UNITED STATES PATENT AND TRADEMARK OFFICE
`
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________________
`
`ROKU, INC.,
`Petitioner,
`
`v.
`
`MEDIA CHAIN, LLC,
`Patent Owner.
`
`Case No. IPR2022-00391
`U.S. Patent No. 10,489,560
`_____________________
`
`DECLARATION OF JOHN TINSMAN IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW OF U.S. PATENT NO. 10,489,560
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`EX1002
`Roku V. Media Chain
`U.S. Patent No. 10,489,560
`
`

`

`
`
`Declaration of John Tinsman
`U.S. Pat. No. 10,489,560
`
`TABLE OF CONTENTS
`
`INTRODUCTION ........................................................................... 1
`QUALIFICATIONS ........................................................................ 2
`MATERIALS CONSIDERED ......................................................... 9
`RELEVANT LEGAL STANDARDS ............................................ 14
`A. Obviousness ............................................................................. 15
`B.
`Level of Skill in the Art ........................................................... 16
`C. Motivation to Combine and Hindsight Bias ............................. 17
`D.
`Claim Construction .................................................................. 18
`TECHNOLOGY BACKGROUND ................................................ 19
`A.
`Licensing and Distribution of Digital Media ............................ 20
` E-Commerce and the Digital Revolution ........................................ 20
` The Rise of Digital Rights Management Technology ..................... 21
` Cloud-Based Streaming and Licensing Models .............................. 24
`B.
`Digital Fingerprinting .............................................................. 25
`C.
`Targeted Marketing Based on User Demographics and
`Preferences .............................................................................. 29
` Targeted Marketing Over the Internet ............................................. 29
` Targeted Marketing Based on Users’ Negative Preferences ............ 33
`OVERVIEW OF THE ’560 PATENT ............................................ 36
`A.
`Summary of the Disclosure ...................................................... 36
` Licensing and Distributing Digital Media Content.......................... 38
` Targeted Marketing ........................................................................ 42
`B.
`Summary of the Claims ........................................................... 43
` Overview of the ’560 Patent Claims ............................................... 43
` The ’560 Patent Claims Relative to Other Claims in the Family ..... 47
`C.
`Summary of the Prosecution History........................................ 49
`OVERVIEW OF THE PRIOR ART .............................................. 50
`A.
`Peled ........................................................................................ 50
`
`- i -
`
`
`I.
`II.
`III.
`IV.
`
`V.
`
`VI.
`
`VII.
`
`
`
`

`

`Declaration of John Tinsman
`U.S. Pat. No. 10,489,560
`B.
`Brandstetter.............................................................................. 58
`Pou .......................................................................................... 65
`C.
`Levy......................................................................................... 70
`D.
`CLAIM CONSTRUCTION ........................................................... 76
`GROUND 1: CLAIMS 1-14, AND 16-19 OF THE ’560 PATENT
`ARE UNPATENTABLE UNDER 35 U.S.C. § 103 OVER PELED
`IN VIEW OF POU ......................................................................... 76
`A. Overview of the Combination of Peled and Pou....................... 77
` A POSA would have been motivated to combine Peled and Pou. ... 77
` A POSA would have known how to combine Peled and Pou and would
`have had a reasonable expectation of success. ................................ 82
`B.
`Independent Claim 1 ................................................................ 83
`[1P] “A computer implemented method for configuring a multimedia
`
`hardware device to enable an authorized stream of a media content item
`included in a digital media file, comprising:” ................................. 83
`[1A] “receiving a request from a user to stream the media content item;” 91
`[1B] “evaluating the request to stream to determine whether the user has
`acquired a license to stream the media content item and offering the
`license to stream the media content item to the user when the user does
`not have the license to stream the media content item;” ................. 95
`[1C] “after the evaluation of the request to stream, extracting user data that
`is specific to the user that is attempting to stream the media content item
`when the user at least one of streams and declines to stream the media
`content item, wherein the user data includes demographic data associated
`with the user that enables a third party online retailer that is providing the
`media content item to be streamed by the user to gauge at least one of a
`demographic that streamed the media content item of a copyright owner
`and a demographic that declined to stream the media content item of the
`copyright owner and the user data includes each media content item that
`the user streamed and each media content item that the user declined to
`stream that enables the third party online retailer to target marketing of
`different media content items to the user based on the demographic of the
`user and based on a history of media content items that the user has
`streamed and media content items that the user has declined to stream to
`determine a trend of interest in media content items by the user and to
`thereby target the marketing of the different media content items to the
`- ii -
`
`
`
`
`
`
`VIII.
`IX.
`
`
`
`
`

`

`Declaration of John Tinsman
`U.S. Pat. No. 10,489,560
`user based on the determined trend of interest associated with the
`user;”............................................................................................ 104
`(a) Peled discloses [1C.1] “after the evaluation of the request to stream,
`extracting user data that is specific to the user that is attempting to
`stream the media content item when the user at least one of streams and
`declines to stream the media content item” ............................... 105
`(b) Peled discloses [1C.2] “wherein the user data includes demographic data
`associated with the user that enables a third party online retailer that is
`providing the media content item to be streamed by the user to gauge at
`least one of a demographic that streamed the media content item of a
`copyright owner and a demographic that declined to stream the media
`content item of the copyright owner and” ................................. 108
`(c) Peled discloses [1C.3] “the user data includes each media content item
`that the user streamed and each media content item that the user
`declined to stream that enables the third party online retailer to target
`marketing of different media content items to the user based on the
`demographic of the user and based on a history of media content items
`that the user has streamed and media content items that the user has
`declined to stream” ................................................................... 114
`(d) Peled discloses [1C.4] “to determine a trend of interest in media content
`items by the user and to thereby target the marketing of the different
`media content items to the user based on the determined trend of
`interest associated with the user” .............................................. 118
`[1D] “aggregating the user data into a statistics record for the request to
`stream the media content item when the user streams or declines to stream
`the media content item, wherein the statistics record summarizes the user
`data associated with the request to steam the media content item;”120
`[1E] “storing in a license database the statistics record so that the user data
`is accessible to the third party online retailer that is providing the media
`content item to be streamed; and” ................................................ 121
`[1F] “analyzing a plurality of statistics records aggregated from each
`request to stream the media content item as provided by the third party
`online retailer to be streamed to provide the third party online retailer with
`the aggregated user data from each request to stream the media content
`item.” ........................................................................................... 127
`C.
`Independent Claim 6 .............................................................. 130
`
`
`
`
`
`
`
`
`
`
`- iii -
`
`

`

`Declaration of John Tinsman
`U.S. Pat. No. 10,489,560
` The combination of Peled and Pou discloses “a media content licensing
`and verification system” ............................................................... 133
` The combination of Peled and Pou discloses “wherein the request to
`stream includes digital media information associated with the media
`content item included in a digital media file and the digital media
`information includes at least one identification characteristic that is unique
`to the media content item that is included in the media content item when
`the media content item is initially created and not dependent on any
`encoding during any mastering of the media content item.” ......... 134
` The combination of Peled and Pou discloses “determining whether the
`request to stream is to be granted based on a media content record stored
`in a media catalog database that is associated with the media content
`item.” ........................................................................................... 138
`D.
`Independent Claim 11 ............................................................ 140
`E.
`Independent Claim 16 ............................................................ 144
`F.
`Claims 2 and 12 ..................................................................... 150
`G.
`Claims 3 and 13 ..................................................................... 156
`H.
`Claims 4, 9, 14, and 18 .......................................................... 159
`I.
`Claims 5 and 19 ..................................................................... 164
`J.
`Claims 7 and 17 ..................................................................... 165
`K.
`Claim 8 .................................................................................. 168
`L.
`Claim 10 ................................................................................ 169
`GROUND 2: CLAIM 15 OF THE ’560 PATENT IS
`UNPATENTABLE UNDER 35 U.S.C. § 103 OVER PELED IN
`VIEW OF POU AND BRANDSTETTER ................................... 170
`GROUND 3: CLAIMS 1-19 OF THE ’560 PATENT ARE
`UNPATENTABLE UNDER 35 U.S.C. § 103 OVER
`BRANDSTETTER IN VIEW OF LEVY ..................................... 172
`A. Overview of the Combination of Brandstetter and Levy ........ 173
` A POSA would have been motivated to combine Brandstetter and
`Levy. ............................................................................................ 173
` A POSA would have known how to combine Brandstetter and Levy and
`would have had a reasonable expectation of success. ................... 180
`B.
`Independent Claim 1 .............................................................. 182
`- iv -
`
`X.
`
`XI.
`
`
`
`
`

`

`
`
`
`
`
`
`Declaration of John Tinsman
`U.S. Pat. No. 10,489,560
`[1P]: “A computer implemented method for configuring a multimedia
`hardware device to enable an authorized stream of a media content item
`included in a digital media file, comprising:” ............................... 182
`[1A] “receiving a request from a user to stream the media content
`item;” ........................................................................................... 191
`[1B] “evaluating the request to stream to determine whether the user has
`acquired a license to stream the media content item and offering the
`license to stream the media content item to the user when the user does
`not have the license to stream the media content item;” ............... 192
`[1C] “after the evaluation of the request to stream, extracting user data that
`is specific to the user that is attempting to stream the media content item
`when the user at least one of streams and declines to stream the media
`content item, wherein the user data includes demographic data associated
`with the user that enables a third party online retailer that is providing the
`media content item to be streamed by the user to gauge at least one of a
`demographic that streamed the media content item of a copyright owner
`and a demographic that declined to stream the media content item of the
`copyright owner and the user data includes each media content item that
`the user streamed and each media content item that the user declined to
`stream that enables the third party online retailer to target marketing of
`different media content items to the user based on the demographic of the
`user and based on a history of media content items that the user has
`streamed and media content items that the user has declined to stream to
`determine a trend of interest in media content items by the user and to
`thereby target the marketing of the different media content items to the
`user based on the determined trend of interest associated with the
`user;”............................................................................................ 203
`(a) Brandstetter discloses [1C.1] “after the evaluation of the request to
`stream, extracting user data that is specific to the user that is attempting
`to stream the media content item when the user at least one of streams
`and declines to stream the media content item” ........................ 204
`(b) Brandstetter discloses [1C.2] “wherein the user data includes
`demographic data associated with the user that enables a third party
`online retailer that is providing the media content item to be streamed
`by the user to gauge at least one of a demographic that streamed the
`media content item of a copyright owner and a demographic that
`declined to stream the media content item of the copyright owner and”
` ................................................................................................. 208
`
`
`
`
`
`
`- v -
`
`

`

`
`
`
`
`
`
`Declaration of John Tinsman
`U.S. Pat. No. 10,489,560
`(c) Brandstetter discloses [1C.3] “the user data includes each media content
`item that the user streamed and each media content item that the user
`declined to stream that enables the third party online retailer to target
`marketing of different media content items to the user based on the
`demographic of the user and based on a history of media content items
`that the user has streamed and media content items that the user has
`declined to stream.” .................................................................. 218
`(d) Brandstetter discloses [1C.4] “to determine a trend of interest in media
`content items by the user and to thereby target the marketing of the
`different media content items to the user based on the determined trend
`of interest associated with the user” .......................................... 221
`[1D] “aggregating the user data into a statistics record for the request to
`stream the media content item when the user streams or declines to stream
`the media content item, wherein the statistics, record summarizes the user
`data associated with the request to steam the media content item;”222
`[1E] “storing in a license database the statistics record so that the user data
`is accessible to the third party online retailer that is providing the media
`content item to be streamed; and” ................................................ 224
`[1F] “analyzing a plurality of statistics records aggregated from each
`request to stream the media content item as provided by the third party
`online retailer to be streamed to provide the third party online retailer with
`the aggregated user data from each request to stream the media content
`item.” ........................................................................................... 229
`C.
`Independent Claim 6 .............................................................. 237
` The combination of Brandstetter and Levy discloses “a media content
`licensing and verification system” ................................................ 240
` The combination of Brandstetter and Levy discloses “wherein the request
`to stream includes digital media information associated with the media
`content item included in a digital media file and the digital media
`information includes at least one identification characteristic that is unique
`to the media content item that is included in the media content item when
`the media content item is initially created and not dependent on any
`encoding during any mastering of the media content item.” ......... 241
` The combination of Brandstetter and Levy discloses discloses
`“determining whether the request to stream is to be granted based on a
`media content record stored in a media catalog database that is associated
`with the media content item.” ....................................................... 247
`
`
`
`
`- vi -
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`

`

`Declaration of John Tinsman
`U.S. Pat. No. 10,489,560
`D.
`Independent Claim 11 ............................................................ 250
`Independent Claim 16 ............................................................ 253
`E.
`Claims 2 and 12 ..................................................................... 259
`F.
`Claims 3 and 13 ..................................................................... 263
`G.
`Claims 4, 9, 14, 18 ................................................................. 266
`H.
`Claims 5 and 19 ..................................................................... 271
`I.
`Claims 7 and 17 ..................................................................... 272
`J.
`Claim 8 .................................................................................. 276
`K.
`Claims 10 and 15 ................................................................... 281
`L.
`OTHER EVIDENCE RELEVANT TO OBVIOUSNESS ............ 283
`
`XII.
`
`
`
`
`- vii -
`
`

`

`
`
`Declaration of John Tinsman
`U.S. Pat. No. 10,489,560
`
`I, John Tinsman, declare as follows:
`
`INTRODUCTION
`I have been engaged by Sterne, Kessler, Goldstein & Fox P.L.L.C. on
`
`
`
`I.
`
`behalf of Roku, Inc. (“Roku”) to provide this Declaration concerning technical
`
`subject matter relevant to the inter partes review of U.S. Patent No. 10,489,560 (“the
`
`’560 Patent”), which is entitled “Digital media reproduction and licensing.”
`
`
`
`I am over 18 years of age. I have personal knowledge of the facts stated
`
`in this Declaration.
`
`
`
`I have reviewed and am familiar with the specification, claims, and
`
`prosecution history of the ’560 Patent. I will cite to the specification of a U.S. Patent
`
`using the following format: (Column:Line Number(s)). For example, the citation to
`
`the ’560 Patent, 1:1-10 points to the ’560 Patent specification at column 1, lines 1-
`
`10.
`
`
`
`In forming my opinions expressed in this Declaration, I have reviewed
`
`and, in some cases, relied upon the list of materials provided in Section III in
`
`preparation of this Declaration. To the best of my knowledge, those exhibits listed
`
`in Section III are true and accurate copies of what they purport to be. An expert in
`
`the field would reasonably rely on them to formulate opinions such as those set forth
`
`in this Declaration.
`
`
`
`- 1 -
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`

`

`Declaration of John Tinsman
`U.S. Pat. No. 10,489,560
`I am being compensated at my standard rate of $300/hour by Roku for
`
`
`
`my time spent in connection with this proceeding. My compensation is not
`
`dependent on and in no way affects, the substance of my opinions. Nor is my
`
`compensation dependent on the outcome of this proceeding. My findings are based
`
`on my education, experience, and background in the fields discussed below.
`
`II. QUALIFICATIONS
` My academic and professional pursuits are closely related to the subject
`
`matter of the ’560 Patent. Based on my education and work experience, I am well
`
`qualified to serve as a technical expert in this matter.
`
`
`
`A summary of my educational and professional experience is set forth
`
`in my curriculum vitae “CV”, which is submitted as Exhibit 1015. Some of the
`
`relevant points in my CV are described below.
`
`
`
`I received a Bachelor’s degree and Master’s degree in Physics from the
`
`University of California, Santa Barbara in 1981 and 1983, respectively. My
`
`specialization for my Master’s degree was medical and scientific instrumentation. I
`
`also received a Master’s in Business Administration from San Jose State University
`
`in 1995. I am a member of the Institute of Electrical and Electronics Engineers
`
`(IEEE) and a registered U.S. Patent and Trademark Office patent agent (Registration
`
`No. 73,427).
`
`
`
`- 2 -
`
`

`

`Declaration of John Tinsman
`U.S. Pat. No. 10,489,560
`Although originally trained as a physicist, I have more than 35 years of
`
`
`
`experience designing, developing, and deploying hardware and software for
`
`scientific, consumer, industrial, and professional environments. I also have extensive
`
`experience in engineering management and business development, including the
`
`management of multinational teams. I have worked for a range of organizations,
`
`from academic institutions such as the Stanford Linear Accelerator Center (SLAC)
`
`at Stanford University and the Signal Processing Laboratory at the École
`
`Polytechnqiue Fédérale de Lausanne (EPFL), to pioneers in multimedia and digital
`
`television, such as Radius, Inc., OpenTV Inc., Qualcomm, and the Kudelski Group.
`
`In that time, I have published a number of papers and made numerous presentations
`
`at academic and professional conferences, as well as before the European
`
`Commission.
`
`
`
`I specialize in the areas of analog and digital signal processing and
`
`communications, and the command and control functions that generally accompany
`
`them. From 1985 to 1989, I developed analog and digital signal processing hardware
`
`and software for data acquisition systems in high energy physics experiments at
`
`SLAC. I also worked on the command and control systems used to operate, calibrate,
`
`and monitor such experiments, as well as the particle accelerator itself.
`
` From 1989 to 1995, I applied these skills to computer graphics and
`
`multimedia systems at Radius. Radius was a leader in high end graphics, and an early
`
`
`
`- 3 -
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`

`

`Declaration of John Tinsman
`U.S. Pat. No. 10,489,560
`developer of Macintosh-based audio and video multimedia systems. These systems
`
`included multimedia ingest, editing, processing, compression, and delivery,
`
`including server-based delivery over networks. Key markets for these products
`
`included pre-press, television post-production, and video serving using video
`
`compression.
`
`
`
`I worked at Radius as an engineer and an engineering manager. Several
`
`of my projects were related to video editing and compression using various codecs,
`
`such as MPEG-2 and Cinepak. This work included video signal processing and video
`
`signal enhancement, as well as the more general aspects of post-production using
`
`Apple Computer’s QuickTime framework. These aspects included the use of time
`
`codes, edit lists, and other metadata to properly combine a collection of input tracks
`
`into the final multimedia output. My other technical activities included the
`
`development of high-speed networks, custom integrated circuits, and remote
`
`rendering and control of high-resolution graphics displays.
`
`
`
`I joined Visual Edge in 1995 as its Vice President of Engineering. I led
`
`a team of engineers in developing and supporting high performance image
`
`processing software for rendering and printing text and images on large format high-
`
`resolution digital printers. This work involved product definition and engineering,
`
`as well as research on algorithms for imaging and color calibration.
`
`
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`- 4 -
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`

`

`Declaration of John Tinsman
`U.S. Pat. No. 10,489,560
`In 1998, I moved to Switzerland to become a Principal Researcher at
`
`
`
`the EPFL, supervising a team of researchers and graduate students studying high
`
`performance signal processing. Specifically, this work involved using the then-new
`
`multimedia instruction sets appearing in microprocessors to accelerate audio, image
`
`and video processing, and compression on high-end desktop computers.
`
` My background in signal and media processing also provided me the
`
`opportunity to use my skills in related contexts. In 2000 and 2001, I consulted for a
`
`search engine company, Albert Inc., to develop a prototype voice navigation and
`
`control module for their textual search engine. The target environment for the
`
`prototype was high-end automobiles, with the goal of enabling voice-based searches
`
`for information and services related to the user’s location. As a result, I worked
`
`extensively to understand a number of fundamental challenges to gathering,
`
`processing, and recognizing speech in an automotive environment.
`
` During this period, I also consulted with Pinnacle Systems, a
`
`manufacturer of digital video hardware and software for the consumer and broadcast
`
`markets. I developed video signal processing algorithms for Pinnacle’s custom
`
`broadcast television graphics integrated circuits and cards, with an emphasis on
`
`noise reduction to improve image quality and compressibility.
`
` From 2001 to 2007, I worked at OpenTV Inc. as a director in the Office
`
`of the Chief Technology Officer. OpenTV was a premier provider of set-top box
`
`
`
`- 5 -
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`

`

`Declaration of John Tinsman
`U.S. Pat. No. 10,489,560
`middleware for cable and satellite platforms and was deeply involved in technology
`
`development and standards making for digital and interactive pay television. In that
`
`position, I worked both as a product architect in Europe and as OpenTV’s
`
`representative at standards groups, such as the Digital Video Broadcasting (DVB)
`
`Project. My architectural job activities included working with other technology
`
`providers, including companies that provided conditional access and Video on
`
`Demand (VOD)
`
`technologies for
`
`integration with OpenTV’s set-top box
`
`middleware, as well as OpenTV’s own products for content recording and playback.
`
`My standards work included contributions at the DVB to various technical and
`
`market development working groups, as well as at the steering board level. This
`
`work included significant involvement in the DVB’s standardization efforts around
`
`their Multimedia Home Platform (MHP) standard for a TV-based interactive
`
`television.
`
` From 2007 to 2009, I worked at Qualcomm Inc. as a Product Manager,
`
`supporting the company’s MediaFLO technology. MediaFLO was a technology for
`
`transmitting audio, video, and data to portable devices, such as mobile phones. The
`
`broadcast media transmitted via MediaFLO included live, real-time audio and video
`
`streams, as well as scheduled video and audio clips and shows. My duties included
`
`providing technology strategy, requirements analysis, and customer support for the
`
`MediaFLO technology.
`
`
`
`- 6 -
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`

`

`Declaration of John Tinsman
`U.S. Pat. No. 10,489,560
` From 2009 to 2014, I returned to OpenTV as its Vice President of
`
`Engineering in the Advanced Advertising Group. In this role, I was responsible for
`
`architectures, technologies, and product development for OpenTV’s advanced
`
`advertising, and engagement solutions across multiple platforms. This work
`
`included the ingest and processing of television program and schedule information,
`
`such as would be used for advertising schedules or electronic program guides. This
`
`work also involved searching, categorizing, and reporting such information for the
`
`purposes of ad placements and ad verifications. I also led the design and
`
`development of a real-time advertising analytics platform. This work involved
`
`extensive processing and presentation of advertising and program schedule
`
`information, including database and user interface design and implementation.
`
` From 2014 to 2017, I served as the Chief Technologist for the Kudelski
`
`Group’s Intellectual Property and Innovation Group. In this role, I supported
`
`inventors and the innovation process across multiple technologies, including
`
`multimedia systems related to content ingest, protection, delivery, and consumption.
`
`I also supported the company’s licensing and acquisition efforts.
`
` Currently, I am the Chief Executive Officer of GadgetJazz, an
`
`engineering design and innovation practice founded in 2017. Leveraging my past
`
`technical experiences, I perform consulting services related to technology and
`
`business development, specifically in the areas of multimedia and communications
`
`
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`- 7 -
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`

`

`Declaration of John Tinsman
`U.S. Pat. No. 10,489,560
`technologies, distributed systems, high performance computing, and consulting on
`
`innovation and the development of intellectual property.
`
`
`
`I am a named inventor on fourteen U.S. patents: (1) Patent No.
`
`10,387,920 titled “System and Method for Offering and Billing Advertisement
`
`Opportunities”; (2) Patent No. 10,235,788, titled “Overlay Contrast Control in
`
`Augmented Reality Displays”; (3) Patent No. 10,152,815, titled “Overlay Emphasis
`
`Modification in Augmented Reality Displays”; (4) Patent No. 10,044,873, titled
`
`“Mute Alert”; (5) Patent No. 10,038,859, titled “Same Screen, Multiple Content
`
`Viewing Method and Apparatus”; (6) Patent No. 10,032,192, titled “Automatic
`
`Localization of Advertisements”; (7) Patent No. 9,877,054, titled “Dynamic
`
`Scheduling for Advanced Advertising in Linear Television”; (8) Patent No.
`
`9,799,048, titled “Intelligent Tool to Support Manual Scheduling of Ads”; (9) Patent
`
`No. 9,711,128, titled “Combined Audio for Multiple Content Presentation”; (10) –
`
`(13) Patent Nos. 9,344,470, 8,782,305, 8,335,873, and 7,930,449, all titled “Method
`
`and Systems for Data Transmission”; and (14) Patent No. D759,684, titled “Display
`
`Screen with a Graphical User Interface.” I am also the named inventor on three
`
`European patents: (1) No. 2,700,200, titled “Methods and Systems for Data
`
`Transmission”; (2) No. 2,602,996, titled “Dynamic Generation, Delivery, and
`
`Execution of Interactive Applications Over a Mobile Broadcast Network”; and (3)
`
`No. 1,912,441, titled “Buffering and Transmitting Video Data upon Request.”
`
`
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`

`

`Declaration of John Tinsman
`U.S. Pat. No. 10,489,560
` Based on my educational background and professional experience, I
`
`consider myself an expert in various technologies, including multimedia systems,
`
`embedded systems and middleware, content protection technologies, streaming
`
`media content, digital television systems, and client-server architectures. I also have
`
`significant experience in standards and standardization related to the DVB Project,
`
`the European Telecommunications Standards Institute (ETSI), and Cable Labs.
`
`III. MATERIALS CONSIDERED
`In formulating my opinions, I have relied upon my training, knowledge,
`
`
`and experience that are relevant to the ’560 Patent. Furthermore, I have considered
`
`specifically the following documents listed below in addition to any other documents
`
`cited in this Declaration. I understand that the references are true and accurate copies
`
`of what they appear to be.
`
`
`
`I have been asked to provide technical review, analysis, insights, and
`
`opinions regarding the references cited in the Petition and discussed below. My
`
`opinions are not only based on these references but also based on my over 30 years
`
`of experience as a computer architect, computer system designer, personal computer
`
`graphics designer, educator, and executive in the electronics industry.
`
`Exhibit No.
`1001
`1003
`1004
`
`Description
`U.S. Patent No. 10,489,560 to Estes (“’560 Patent”)
`U.S. Patent Publication No. 2004/0010417 to Peled (“Peled”)
`U.S. Patent Publication No. 2011/0191246 to Brandstetter et al.
`(“Brandstetter”)
`
`
`
`- 9 -
`
`

`

`Declaration of John Tinsman
`U.S. Pat. No. 10,489,560
`
`Description
`U.S. Patent Publication No. 2005/0004873 to Pou et al. (“Pou”)
`U.S. Patent Publication No. 2008/0140433 to Levy et al.
`(“Levy”)
`U.S. Patent No. 7,818,261 to Weiskopf et al. (“Weiskopf”)
`Prosecution History of U.S. Patent No. 9,715,581 (“’581
`Prosecution History”)
`Prosecution History of U.S. Patent No. 9,898,590 (“’590
`Prosecution History”)
`Prosecution Histor