U.S. Patent No. 7,386,455
`DECLARATION OF STUART J. LIPOFF
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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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`GOOGLE LLC,
`Petitioner,
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`v.
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`PARUS HOLDINGS INC.,
`Patent Owner.
`_____________
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`Case No. IPR2022-00355
`Patent No. 7,386,455
`_____________
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`DECLARATION OF STUART J. LIPOFF IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW
`UNDER 35 U.S.C. §§ 311-319 AND 37 C.F.R. § 42.1 et seq
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`Petitioner Google Ex-1002, 0001
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`U.S. Patent No. 7,386,455
`DECLARATION OF STUART J. LIPOFF
`TABLE OF CONTENTS
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`I.
`INTRODUCTION ........................................................................................... 9
`BACKGROUND AND QUALIFICATIONS ................................................. 9
`II.
`INFORMATION CONSIDERED ................................................................. 19
`III.
`IV. RELEVANT LEGAL STANDARDS ........................................................... 20
`A. Claim Interpretation ............................................................................. 20
`B. Written Description .............................................................................. 20
`C. Perspective of One of Ordinary Skill in the Art ................................... 21
`D. Obviousness .......................................................................................... 21
`SUMMARY OF OPINIONS ......................................................................... 24
`V.
`VI. THE CHALLENGED PATENT ................................................................... 24
`A. Specification ......................................................................................... 24
`B. Prosecution History .............................................................................. 28
`C. Priority Date ......................................................................................... 30
`VII. TECHNOLOGY BACKGROUND ............................................................... 32
`A. Storing electronic documents in a magnetic medium was well
`known in the art. ................................................................................... 32
`B. Voice Recognition was well known. .................................................... 32
`C. A polling mechanism was well known. ............................................... 34
`D. Ranking agent was well known. ........................................................... 36
`VIII. LEVEL OF ORDINARY SKILL IN THE ART ........................................... 39
`IX. CLAIM CONSTRUCTION .......................................................................... 39
`X.
`BRIEF EXPLANATION OF THE PRIOR ART REFERENCES ................ 40
`A. Buchner (Ex-1008) ........................................................................ 40
`B. Launey (Ex-1009) ......................................................................... 42
`XI. EXPLANATION OF GROUNDS ................................................................ 44
`A. Grounds 1 and 2: Claims 1-16 Would Have Been Obvious over
`Buchner Alone (Ground 1) and/or Buchner in View of Launey
`(Ground 2) ............................................................................................ 45
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`2.
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`U.S. Patent No. 7,386,455
`DECLARATION OF STUART J. LIPOFF
`1. A POSITA would be motivated to combine the teachings of
`Buchner and Launey and would have a reasonable
`expectation of success in doing so. ............................................... 45
`Independent Claims 1, 9, and 16 ................................................... 46
`a.
`[1PRE], [9PRE]: A [method]/[system] for controlling
`at least one remote system [operatively connected to
`the internet] by uttering speech commands into a
`[voice enabled device]/[phone], said
`[method]/[system] comprising [the steps of]: ...................... 46
`[16PRE]: A method for controlling at least one remote
`system by uttering speech commands into a voice
`enabled device, said at least one remote system
`comprising an outdoor lighting system, an indoor
`lighting system, a security system, a heating system, or
`an air conditioning system, said method comprising
`the steps of: .......................................................................... 46
`[1A]/[16A]: providing a computer operatively
`connected to the internet, … ................................................ 47
`[1Ai]/[16Ai]: said computer further being operatively
`connected to at least one speaker-independent speech
`recognition engine ................................................................ 53
`[9B]: at least one speaker-independent speech recognition
`engine, said speaker-independent speech recognition
`engine operatively connected to said computer; .................. 53
`[1Aii]/[16Aii]: [and said computer further being
`operatively connected to] at least one speech synthesis
`engine; .................................................................................. 57
`[1B]/[16B]: providing a voice enabled device
`operatively connected to said computer, said voice
`enabled device configured to receive speech
`commands from users; ......................................................... 58
`[1C]/[16C]: providing at least one instruction set
`stored in a database operatively connected to said
`computer, ............................................................................. 61
`[1Ci]/[16Ci]/[9Ei]: said instruction set comprising: at
`least one internet address, said at least one internet
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`e.
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`f.
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`U.S. Patent No. 7,386,455
`DECLARATION OF STUART J. LIPOFF
`address identifying the location of said at least one
`remote system, said at least one remote system
`configured to execute at least one pre-selected
`function; and ........................................................................ 64
`[1Cii]/[16Cii]/[9Eii]: [said instruction set comprising:]
`said at least one pre-selected function; ................................ 69
`[16Ciii]: said pre-selected function comprising turning
`the outdoor lighting on, turning the outdoor lighting
`off, dimming the outdoor lighting, turning the indoor
`lighting on, turning the indoor lighting off, dimming
`the indoor lighting, arming the security system,
`disarming the security system, turning the heating
`system on, turning the heating system off adjusting the
`heating system temperature, turning the air
`conditioning on, turning the air conditioning off, or
`adjusting the air conditioning temperature; ......................... 71
`[9F]: at least one recognition grammar stored in said
`database, each said recognition grammar
`corresponding to each said instruction set and
`corresponding to a speech command; .................................. 73
`[1D]/[16D]: providing a speech command to said
`speaker-independent speech recognition engine, said
`speech command corresponding to said instruction set; ..... 75
`[1E]/[16E]: said speaker-independent speech
`recognition engine assigning said speech command to
`a recognition grammar, said speech command and said
`recognition grammar corresponding to said instruction
`set; ........................................................................................ 76
`[1F]/[16F]: transmitting said speech command to said
`speaker-independent speech recognition engine; ................ 78
`[1G]/[16G]: said speaker-independent speech
`recognition engine receiving said speech command
`and selecting the corresponding recognition grammar
`upon receiving said speech command; ................................ 79
`[9G]: said speaker-independent speech recognition engine
`configured to receive from users via said phone a
`speech command and to select the corresponding
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`U.S. Patent No. 7,386,455
`DECLARATION OF STUART J. LIPOFF
`recognition grammar upon receiving said speech
`command; ............................................................................. 79
`[1H]/[16H]: said computer retrieving said instruction
`set corresponding to said recognition grammar selected
`by said speaker-independent speech recognition
`engine; .................................................................................. 81
`[9H]: said computer configured to retrieve said instruction
`set corresponding to said recognition grammar selected
`by said speaker-independent speech recognition
`device; .................................................................................. 81
`[1I]/[16I]: said computer accessing said at least one
`remote system identified by said instruction set to
`prompt said at least one remote system to execute said
`at least one pre-selected function; and ................................. 81
`[9I]: said computer further configured to access said at least
`one remote system identified by said instruction set to
`prompt said at least one remote system to execute said
`at least one pre-selected function; and ................................. 81
`[1J]/[16J]/[9J]: said at least one remote system
`executing said at least one pre-selected function. ................ 82
`[16K]: said computer periodically polling said at least
`one remote system to determine whether said at least
`one remote system is operational or out of service. ............ 83
`3. Dependent Claims 2-8 and 10-15.................................................. 86
`a. Claim 2: The method of claim 1 wherein said at least
`one remote system comprises a home-based system. .......... 86
`b. Claim 3: The method of claim 2 wherein said system is
`selected from the group consisting of: outdoor lighting,
`indoor lighting, security system, heating system, and
`air conditioning system. ....................................................... 87
`c. Claim 4: The method of claim 3 wherein said at least
`one pre-selected function is selected from the group
`consisting of: turning the outdoor lighting on, turning
`the outdoor lighting off, dimming the outdoor lighting,
`turning the indoor lighting on, turning the indoor
`lighting off, dimming the indoor lighting, arming the
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`U.S. Patent No. 7,386,455
`DECLARATION OF STUART J. LIPOFF
`security system, disarming the security system, turning
`the heating system on, turning the heating system off,
`adjusting the heating system temperature, turning the
`air conditioning on, turning the air conditioning off,
`and adjusting the air conditioning temperature. .................. 88
`d. Claim 5: The method of claim 1 wherein said at least
`one remote system comprises an office-based system. ....... 88
`e. Claim 6: The method of claim 5 wherein said system is
`selected from the group consisting of: outdoor lighting,
`indoor lighting, security system, heating system, and
`air conditioning system. ....................................................... 89
`f. Claim 7: The method of claim 6 wherein at least one
`pre-selected function is selected from the group
`consisting of: turning the outdoor lighting on, turning
`the outdoor lighting off, dimming the outdoor lighting,
`turning the indoor lighting on, turning the indoor
`lighting off, dimming the indoor lighting, arming the
`security system, disarming the security system, turning
`the heating system on, turning the heating system off,
`adjusting the heating system temperature, turning the
`air conditioning on, turning the air conditioning off,
`and adjusting the air conditioning temperature. .................. 89
`g. Claim 8: The method of claim 1 further comprising the
`step of periodically polling said at least one remote
`system to determine whether said remote system is
`operational or out of service. ............................................... 89
`h. Claim 10: The system of claim 9 wherein said phone
`comprises a standard telephone, a cellular phone, or an
`IP phone. .............................................................................. 89
`Claim 11: The system of claim 9 wherein said internet
`is a local area network. ........................................................ 90
`Claim 12: The system of claim 9 wherein said internet
`is a wide area network. ........................................................ 91
`k. Claim 13: The system of claim 9 wherein said internet
`is the Internet. ....................................................................... 92
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`DECLARATION OF STUART J. LIPOFF
`Claim 14: The system of claim 9 wherein said at least
`one remote system is selected from the group
`consisting of: outdoor lighting, indoor lighting,
`security system, heating system, and air conditioning
`system. ................................................................................. 92
`m. Claim 15: The system of claim 14 wherein said at least
`one pre-selected function is selected from the group
`consisting of: turning the outdoor lighting on, turning
`the outdoor lighting off, dimming the outdoor lighting,
`turning the indoor lighting on, turning the indoor
`lighting off, dimming the indoor lighting, arming the
`security system, disarming the security system, turning
`the heating system on, turning the heating system off,
`adjusting the heating system temperature, turning the
`air conditioning on, turning the air conditioning off,
`and adjusting the air conditioning temperature. .................. 93
`XII. SECONDARY CONSIDERATIONS ........................................................... 93
`XIII. CONCLUSION .............................................................................................. 93
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`U.S. Patent No. 7,386,455
`DECLARATION OF STUART J. LIPOFF
`LISTING OF EXHIBITS
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`Exhibit Description
`1001
`U.S. Patent No. 7,386,455
`1002
`Declaration of Mr. Stuart J. Lipoff
`1003
`Curriculum Vitae of Mr. Stuart J. Lipoff
`1004
`INTENTIONALLY LEFT BLANK
`1005
`INTENTIONALLY LEFT BLANK
`1006
`INTENTIONALLY LEFT BLANK
`1007
`INTENTIONALLY LEFT BLANK
`1008
`EP0911808A1 (“Buchner”)
`1009
`U.S. Patent No. 5,086,385 (“Launey”)
`1010
`INTENTIONALLY LEFT BLANK
`1011
`INTENTIONALLY LEFT BLANK
`1012
`INTENTIONALLY LEFT BLANK
`1013
`INTENTIONALLY LEFT BLANK
`1014
`INTENTIONALLY LEFT BLANK
`1015
`INTENTIONALLY LEFT BLANK
`1016
`INTENTIONALLY LEFT BLANK
`1017
`INTENTIONALLY LEFT BLANK
`1018
`INTENTIONALLY LEFT BLANK
`1019
`INTENTIONALLY LEFT BLANK
`1020
`Claim Mapping Table
`1021
`Prosecution History of U.S. Patent Application No. 11/409,703 (U.S.
`Patent No. 7,386,455)
`U.S. Patent No. 5,855,020
`U.S. Patent No. 6,085,160
`U.S. Patent No. 6,434,524
`INTENTIONALLY LEFT BLANK
`INTENTIONALLY LEFT BLANK
`INTENTIONALLY LEFT BLANK
`INTENTIONALLY LEFT BLANK
`Petitioner’s Stipulation Letter to Patent Owner, dated Jan. 7, 2022
`INTENTIONALLY LEFT BLANK
`Redline Comparison of Provisional Applications
`U.S. Patent No. 6,418,433
`Evolution of Magnetic Storage by L.D. Stevens (1981)
`U.S. Patent No. 6,285,999
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`1022
`1023
`1024
`1025
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`U.S. Patent No. 7,386,455
`DECLARATION OF STUART J. LIPOFF
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`1039
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`Exhibit Description
`1035
`Scientific American: Feature Article: “Hypersearching the Web”: June
`1999 by Members of the Clever Project
`(https://www.cs.cornell.edu/home/kleinber/sciam99.html)
`“NLP Meets the Jabberwocky: Natural Language Processing in
`Information Retrieval” by Susan Feldman, May 1999
`“Information Retrieval on the Web” by MEI KOBAYASHI and
`KOICHI TAKEDA, IBM Research, ACM Computing Surveys, Vol.
`32, No. 2, June 2000
`INFORMATION RETRIEVAL USING STATISTICAL
`CLASSIFICATION by Hull – 1994
`Search Engines for the World Wide Web: A Comparative Study and
`Evaluation Methodology, by Heting Chu and Marilyn Rosenthal, 1996
`U.S. Provisional Application No. 60/233,068 (’068 provisional), filed
`September 15, 2000
`Ratnayake, Nimal & Savic, M. & Sorensen, Jeffrey, “Use of semi-
`Markov models for speaker-independent phoneme recognition.
`Acoustics, Speech, and Signal Processing,” IEEE International
`Conference on Acoustics, Speech and Signal Processing, pp. 565-568
`(1992)
`Chen, Walter Y., “Emerging Home Digital Networking Needs,” 1997
`Fourth International Workshop on Community Network Processing,
`pp. 7-12 (1997)
`Loen, Vance and Miller, Eugene, “Subscriber Terminal Unites for
`Video Dial Tone Systems” IEEE Network, pp. 48-57
`(September/October 1995)
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`1036
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`1037
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`1038
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`1040
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`1041
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`1042
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`1043
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`I.
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`U.S. Patent No. 7,386,455
`DECLARATION OF STUART J. LIPOFF
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`INTRODUCTION
`1.
`I have been retained by Google LLC (“Google” or “Petitioner”) as an
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`independent expert consultant in this inter partes review (“IPR”) proceeding
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`before the United States Patent and Trademark Office (“PTO”).
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`2.
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`I have been asked by Google Counsel (“Counsel”) to consider
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`whether certain references teach or suggest the features recited in Claims 1-16 (the
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`“challenged claims”) of U.S. Patent No. 7,386,455 (“the ’455 Patent”) (Ex-1001).
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`My opinions and the bases for my opinions are set forth below.
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`3.
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`I am being compensated at my ordinary and customary consulting rate
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`for my work, which is $375 per hour. My compensation is in no way contingent on
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`the nature of my findings, the presentation of my findings in testimony, or the
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`outcome of this or any other proceeding. I have no other financial interest in this
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`proceeding.
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`II. BACKGROUND AND QUALIFICATIONS
`4.
`All of my opinions stated in this declaration are based on my own
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`personal knowledge and professional judgment. In forming my opinions, I have
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`relied on my knowledge and experience in designing, developing, researching, and
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`teaching the technology referenced in this declaration.
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`5.
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`I am over 18 years of age and, if I am called upon to do so, I would be
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`competent to testify as to the matters set forth herein. I understand that a copy of
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`U.S. Patent No. 7,386,455
`DECLARATION OF STUART J. LIPOFF
`my current curriculum vitae, which details my education and professional and
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`academic experience, is being submitted as Ex-1003. The following provides a
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`brief overview of some of my experience that is relevant to the matters set forth in
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`this declaration.
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`6.
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`I am currently president of IP Action Partners Inc., a consulting
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`practice that serves the telecommunications, information technology, media,
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`electronics, and e-business industries.
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`7.
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`I earned a Bachelor of Science degree in Electrical Engineering in
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`1968 and a second Bachelor of Science degree in Engineering Physics in 1969,
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`both from Lehigh University. I earned a Master of Science degree in Electrical
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`Engineering from Northeastern University in 1974, and then a Master of Business
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`Administration degree from Suffolk University in 1983.
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`8.
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`I hold a Federal Communications Commission (“FCC”) General
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`Radiotelephone License. I also hold a Certificate in Data Processing from the
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`Institute for the Certification of Computing Professionals (“ICCP”), which is
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`supported by the Association for Computing Machinery (“ACM”).
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`9.
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`I am also a registered professional engineer (PE) in the
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`Commonwealth of Massachusetts and in the State of Nevada.
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`10.
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`I am a fellow of the Institute of Electrical and Electronics Engineers
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`(“IEEE”) Consumer Electronics, Communications, Computer, Circuits, and
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`U.S. Patent No. 7,386,455
`DECLARATION OF STUART J. LIPOFF
`Vehicular Technology Groups. I have been a member of the IEEE Consumer
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`Electronics Society National Board of Governors (formerly known as the
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`Administrative Committee) since 1981, and I was Boston Chapter Chairman of the
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`IEEE Vehicular Technology Society from 1974 to 1976. I served as the 1996-1997
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`President of the IEEE Consumer Electronics Society, and from 1999 to 2018 I
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`served as Chairman of the Society’s Technical Activities and Standards Committee
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`and as Vice President of Publications for the Society. Since 2018 I have served as
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`Vice President of Standards and Industry Activities for the Society. I have also
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`served as an Ibuka Award committee member for the IEEE’s Award in the field of
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`consumer electronics.
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`11.
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`I have prepared and presented numerous papers at the IEEE and at
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`other professional meetings. For example, in fall 2000, I served as general program
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`chair for IEEE’s Vehicular Technology Conference on advanced wireless
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`communication technology. I have organized sessions at The International
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`Conference on Consumer Electronics, and I was the 1984 program chairman. I
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`conducted an eight-week IEEE-sponsored short course on Fiber Optics System
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`Design. I received IEEE’s Centennial Medal in 1984, and I received IEEE’s
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`Millennium Medal in 2000.
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`12. As Vice President and Standards Group Chairman for the Association
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`of Computer Users (“ACU”) from 1980 to 1983, I served as the ACU
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`U.S. Patent No. 7,386,455
`DECLARATION OF STUART J. LIPOFF
`representative to the ANSI X3 Standards Group. From 1976 to 1978, I served as
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`Chairman of the task group on user rule compliance for the FCC’s Citizens
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`Advisory Committee on Citizen’s Band Radio.
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`13. Over the last 25 years, I have been a member of the Society of Cable
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`Television Engineers, the Association for Computing Machinery, and The Society
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`of Motion Picture and Television Engineers. From 2001 to 2004, I served as a
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`member of the USA advisory board to the National Science Museum of Israel. In
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`1998, I presented a short course on international product development strategies as
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`a faculty member for Technion Institute of Management in Israel. From 2001 to
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`2003, I served as a member of the board or directors of The Massachusetts Future
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`Problem Solving Program.
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`14.
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`I am a named inventor on seven United States patents and have
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`several publications on data communications in publications, including Electronics
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`Design, Microwaves, EDN, the Proceedings of the Frequency Control Symposium,
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`Optical Spectra, and IEEE publications.
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`15. During my professional career dating from 1969 to the present, I have
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`been heavily engaged in the study, analysis, evaluation, design, and
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`implementation of products and technology associated with consumer electronics
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`and electronic appliances. A particular focus of my professional activities has been
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`improving the man-machine interface including voice, speech, and speaker
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`U.S. Patent No. 7,386,455
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`recognition for man-machine interactions. I also have extensive experience in
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`studying foundation technologies and the applications supporting home
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`automation, home appliance control, residential energy management, and home
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`security and monitoring.
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`16. For approximately three years, from 1969 to 1972, I served as Project
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`Engineer for Motorola’s Communications Division, where I had project design
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`responsibilities for paging and wireless communication products. Projects I worked
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`on while employed at Motorola included work on paging systems that included
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`digital voice storage, voice compression, and voice synthesis. I also worked on
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`projects that interfaced wireless data communications terminals to public safety
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`computer systems for mobile data retrieval and data entry.
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`17. For approximately four years, from 1972 to 1976, I served as Section
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`Manager for Bell & Howell Communications Company, where I also had project
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`design responsibilities for paging and wireless communication products. The
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`projects I supported included covert audio intelligence systems that recognized
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`speech and activated digital voice compression recording systems. I also led
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`projects for voice-based radio paging systems that recorded speech input,
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`processed the speech to remove silence, processed the speech to digitally compress
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`the speech, and store and forward the speech upon demand from DTMF or
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`computer keyboard retrieval from the servers.
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`U.S. Patent No. 7,386,455
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`18. For 25 years from 1976 to 2001, I worked for Arthur D. Little, Inc.
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`(ADL), where I became the Vice President and Director of Communications,
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`Information Technology, and Electronics (CIE) and served in that role for 10
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`years, from 1991 to 2001. At ADL, I was responsible for the firm’s global CIE
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`practice in laboratory-based contract engineering, product development, and
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`technology-based consulting. I was also involved in multiple pioneering efforts to
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`identify and explore customer-to-business and business-to-business electronic
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`commerce and transactions information processing opportunities (e-commerce).
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`These projects involved technology assessment and analysis as well as developing
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`architectures and systems to support multiple applications, and typically involved
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`an information retrieval component.
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`19. While at ADL, I worked on several projects involving the
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`combination of voice interfaces (including speech recognition and voice audio
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`output) and information retrieval as well as working on projects for utilities,
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`service providers, and consumer electronics OEMs for home automation and
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`energy management. For example, over the course of three years in the early-
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`1990s, I worked on a project for Bolt Beranek and Newman (BB&N), where I
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`evaluated and benchmarked technology for a voice input/output application that
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`allowed end users (e.g., travel agents) to use speech inputs to interact with airline
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`reservation databases to retrieve information about travel reservation options,
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`U.S. Patent No. 7,386,455
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`where the results were returned to the user in an audible message. This system
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`included a natural language front-end speech-interface module with speech
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`recognition that used pre-defined recognition grammars to convert the end user’s
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`speech into structured commands supported by an airline reservation system. As
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`another example, over the course of three years in the mid-1990s, I worked on a
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`project for Texas Instruments that applied a speech-recognition interface for a
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`variety of applications that retrieved information from database servers. My work
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`for electric, gas, and water utilities included a focus on remote and automatic meter
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`reading and energy management of appliances and residential HVAC systems.
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`20. Other projects that I worked on at various points in my 25 years at
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`ADL and afterwards that involved speech recognition technologies included the
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`following.
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`21. Over the course of three years in the early 1990s, I worked on a voice-
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`interface project developing spoken digit telephone number recognition and
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`voiceprint matching for Sprint’s long distance alternative access telephone
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`services.
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`22. Over the course of a year in the late 1980s, I worked on a voice
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`interface project evaluating the processing power needed to perform various voice
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`recognition applications by Rockwell Semiconductor’s signal processing
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`technology.
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`U.S. Patent No. 7,386,455
`DECLARATION OF STUART J. LIPOFF
`23. Other projects that I worked on at various points in my 25 years at
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`ADL that involved information-retrieval technologies included the following.
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`24. Over the course of 15 years starting in the early 1980’s, I worked on a
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`project for the United States Postal Service (USPS), where we developed a real-
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`time automated postal teller system that served as an interface between end-users
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`and the USPS’s information systems. This system included voice prompts for the
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`vision impaired.
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`25. Over the course of two years in the early 1990’s, I worked on a
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`project for the grocery industry consortium of The Food Marketing Institute and
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`The Grocery Manufacturers Association, where I developed standards used by the
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`industry for direct exchange electronic data interchange (DEX/UCS EDI). This
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`project involved developing a business model for vendors who make direct store
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`delivery of merchandise to retail stores (e.g., fast-moving goods that do not come
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`via a warehouse such as soda, meat, bread) so that legacy paper receipts and
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`signature could be captured on hand-held portable computers and then uploaded to
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`the vendors’ billing computers at some later time to generate invoices.
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`26. Over the course of two years in the early 1990’s, I worked on a
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`project for MasterCard and Visa, where I supported a project exploring the
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`applications and security issues associated with the use of smart cards in
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`eCommerce. This project explored both physical security properties of the card
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`16
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`Petitioner Google Ex-1002, 0017
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`U.S. Patent No. 7,386,455
`DECLARATION OF STUART J. LIPOFF
`media as well as issues associated with the back-end information processing
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`servers. For example, I explored electronic watermarks resident on a credit card
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`where the watermark digital content was captured at point of sale and then
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`uploaded to the back-end credit card processor so that the card media could be
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`authenticated as genuine.
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`27. Over the course of two years in the late 1970s, I worked on a project
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`for a multi-client consortium of newspapers and information publishers, where I
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`participated in a project to understand opportunities for electronic home
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`information and transaction services using both dedicated videotext terminals as
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`well as home computers. The project was focused on providing end consumers in
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`ordinary households with the means to read newspapers, interact with classified
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`advertising, send messages, access telephone directors, and search for information.
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`28. Over the course of two years in the late 1980s, I worked on a project
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`in support of a multi-client study of new opportunities for financial industry firms,
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`where I studied the security and encryption requirements to support electronic
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`banking. This work involved consideration of counterfeit projection for media,
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`physical security of systems, and the development of security protocols for home
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`banking videotex terminals. This project focused on providing ordinary end
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`consumer households with the means to conduct home banking in a secure and
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`simple interface via a keyboard and visual display.
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`17
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`Petitioner Google Ex-1002, 0018
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`U.S. Patent No. 7,386,455
`DECLARATION OF STUART J. LIPOFF
`I also have extensive experience in public and private network wired
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`29.
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`and wireless voice telecommunications while employed by Motorola, Bell &
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`Howell, and Arthur D Little, and while self-employed. In the course of these
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`telecommunications projects ranging from 1969 to the present, I have encountered
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`a number of applications where audio input and voice are used to activate devices,
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`for example for the purpose of saving battery power by entering into low power,
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`so-called “sleep” modes. These projects have involved the design of cellular
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`telecommunications systems that implement industry standard means of entering
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`lower power modes in the absence of voice.
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`30. Examples of other projects that I worked on at various points in my 25
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`years at ADL and afterwards that involved home automation, control, and energy
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`management included.
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`31. Support of a unique two-way power line carrier system from electric
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`utility substations to served homes for automatic meter reading and load
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`management to cycle air conditioners and heating systems. The system was
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`deployed by New England Electric Systems and sold worldwide by Emerson
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`Electric.
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`32.
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`I have served for over 30 years as a member of the IEEE International
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`Conference on Consumer Electronics (ICCE) annual technical conference as a
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`member of technical program committee track on home automation and control. In
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`18
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`Petitioner Google Ex-1002, 0019
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`U.S. Patent No. 7,386,455
`DECLARATION OF STUART J. LIPOFF
`this capacity, I reviewed dozens of research paper contributions under
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`consideration for presentation at the ICCE.
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`33. For Honeywell, I performed a project to study alternative technologies
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`suitable for in home network energy management and environmental control
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`including wireless thermostats. The project involved consideration of power line
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`carrier, wireless radio frequency