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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Dell Inc., and Dell Technologies Inc.
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`Petitioner
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`v.
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`NEO WIRELESS LLC
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`Patent Owner
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`U.S. Patent No. 8,467,366 & U.S. Patent No. 10,833,908
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`DECLARATION OF CRAIG BISHOP
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`DELL 1012
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`Declaration of Craig Bishop
`Inter Partes Review of 8,467,366 and 10,833,908
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`I.
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`INTRODUCTION
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`I, Craig Bishop, declare the following:
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`1.
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`I have been retained as an independent expert witness on behalf of Dell Inc.,
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`and Dell Technologies Inc. (“Petitioner”) related to the Inter Partes Reviews
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`(“IPRs”) of U.S. Patent No. 8,467,366 (“the ’366 patent”) and U.S. Patent No.
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`10,833,908 (“the ’908 patent”).
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`2.
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`I am being compensated for my work in this matter at my normal consulting
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`hourly rate. I am also being reimbursed for reasonable and customary expenses
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`associated with my work and testimony in this investigation. My compensation is
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`not contingent on the results of my study, the substance of my opinions, or the
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`outcome of this matter.
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`3.
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`I have no financial interest in Petitioner. I similarly have no financial
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`interest in the ’366 patent or the ’908 patent and have had no contact with the
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`named inventor of said patent. Neither have I reviewed the ’366 patent or the ’908
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`patent in detail, nor do I have any personal interest in the outcome of this IPR.
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`4.
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`In the preparation of this declaration and in forming the opinions expressed
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`herein, I have considered my own academic background, knowledge, and
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`professional experiences in the field of wireless communications and 3rd
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`Declaration of Craig Bishop
`Inter Partes Review of 8,467,366 and 10,833,908
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`Generation Partnership Project (3GPP) standards-development, as described below
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`and in my Curriculum Vitae which is attached as Appendix A. I have also
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`reviewed the other referenced materials listed below, each of which is the sort of
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`material that experts in my field would reasonably rely upon when forming their
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`opinions:
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`I. ETSI TR 101 146 V3.0.0 entitled “Universal Mobile
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`Telecommunications System UMTS); UMTS Terrestrial Radio
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`Access (UTRA); Concept evaluation (UMTS 30.06 version 3.0.0)”
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`(1997-12) (referred to as “TR 101-146,” EX-1006)
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`II. ETSI SMG Report UMTS 30.06 version 3.0.0 entitled “Universal
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`Mobile Telecommunications System (UMTS); UMTS Terrestrial
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`Radio Access (UTRA); Concept evaluation (UMTS 30.06 version
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`3.0.0)” (referred to as “SMG Report,” EX-1016)
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`III. Craig Bishop, Curriculum Vitae (Appendix A).
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`IV. ETSI GA32 PD09R2 (Appendix B).
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`V. About ETSI, archive from 1999, available at:
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`http://web.archive.org/web/19990128030906/http://www.etsi.org/
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`(Appendix C)
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`Declaration of Craig Bishop
`Inter Partes Review of 8,467,366 and 10,833,908
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`VI. TR 101 146 Work Item description, available at
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`https://portal.etsi.org/webapp/workprogram/Report_WorkItem.asp
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`?WKI_ID=6272 (Appendix D)
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`VII. ETSI publications catalogue Q3 2002, available at
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`https://web.archive.org/web/20030801140411/http://docbox.etsi.or
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`g/catalog/etsi_catalogue.pdf (Appendix E)
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`II. QUALIFICATIONS
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`5. My complete qualifications and professional experience are described in my
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`curriculum vitae, a copy of which is attached as Appendix A. The following is a
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`summary of my relevant qualifications and professional experience.
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`6.
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`I earned my Bachelor of Electronic Engineering degree with Honors from
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`Polytechnic of Central London in 1989. In 2005, I earned my MSC in Computer
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`Science with Distinction from the University of Kent.
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`7.
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`After graduating with my first degree, I worked as an operations engineer at
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`the British Broadcasting Corporation (BBC) for 4 years, then as a civil servant at
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`the UK Radiocommunications Agency until 1996, during which time I first
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`became involved in telecommunications standardization in the European
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`Telecommunication Standards Institute (“ETSI”), working in Technical Committee
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`Declaration of Craig Bishop
`Inter Partes Review of 8,467,366 and 10,833,908
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`TC RES 2 concerned with the standardization of Private Mobile Radio (PMR).
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`From 1994 through 1996, I acted as Rapporteur for voice and data related PMR
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`standards ETS 300 113, ETS 300 219 and ETS 300 390. Between 1994 and 1996,
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`I participated as the only TC RES 2 delegate on behalf of the UK
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`Radiocommunications Agency, generating proposals in support of UK
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`administration and business requirements, downloading and reviewing other
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`meeting input documents, and proposing changes as necessary to ensure input
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`documents and the resulting specifications were in line with said requirements.
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`8.
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`In 1996, I joined Samsung Electronic Research Institute as a Senior
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`Standards Engineer where I worked for 16 years, eventually becoming Director of
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`Standards and Industry Affairs in 2011. My work at Samsung mainly focused on
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`the standardization of the GSM/GPRS, UMTS, and LTE/EPS mobile
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`communications systems. Initially, I participated in ETSI Special Mobile Group
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`(SMG) committees SMG1, SMG2, SMG4, SMG5, and SMG9 and relevant UMTS
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`related sub-committees, working on the air interface radio access network
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`protocols, services, and terminal aspects of UMTS and GSM/GPRS until 1999. I
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`was specifically involved in the ETSI SMG2 meetings that worked on the
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`evaluation of UMTS Terrestrial Radio Access concepts leading up to the selection
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`of WCDMA as the radio access technology for the Frequency Division Duplex
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`Declaration of Craig Bishop
`Inter Partes Review of 8,467,366 and 10,833,908
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`mode of UMTS by SMG #24bis in January 1998.
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`9.
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`Beginning in December 1998, I worked as a Principal Standards Engineer in
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`the 3rd Generation Partnership Project (3GPP) on UMTS, attending Radio Access
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`Network committees RAN1 and RAN2, SA1 (Services Aspects), T2 (Terminals),
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`and other working groups and Technical Specification Group (TSG) plenary
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`meetings covering the same technical aspects as in my previous work in ETSI. As
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`an example, RAN1 was in 1999 the working group responsible for radio Layer 1,
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`the physical layer of 3GPP UMTS mobile communication access network. It
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`remains the working group responsible for the radio Layer 1 of the LTE, LTE-Adv,
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`and 5G mobile communications access network. As part of my work in 3GPP
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`committees, I would prepare meeting contributions in support of Samsung’s
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`research and development activities. Also, by way of preparation for each meeting,
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`I would download all contributions and review those of interest to Samsung, and
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`where necessary, prepare additional input to the meeting based on said review.
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`10. From 2000, I acted as project manager and then as manager of the Systems
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`Engineering group providing technical requirements for the team working on
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`Samsung’s UMTS modem development. This involved scrutiny of ongoing
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`standardization work, particularly that of 3GPP RAN2 and 3GPP Core Networks
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`Working Group 1 (CN1 – responsible for layer 3 Non-Access Stratum signalling
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`Declaration of Craig Bishop
`Inter Partes Review of 8,467,366 and 10,833,908
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`between the terminal and the core network of the mobile communications system)
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`from which I would download and assess the impact of meeting contributions on
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`the protocol stack of the development project, ensuring that the development team
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`was kept informed about the latest developments as layers 2 and 3 of the UMTS
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`standard were stabilized.
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`11. During this period, in addition to authoring and presenting technical
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`contributions for the 3GPP standard, and producing technical requirements for the
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`radio modem, I acted as rapporteur for 3GPP Technical Reports covering User
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`Equipment (“UE”) capability requirements (3GPP TR 21.904) from 1999-2000,
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`and the Evolution of the 3GPP System (3GPP TR 21.902) in 2003 (the first Study
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`Item to consider the 3GPP system beyond UMTS towards LTE/EPS).
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`12.
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`In 2005, I became Head of Advanced Technologies, Standards and
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`Regulation (ATSR) at Samsung. In addition to my managerial duties which
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`included responsibility for three standards engineers regularly attending 3GPP
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`RAN WG2, and CT WG1 working groups, I continued to work directly on 3GPP
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`standardization issues. From 2005 until 2008 I regularly participated in 3GPP SA
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`WG2 meetings mainly focusing on IP Multimedia Subsystem (IMS) including
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`voice over IMS but also looking at wider Evolved Packet System (EPS) related
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`issues. From 2008 until 2011 I regularly participated in 3GPP SA WG1 meeting
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`Declaration of Craig Bishop
`Inter Partes Review of 8,467,366 and 10,833,908
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`working on service requirements. I also participated in 3GPOP TSG SA plenary
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`meetings from 2008 until I left Samsung in 2013. As well as generating
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`contributions in support of Samsung's research and development in preparation for
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`each meeting, I would download and review documents from other 3GPP
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`members, identifying, and where necessary preparing, additional contributions on
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`those of interest to Samsung. The work required a sound working knowledge of the
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`broader 3GPP system to ensure effective management of the ATSR team, effective
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`participation in meeting discussions, assessment of third-party contributions, and
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`provision of implementation guidance to Samsung developers.
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`13. From 2006 until I stopped attending SA WG1 meetings in 2011, I authored
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`and presented over 100 contributions to SA WG2 and SA WG1 meetings at 3GPP
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`and appeared as an author/co-author on 18 patent applications related to User
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`Equipment operation in the IMS and the 3GPP Core Network.
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`14.
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`In 2011, I became Director of Standards and Industry Affairs at Samsung,
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`and in November of that year I was elected to the Board of the ETSI on which I
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`served for a term of 3 years until November 2014. Throughout this period and
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`continuing through today, ETSI remained the main organisational partner of the
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`3GPP, accounting for the largest share of 3GPP members and providing secretarial
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`support for the project through its Mobile Competence Centre. ETSI also
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`continued to publish 3GPP specifications and be responsible for the management
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`of content 3GPP website and servers as well as on the ETSI website. As the
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`manager and then directory of Samsung’s standards group in Europe and official
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`contact for ETSI, I therefore remained abreast of technical and organisational
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`developments in ETSI.
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`15. Since leaving Samsung, my company has joined ETSI as a full member, and
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`as part of various projects undertaken, I have continued to regularly access the
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`3GPP and ETSI document servers, and to keep abreast of 3GPP and ETSI
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`document handling practices. In particular, I have participated as an expert in two
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`ETSI Specialist Task Forces (STFs), producing technical reports on the use of
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`multimedia and machine to machine communications in support to emergency
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`communications.
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`16. Through my extensive work on ETSI and 3GPP standardization issues, I
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`have become very familiar with ETSI as well as 3GPP’s practices relating to
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`making draft standards and standards contributions publicly available, including in
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`the 1997 - 2004 timeframe. The remainder of my declaration focuses on activities
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`in the 1997 - 2004 timeframe, prior to 2004-01-29, unless stated otherwise.
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`III. PUBLIC AVAILABILITY OF ETSI STANDARDS PROPOSALS AND
`OTHER DOCUMENTS
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`Declaration of Craig Bishop
`Inter Partes Review of 8,467,366 and 10,833,908
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`17. Based on my years of experience working in various capacities on ETSI and
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`3GPP standards issues, I am very familiar with the regular business practices of
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`ETSI and the 3rd Generation Partnership Project (“3GPP”) relating to technical
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`documents, including the publication of technical specification and reports.
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`18. ETSI is a standards organization that provides members with an open and
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`inclusive environment to support the timely development, ratification and testing
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`of globally applicable standards for Information and Communication Technology
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`(ICT) enabled systems, applications and services across all sectors of industry and
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`society. It is a not-for-profit body and is one of only three bodies officially
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`recognized by the EU as a European Standards Organization (ESO). ETSI
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`currently comprises more than nine hundred members worldwide, drawn from
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`sixty-five countries and five continents. Members range from large multi-national
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`corporations to small private companies, and also include research entities,
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`academia, government and public organizations. The technical specifications
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`developed by ETSI were, and remain, contribution-driven by the ETSI member
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`companies and the many individual participants from these companies, though they
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`are sometimes developed by members in response to European Commission
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`initiatives or regulatory requirements.
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`19. According to the ETSI General Assembly Meeting #32 permanent document
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`Declaration of Craig Bishop
`Inter Partes Review of 8,467,366 and 10,833,908
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`PD09R2 (attached as Appendix B), there were approximately 634 full and
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`associate ETSI members and 62 observers in June 1999. Appendix B at 1.
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`20.
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`In 1997 through 1999, the Technical Organisation of ETSI comprised a
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`number of Technical Committees (TCs) and Projects (EPs) comprising Working
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`Groups (WGs) covering a range of technologies. Work on GSM and GPRS
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`specifications, which pertained to 2G was undertaken in ETSI EP Special Mobile
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`Group (SMG) (previously TC SMG) under which there were 12 WGs (previously
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`Sub TCs)1 as follows: SMG1 Services & Facilities; SMG2 Radio; SMG3 Network
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`Aspects; SMG4 Data Services; SMG5 UMTS; SMG6 Operations & Maintenance;
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`SMG7 Mobile Station Testing; SMG8 Base Station System (BSS) Testing; SMG9
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`SIM Aspects; SMG10 Security; SMG11 Speech (Codec) Aspects; and SMG12
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`System Architecture. ETSI SMG and its sub committees were also responsible
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`during 1997 and 1998 for work on the then new 3G UMTS standard. Work on the
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`UMTS standard was transferred to the 3GPP on its creation in 1998. TC SMG was
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`subsequently closed in 2000 when the work on GSM / GPRS was also transferred
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`1 Although SMG was officially designated an ETSI Project by this time, it was
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`often still referred to by its previous designation as a Technical Committee or TC.
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`Inter Partes Review of 8,467,366 and 10,833,908
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`to 3GPP.
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`21. ETSI’s primary goal in at that time (and now) was to prepare, approve, and
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`maintain voluntary telecommunications standards for Europe and promote
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`worldwide standardization processes wherever possible. Appendix C. These
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`standards are documented in “technical specifications,” which ETSI periodically
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`published as a complete set (referred to as a “Release”).
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`22.
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`In the ordinary course of working events in ETSI Technical Committee
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`SMG, proposals for work that would lead to new specifications (or major changes
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`to existing specifications) were brought to SMG Working Groups in the form of
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`Work Item (WI) proposals. To be approved, proposed Work Items would require
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`the support of four ETSI members. Once approved, the Work Item would be
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`recorded in the ETSI work programme and interested members would bring
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`contributions relating to the Work Item for consideration by the Working Group.
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`Through this process, the working groups would elaborate versions of draft
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`specifications until such time that the specification was deemed sufficiently mature
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`for publication by ETSI as an approved standard, was thus approved by SMG, and
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`was subsequently placed under change control. Note that the specification number
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`for the published document would not always correspond to the Work Item number
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`used by SMG as it depended on the nature of the deliverable, e.g., whether the
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`Declaration of Craig Bishop
`Inter Partes Review of 8,467,366 and 10,833,908
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`document would be used for regulatory purposes. The ETSI Publications
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`Catalogue provided a description of different deliverable types and associated
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`ETSI numbering so that draft and approved specifications could be readily located.
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`By way of an example, one such Work Item in SMG2 was DTR/SMG-023006U
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`(Appendix D) being the UMTS concept evaluation Work Item that would result in
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`the publication of TR 101 146.
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`23. The version number for UMTS-related deliverables had the format x.y.z.
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`Phase number x = 0, 1, 2 corresponded to draft UMTS versions, x = 3, x = 4, and
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`so on corresponded to approved versions of UMTS releases. The second version
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`number digit, y, was incremented for all changes of substance, such as technical
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`enhancements, corrections, updates, and others. The third version number digit, z,
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`was incremented when editorial-only changes were incorporated in the document.
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`After a specification or report was placed under “change control” it could be
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`modified only by formal Change Requests submitted to and agreed by the relevant
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`WG and then formally approved by Technical Committee plenary meetings. Once
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`a Technical Specification or Report was approved, it would published as ETSI
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`deliverable, sometimes following public enquiry and national administration voting
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`in the case of specifications that would constitute European standards.
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`24. During the 1997 - 2004 timeframe, ETSI publications could be obtained by
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`Declaration of Craig Bishop
`Inter Partes Review of 8,467,366 and 10,833,908
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`both members and non-members alike either directly from ETSI or from National
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`Standards Organizations (NSOs). From 1997, ETSI produced a quarterly CD-ROM
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`(later DVD-ROM) which contained published standards that members of the
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`public could obtain by purchase or subscription. By at least September 1998,
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`ETSI’s practice for publishing standards further included making standards
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`available via the ETSI website so that they could be individually accessed via a
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`search capability on the site or by following a series of links, and then downloaded
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`free of charge. The above is supported by the following screenshot of an archived
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`ETSI web page from October 2003. This is consistent with my recollection of
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`accessing ETSI deliverables via its website at that time. The webpage shown in the
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`screenshot can be found at:
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`https://web.archive.org/web/20031011183012/http://pda.etsi.org:80/pda/QueryFor
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`m.asp
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`Declaration of Craig Bishop
`Inter Partes Review of 8,467,366 and 10,833,908
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`25.
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`In addition, specifications, reports, and working documents would often be
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`made available in the committee specific directories on the ETSI document server,
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`the ETSI docbox (docbox.etsi.org) from where they could be freely obtained and
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`distributed without restriction by any person holding an ETSI On Line (EOL)
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`account.
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`IV. TR 101 146 V3.0.0 (1997-12) (“TR 101-146”): TECHNICAL REPORT
`UNIVERSAL MOBILE TELECOMMUNICATIONS SYSTEM
`(UMTS); UMTS TERRESTRIAL RADIO ACCESS (UTRA)
`CONCEPT EVALUATION (UMTS 30.06 VERSION 3.0.0)
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`26. TR 101 146 is a Technical Report produced by ETSI TC SMG2 which
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`describes the detailed evaluation work towards the definition of the Universal
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`Declaration of Craig Bishop
`Inter Partes Review of 8,467,366 and 10,833,908
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`Mobile Telecommunications System UMTS Terrestrial Radio Access (UTRA)
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`within that group. TR 101 146 has a cover date of December 1997, being the date
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`when the UTRA concept evaluation was completed in SMG2. The report was
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`approved by TC SMG and its contents used as input to inform the TC SMG
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`decision on which technology to use for the UTRA. The title of TR 101 146 also
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`includes the SMG allocated number UMTS 30.06 version 3.0.0 which reflects the
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`Work Item that resulted in the report.
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`27. To obtain TR 101 146, I went to the ETSI website (www.etsi.org), and I
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`selected the Standards link at the top of the page. In the search box, I entered “TR
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`101 146” and hit return. The first entry returned was TR 101 146 v3.0.0 showing a
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`publication date of December 1997. I downloaded a PDF copy of the document by
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`following the PDF link.
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`The publication date of December 16, 1997 is confirmed by the Work Item details
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`(Appendix D) which also confirm the scope and field of the TR including the
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`evaluation of OFDMA technology as part of the study. The publication date
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`Declaration of Craig Bishop
`Inter Partes Review of 8,467,366 and 10,833,908
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`reflects the date after which any interested person could have downloaded TR 101
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`146 from ETSI free of charge, regardless of membership, and shared it without
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`restriction. Note that the results of the search are the same when using the search
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`term 30.06 as shown in the screenshot below.
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`Note further that the results of the search are the same when using the search terms
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`“UTRA” and “evaluation” in place of “TR 101 146” (or “30.06”) and setting the
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`publication date prior to January 29, 2004, as shown below. The “Contents” check
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`box is unticked to ensure the search process is consistent with the ETSI standards
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`search process in use before January 29, 2004 and which I used at that time to
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`search for and retrieve such standards.
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`Declaration of Craig Bishop
`Inter Partes Review of 8,467,366 and 10,833,908
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`28. The publication date of December 16, 1997, and availability before 2004 is
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`further supported by the subsequent upload date to the ETSI docbox of the
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`technically identical SMG Report UMTS 30.06 version 3.0.0.2 The following
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`2 The only difference between the two is that TR 101 146, the PDF version
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`obtained by following the PDF link is a single document which includes the four
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`annexes, whereas the SMG Report UMTS 30.06 version 3.0.0, retrieved from
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`ETSI docbox, is a zipped archive containing a file 3006-300.doc which includes
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`the main body of the report with sections for each of the annexes, and with the four
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`annexes themselves provided in four separate zipped files each containing the
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`Declaration of Craig Bishop
`Inter Partes Review of 8,467,366 and 10,833,908
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`screenshot shows that UMTS 30.06 v3.0.0, “3006_300.zip”, was available for
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`download by EOL account holders also from the ETSI docbox
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`(docbox.etsi.org/zArchive/SMG/SMG/specs/UMTS) from May 28, 1998, after
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`which it could be shared without restriction.
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`29. The public availability of TR 101 146 from ETSI is also supported by the
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`fact that it is listed in the ETSI publications catalogue for 3rd Quarter 2002. The
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`following screenshot shows an archived copy of the ETSI homepage as it appeared
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`in 2003 (https://web.archive.org/web/20030928131304/http://www.etsi.org:80/).
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`contents of one annex.
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`Declaration of Craig Bishop
`Inter Partes Review of 8,467,366 and 10,833,908
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`Following the “Get a Standard” link from that page opens the ETSI Telecoms
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`Standard page
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`(https://web.archive.org/web/20030801073204/http://www.etsi.org/getastandard/h
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`ome.htm) which itself has a link to a printable PDF version of the ETSI
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`publications catalogue (Appendix E). Searching the catalogue using the term
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`“UTRA” returns 56 entries, the 8th of which is TR 101 146. Searching the
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`catalogue using the term “concept evaluation” returns only the entry for TR 101
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`146. This search capability is consistent with that I recall for the Adobe PDF reader
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`prior to January 29, 2004, which I would use at that time, for example, to search
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`the ETSI catalogue as well as to search for key terms in PDF versions of ETSI
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`deliverables downloaded from the ETSI website.
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`Declaration of Craig Bishop
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`30.
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`In addition, having been a participant in the SMG2 meetings in 1997 that
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`resulted in the creation of TR 101 146, and in SMG meetings #24 and #24bis, in
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`December 1997 and January 1998 respectively, that considered the contents of TR
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`101 146 as the main technical input to its decision on the UMTS Terrestrial Radio
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`Access (UTRA) technology, I can personally attest to the fact that the document
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`was made freely available to ETSI participants and shared widely within ETSI
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`member organisations and beyond from its publication date of December 1997 and
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`no later than January 29, 2004.
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`31. As such, based on the above it is my opinion that any interested member of
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`the public using reasonable diligence would have been able to identify, find, and
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`Declaration of Craig Bishop
`Inter Partes Review of 8,467,366 and 10,833,908
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`obtain TR 101 146 free of charge from ETSI, from its publication date of
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`December 16, 1997 until January 29, 2004.
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`VIII. CONCLUSIONS
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`32. As described under section IV of the present document, it is my opinion that
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`TR 101-146 titled “Universal Mobile Telecommunications System (UMTS);
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`UMTS Terrestrial Radio Access (UTRA); Concept evaluation (UMTS 30.06
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`version 3.0.0)” and provided as EX-1006, was publicly available to download from
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`the ETSI website or file server following its publication in December 16, 1997
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`well before January 29, 2004 and remained available for download thereafter.
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`33.
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` I declare under penalty of perjury that the statements made herein are
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`believed to be true based upon either my personal knowledge or to the best of my
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`knowledge, information, and belief. I hereby declare that all statements made
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`herein of my own knowledge are true and that all statements made on information
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`and belief are believed to be true; and further that these statements were made with
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`the knowledge that wilful false statements and the like so made are punishable by
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`fine or imprisonment, or both, under Section 1001 of Title 18 of the United States
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`Code.
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`Declaration of Craig Bishop
`Inter Partes Review of 8,467,366 and 10,833,908
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`Date:
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`September 02, 2021
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`By:
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`/ //
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`Printed Name: Craig Bishop
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`Name:
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`Contact Tel No.:
`Email:
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`Current job title:
`Address:
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`Curriculum Vitae – May 2021
`Craig Bishop
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`+44 (0)7984 564949 (mobile)
`craig@bishopcom.co.uk
`Independent Consulting Engineer, CEO
`32 Nightingale Road, Faversham, Kent, ME13 8RF
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`Key Skills and Experience
`(cid:120) 31 years Telecoms, Radio and Broadcast experience
`(cid:120) 24 years experience in 2G/3G/4G telecoms standardisation and mobile handset development
`(cid:120) Extensive knowledge of 3GPP and ETSI specifications and procedures including ETSI role from
`regulatory perspective (harmonised standards, mandates, spectrum, etc)
`(cid:120) Sound understanding of 3GPP systems, including Radio Access Interfaces and Networks, Access
`Stratum protocols, Core Networks, Non-Access Stratum protocols, and IMS
`(cid:120) Depositions, reports, and declarations as expert witness in cases on 3GPP technologies and on
`3GPP & ETSI practices and procedures.
`Intellectual property analysis including prior art search and evaluation of patent essentiality
`(cid:120)
`(cid:120) Application of data analytics and machine learning techniques to standards and IP data
`(cid:120) Programming in Java, Python, C, Octave (Matlab)
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`Career History
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`Bishop Communications Ltd.
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`01/13 –
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`Independent Telecommuncations Standards and Intellectual Property
`Consultant
`Full ETSI member
`Activities have included:
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`Provision of expertise for EC funded ETSI Specialist Task Force (STF489) to produce
`implementation guidelines for Total Conversation for emergency services. Project delivered on
`time / budget and well received. Ouput published March 2016 as ETSI TR 103 201.
`Provision of expertise for ETSI Specialist Task Force (STF555) assessing the impact on existing
`standards of communications involving IoT devices in all types of emergency situations. Project
`delivered on time / budget and well received. Ouput published July 2019 as ETSI TR 103 582.
`Provision of expert support for IPR litigation from standards landscape analysis / background
`technical reports to expert testimony reports / declarations and depositions.
`Intellectual property analysis assessing strengths and weaknesses of patents and patent
`portfolios, conducting searches for prior art, evaluating patent essentiality, and acquring relevant
`documentation.
`Provision of standards consultancy services for Samsung Electronics in ETSI including
`membership of the ETSI Board until November 2014
`Technologies covered in patent related work include: 3GPP GSM, UMTS, LTE radio interface
`technologies (Phy, MAC, RLC, RRC), 3GPP access and core networks (GPRS/UMTS & EPC NAS),
`IMS. Organisations covered include 3GPP & ETSI.
`Clients served during last 8 years include: Addy Hart LLP, Alston & Bird LLP, Banner Witcoff LLP, DLA
`Piper LLP, European Telecommunications Standards Institute (ETSI), Fish & Richardson P.C., Gibson
`Dunn LLP, Haynes and Boone LLP, Hillebrand-CE GmbH (work for third party clients as Consulting
`Engineer for Hillebrand-CE), Kilpatrick Townsend & Stockton, Kirkland & Ellis LLP, KL Gates LLP
`Morgan, Lewis & Bokius LLP, MckoolSmith LLP, PV Law LLP, Paul Hastings LLP, Perkins Coie LLP,
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`CB c:\winword\wp\pers\cv.doc 21/05/21
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`Powell Gilbert LLP, Sidley Austin LLP, Samsung Electronics Research & Development Institute UK
`(SRUK), Taylor Wessing LLP, Williams & Connolly LLP, WilmerHale LLP.
`Expert testimony through deposition:
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`Huawei Technologies Co. Ltd. vs. T-Mobile US, Inc., et al., Case Nos. 2:16-cv-0052-JRG-RSP,
`2:16-cv-0055-JRG-RSP, 2:16-cv-0056-JRG-RSP, and 2:16-cv-0057-JRG-RSP (E.D. Tex.). On
`behalf of T-Mobile US Inc.
`T-Mobile US, Inc., et al. v. Huawei Technologies Co. Ltd., IPR Nos. IPR2017-00696 and
`IPR2017-00697 (PTAB). On behalf of T-Mobile US Inc.
`LG Electronics, Inc., v. Koninklijke KPN N.V., IPR Nos. Case IPR2018-00558 (PTAB). On behalf
`of LG Electronics, Inc.
`Expert testimony in court:
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`Between IPCom GmbH and Vodafone, et al., Claim No. HP-2018-000030 Claim No. HP-2018-
`000031, High Court of Justice, Business & Property Courts of England and Wales, Intellectual
`Property List (ChD), Patents Court. Retained by Vodafone.
`Between (1) Mitsubishi Electric Corporation (2) Sisvel International SA and Oneplus Mobiletech
`UK Limited, Oppo Mobile UK Ltd, Xiaomi Technology UK Limited, et al., Claim No. HP-2019-
`000014, High Court of Justice, Business & Property Courts of England and Wales, Intellectual
`Property List (ChD), Patents Court. Retained by Oneplus, Oppo, and Xiaomi (trial held remotely
`due to COVID-19 restrictions)
`A list of reports and declarations submitted but not deposed for can be provided upon request.
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`Samsung Electronics Research Institute (SERI)
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`12/96 – 01/13
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`03/11 – 01/13
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`Director Standards and Industry Affairs
`Mission and Tasks as for previous role plus:
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`Proactive member of ETSI Board following election as Board member in November 2011
`- Worked with Samsung internal and external legal counsel in response to EC investigation into
`Samsung suspected abuse of Standards Essential Patents.
`Deposed by Apple as fact witness in ITC investigation 337-TA-794.
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`09/05 - 03/11
`Head of Advanced Technologies Standards & Regulation
`Mission: To help position Samsung and SERI at the forefront of mobile telecommunication
`developments through participation in and leadership of mobile communications standards and
`European regulatory affairs
`Key tasks:
`- Developed standards and research strategy and coordinated activites with head office, acting as
`official Samsung contact for the European Telecommunications Standars Institute.
`Programme managed standardisation and regulation projects covering 3GPP (RAN2, CT1, SA2,
`SA1, SA, RAN, CT), OMA, and mobile Broadcast strategies and technologies (DVB Forum),
`European Framework projects (FP7), Spectrum Management (CEPT, ETSI EM, TFES, BRAN, …)
`and European Regulatory affairs (Digital Europe, relation