he method of claim 1, further comprising:
`Receiving a request for biometric verification, and
`responsive to a determination that the scan data does not
`match the biometric data, indicating the smartphone
`cannot verify the scan data as being from the legitimate
`user, the smartphone does not send the ID code.” ................... 26
`
`(1) Motivation to Combine........................................ 27
`
`C.
`
`Claim 3: “[t]he method of claim 1, wherein completing
`the transaction includes accessing an application.” ................. 28
`
`
`
`ii
`
`

`

`
`
`Ex. 1003
`
`D.
`
`Claim 4: “[t]he method of claim 1, wherein the
`transaction being completed responsive to the third-party
`trusted authority successfully authenticating the ID code
`includes the third-party trusted authority sending an
`indication that the third-party trusted authority
`authenticated the ID code to another party.” ........................... 28
`
`E.
`
`Claim 5: .................................................................................... 29
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`8.
`
`9.
`
`10.
`
`[5pre]: A smartphone comprising: ................................. 29
`
`[5A]: a persistent storage having an input that
`receives an identification (ID) code from a third-
`party trusted authority, and biometric data, ................... 29
`
`[5B]: wherein the biometric data is one selected
`from a group consisting of facial recognition, a
`fingerprint scan, and a retinal scan, of a legitimate
`user ................................................................................. 29
`
`[5C]: the ID code uniquely identifying the
`smartphone among a plurality of smartphones .............. 30
`
`[5D]: the persistent storage storing the biometric
`data and the ID code, ..................................................... 30
`
`[5E]: the persistent storage having an output
`configured to provide a first set of biometric data
`and the ID code for use on the smartphone; .................. 30
`
`[5F]: a validation module, coupled to
`communicate with the persistent storage to receive
`the biometric data from the persistent storage, .............. 30
`
`[5G]: the validation module having a scan pad to
`capture scan data from a biometric scan, ....................... 31
`
`[5H]: the validation module comparing the scan
`data to the biometric data to determine whether the
`scan data matches the biometric data; and ..................... 31
`
`[5I]: a wireless transceiver that, responsive to a
`determination that the scan data matches the
`biometric data, sends the ID code for comparison
`by the third-party trusted authority against one or
`more previously registered ID codes maintained by
`the third-party trusted authority, .................................... 31
`
`
`
`iii
`
`

`

`
`
`Ex. 1003
`
`11.
`
`12.
`
`[5J]: a transaction being completed responsive to
`the third-party trusted authority successfully
`authenticating the ID code, ............................................ 31
`
`[5K]: wherein the transaction being completed
`includes accessing one or more from a group
`consisting of a casino machine, a keyless lock, an
`ATM machine, a web site, a file and a financial
`account. .......................................................................... 32
`
`F.
`
`Claim 6: “[t]he smartphone of claim 5, wherein the ID
`code is transmitted to the third-party trusted authority
`over a network.” ....................................................................... 32
`
`G.
`
`Claim 7 ..................................................................................... 32
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`8.
`
`[7pre]: A system, comprising: ...................................... 32
`
`[7A]: a smartphone that persistently stores
`biometric data and an ID code ....................................... 32
`
`[7B]: wherein the biometric data is one selected
`from a group consisting of facial recognition, a
`fingerprint scan, and a retinal scan data of a
`legitimate user ................................................................ 32
`
`[7C]: and the ID code is received from a third-
`party trusted authority, the ID code uniquely
`identifying the smartphone among a plurality of
`smartphones ................................................................... 33
`
`[7D]: the smartphone configured to indicate that a
`biometric authentication is requested ............................ 33
`
`[7E]: the smartphone configured to wirelessly send
`the ID code to the third-party trusted authority for
`authentication responsive to determining that scan
`data from a biometric scan performed using the
`smartphone matches the biometric data of the
`legitimate user, ............................................................... 34
`
`[7F]: wherein a transaction is completed
`responsive to successful authentication of the ID
`code by the third-party trusted authority ....................... 34
`
`[7G]: wherein the transaction being completed
`includes accessing one or more from a group
`
`
`
`iv
`
`

`

`
`
`Ex. 1003
`
`9.
`
`10.
`
`consisting of a casino machine, a keyless lock, an
`ATM machine, a web site, a file and a financial
`account; and ................................................................... 35
`
`[7H]: the third-party trusted authority operated by
`a third party .................................................................... 35
`
`[7I]: the third-party trusted authority storing a
`plurality of legitimate ID codes and authenticating
`the ID code received based on a comparison of the
`ID code received and the legitimate ID codes
`included in the plurality of the legitimate ID codes. ..... 36
`
`H.
`
`Claim 8: “[t]he system of claim 7, wherein the
`smartphone receives an authentication request, and in
`response, requests biometric scan from a user to generate
`the scan data and, when the smartphone cannot verify the
`scan data as being from the legitimate user, the
`smartphone does not send the ID code.” .................................. 36
`
`I.
`
`Claim 9: “[t]he system of claim 7, wherein completing
`the transaction includes accessing an application.” ................. 36
`
`XI. GROUND 2: CLAIMS 1-9 ARE RENDERED OBVIOUS BY
`BERARDI, SHREVE, AND KINOSHITA. ...................................... 36
`
`A.
`
`Claim 1 ..................................................................................... 36
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`[1pre]: A method comprising: ...................................... 36
`
`[1A]: receiving, at a smartphone, an identification
`(ID) code from a third-party trusted authority, the
`ID code uniquely identifying the smartphone
`among a plurality of smartphones; ................................ 37
`
`[1B]: persistently storing biometric data and the ID
`code on the smartphone, ................................................ 39
`
`[1C]: wherein the biometric data is one selected
`from a group consisting of facial recognition, a
`fingerprint scan, and a retinal scan of a legitimate
`user; ................................................................................ 40
`
`[1D]: receiving, at the smartphone, scan data from
`a biometric scan using the smartphone; ......................... 40
`
`
`
`v
`
`

`

`6.
`
`7.
`
`8.
`
`9.
`
`10.
`
`
`
`Ex. 1003
`
`[1E]: comparing, using the smartphone, the scan
`data to the biometric data; .............................................. 41
`
`[1F]: determining whether the scan data matches
`the biometric data; and ................................................... 41
`
`[1G]: responsive to a determination that the scan
`data matches the biometric data, wirelessly
`sending, from the smartphone, the ID code for
`comparison by the third-party trusted authority
`against one or more previously registered ID codes
`maintained by the third-party trusted authority, ............ 41
`
`(1) Motivation to Combine........................................ 43
`
`[1H]: a transaction being completed responsive to
`the third-party trusted authority successfully
`authenticating the ID code, ............................................ 43
`
`(1) Motivation to Combine........................................ 44
`
`[1I]: wherein the transaction being completed
`includes accessing one or more from a group
`consisting of a casino machine, a keyless lock, an
`ATM machine, a web site, a file and a financial
`account. .......................................................................... 45
`
`B.
`
`C.
`
`D.
`
`Claim 2: “[t]he method of claim 1, further comprising:
`Receiving a request for biometric verification, and
`responsive to a determination that the scan data does not
`match the biometric data, indicating the smartphone
`cannot verify the scan data as being from the legitimate
`user, the smartphone does not send the ID code.” ................... 45
`
`Claim 3: “[t]he method of claim 1, wherein completing
`the transaction includes accessing an application.” ................. 47
`
`Claim 4: “[t]he method of claim 1, wherein the
`transaction being completed responsive to the third-party
`trusted authority successfully authenticating the ID code
`includes the third-party trusted authority sending an
`indication that the third-party trusted authority
`authenticated the ID code to another party.” ........................... 48
`
`E.
`
`Claim 5: .................................................................................... 48
`
`1.
`
`[5pre]: A smartphone comprising: ................................. 48
`
`
`
`vi
`
`

`

`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`8.
`
`9.
`
`10.
`
`11.
`
`12.
`
`
`
`Ex. 1003
`
`[5A]: a persistent storage having an input that
`receives an identification (ID) code from a third-
`party trusted authority, and biometric data, ................... 48
`
`[5B]: wherein the biometric data is one selected
`from a group consisting of facial recognition, a
`fingerprint scan, and a retinal scan, of a legitimate
`user ................................................................................. 49
`
`[5C]: the ID code uniquely identifying the
`smartphone among a plurality of smartphones .............. 49
`
`[5D]: the persistent storage storing the biometric
`data and the ID code, ..................................................... 49
`
`[5E]: the persistent storage having an output
`configured to provide a first set of biometric data
`and the ID code for use on the smartphone; .................. 50
`
`[5F]: a validation module, coupled to
`communicate with the persistent storage to receive
`the biometric data from the persistent storage, .............. 50
`
`[5G]: the validation module having a scan pad to
`capture scan data from a biometric scan, ....................... 50
`
`[5H]: the validation module comparing the scan
`data to the biometric data to determine whether the
`scan data matches the biometric data; and ..................... 50
`
`[5I]: a wireless transceiver that, responsive to a
`determination that the scan data matches the
`biometric data, sends the ID code for comparison
`by the third-party trusted authority against one or
`more previously registered ID codes maintained by
`the third-party trusted authority, .................................... 51
`
`[5J]: a transaction being completed responsive to
`the third-party trusted authority successfully
`authenticating the ID code, ............................................ 51
`
`[5K]: wherein the transaction being completed
`includes accessing one or more from a group
`consisting of a casino machine, a keyless lock, an
`ATM machine, a web site, a file and a financial
`account. .......................................................................... 51
`
`
`
`vii
`
`

`

`
`
`Ex. 1003
`
`F.
`
`Claim 6: “[t]he smartphone of claim 5, wherein the ID
`code is transmitted to the third-party trusted authority
`over a network.” ....................................................................... 51
`
`G.
`
`Claim 7 ..................................................................................... 51
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`8.
`
`9.
`
`10.
`
`[7pre]: A system, comprising: ...................................... 51
`
`[7A]: a smartphone that persistently stores
`biometric data and an ID code ....................................... 52
`
`[7B]: wherein the biometric data is one selected
`from a group consisting of facial recognition, a
`fingerprint scan, and a retinal scan data of a
`legitimate user ................................................................ 52
`
`[7C]: and the ID code is received from a third-
`party trusted authority, the ID code uniquely
`identifying the smartphone among a plurality of
`smartphones ................................................................... 52
`
`[7D]: the smartphone configured to indicate that a
`biometric authentication is requested ............................ 52
`
`[7E]: the smartphone configured to wirelessly send
`the ID code to the third-party trusted authority for
`authentication responsive to determining that scan
`data from a biometric scan performed using the
`smartphone matches the biometric data of the
`legitimate user, ............................................................... 52
`
`[7F]: wherein a transaction is completed
`responsive to successful authentication of the ID
`code by the third-party trusted authority ....................... 52
`
`[7G]: wherein the transaction being completed
`includes accessing one or more from a group
`consisting of a casino machine, a keyless lock, an
`ATM machine, a web site, a file and a financial
`account; and ................................................................... 53
`
`[7H]: the third-party trusted authority operated by
`a third party .................................................................... 53
`
`[7I]: the third-party trusted authority storing a
`plurality of legitimate ID codes and authenticating
`the ID code received based on a comparison of the
`
`
`
`viii
`
`

`

`
`
`Ex. 1003
`
`ID code received and the legitimate ID codes
`included in the plurality of the legitimate ID codes. ..... 53
`
`H.
`
`Claim 8: “[t]he system of claim 7, wherein the
`smartphone receives an authentication request, and in
`response, requests biometric scan from a user to generate
`the scan data and, when the smartphone cannot verify the
`scan data as being from the legitimate user, the
`smartphone does not send the ID code.” .................................. 53
`
`I.
`
`Claim 9: “[t]he system of claim 7, wherein completing
`the transaction includes accessing an application.” ................. 54
`
`XII. SECONDARY CONSIDERATIONS ................................................ 54
`
`XIII. CONCLUSION .................................................................................. 54
`
`
`
`
`ix
`
`

`

`Ex. 1003
`
`LIST OF EXHIBITS
`
`Exhibit
`
`Description
`
`1001
`
`1002
`
`1003
`
`1004
`
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`1012
`
`1013
`
`1014
`
`1015
`
`1016
`
`U.S. Patent No. 10,698,989
`
`File History for U.S. Patent No. 10,698,989
`
`Declaration of Andrew Wolfe, Ph.D.
`
`Curriculum vitae of Andrew Wolfe, Ph.D.
`
`International App. No. WO 1999056429 to Scott et al.
`
`Intentionally Left Blank
`
`U.S. Patent Pub. No. 2001/0000535 A1 to Lapsley et al.
`
`Intentionally Left Blank
`
`Intentionally Left Blank
`
`U.S. Patent No. 7,239,226 B2 to Berardi et al.
`
`Intentionally Left Blank
`
`U.S. Patent Pub. No. 2002/0109580 A1 to Shreve et al.
`
`U.S. Patent Pub. No. 2003/0055792 A1 to Kinoshita et al.
`
`“Applied Cryptography—Protocols, Algorithms, and Source
`Code in C” (1996) by Schneier
`
`Declaration of Sylvia Hall-Ellis, Ph.D.
`
`Intentionally Left Blank
`
`
`
`x
`
`
`
`
`
`
`
`
`
`

`

`Ex. 1003
`
`LIST OF CHALLENGED CLAIMS
`
`Claim
`
`U.S. Patent No. 9,298,905
`
`1pre
`
`A method comprising:
`
`1A
`
`1B
`
`1C
`
`1D
`
`1E
`
`2
`
`3
`
`4
`
`5
`
`persistently storing biometric data of a legitimate user and an ID code on
`an integrated device;
`
`responsive to receiving a request for a biometric verification of a user,
`receiving, from a biometric sensor, scan data from a biometric scan
`performed by the biometric sensor;
`
`comparing the scan data to the biometric data to determine whether the
`scan data matches the biometric data;
`
`responsive to a determination that the scan data matches the biometric
`data, wirelessly sending the ID code for comparison by a third-party
`trusted authority against one or more previously registered ID codes
`maintained by the third-party trusted authority; and
`
`responsive to receiving an access message from the third-party trusted
`authority-indicating that the third-party trusted authority successfully
`authenticated the ID code, allowing the user to complete a financial
`transaction.
`
`The method of claim 1, further comprising: registering an age
`verification for the user in association with the ID code.
`
`The method of claim 1, wherein an indication that the biometric
`verification was successful is sent with the ID code.
`
`The method of claim 1, wherein the biometric data includes data from
`one or more of a fingerprint, palm print, a retinal scan, an iris scan, a
`hand geometry, a facial recognition, a signature recognition and a voice
`recognition.
`
`The method of claim 1, wherein the integrated device comprises one or
`more of a mobile phone, tablet, laptop, mp3 player, mobile gaming
`device, watch and a key fob.
`
`xi
`
`
`
`
`
`
`

`

`Ex. 1003
`
`
`
`
`6
`
`7
`
`The method of claim 1, wherein completing the financial transaction
`includes accessing an application.
`
`he method of claim 1, wherein completing the financial transaction
`includes accessing one or more of a casino machine, a keyless lock, an
`ATM machine, a web site, a file and a financial account.
`
`8pre
`
`The method of claim 1, further comprising:
`
`8A
`
`8B
`
`responsive to determining the action does not require biometric
`verification, receiving a request for the ID code without a request for
`biometric verification; and
`
`wherein the biometric data is selected from a group consisting of a palm
`print, a retinal scan, an iris scan, a hand geometry, a facial recognition, a
`signature recognition and a voice recognition;
`
`9pre
`
`An integrated device comprising:
`
`9A
`
`9B
`
`9C
`
`10
`
`11
`
`12
`
`a persistent storage media that persistently stores biometric data of a user
`and an ID code;
`
`a validation module, coupled to communicate with the persistent storage
`media, that receives scan data from a biometric scan for comparison
`against the biometric data,
`a validation module . . .that sends the ID code for comparison by a third-
`party trusted authority against one or more previously registered ID
`codes maintained by the third-party trusted authority; and
`
`a radio frequency communication module that receives an access
`message from the third-party trusted authority indicating that the third-
`party trusted authority successfully authenticated the ID code sent to the
`third-party trusted authority based on the comparison of the ID code and
`allowing the user to—complete a financial transaction.
`
`The integrated device of claim 7, wherein the ID code is transmitted to
`the third-party trusted authority over a network.
`
`The integrated device of claim 7, wherein an age verification is
`registered in association with the ID code.
`
`The integrated device of claim 7, wherein the integrated device
`comprises one or more of a mobile phone, tablet, laptop, mp3 player,
`mobile gaming device, watch and a key fob.
`
`
`
`xii
`
`

`

`
`
`
`
`
`
`
`Ex. 1003
`Ex. 1003
`
`
`
`
`
`xiii
`xiii
`
`

`

`Ex. 1003
`
`GROUNDS OF CHALLENGE (37 C.F.R. § 42.204(b)(2))
`
`No. Ground for Challenge
`
`1
`
`2
`
`3
`
`Scott and Lapsley render obvious Claims 1, 3-10, and 12
`
`Scott, Lapsley, and Robinson render obvious Claims 2 and 11
`
`Berardi, Shreve, and Kinoshita render obvious Claims 1, 3-7, 9-10,
`and 12
`
`xiv
`
`
`
`
`
`
`
`
`
`

`

`
`
`I.
`
`INTRODUCTION
`
`Ex. 1003
`
`1.
`
`I have been retained by Petitioner Samsung Electronics America,
`
`Inc. to provide an opinion on the validity of U.S. Patent No. 10,698,989,
`
`owned by Patent Owner Proxense, LLC. My opinions are based on
`
`information currently available to me. To the extent that additional
`
`information becomes available, I reserve the right to continue my
`
`investigation and study, which may include a review of documents and
`
`information that recently have been or may be produced, as well as testimony
`
`from depositions that may yet be taken in this case. I may thus expand or
`
`modify my opinions as my investigation and study continues. I may also
`
`supplement my opinions in response to any additional information that
`
`becomes available to me or that Patent Owner makes available, any matters
`
`raised by Patent Owner and/or opinions provided by Patent Owner’s experts,
`
`or in light of any relevant orders from the Patent Trial and Appeal Board.
`
`II. EDUCATION AND WORK EXPERIENCE
`
`2.
`
`A copy of my curriculum vitae that fully sets forth my
`
`qualifications can be found at Ex. 1004. Below is a summary of my education,
`
`work experience, and other qualifications.
`
`3.
`
`In 1985, I earned a B.S.E.E. degree in Electrical Engineering and
`
`Computer Science from The Johns Hopkins University. In 1987, I received
`
`
`
`1
`
`

`

`
`
`an M.S. degree in Electrical and Computer Engineering from Carnegie Mellon
`
`Ex. 1003
`
`University. In 1992, I received a Ph.D. in Computer Engineering from
`
`Carnegie Mellon University. My doctoral dissertation proposed a new
`
`approach for the architecture of a computer processor.
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`4.
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`I have more than 35 years of experience as a computer architect,
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`computer system designer, personal computer graphics designer, educator,
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`and executive in the electronics industry.
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`5.
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`In 1983, I began designing touch sensors, microprocessor-based
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`computer systems, and I/O (input/output) cards for personal computers as a
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`senior design engineer for Touch Technology, Inc. During the course of my
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`design projects with Touch Technology, I designed I/O cards for PC-
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`compatible computer systems, including the IBM PC-AT, to interface with
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`interactive touch-based computer terminals that I designed for use in public
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`information systems. I continued designing and developing related
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`technology as a consultant to the Carroll Touch division of AMP, Inc., where
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`in 1986 I designed one of the first custom touch-screen integrated circuits. I
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`designed the touch/pen input system for the Linus WriteTop, which many
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`believe to be the first commercial tablet computer.
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`6.
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`From 1986 through 1987, I designed and built a high-
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`performance computer system as a student at Carnegie Mellon University.
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`From 1986 through early 1988, I also developed the curriculum and
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`Ex. 1003
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`supervised the teaching laboratory for processor design courses.
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`7.
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`In the latter part of 1989, I worked as a senior design engineer
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`for ESL-TRW Advanced Technology Division. While at ESL-TRW, I
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`designed and built a bus interface and memory controller for a workstation-
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`based computer system, and also worked on the design of a multiprocessor
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`system.
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`8.
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`At the end of 1989, I (along with some partners) reacquired the
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`rights to the technology I had developed at Touch Technology and at AMP
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`and founded The Graphics Technology Company. Over the next seven years,
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`as an officer and a consultant for The Graphics Technology Company, I
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`managed the company's engineering development activities and personally
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`developed dozens of touch screen sensors, controllers, and interactive touch-
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`based computer systems.
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`9.
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`I have consulted, formally and informally, for a number of
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`fabless semiconductor companies. In particular, I have served on the technical
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`advisory boards for two processor design companies: BOPS, Inc., where I
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`chaired the board; and Siroyan Ltd., where I served in a similar role for three
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`networking chip companies—Intellon, Inc., Comsilica, Inc., and Entridia,
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`Inc.—and one 3D game accelerator company, Ageia, Inc.
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`Ex. 1003
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`10.
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`I have also served as a technology advisor to Motorola and to
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`several venture capital funds in the U.S. and Europe. Currently, I am a
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`director of Turtle Beach Corporation, providing guidance in its development
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`of premium audio peripheral devices for a variety of commercial electronic
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`products.
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`11.
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`From 1991 through 1997, I served on the Faculty of Princeton
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`University as an Assistant Professor of Electrical Engineering. At Princeton,
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`I taught undergraduate and graduate-level courses in Computer Architecture,
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`Advanced Computer Architecture, Display Technology, and Microprocessor
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`Systems, and conducted sponsored research in the area of computer systems
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`and related topics. I was also a principal investigator for DOD research in
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`video technology and a principal investigator for the New Jersey Center for
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`Multimedia Research. From 1999 through 2002, while a Consulting Professor,
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`I taught a Computer Architecture course to both undergraduate and graduate
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`students at Stanford University. At Princeton, I received several teaching
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`awards, both from students and from the School of Engineering. I have also
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`taught advanced microprocessor architecture to industry professionals in
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`seminars sponsored by the Institute of Electrical and Electronics Engineers
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`(“IEEE”) and the Association for Computing Machinery (“ACM”). I am
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`currently a lecturer at Santa Clara University teaching courses on
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`Ex. 1003
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`Microprocessor Systems, Real-Time Computing, and Mechatronics.
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`12.
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`From 1997 through 2002, I held a variety of executive positions
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`at a publicly-held fabless semiconductor company originally called S3, Inc.
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`and later called SonicBlue Inc. I held the positions of Chief Technology
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`Officer, Vice President of Systems Integration Products, Senior Vice
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`President of Business Development, and Director of Technology, among
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`others. At the time I joined S3, the company supplied graphics accelerators
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`for more than 50% of the PCs sold in the United States. At S3 I supervised
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`the design of several PC graphics accelerators. During my time at SonicBlue
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`we launched more than 30 new consumer electronics products including
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`devices to support copy-protected video and many of the first commercial
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`products to support copy-protected internet audio content. These included
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`some of the first consumer products to support playback of encrypted content
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`using digital rights management (DRM) based security. I also worked with
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`Universal Music Group and Sony Entertainment on the development of
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`systems for distribution and management of secure, encrypted content.
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`13.
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`I have published more than fifty peer-reviewed papers in
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`computer architecture and computer systems and IC design. I also have
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`chaired IEEE and ACM conferences in microarchitecture and integrated
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`circuit design and served as an associate editor for IEEE and ACM journals.
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`Ex. 1003
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`I served on the IEEE Computer Society Awards committee. I am a Senior
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`Member of IEEE and a Member of ACM. I am a named inventor on at least
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`fifty-seven U.S. patents and thirty-seven foreign patents, which are listed in
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`my curriculum vitae. Some of these patents relate to encryption systems
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`14.
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`In 2002, I was the invited keynote speaker at the ACM/IEEE
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`International Symposium on Microarchitecture and at the International
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`Conference on Multimedia. From 1990 through 2005, I have also been an
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`invited speaker on various aspects of technology and the PC industry at
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`numerous industry events including the Intel Developer’s Forum, Microsoft
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`Windows Hardware Engineering Conference, Microprocessor Forum,
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`Embedded Systems Conference, Comdex, and Consumer Electronics Show,
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`as well as at the Harvard Business School and the University of Illinois Law
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`School. I have been interviewed on subjects related to computer graphics and
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`video technology and the electronics industry by publications such as the Wall
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`Street Journal, New York Times, Los Angeles Times, Time, Newsweek,
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`Forbes, and Fortune as well as on CNN, NPR, and the BBC. I have also
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`spoken at dozens of universities including MIT, Stanford, University of Texas,
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`Carnegie Mellon University, UCLA, University of Michigan, Rice University,
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`and Duke University.
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`III. COMPENSATION
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`Ex. 1003
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`15.
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`I am being comp