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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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`Medivis, Inc.
`Petitioner
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`v.
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`Novarad Corp.
`Patent Owner
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`
`
`Case IPR2023-00042
`US Patent No. 11,004,271
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`
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`DECLARATION OF MAHESH S. MULUMUDI, M.D.
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`1
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`Page 1 of 79
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`TABLE OF CONTENTS
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`I. QUALIFACTIONS ................................................................................................................. 7
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`II. MY EXPERTISE AND THE PERSON OF ORDINARY SKILL IN THE ART ................ 11
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`III.
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`LEGAL STANDARDS ..................................................................................................... 12
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`IV. OVERVIEW OF THE USE OF AUGMENTED REALITY (AR) IN MEDICAL
`PRACTICE AT THE TIME OF THE ’271 PATENT .................................................................. 15
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`V. THE ’271 PATENT AND THE CHALLENGED CLAIMS ................................................ 20
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`A. The ’271 Patent Requires Direct Volume Rendered 3D Data. .......................................... 20
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`B. The ’271 Patent Provides a Novel Method for Navigating, in Real-Time, Direct Volume
`Rendered Data While It is Projected onto Non-Image Actual Views of a Patient. .................. 23
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`VI. CONSTRUCTION OF CERTAIN CLAIM TERMS ........................................................ 25
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`1. “three-dimensional (3D) data … including an outer layer of the patient and multiple inner
`layers of the patient” ................................................................................................................. 27
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`2. “inner layer(s) of the patient” ............................................................................................ 29
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`3. “confined within a virtual 3D shape”................................................................................. 31
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`4. “being having” ................................................................................................................... 34
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`5. Summary Table of Claim Interpretation ............................................................................ 34
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`VII. ANALYSIS OF THE PRIOR ART ................................................................................... 35
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`A. Doo (Ex. 1008)................................................................................................................... 35
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`B. Chen (Ex. 1009) ................................................................................................................. 41
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`C. 3D Slicer (Ex. 1010) .......................................................................................................... 42
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`D. 3D Visualization (Ex. 1007) .............................................................................................. 44
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`E. Amira (Ex. 1005) ............................................................................................................... 45
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`VIII. GROUNDS OF PATENTABILITY .................................................................................. 45
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`A. Ground 1: Doo Does Not Anticipate Claims 1, 5, and 6. .................................................. 45
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`1. Doo does not anticipate independent claim 1................................................................. 46
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`2. Doo does not anticipate dependent claims 5 and 6. ....................................................... 54
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`B. Ground 2: Doo Alone or in View of Amira Does Not Render Claims 1-6 Obvious. ........ 55
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`1. Non-disclosure with respect to claims 1-6 ..................................................................... 55
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`2. Non-disclosure with respect to independent claim 11 ................................................... 61
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`3. Non-Disclosure with respect to claims 12-20 ................................................................ 63
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`4. No motive to combine Doo and Amira .......................................................................... 64
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`C. Ground 3: Chen in View of 3D Visualization and 3D Slicer Does Not Render Claim 1-6
`and 11-20 Obvious. ................................................................................................................... 66
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`1. Chen’s non-disclosure with respect to independent claim 1 .......................................... 67
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`2. Chen’s disclosure with respect to dependent claims 2-6 ................................................ 70
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`3. Chen’s disclosure with respect to independent claim 11 ............................................... 72
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`4. Non-disclosure with respect to dependent claims 12-20 ................................................ 75
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`5. No motive to combine Chen, 3D Visualization, and 3D Slicer. .................................... 76
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`Page 3 of 79
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`I, Mahesh S. Mulumudi, M.D., declare as follows:
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`1.
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`I am over 21 years of age and otherwise competent to make this
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`declaration. I make this declaration based upon facts and matters within my own
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`knowledge and on information provided to me by others.
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`2.
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`I have been retained as an expert witness to provide testimony on
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`behalf of Novarad Corp. (“Patent Owner”) as part of the above-captioned inter
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`partes review proceeding (“IPR”).
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`3. More specifically, I have been asked primarily to assist in evaluating
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`the grounds raised in the Petition (Paper 3) and in Dr. Kazanzides’ declaration (Ex.
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`1012) in support of that Petition.
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`4.
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`I reserve the right to supplement this Declaration in response to
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`additional evidence that may come to light.
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`5.
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`I am not currently, nor have I ever been, employed by Patent Owner.
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`Nor have I previously served as an expert witness on behalf of Patent Owner.1
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`6.
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`I understand that Patent Owner owns U.S. Patent No. 11,004,271
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`(“the ’271 Patent”), entitled AUGMENTING REAL-TIME VIEWS OF A
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`PATIENT WITH THREE-DIMENSIONAL DATA,” the validity of which
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`Medivis, Inc. (“Petitioner”) challenges.
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`1 Nor have I performed work for, met, or ever spoken with Dr. Steven Cvetko or Dr. Wendell
`Gibby, the named inventors in the ’271 Patent.
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`7.
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`I have reviewed the specification of the ’271 Patent as well as its
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`prosecution history. I am familiar with the ’271 Patent. A copy of the ’271 Patent
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`was provided as Exhibit 1001.
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`8.
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`I am familiar with the technology at issue at the time of the ’271
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`Patent, which Petitioner has assumed to be on or before March 30, 2017. Petition
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`at 10.
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`9.
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`I have also reviewed the Petition. The Petition presents several
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`grounds for challenging the claims of the ’271 Patent, which appear deficient to me
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`for reasons I address in more detail below. See infra at ¶¶ 98-179.
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`10.
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`I have also reviewed the declaration of Dr. Kazanzides (Ex. 1012),
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`which I also address.
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`11.
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`I have also reviewed the following references cited by Petitioner as
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`prior art and other documents included in the exhibit list below:
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`Description
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`Exhibit
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`Ex. 1001 U.S. Patent No. 11,004,271 (the ’271 Patent)
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`Ex. 1002 Excerpts of file history of Application No. 16/574,524, now the ’271
`Patent
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`Ex. 1003 Excerpts of file history of Application No. 15/894,595, now U.S.
`Patent No. 10,475,244.
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`Ex. 1004 Excerpts of file history of Application No. 15/474,702, now U.S.
`Patent No. 9,892,564.
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`Ex. 1005 Excerpt of Amira 5 User’s Guide (“Amira”)
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`Ex. 1006 U.S. Publication No. US 2016/0191887 A1 to Casas (“Casas”)
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`Ex. 1007 S. Pujols, Ph.D. et al., 3D Visualization of DICOM Images for
`Radiological Applications (“3D Visualization”)
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`Ex. 1008 International Publication No. WO 2015/164402 A1 to Doo et al.
`(“Doo”)
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`Ex. 1009 X. Chen et al., “Development of Surgical Navigation System Based
`On Augmented Reality Using an Optical See-Through Head-Mounted
`Display,” 55 JOURNAL OF BIOMEDICAL INFORMATICS 124-131 (2015)
`(“Chen”)
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`Ex. 1010 Main Application GUI for 3D Slicer
`<https://www.slicer.org/wiki/Documentation/4.6/Slicer/Application/
`MainApplicationGUI> (“3D Slicer”)
`Ex. 1011 E. Azimi et al. “Augmentation Reality Goggles with an Integrated
`Tracking System for Navigations in Neurosurgery,” IEEE VIRTUAL
`REALITY 123-124, 123 (IEEE 2012) (“AR Goggle for Neurosurgery”)
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`Ex. 1012 Declaration of Peter Kazanzides, Ph.D.
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`Ex. 1013 Curriculum Vitae of Peter Kazanzides Ph.D.
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`12.
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`I am being compensated for my time in connection with the IPR at a
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`rate of $700 per hour. I am also being compensated for any out-of-pocket
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`expenses for my work in this review. My compensation as an expert is in no way
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`dependent upon the results of any investigations I undertake, the substance of any
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`opinion I express, or the ultimate outcome of the review proceedings.
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`I.
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`QUALIFACTIONS
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`13.
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`I believe I am qualified to serve as a technical expert in this
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`proceeding based on my educational and work experience, including my 20+ years
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`of experience in imaging, virtual reality, augmented reality with biofeedback, and
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`treating peripheral vascular and coronary artery diseases from 2000 through today.
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`14. This declaration sets forth my opinions, which I formed based on my
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`study of the evidence; my understanding as an expert in the field; and my training,
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`education, research, knowledge, and personal and professional experience. All of
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`my opinions stated in this declaration are based on my own personal knowledge,
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`expertise, training, education, and professional judgment. In forming my opinions,
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`I have relied on my knowledge and experience in human factors, user interface
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`design, user interaction design, human-computer interaction, and software
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`engineering.
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`15.
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`If I am called upon to do so, I would be competent to testify to the
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`matters set forth herein. My qualifications to testify about the technical subject
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`matter in this case and the relevant technology are outlined in my curriculum vitae
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`and this section of this declaration. A copy of my current curriculum vitae is
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`provided for this proceeding as Exhibit 2003.
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`16.
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`I earned my Bachelor of Medicine and Bachelor of Surgery, the
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`equivalent to a Doctor of Medicine degree, from Kurnool Medical College in 1990.
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`After graduation, I completed an internship at the Government General Hospital in
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`India.
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`17. Upon completion of my internship, I continued my studies at the
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`University of Texas at Austin as a PhD student in the Department of Pharmacology
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`and Toxicology from 1992 to 1994. As a PhD student, I researched the effects of
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`multiple oral doses of ICI D2138 on allergen induced bronchoconstriction,
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`conducting Phase I and Phase II of the clinical studies at Health Quest Research.
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`18.
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`I completed my residency in Internal Medicine at Detroit Medical
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`Center in 1997. Following my residency, in 1998, I was the primary investigator
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`for the Phase IIIb clinical trial of a cyclooxygenase inhibitor versus naproxen
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`sodium in the treatment of osteoarthritis.
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`19. From 2000 to 2005, I was engaged in two cardiology fellowships at
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`the Oschner Clinic Foundation in New Orleans, Louisiana. During these
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`fellowships, I organized clinical research investigating the role of abciximab in
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`improving myocardial blush after primary coronary intervention for acute ST
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`segment elevation myocardial infarction. I also researched the concept of kidney
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`frame counts in the renal angiography and the relationship of tissue myocardial
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`perfusion to the intravascular ultrasound of the epicardial coronary arteries in
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`orthotopic heart transplant patients.
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`20. Following my fellowships, I became certified in Interventional
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`Cardiology through the American Board of Internal Medicine in 2005. In 2013, I
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`became board certified in Cardiovascular Disease through the American Board of
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`Internal Medicine.
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`21.
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`I have filed for nineteen patents involving the invention of electronic
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`devices in conjunction with anatomic regions.
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`22.
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`I am the author of fifteen research papers in professional journals and
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`proceedings in cardiac and renal assessment and functions.
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`23.
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`I am the inventor of a virtual reality application that leverages
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`biofeedback to offer mindfulness exercises in an effort to reduce stress and
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`enhance focus. I also created a virtual reality telemedicine solution that enhances
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`remote healthcare delivery by enabling purposeful and engaging interactions
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`between patients and their healthcare providers.
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`24.
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`I currently serve as President and CEO of StratoScientific, Inc.;
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`Division Chief of Medicine; Section Head of Cardiology; and Medical Director of
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`Interventional Cardiology and Chest Pain Programs at Providence Regional
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`Medical Center in Washington. I am also the Director of Vascular Laboratory and
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`Heart & Vascular Department at the Everett Clinic. From 2006 through 2012, I
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`served as Facilities Medical Director I the Department of Heart & Vascular,
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`Neurology, and Nephrology at the Everett Clinic.
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`25. More information about my educational and professional background
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`can be found in my curriculum vitae, Exhibit 2003.
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`26. The combination of my education, research, training, and work
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`experience in cardiovascular health and virtual reality technology in healthcare as
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`it relates to improving the patient experience enables me to provide analysis and
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`opinions on the subject matter of this litigation.
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`27.
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`I am being compensated for my work on this case and my fee is not
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`contingent on the outcome of this case or on any of my opinions or the technical
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`positions I explain in this report. In addition, I have no financial interest in the
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`outcome of this case, or any of the parties involved this case. I have worked on a
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`number of litigation cases, several of which were related to the role technology
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`plays in the standard of care received by patients.
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`28. Based on the above credentials and experience, and as further
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`documented in my attached CV, I believe that I have the necessary education,
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`training, research, scholarship, and experience to analyze the ’271 Patent and opine
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`on how a person of ordinary skill in the art (as further defined below) would have
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`understood it and its validity in the context of the relevant prior art.
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`II. MY EXPERTISE AND THE PERSON OF ORDINARY SKILL IN
`THE ART
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`29. My opinions in this declaration are based on my experience in this
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`technical field. More specifically, my over 20+ years of experience in imaging,
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`virtual reality, augmented reality with biofeedback, and treating peripheral vascular
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`and coronary artery diseases from 1983 through today. I am qualified to provide
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`expert opinions on some aspects of the technology described in the ’271 Patent and
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`on the references cited by Petitioner and Dr. Kazanzides.
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`30.
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`I understand that my opinion must be taken from the perspective of
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`what would have been known or understood by a person of ordinary skill in the art
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`(“POSITA”) at the time of the invention.
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`31.
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`I understand that Dr. Kazanzides has concluded that the relevant art is
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`“systems and methods for using augmented reality during medical procedures.”
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`Ex. 1012, ¶ 23.
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`32.
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`I further understand that Petitioner has defined POSITA at the time of
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`the ’271 Patent as “a person with a bachelor’s degree in computer science,
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`electrical engineering, or a related field with several years of experience in the
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`design, development, and study of augmented reality devices and either (a) familiar
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`with conventional medical imaging data and visualization of data for medical
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`procedures or (b) working with a team including someone with such familiarity.”
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`Ex. 1012, ¶ 25.
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`33.
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`I understand, and have been informed, that for purposes of assessing
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`the obviousness of a claimed invention, the level of ordinary skill possessed by a
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`POSITA is informed by, among other things, the type of problems encountered in
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`the relevant art, the prior art solutions to those problems, the rapidity with which
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`innovations are made in the relevant art, the sophistication of the relevant
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`technology, and the educational level of active workers in the field.
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`III. LEGAL STANDARDS
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`34.
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`I am not an attorney. My analysis and opinions are based on my
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`expertise as an interventional cardiologist, as well as the instructions I have been
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`given by counsel for the legal standards relating to patent validity.
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`35.
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`I understand that a claim of an issued patent may be found to be
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`unpatentable if the claim is not novel or would have been obvious in view of the
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`prior art. I understand that this determination is made from the perspective of a
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`person having ordinary skill in the art who is presumed to be aware of all prior art.
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`36.
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`I understand that a patent claim will not be unpatentable due to what
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`is called anticipation unless all elements of a claim, arranged in the same way, are
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`found in a single reference. I have also been informed that for anticipation, each
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`and every claim limitation must be explicitly or inherently disclosed in the prior
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`art.
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`37.
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`I have also been informed and understand that anticipation by inherent
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`disclosure is appropriate only when the reference necessarily includes the unstated
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`limitation. Thus, it has been explained to me that inherency may not be established
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`by probabilities or possibilities, and the mere fact that a certain thing may result
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`from a given set of circumstances is insufficient.
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`38.
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`I understand that a patent claim will not be unpatentable due to
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`obviousness unless the differences between the claimed invention and the prior art
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`are such that the subject matter as a whole would have been obvious to a POSITA
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`at the time of the invention.
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`39.
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`I understand that the following factors are considered in assessing
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`obviousness: (1) the scope and content of the prior art; (2) the differences between
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`the prior art and the claimed invention; (3) the level of ordinary skill in the art at
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`the time of the invention; and (4) “objective indicia of non-obviousness,” also
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`referred to as secondary considerations of non-obviousness. Those objective
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`indicia include considerations such as whether a product covered by the claims is
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`commercially successful due to the merits of the claimed invention, whether there
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`was a long felt need for the solution provided by the claimed invention, whether
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`others failed to find the solution provided by the claimed invention, and whether
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`there was acceptance by others of the claimed invention as shown by praise from
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`others in the field.
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`40.
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`I also understand that one should analyze whether the prior art
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`references disclose each and every element of the claim as those references would
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`have been read by a POSITA. I understand that obviousness cannot be proven by
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`mere conclusory statements.
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`41.
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`I understand that a claim is not proved obvious merely by showing
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`that each of the individual elements existed somewhere in the prior art.
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`42.
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`I understand that when a combination of prior art references is relied
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`upon to assert obviousness, the party asserting obviousness must also identify a
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`reason or motivation that would have prompted one of ordinary skill in the art to
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`combine the elements of the references in the same way as the claimed invention
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`and with a reasonable expectation of success.
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`43.
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`I also understand that in assessing obviousness, it is improper to rely
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`upon hindsight and that one should avoid using the claimed invention as a roadmap
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`to piece together disclosures from the prior art.
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`44.
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`I understand that in this inter partes review proceeding, the claims of
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`the ’271 Patent are generally given their ordinary and customary meaning as
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`understood by a POSITA in light of the patent’s specification and the prosecution
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`history.
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`45.
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`I also understand that claim terms should be given their broadest
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`reasonable interpretation to a POSITA, which interpretation must be consistent
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`with the patent’s specification.
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`46. Similarly, I understand that the prosecution history contains the
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`complete record of all the proceedings before the Patent and Trademark Office and
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`may contain contemporaneous exchanges between the patent applicant and the
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`PTO about what the claims mean. Thus, I understand that the prosecution history
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`can inform the meaning of the claim language by demonstrating how the inventor
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`understood the invention and whether the inventor limited the invention in the
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`course of prosecution.
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`47.
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`I understand that where a patent expressly defines a claim term, that
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`definition may also inform the understanding of a POSITA. I have applied these
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`standards in my analysis in this declaration.
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`IV. OVERVIEW OF THE USE OF AUGMENTED REALITY (AR) IN
`MEDICAL PRACTICE AT THE TIME OF THE ’271 PATENT
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`48. One common source of medical imaging is a computed tomography
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`(CT) scan, which uses X-rays to create detailed images of the inside of the body.
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`When the X-ray source and detectors rotate around the patient, they record from
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`many different angles. Conventionally, a computer then uses this 3D data to
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`reconstruct a set of 2D images or slices. This set of 2D slices are conventionally
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`reconstructued along one of three planes: coronal (front to back), sagittal (left to
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`right), or axial (top to bottom):
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`Coronal Slices
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`Sagittal Slices
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`Each of these 2D images represents distribution of X-ray attenuation in the
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`Axial Slices
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`patient’s body.
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`49. Each 2D CT scan image consists of a grid of 2D pixels. The value of
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`the pixel corresponds to the radiodensity of the tissue within the pixel. While each
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`pixel represents a small volume element, or voxel2, of the patients body, a 2D CT
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`scan image actually provides no information about the patient anatomy between
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`the slices.
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`Pixel on 2D Plane
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`2 A voxel is the 3D equivalent of a pixel.
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`3D Voxel
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`50. Another common source of medical imaging is a magnetic resonance
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`imaging (MRI) scan, which uses a strong magnetic field and radio waves to create
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`images of the inside of the body. The output of an MRI scan, conventionally, is
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`one of three sets of 2D images or slices (coronal, sagittal, and axial), similar to a
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`CT scan. Again, each 2D image consists of a grid of 2D pixels. The value of the
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`pixel corresponds to the strength of the MRI signal received at that pixel, which
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`depends on the type of tissue in the pixel. The pixel value also depends on the
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`MRI sequence used, among other factors. While each pixel represents a small
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`volume of element of the patient’s body, a 2D MRI scan image provides no
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`information about layers of the patient anatomy between the 2D slices.
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`51. There are various methods for visualizing CT and MRI scan data,
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`including “slice-by-slice viewing,” “multiplanar reconstruction (MPR), surface
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`rendering, and direct volume rendering (DVR). One of the earliest, and still most
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`common, methods for visualizing medical imaging data is “slice-by-slice viewing.”
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`This is where individual 2D slices are viewed sequentially, one at a time, in the
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`direction they were compiled. Traditionally, CT and MRI slices are acquired and
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`viewed along only one axis, typically the axial or transverse plane (horizontal
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`slices as if looking from the feet towards the head). This “slice-by-slice viewing”
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`method does not provide a complete 3D view of anatomical structures within the
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`volume of a patient.
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`52. Another method for visualizing a specific anatomical feature from CT
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`and/or MRI data is “surface rendering.” This method involves creating a 3D
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`surface model of an anatomical feature of interest from the medical imaging data.
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`This is done by first performing a segmentation step to identify the voxels within
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`the original 3D dataset that belong to an anatomical structure of interest. After
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`segmentation, a polygonal model of the surface of the identified anatomical
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`structure, i.e., a shell, is generated. Since surface rendering only provides a view
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`of the modeled surface of the previously identified anatomical structure, it is used
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`when the focus is on a specific structure of interest. But it does not provide
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`information about the antomical areas of interest within the structure to which a
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`modeled surface was rendered.
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`53. Surface rendering can be time-consuming and requires a high-level of
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`expertise to perform the segmentation step accurately. Also, surface rendering
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`may not accurately represent complex or internal structures because it relies on
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`identifying and rendering the surfaces of structures. As a result, minor errors or
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`noise in the data can cause significant errors in the final surface rendering. In
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`surface rendering, it is common to apply thresholding to distinguish between
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`different types of tissues or materials in the data. However, if thresholds are not
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`set correctly, this can lead to errors or omissions in the final surface rendering. It
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`might also oversimplify the complexity of the data. Also, surface rendering is
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`unable to represent semi-transparent or overlapping structures accurately which
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`can be a disadvantage with medical imaging where these types of structures are
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`common.
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`54. Direct volume rendering (DVR) is very different from the other
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`visualization methods described above. DVR is a method for visualizing medical
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`imaging data, including CT and MRI scan or ultrasound data, in three-dimensions.
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`DVR gives physicians a more realistic and intuitive view of complex anatomical
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`situations avoiding geometric assumptions. It can offer perspectives that are not
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`limited to the traditional planes (e.g., axial, sagittal, and coronal), enabling a view
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`of the anatomical structures within the volume of a patient from any direction.
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`55. Unlike surface rendering, DVR is not feature specific, but takes into
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`account the complete volume of the patient data. While surface models depict the
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`external surfaces or boundaries of an object, DVR creates a 3D image by
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`considering every individual voxel in the dataset allowing for the visualization of
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`internal stuctures, and not just outer surfaces of a particular anatomical feature.
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`56. Also, unlike surface rendering, DVR does not require the creation of
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`an intermediate surface representation and does not require segmentation of the
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`data into different structures or tissues. Instead, DVR operates directly on the
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`original 3D dataset (i.e., grid of voxels that make up the raw volume data). Each
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`voxel within the 3D dataset is assigned a color and opacity based on transfer
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`fuctions. All the voxels are then composited, or blended together, to create a 3D
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`image of the entire volume of the patient anatomy.
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`57. DVR is incredibly beneficial in surgerical applications where the
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`anatomical features of interest do not align along conventional axial, sagittal, or
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`coronal planes or are intertwined with other structures. DVR is not limited to
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`conventional planes. It provides improved depth perception and spatial
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`relationships between different structures, which is crucial in complex surgeries.
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`The other visualization methods described above do not provide these same
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`benefits.
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`58. Although DVR is more computationally intensive than other
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`visualization methods, it provides a unique comprehensive and flexible
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`visualization of 3D medical imaging. At the same time, because DVR provides a
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`comprehensive and flexible visualization of 3D medical imaging, controls are
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`needed to help isolate and identify areas of interest within a DVR volume—
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`especially in an augmented reality (AR) environment. For example, when
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`projected onto real, non-image, actual views of a patient in an operating room.
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`V. THE ’271 PATENT AND THE CHALLENGED CLAIMS
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`A. The ’271 Patent Requires Direct Volume Rendered 3D Data.
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`59. The ’271 Patent discloses “[a]ugmenting real-time views of a patient
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`with three-dimensional (3D) data.” Ex. 1001, Abstract. This “3D data” includes
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`“an outer layer of the patient and multiple inner layers of the patient.” Ex. 1001,
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`1:46-49. The ’271 Patent further discloses displaying the full volume of the “3D
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`data,” and any lesser portion of the full volume, including a single slice. See Ex.
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`1001, 5:34-25 (“display a slice of the 3D data instead of a volume of the 3D data”).
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`The 3D slices can be cut along any axis. Ex. 1001, 5:38-40 (“display different
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`slices of the 3D data including, but not limited to, axial slices, coronal slices,
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`sagittal slices, and oblique slices.”); 6:17-21 ("Slices may be … 3D slices [and] …
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`[m]ay include curved slices, such as curved slices that follow the natural curve of
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`an anatomical feature, or slices that have depth as well as height and width”). The
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`’271 Patent further discloses that the user can navigate, e.g., move between, the
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`slices cut along any axis in real time. Ex. 1001, 8:44-47 (“the user may … change
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`from viewing the axial slice to a sagittal slice, and then from the sagittal slice to a
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`coronal slice, respectively.”). The projected 3D data may be viewed from any
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`angle. Ex. 1001, 4:55-56. (“the 3D data of the patient 106 may be viewed by the
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`user 104 from any angle”). The “multiple inner layers may be layers that go all the
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`way through the patient 106, or may be layers that only go to a certain partial depth
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`into the patient.” Ex. 1001: 12:13-16.
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`60.
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`In view of the foregoing, a POSITA understands that the ’271 Patent
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`describes direct volume rendered 3D data because only a DVR image is 3D,
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`includes an outer layer and multiple inner layers of the patient, and can be cut
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`along any axis and viewed from any angle in real-time. A POSITA understands
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`that only DVR provides the comprehensiveness, detail, and flexibility to visualize
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`and navigate the internal layers of a projected 3D volume of a patient in real-time:
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`“all the way through the patient,” at a “certain partial depth into the patient,” and
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`along multiple axes, as described and claimed in the ’271 Patent.
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`61. A POSITA understands that this cannot be done using any of the other
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`known methods. For example, as mentioned above, “slice-by-slice viewing” and
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`“multiplanar reconstruction (MPR)” do not provide a full 3D view. They also
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`cannot be viewed or navigated in real-time along multiple axes. Conventional
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`“slice-by-slice viewing” is limited to the axis of the original scan (e.g., axial,
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`sagittal, or coronal). Similarly, MPR is limited to the plane selected for “re-
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`slicing.” Additionally, anatomical structures do not always align themselves along
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`the conventionally defined axial planes (e.g., axial, sagittal, or coronal). A POSITA
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`appreciates that anatomical structures are very unique to each patient and tend to
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`traverse in and out of conventional planes as they course through the human body.
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`62. A POSITA understands that “surface rendering” is also limited. For
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`example, surface rendering only provides a view of a surface model, i.e., shell, of a
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`specific feature of interest and nothing else. A surface model does not include any
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`of the surrounding