Case 6:21-cv-00210-ADA Document 33-2 Filed 10/28/21 Page 1 of 25
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`Exhibit A
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`Patent Owner Exhibit 2003, Page 1 of 25
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`Case 6:21-cv-00210-ADA Document 33-2 Filed 10/28/21 Page 2 of 25
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`PROXENSE, LLC,
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`Plaintiff,
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`vs.
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`SAMSUNG ELECTRONICS, CO., LTD.
`AND SAMSUNG ELECTRONICS
`AMERICA, INC.,
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`Defendant.
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`Case Nos. 6:21-cv-00210-ADA
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`JURY TRIAL DEMANDED
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`DECLARATION OF DR. SETH JAMES NIELSON IN SUPPORT OF SAMSUNG’S
`OPENING CLAIM CONSTRUCTION BRIEF
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`1
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`Patent Owner Exhibit 2003, Page 2 of 25
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`Case 6:21-cv-00210-ADA Document 33-2 Filed 10/28/21 Page 3 of 25
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`I, Seth James Nielson, declare as follows:
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`1.
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`I am qualified and authorized to attest to the matters set forth in this Declaration. I
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`have knowledge of the facts set forth in this Declaration based on my own personal information
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`or investigation into the relevant subject matter.
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`I.
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`INTRODUCTION
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`2.
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`I am over the age of 18 and am competent to make this Declaration. I have personal
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`knowledge or have developed knowledge of these technologies based upon education, training, or
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`experience, of the matters set forth herein.
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`3.
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`I have been retained by counsel for defendants Samsung Electronics, Co., Ltd. and
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`Samsung Electronics America, Inc. (collectively, “Samsung”) as an expert to provide opinions
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`regarding the understanding of a person of ordinary skill in the art (“POSITA”) in connection with
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`certain terms in the claims of U.S. Patent Nos. 8,352,730 (the “’730 patent”), 9,049,188 (the “’188
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`patent”), 9,235,700 (the “’700 patent”), 9,298,905 (the “’905 patent”), and 10,698,989 (the “’989
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`patent”) (collectively, “Patents-in-Suit”).
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`4.
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`I am being compensated at my usual hourly rate of $600 per hour. I am also being
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`reimbursed for any out-of-pocket expenses. I have no financial interest in, or affiliation with,
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`Samsung. My compensation does not depend in any way on the outcome of this case, the substance
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`of my testimony, or opinions that I express.
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`5.
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`In rendering my opinions, I have considered the patents at issue, their file histories,
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`the parties’ claim construction disclosures, and any other documents referenced, discussed, or
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`listed in my declaration, and my own knowledge and experience in the user interface, computer
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`networking, wireless communications,
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`telecommunications networks, relational database
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`management system, data structures, algorithms, and other computing fields relevant to the
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`asserted patents.
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`6.
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`In forming my opinions, I understand that the claims should be interpreted as they
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`would be understood by a POSITA of the patent at the time its application was filed. I understand
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`that the claims are to be construed with reference to the patent’s specification, the claims, the
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`prosecution history, in light of the plain meaning of the terms used in the claims, and with potential
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`reference to other sources of information, such as dictionaries, textbooks, and literature or other
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`patents in the same or related fields.
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`7.
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`My analysis of the materials produced in this matter is ongoing and I will continue
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`to review any new material as it is provided. This declaration represents only those opinions I
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`have formed to date. I reserve the right to amend or supplement my opinions based on additional
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`documents or evidence I am presented, including without limitation any arguments or expert
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`declarations advanced by either party in this case.
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`I.
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`QUALIFICATIONS AND EXPERIENCE
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`8.
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`My qualifications are summarized below and are addressed more fully in my CV
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`attached as Exhibit A to this declaration.
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`9.
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`I am a subject matter expert in cyber security, including the sub-fields of applied
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`cryptography and network security. I am the Founder and Chief Scientist of Crimson Vista, a
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`computer security research and engineering company. Furthermore, I hold appointments at the
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`University of Texas at Austin as an Adjunct Associate Professor in the Department of Computer
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`Science and as a Cybersecurity Fellow in the Robert Strauss Center for International Security and
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`Law.
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`10.
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`I have been working professionally in the field of computer security since August
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`of 2005 and within the field of computer science generally since June 2000. My experience
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`includes graduate-level teaching, academic research, industry employment, and consulting
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`practice.
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`11.
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`I received my B.S. in Computer Science in April of 2000. During my final
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`undergraduate semester, I worked both as a teaching assistant for a Computer Networking course
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`and as a researcher in the Networked Computing Lab. In these capacities, I assisted students in
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`debugging and designing TCP/IP protocol stacks, Address Resolution Protocol implementations,
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`and Remote Procedure Call projects. I have collaborated on investigations of statistical traffic
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`engineering for bandwidth allocation, including a published paper entitled, “Effective Bandwidth
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`for Traffic Engineering.”
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`12.
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`After graduation (from 2001 through 2003), I worked as a software engineer at
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`Metrowerks (formerly Lineo, Inc.), where I had substantial responsibilities relating to software
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`architecture, computer networking, and technical project management.
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`13.
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`As part of my technical training and development at Lineo/Metrowerks, I also
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`gained and employed a wide exposure to computer networking and an introduction to network
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`security. I tested and evaluated a prototype firewall product, built a custom VPN solution, and
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`trained in the use of web server and mail server administration. I ran my own personal MTA with
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`an IMAP and POP3 server based on these tools under development.
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`14.
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`Another major networking project involved porting the Embedix SDK from Linux
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`to Windows. For this project I used a virtual-machine/networked solution. The underlying SDK
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`engine remained running in a Linux VM while the GUI operated in native Windows. I developed
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`all of the code for this remote communication system.
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`15.
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`Additionally, the SDK provided extensibility through a scripting system based on
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`Python. A critical task was to make the existing Python scripts, built to run in Linux, work
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`unmodified with the new Windows system. I engineered a framework that automatically
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`intercepted certain Python commands and sent them across the network to the other side, similar
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`to RPC technology. From the perspective of the scripts, all of the function calls were local when,
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`in fact, certain operations were executed remotely.
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`16. While working at Lineo/Metrowerks, I also returned to BYU to pursue my Master’s
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`degree in Computer Science. In addition to the graduate level course work in wireless computer
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`networks and compilers, I pursued graduate research in software engineering topics, with a special
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`emphasis on how programmers think while creating and modifying code. My research included a
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`study of computer architectural patterns and how those patterns might need to change as
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`programming languages change and evolve. Based on my research, I proposed a concept called
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`“Design Dysphasia,” wherein a programmer or software developer becomes trapped in their
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`approach to solving problems based on the paradigms and design approaches of the programming
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`language. My research was published as “Design dysphasia and the pattern maintenance cycle,”
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`in the Journal Information and Software Technology August 2006. This work also was a major
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`component of my Master’s thesis.
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`17.
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`After finishing my Master’s degree, I moved to Houston TX in 2004 to begin a PhD
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`program at Rice University. At this point, my interest in computer security took priority over my
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`interests in programming languages and software engineering, and my classes and research were
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`directed to that topic.
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`18.
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`During the 2004 fall semester of my Ph.D. program at Rice University, I identified
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`a security vulnerability in the Google Desktop Search that could have allowed hackers to
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`compromise users’ computers and obtain private information. After contacting Google and
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`assisting them in closing the vulnerability, we published the details of our investigation.
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`19.
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`In 2005, I completed an internship at Google, where I designed and implemented a
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`solution to privacy loss in Google Web Accelerator. The Google Web Accelerator was designed
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`to increase the speed of browsing the Internet. Once installed on a user’s computer, the browser
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`would request all content through a Google Proxy. The proxy performed pre-fetching and
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`extensive caching in order to provide fast and responsive service to the user. At the time of my
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`internship, news reports had identified odd problems in which users of the Accelerator were
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`accessing other individual’s private pages. During my internship, I designed and implemented a
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`prototype solution for this issue in C++.
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`20.
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`In 2005, I published a paper entitled, “A Taxonomy of Rational Attacks.” This
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`paper categorized and described the various types of attacks that one might see in a decentralized,
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`peer-to-peer network. When there is no centralized authority, users have to cooperate to obtain
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`service. The term “rational attacks” refers to the economic incentives to not cooperate while still
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`exploiting the system for service.
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`21. My Ph.D. Thesis was entitled “Designing Incentives for Peer-to-Peer Systems,”
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`and it built on this concept. Given a network where participants cannot be forced to cooperate, the
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`operation of said network must induce cooperation by design of the outcomes. In other words, it
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`must be in each participant’s best interest to contribute to the cooperative operation. I conducted
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`experiments including simulated extensions to the BitTorrent peer-to-peer protocol for long-term
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`identities and mechanisms for cooperative anonymity.
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`22.
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`From 2005 through 2008, with the approval of my PhD adviser, I worked as a
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`Security Analyst and for Independent Security Evaluators (ISE). Much of my early work was
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`spent developing a software encryption library, including the necessary tests and procedures for
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`FIPS-certification. The encryption library provided advanced operations such as secure data
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`splitting and recovery.
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`23.
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`In 2009, I went to work full time for ISE as a Security Analyst and later as a Senior
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`Security Analyst. I built a number of advanced projects including a parallel-program for massive
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`code coverage analysis, GPU hardware-accelerated AES encryption, and encrypted file-system
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`prototypes.
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`24.
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`In addition to the software development, I also performed security evaluation
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`services that included port-scanning analyses, security protocol analysis using formal and
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`exploratory methods, and investigated security breaches.
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`25.
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`I also designed and managed the implementation of a secure communication
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`technology that splits trust between multiple SSL Certificate Authorities (CA), so that if one CA
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`is compromised, the communication stream can still be safely authenticated. My work on the
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`secure communications technology project led to the issuance of multiple patents. In total, I wrote
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`hundreds of thousands of lines of code in C, C++, and Python, including projects where I had to
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`implement the same functionality in two separate languages.
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`26.
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`In 2011, I began work as a Research Scientist at Harbor Labs and continued with
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`that consulting firm until fall 2015. I worked with a wide range of clients, specializing in network
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`security, network communications, software architecture, and programming languages. I analyzed
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`an extensive collection of commercial software, including software related to secure email, cloud-
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`based multimedia delivery, document signing, anti-virus and anti-intrusion, high-performance
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`routing, networking protocol stacks in mobile devices, PBX telecommunications software, VoIP,
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`and peer-to-peer communications. I also analyzed security considerations for potential technology
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`acquisitions.
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`27.
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`Also at Harbor Labs, I reviewed technology and source code for multiple clients
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`related to accusations of theft and/or misappropriation of trade secrets. These engagements
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`included an analysis of C, C++, Java, Python, and other source code languages in high-frequency
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`trading, e-commerce, and other similar systems.
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`28.
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`I also assessed the security and privacy technologies and policies provided by a
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`third-party vendor to the Center for Copyright Infringement (CCI). CCI represents content owners,
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`such as the RIAA and the MPAA, in finding and reducing piracy online.
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`29.
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`For other clients, I have “resurrected” or re-created legacy software systems. For
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`example, I assisted one client make code from the mid 90’s operational. I helped them identify
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`the most compatible components from an old CVS repository, obtain the necessary legacy
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`hardware and software to rebuild the source code, and diagnose why the separate components
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`weren’t completely compatible with each other. Using tools from the era (i.e., the mid-90’s), I
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`identified and fixed these issues in C++ and Java code, and successfully demonstrated the
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`operational system.
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`30.
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`In other similar examples, I re-created basic software in x86 Assembly code that
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`mimicked the behavior of 1990’s era viruses, wrote a file transfer system similar to FTP in pre-2.0
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`Java, and demonstrated the use of a command-line antivirus software adapted for router/gateway
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`scanning.
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`31.
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`During my final year at Harbor Labs, I was engaged as the principal consultant with
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`a large biomedical device firm in a twelve-month analysis of the security of their products.
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`Notably, medical devices were for some time not considered significant threats in terms of
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`computer security. However, recent demonstrations by security researchers of the various ways
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`in which a malicious individual might harm a person using a medical device has shifted the
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`thinking in the industry. Accordingly, I was engaged to assist this company in the analysis of their
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`products, their process, and their future roadmap in order to ensure that patients are not harmed.
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`My team and I analyzed design documents, hardware, and a broad range of additional resources in
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`order to expose potential problems. The security of these systems depends, in part, on the
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`architecture and deployment of the networks in which they operate.
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`32.
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`In May 2016, I founded Crimson Vista, Inc. as a boutique computer security
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`engineering company. Similar to the work that I did at Harbor Labs, I continue to provide technical
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`expertise to a wide range of clients in areas of programming languages, computer networks, and
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`network security. My expertise in the area of “security engineering” provides comprehensive
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`analysis, design, and insight into cybersecurity concerns before, during, and after development.
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`33.
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`For example, I have been retained by a start-up in telecommunications security to
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`provide cryptography expertise and evaluations of their protocols and architectures. My team and
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`I have prototyped new protocols, written up analyses, and presented to potential partners and
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`investors.
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`34.
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`Another start-up company retained me for guidance in matters relating to
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`Blockchain and Smart Contracts. This technology is very much dealing with a “fad” phase where
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`there is a lot of misinformation and hype. I guided the start-up company through where these kinds
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`of technologies would help and where they would not. I have also provided training on Blockchain
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`at the Data Architecture Summit and Enterprise Data World conferences.
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`35.
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`I have also provided technical guidance to an antitrust team in the United States
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`Department of Justice. Although the technologies and parties are confidential, I can disclose that
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`I provided in-person training on technical topics and analyses of competing security products.
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`36. More recently, I been retained by clients, including a Fortune 100 financial
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`institution, to provide them with post-data-breach analyses of what went wrong, the impact of the
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`lost data, and guidance on resolution. In these engagements, I provided reverse engineering of the
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`data to demonstrate how an attacker can or would use the compromised information, analyzed
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`software development to determine when the system became vulnerable, and helped identify
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`impacted customers that had been missed in the investigations.
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`37.
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`Through Crimson Vista, I also invest in research and development. Recent projects
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`include engaging with a partner to implement prototypes of communications security protocols for
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`next-generation automobiles. I also gave a talk on “Detecting Malicious Sandboxes” at the
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`Workshop on Defensive Deception and Trust in Autonomy, in association with the 2018 Naval
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`Applications of Machine Learning Workshop.
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`38.
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`I also continue to perform a wide range of code reviews for diverse technologies
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`including CAD software, video game systems, digital mobile radios (DMRs), video streaming,
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`and digital rights management (DRM).
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`39. Moreover, I maintain ties to academia. I have held adjunct appointments at Johns
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`Hopkins University from 2014 to 2019. From July 2016 to July 2019 I also held an appointment
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`as the Director of Advanced Research Projects in the Johns Hopkins University Information
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`Security Institute.
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`40.
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`At Johns Hopkins University I taught Network security and Advanced Network
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`Security. I created a custom curriculum and lab experience wherein students develop their own
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`security protocols as a class and then attempt to break their own creations. Students learn how
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`hard it is to get security right, and how easy it is to find something wrong. I published a paper
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`about the labwork in the Journal of Computer Science Education entitled, “PLAYGROUND:
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`Preparing Students for the Cyber Battleground.”
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`41.
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`The labwork in the advanced course builds on the same framework, but adds in
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`mobile, autonomous vehicles in a game-like simulation. Students program “bots” with computer
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`program “brains,” that are used to gather resources, attack, communicate, and so forth. The
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`students explore various opportunities for compromising the brains of the other students as part of
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`the labs.
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`42.
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`One of the components of the students’ lab work is to create a protected “sandbox”
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`for running untrusted code. The sandbox must provide access to the system in a manner that cannot
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`be exploited. Conversely, the other half of their assignment is to design exploitative code that
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`attempts to bypass and/or neutralize the protections of the sandbox environment. This
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`experimental framework enables the students to learn about creating, identifying, and neutralizing
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`malware such as viruses.
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`43.
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`Beyond course instruction, I also mentored Masters students at Johns Hopkins in
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`their capstone projects. These projects include networking security and privacy concerns across a
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`wide range of technologies including cryptography, drone security, iOS security, BitCoin, SSL
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`vulnerabilities, and Twitter “botnets.” My students and I have published multiple papers from
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`these capstone projects.
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`44.
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`During my tenure as the Director of Advanced Research Projects, I was tasked with
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`developing collaborative research opportunities. Through my efforts, a wide range of student
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`capstones have been executed with partners from the Johns Hopkins Applied Physics Lab or
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`outside corporate partners.
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`45.
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`For example, we coordinated with the company OnBoard Security to develop better
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`security for anti-collision protocols for air traffic. Students demonstrated the potential issues
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`related to leaving the protocol unsecured and built a working prototype of a secured variant.
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`OnBoard and Johns Hopkins published press releases which were picked up by aviation-focused
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`news sources.
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`46.
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`I am now an adjunct professor at the University of Texas at Austin. I teach the
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`undergraduate Network Security and Privacy class in the Computer Science department. I also
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`teach the Introduction to Cybersecurity Technology class in the Law School
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`47.
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`I am also the co-founder and current director of the Crypto Done Right Foundation,
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`a non-profit. The foundation grew out of a research project initially hosted at Johns Hopkins
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`University and funded by a grant from Cisco. Crypto Done Right is designed to bridge the gap
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`between cryptography SME’s and the IT professionals that use it. It provides authoritative
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`guidance on deployment, lifecycle, and management of cryptography in IT systems, software
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`development, and technical management.
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`48.
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`I am also the author of “Cryptography in Python: Learning Correct Cryptography
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`by Example.”
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`II.
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`LEGAL STANDARDS
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`A.
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`Claim Construction
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`49.
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`I am not a lawyer, and I do not intend to offer any opinions as to the interpretation
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`of the law. However, I have a general understanding of claim construction based on my experience
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`with patents, my work as an expert in other cases, and my conversations with counsel.
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`50.
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`I am informed that on the law regarding claim construction and patent claims, a
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`patent may include two types of claims, independent claims and dependent claims. An
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`independent claim stands alone and includes only the limitations it recites. A dependent claim can
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`depend from an independent claim.
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`51.
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`I am informed that claim construction is a matter of law to be decided by the Court.
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`I understand that claim terms are presumed to have their plain and ordinary meaning, as understood
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`by a POSITA at the time of the invention, in the context of the patent specification, the prosecution
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`history, and any other relevant evidence.
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`52.
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`I am informed that to determine how a POSITA would understand a claim term,
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`one should look to those sources available that show what a person of skill in the art would have
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`understood the disputed claim language to mean. Such sources include the words of the claims
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`themselves, the remainder of the patent’s specification, the prosecution history of the patent and
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`the cited references (all considered “intrinsic” evidence), and “extrinsic” evidence, such as
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`dictionary definitions, learned treatises and the opinions of qualified experts concerning relevant
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`scientific principles, the meaning of technical terms, and the state of the art.
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`53.
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`I am informed that, in construing a claim term, one looks primarily to the intrinsic
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`patent evidence, including the words of the claims themselves, the remainder of the patent
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`specification, and the prosecution history.
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`54.
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`I am informed that extrinsic evidence, which is evidence external to the patent and
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`the prosecution history, may also be useful in interpreting patent claims when the intrinsic evidence
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`itself is insufficient.
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`55.
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`In construing claims, the claims themselves, the patent specification, and the
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`prosecution history are of paramount importance. Additionally, the specification and prosecution
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`history must be consulted to confirm whether the patentee has acted as its own lexicographer (i.e.,
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`provided its own special meaning to any disputed terms), or intentionally disclaimed, disavowed,
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`or surrendered any claim scope.
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`56.
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`I understand that the claims of a patent define the scope of the rights conferred by
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`the patent. The claims must particularly point out and distinctly claim the subject matter which
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`the patentee regards as his invention. Because the patentee is required to define precisely what he
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`claims his invention to be, it is improper to construe claims in a manner different from the plain
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`import of the terms used consistent with the specification. Accordingly, a claim construction
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`analysis must begin with and remain centered on the claim language itself. Additionally, the
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`context in which a term is used in the asserted claim can be highly instructive. Likewise, other
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`claims of the patent in question, both asserted and unasserted, can inform the meaning of a claim
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`term. For example, because claim terms are normally used consistently throughout the patent, the
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`usage of a term in one claim can often illuminate the meaning of the same term in other claims.
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`Differences among claims can also be a useful guide in understanding the meaning of particular
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`claim terms.
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`57.
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`I understand that a POSITA is deemed to read a claim term not only in the context
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`of the particular claim in which the disputed term appears, but in the context of the entire patent,
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`including the specification. For this reason, the words of the claim must be interpreted in view of
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`the entire specification. The specification is the primary basis for construing the claims and
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`provides a safeguard such that correct constructions closely align with the specification.
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`Ultimately, the interpretation to be given a term can only be determined and confirmed with a full
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`understanding of what the inventors actually invented and intended to envelope with the claim as
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`set forth in the patent itself.
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`58.
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`I understand that while intrinsic evidence is of primary importance, extrinsic
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`evidence, e.g., all evidence external to the patent and prosecution history, including expert and
`
`inventor testimony, dictionaries, and learned treatises, can also be considered. For example,
`
`technical dictionaries may help one better understand the underlying technology and the way in
`
`which one of skill in the art might use the claim terms. Extrinsic evidence should not be
`
`considered, however, divorced from the context of the intrinsic evidence. Evidence beyond the
`
`patent specification, prosecution history, and other claims in the patent should not be relied upon
`
`unless the claim language is ambiguous in light of these intrinsic sources. Moreover, while
`
`extrinsic evidence can shed useful light on the relevant art, it is less significant than the intrinsic
`
`record in determining the legally operative meaning of the claim language.
`
`B.
`
`Indefiniteness
`
`59.
`
`I understand that a patent must satisfy a definiteness requirement under 35 U.S.C.
`
`§112, ¶2, which requires that it conclude with one or more claims particularly pointing out and
`
`distinctly claiming the subject matter which the applicant regards as the invention.
`
`60.
`
`I understand that definiteness requires that a patent’s claims, viewed in light of the
`
`specification and file history from the perspective of a person skilled in the relevant art, inform
`
`those skilled in the art about the scope of the invention with reasonable certainty.
`
`61.
`
`I understand that a patent must be precise enough to afford clear notice of what is
`
`claimed and apprise the public of what is still open to them in a manner that avoids a zone of
`
`uncertainty which enterprise and experimentation may enter only at the risk of infringement
`
`claims.
`
`62.
`
`I understand that patents are presumed valid and indefiniteness is an invalidity
`
`defense. So, I understand that indefiniteness must be shown by clear and convincing evidence.
`
`III. LEVEL OF ORDINARY SKILL IN THE ART
`
`
`
`
`15
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`Patent Owner Exhibit 2003, Page 16 of 25
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`

`

`Case 6:21-cv-00210-ADA Document 33-2 Filed 10/28/21 Page 17 of 25
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`
`
`63.
`
`I understand that the claims must be understood from the perspective of a POSITA
`
`at the time of the alleged inventions. I also understand that to determine the level of skill of a
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`POSITA, one must consider several factors including the types of problems encountered in the art,
`
`the solutions to those problems, the rapidity with which innovations are made, the sophistication
`
`of the technology, and the education level of active workers in the field. I further understand that
`
`the ’730, ’905, and ’989 patents originate from a common application and relate to substantially
`
`similar subject matter, as such the level of ordinary skill in the art of these patents would be the
`
`same. I understand this to be the same with regard to the ’188 and ’700 patents.
`
`64.
`
`In my opinion, with respect to the Patents-in-Suit, a POSITA at the time of the
`
`alleged inventions would have had a bachelor’s degree in computer or electrical engineering (or
`
`an equivalent degree) with at least three years of experience in the field of encryption and security
`
`(or an equivalent). This level of skill is approximate, and more experience would compensate for
`
`less formal education, and vice versa.
`
`65.
`
`I meet these criteria and consider myself a person with at least ordinary skill in the
`
`art pertaining to the asserted patents. I would have been such a person at the time of the invention
`
`of each of the asserted patents.
`
`66.
`
`I applied this level of skill of a POSITA for purposes of my analysis in this
`
`Declaration. To my knowledge, none of Proxense’s experts has yet proposed an alternative level
`
`of skill of a POSITA in this case. If and when they do, I reserve the right to provide further
`
`opinions concerning the appropriateness of that proposed level of skill of a POSITA, and to provide
`
`further opinions concerning any impact that the alternative level of skill of a person of ordinary
`
`skill would have on my analysis.
`
`IV.
`
`PATENTS IN SUIT
`
`
`
`
`16
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`Patent Owner Exhibit 2003, Page 17 of 25
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`

`

`Case 6:21-cv-00210-ADA Document 33-2 Filed 10/28/21 Page 18 of 25
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`
`
`67.
`
`I understand the ’730 patent, the ’905 patent and the ’989 patent are all part of the
`
`same family, and are in the same chain of continuations, and therefore share substantially identical
`
`specifications. Furthermore, many of the claims of the ’730 patent, the ’905 patent and the ’989
`
`patent use the same phrases or share similar structure. Because of the substantially identical
`
`specifications and the overlap in claim language, a POSITA would interpret the claim terms of the
`
`’730 patent, the ’905 patent and the ’989 patent in the same context.
`
`68.
`
` Similarly, I understand the ’188 patent and the ’700 patent are part of the same
`
`family, and are in the same chain of continuations, and therefore share substantially identical
`
`specifications. Furthermore, many of the claims of the ’188 patent and the ’700 patent use the
`
`same phrases or share similar structure. Because of the substantially identical specifications and
`
`the overlap in claim language, a POSITA would interpret the claim terms of the ’188 patent and
`
`the ’700 patent in the same context.
`
`V.
`
`“THIRD PARTY TRUSTED AUTHORITY”
`
`69.
`
`In my opinion, a POSITA would not understand the term “third party trusted
`
`authority” to be “a third component that provides a second level of authentication” according to
`
`Proxense’s construction. In particular a POSITA would have understood