IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`COMMSCOPE, INC.
`Petitioner,
`
`v.
`
`TQ Delta, LLC,
`Patent Owner.
`
`––––––––––
`
`Case No. IPR2023-00066
`Patent 7,836,381
`––––––––––
`
`DECLARATION OF SYLVIA D. HALL-ELLIS, PH.D.
`
`CommScope, Inc.
`IPR2023-00066, Ex. 1033
`Page 1 of 233
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`I, Sylvia D. Hall-Ellis, declare as follows:
`I.
`INTRODUCTION
`1.
`My name is Sylvia D. Hall-Ellis. I have been retained as an expert by
`
`CommScope, Inc., the Petitioner.
`
`2.
`
`I have written this declaration at the request of the Petitioner to
`
`provide my expert opinion regarding the authenticity and public availability of a
`
`document. My declaration sets forth my opinions in detail and provides the basis
`
`for my opinions regarding the authenticity and public availability of this
`
`publication. If called to testify in the above-captioned proceeding, I will testify
`
`with regard to the opinions and bases set forth below.
`
`3.
`
`I reserve the right to supplement or amend my opinions, and bases for
`
`them, in response to any additional evidence, testimony, discovery, argument,
`
`and/or other additional information that may be provided to me after the date of
`
`this declaration.
`
`4.
`
`As of the preparation and signing of this declaration, many libraries
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`across the nation are partially closed or permit only limited access due to the
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`COVID-19 virus. However, were the libraries open, I would expect to be able to
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`obtain paper copies of at least some of the documents in this Declaration.
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`Additionally, it is my typical practice to obtain a paper copy of each publication to
`
`1
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`CommScope, Inc.
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`further confirm my opinions. I reserve the right to supplement my declaration
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`when the libraries reopen to provide such information.
`
`5.
`
`I am being compensated for my time spent working on this matter at
`
`my normal consulting rate of $325 per hour, plus reimbursement for any additional
`
`reasonable expenses. My compensation is not in any way tied to the content of this
`
`declaration, the substance of my opinions, or the outcome of this proceeding. I
`
`have no other interests in this proceeding or with any of the parties.
`
`6.
`
`All of the materials that I considered and relied upon are discussed
`
`explicitly in this declaration.
`
`II. QUALIFICATIONS
`7.
`I am currently an Adjunct Professor in the School of Information at
`
`San José State University in San José, California. I obtained a Master of Library
`
`Science from the University of North Texas in 1972 and a Ph.D. in Library and
`
`Information Science from the University of Pittsburgh in 1985. Over the last forty-
`
`five years, I have held various positions in the field of library and information
`
`resources. I was first employed as a librarian in 1966 and have been involved in the
`
`field of library sciences since, holding numerous positions.
`
`8.
`
`I am a member of the American Library Association (ALA) and its
`
`Association for Library Collections & Technical Services (ALCTS) Division, and I
`
`served on the Committee on Cataloging: Resource and Description (which wrote
`
`2
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`the new cataloging rules) and as the chair of the Committee for Education and
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`Training of Catalogers and the Competencies and Education for a Career in
`
`Cataloging Interest Group. I also served as the founding Chair of the ALCTS
`
`Division’s Task Force on Competencies and Education for a Career in Cataloging.
`
`Additionally, I have served as the Chair for the ALA Office of Diversity’s
`
`Committee on Diversity, as a member of the REFORMA National Board of
`
`Directors, and as a member of the Editorial Board for the ALCTS premier
`
`cataloging journal, Library Resources and Technical Services. Currently I serve as
`
`a Co-Chair for the Library Research Round Table of the American Library
`
`Association.
`
`9.
`
`I have also given over one hundred presentations in the field,
`
`including several on library cataloging systems and Machine-Readable Cataloging
`
`(“MARC”) standards. My current research interests include library cataloging
`
`systems, metadata, and organization of electronic resources.
`
`10.
`
`I have been deposed twenty-three times: (1) Symantec Corp. vs.
`
`Finjan, Inc., Petition for Inter Partes Review of U.S. Patent No. 7,613,926,
`
`May 26, 2016, on behalf of Symantec Corp.; (2) Symantec Corp. vs.
`
`Finjan, Inc., 14-cv-299-HSG (N.D. Cal.), on behalf of Symantec Corp.,
`
`September 14, 2017; (3) one deposition for ten matters: Intellectual Ventures I
`
`LLC vs. AT&T Mobility LLC; AT&T Mobility II LLC, New Cingular Wireless
`
`3
`
`CommScope, Inc.
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`Services, Inc., SBC Internet Services, Inc., Wayport, Inc., and Cricket Wireless
`
`LLC, C.A. No. 12-193 (LPS); Intellectual Ventures II LLC vs. AT&T Mobility
`
`LLC; AT&T Mobility II LLC, New Cingular Wireless Services, Inc., SBC Internet
`
`Services, Inc., Wayport, Inc., and Cricket Wireless LLC, C.A. No. 13-1631 (LPS);
`
`Intellectual Ventures I LLC vs. T-Mobile USA, Inc. and T-Mobile US, Inc., C.A.
`
`No. 13-1632 (LPS); Intellectual Ventures II LLC vs. T-Mobile USA, Inc. and T-
`
`Mobile US, Inc., C.A. No. 13-1633 (LPS); Intellectual Ventures I LLC, vs. Nextel
`
`Operations, Inc., Sprint Spectrum L.P., Boost Mobile, LLC and Virgin Mobile
`
`USA, L.P., C.A. No. 13-1634 (LPS); Intellectual Ventures II LLC vs. Nextel
`
`Operations, Inc., Sprint Spectrum L.P., Boost Mobile, LLC and Virgin Mobile
`
`USA, L.P., C.A. No. 13-1635 (LPS); Intellectual Ventures I LLC, vs. United States
`
`Cellular Corporation, C.A. No. 13-1636 (LPS); Intellectual Ventures I LLC vs.
`
`United States Cellular Corporation, C.A. No. 13-1637 (LPS); Intellectual Ventures
`
`II LLC vs. AT&T Mobility LLC, AT&T Mobility II LLC, New Cingular Wireless
`
`Services, Inc., C.A. No. 15-799 (LPS); Intellectual Ventures I LLC vs. T-Mobile
`
`USA, Inc. and T-Mobile US, Inc., C.A. No. 15-800 (LPS), on behalf of AT&T
`
`Mobility LLC; AT&T Mobility II LLC, Boost Mobile, LLC Cricket Wireless LLC,
`
`Nextel Operations, Inc., New Cingular Wireless Services, Inc., SBC Internet
`
`Services, Inc., Sprint Spectrum L.P., T-Mobile USA, Inc., T-Mobile US, Inc.,
`
`United States Cellular Corporation Virgin Mobile USA, L.P., and Wayport, Inc.,
`
`4
`
`CommScope, Inc.
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`November 15, 2016; (4) Hitachi Maxell, LTD., v. Top Victory Electronics
`
`(Taiwan) Co. Ltd., et al., 2:14-cv-1121 JRG-RSP (E.D. Texas), on behalf of Top
`
`Victory Electronics (Taiwan) Co. LTD, et. al., January 20, 2016; (5) Sprint
`
`Spectrum, L.P. vs. General Access Solutions, Ltd., Petition for Inter Partes Review
`
`of U.S. Patent No. 7,173,916, on behalf of Sprint Spectrum L.P., July 13, 2018;
`
`(6) Nichia Corporation vs. Vizio, Inc., 8:16-cv-00545; on behalf of Vizio, Inc.,
`
`October 12, 2018; (7) Intellectual Ventures I LLC, vs. T-Mobile USA, Inc., T-
`
`Mobile US, Inc., Ericsson Inc., and Telefonaktiebolaget LM Ericsson, 2:17-cv-
`
`00557 (JRG), on behalf of T-Mobile USA, Inc., T-Mobile US, Inc., Ericsson Inc.,
`
`and Telefonaktiebolaget LM Ericsson, October 19, 2018; (8) Pfizer, Inc. vs.
`
`Biogen, Inc., Petition for Inter Partes Review of U.S. Patent No. 8,821,873, on
`
`behalf of Pfizer, November 3, 2018; (9) Finjan, Inc. vs. ESET, LLC and ESET
`
`SPOL. S.R.O., 3:17-cv-00183-CAB-BGS, on behalf of ESET, January 15, 2019;
`
`(10) Finjan, Inc. vs. Cisco Systems, Inc., 5:17-cv-00072-BLF-SVK, on behalf of
`
`Cisco Systems, Inc., September 6, 2019; (11) Facebook, Inc., Instagram, LLC and
`
`Whatsapp Inc. vs. Blackberry Limited, Petition for Inter Partes Review of U.S.
`
`Patent No. 9,349,120 B2, on behalf of Facebook, Inc., Instagram, LLC and
`
`Whatsapp Inc. December 20, 2019; (12) 3Shape A/S and 3Shape Inc. v. Align
`
`Technology, Inc., Petition for Inter Partes Review of U.S. Patent No. 7,156,661,
`
`IPR 2020-00222 and IPR 2020-00223, August 10, 2020, on behalf of 3Shape A/S
`
`5
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`CommScope, Inc.
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`and 3Shape Inc.; (13) Finjan Inc. v. Rapid7, Inc. and Rapid7 LLC, Northern
`
`District of Delaware; 1:18-cv-01519-MN, September 15, 2020; (14) VLSI
`
`Technology LLC v. Intel Corporation, Western District of Texas, 6:19-cv-00254,
`
`6:19-cv-00255, 6:19-cv-00256, on behalf of Intel Corporation, September 23,
`
`2020; (15) Finjan Inc. v. Sonicwall, Inc., Northern District of California, 5:17-cv-
`
`04467-BLF-HRL, on behalf of Sonicwall, Inc., October 27, 2020; (16) VLSI
`
`Technology, LLC v. Intel Corporation, District of Delaware, 1:18-cv-00966-CFC-
`
`CJB, February 5, 2021, on behalf of the Intel Corporation; (17) Unified Patents,
`
`LLC v. Good Kaisha IP Bridge 1, Petition for Inter Partes Review of U. S. Patent
`
`7,817,868, February 11, 2021, on behalf of Unified Patents; (18) Finjan, Inc. v.
`
`Qualsys, Inc., Northern District of California, 4:18-cv-07229-YGR, March 1,
`
`2021, on behalf of Qualsys, Inc.; (19) Qualcomm, Inc. v. Monterey Research LLC,
`
`Petition for Inter Partes Review of U. S. Patent 6,534,805, May 6, 2021, on behalf
`
`of Qualcomm, Inc.; (20) Hulu, LLC v. Sound View Innovations, LLC, Petition for
`
`Inter Partes Review of U. S. Patent 5,806,062, May 14, 2021, on behalf of Hulu,
`
`LLC; (21) VLSI Technology LLC v. Intel Corporation, Western District of Texas,
`
`6:19-cv-00254, 6:19-cv-00255 and 6:19-cv-00256, August 3, 2021, on behalf of
`
`Intel Corporation; (22) Liquidia Technologies, Inc. v. United Therapeutics
`
`Corporation, Petition for Inter Partes Review of U. S. Patent 10,716,793 B2,
`
`October 20, 2021, on behalf of Liquidia Technologies, Inc.; and, (23) EcoFactor,
`
`6
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`CommScope, Inc.
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`Inc. v. Google, Inc., Western District of Texas, 6:20-cv-00075 (ADA), 6:20-
`
`0078-ADA, and 6:20-cv-00080 ADA, October 27, 2021, on behalf of Google,
`
`Inc.
`
`11. My full curriculum vitae is attached hereto as Attachment 1.
`
`III. PRELIMINARIES
`A.
`Scope of Declaration and Legal Standards
`12.
`I am not an attorney and will not offer opinions on the law. I am,
`
`however, rendering my expert opinion on the authenticity of the documents
`
`referenced herein and on when and how each of these documents was disseminated
`
`or otherwise made available to the extent that persons interested and ordinarily
`
`skilled in the subject matter or art, exercising ordinary diligence, could have
`
`located the documents before October 12, 2003.
`
`13.
`
`I am informed by counsel that a printed publication qualifies as
`
`publicly accessible as of the date it was disseminated or otherwise made available
`
`such that a person interested in and ordinarily skilled in the relevant subject matter
`
`could locate it through the exercise of ordinary diligence.
`
`14. While I understand that the determination of public accessibility under
`
`the foregoing standard rests on a case-by-case analysis of the facts particular to an
`
`individual publication, I also understand that a printed publication is rendered
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`“publicly accessible” if it is cataloged and indexed by a library such that a person
`
`7
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`interested in the relevant subject matter could locate it (i.e., I understand that
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`cataloging and indexing by a library is sufficient, though there are other ways that
`
`a printed publication may qualify as publicly accessible). One manner of sufficient
`
`indexing is indexing according to subject matter category. I understand that the
`
`cataloging and indexing by a single library of a single instance of a particular
`
`printed publication is sufficient, even if the single library is in a foreign country. I
`
`understand that, even if access to a library is restricted, a printed publication that
`
`has been cataloged and indexed therein is publicly accessible so long as a
`
`presumption is raised that the portion of the public concerned with the relevant
`
`subject matter would know of the printed publication. I also understand that the
`
`cataloging and indexing of information that would guide a person interested in the
`
`relevant subject matter to the printed publication, such as the cataloging and
`
`indexing of an abstract for the printed publication, is sufficient to render the
`
`printed publication publicly accessible.
`
`15.
`
`I understand that routine business practices, such as general library
`
`cataloging and indexing practices, can be used to establish an approximate date on
`
`which a printed publication became publicly accessible.
`
`B.
`16.
`
`Persons of ordinary skill in the art.
`I am told by counsel that the subject matter of this proceeding relates
`
`to resource allocation in a Digital Subscriber Line (DSL) environment.
`
`8
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`17.
`
`I have been informed by counsel that a “person of ordinary skill in the
`
`art at the time of the invention” (“POSITA”) is a hypothetical person who is
`
`presumed to be familiar with the relevant field and its literature at the time of the
`
`inventions. This hypothetical person is also a person of ordinary creativity, capable
`
`of understanding the scientific principles applicable to the pertinent field.
`
`18.
`
`I am told by counsel that persons of ordinary skill in this subject
`
`matter or art would have had a Bachelor’s degree in electrical engineering, or a
`
`related field, and at least 6-7 years of experience in telecommunications or related
`
`field; a master’s degree in electrical or computer engineering, or the equivalent,
`
`and at least 3-4 years of experience in telecommunications or related field; or a
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`Ph.D. in electrical or computer engineering, or the equivalent, with at least 1-2
`
`years of experience in telecommunications or related field. I understand that
`
`additional education could compensate for less practical experience and vice versa.
`
`I have been further informed by counsel that a person of ordinary skill in the art
`
`would have been familiar with and able to understand the information known in the
`
`art relating to these fields, including the publication discussed in this declaration.
`
`19.
`
`It is my opinion that such a person would have been engaged in
`
`research, learning, study, and practice in the field, and possibly formal instruction
`
`so that bibliographic resources relevant to his or her research would be familiar.
`
`Before October 12, 2003, such a person would have had access to a vast array of
`
`9
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`long-established print resources in DSL development as well as to a rich set of
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`online resources providing indexing information, abstracts, and full text services.
`
`IV. LIBRARY PROFESSIONAL PRACTICES
`20.
`In preparing this declaration, I used authoritative databases, such as
`
`the OCLC bibliographic database, the Library of Congress Online Catalog, and the
`
`Library of Congress Subject Authorities, to confirm citation details of the various
`
`publications discussed. Unless I note otherwise below in reference to a specific
`
`serial publication, it is my expert opinion that this standard protocol was followed
`
`for the serial publication discussed below.
`
`21.
`
`Indexing. A researcher may discover material relevant to his or her
`
`topic in a variety of ways. One common means of discovery is to search for
`
`relevant information in an index of periodicals and other publications. Having
`
`found relevant material, the researcher will then normally obtain it online, look for
`
`it in libraries, or purchase it from the publisher, a bookstore, a document delivery
`
`service, or other provider. Sometimes, the date of a document’s public accessibility
`
`will involve both indexing and library date information. However, date information
`
`for indexing entries is often unavailable. This is especially true for online indices.
`
`22.
`
`Indexing services use a wide variety of controlled vocabularies to
`
`provide subject access and other means of discovering the content of documents.
`
`The Library of Congress Subject Authorities includes standard forms of terms and
`
`10
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`cross references that are included in bibliographic records. Subject headings are
`
`terms that an individual seeking a document regardless of format can enter in the
`
`search bar of the online catalog. Subjects also connect an authenticated term (one
`
`included in the Library of Congress subject headings list) with related, broader,
`
`and narrower terms. The formats in which these access terms are presented vary
`
`from service to service.
`
`23. Online
`
`indexing
`
`services
`
`commonly provide bibliographic
`
`information, abstracts, and full-text copies of the indexed publications, along with
`
`a list of the documents cited in the indexed publication. These services also often
`
`provide lists of publications that cite a given document. A citation of a document is
`
`evidence that the document was publicly available and in use by researchers no
`
`later than the publication date of the citing document. Prominent indexing services
`
`include Scopus, the IEEE Xplore database, the ACM Digital Library, Google
`
`Scholar, and the Internet Archive.
`
`V.
`
`PUBLICATION 1: EXHIBIT 1007 (“ETSI STANDARD”)
`24.
`The exhibit filed in this proceeding as Exhibit 1007 is a true and
`
`accurate copy of the document Transmission and Multiplexing (TM); Access
`
`Transmission Systems on Metallic Access Cables; Very High Speed Digital
`
`Subscriber Line (VDSL); Part 2: Transceiver Specification (ETSI TS 101 270-2,
`
`11
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`Version 1.2.1, July 2003)1 (hereafter called the “ETSI document”) as captured by
`
`me from the Internet by inserting the website address in Microsoft Internet
`
`Explorer and downloading the pdf. Exhibit 1007 accurately reflects the contents of
`
`the above website link on the date of capture and has not been changed or altered
`
`in any way—the text of the ETSI document in Exhibit 1007 is complete; no pages
`
`are missing; and, further, there are no visible alterations to the document. It is my
`
`opinion that the appearance, contents, substance, and distinctive characteristics of
`
`Exhibit 1007 creates no suspicion about its authenticity. As such, it is my opinion
`
`that Exhibit 1007 is authentic.
`
`25.
`
`I understand that prior to October 12, 2003, ETSI would have been
`
`known to persons at least of ordinary skill in the art as a European standards
`
`organization that produced technical standards related to telecommunications,
`
`including DSL. Furthermore, I understand that persons of ordinary skill in the art
`
`would have reasonably considered
`
`this organization and
`
`its website –
`
`http://www.etsi.org – as reliable and useful sources of information for research,
`
`study, development, or design of systems using DSL technologies. I understand
`
`1 h
`
`ttps://portal.etsi.org/webapp/workprogram/Report_WorkItem.asp?WKI_ID=1182
`8
`
`12
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`that the ETSI document is a reliable authority for research, study, development, or
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`design of systems using DSL technologies.
`
`26.
`
`Specifically, the text of the ETSI TS 101 270-2, Version 1.2.1, July
`
`2003, is complete; no pages are missing, and the text on each page appears to flow
`
`seamlessly from one page to the next; further, there are no visible alterations to the
`
`document. Exhibit 1007 was found within the custody of the issuing organization
`
`– a place where, if authentic, a copy of this standard would likely be. Exhibit 1007
`
`is a true and correct copy in a condition that creates no suspicion about
`
`authenticity.
`
`27.
`
`The European Telecommunications Standards Institute (ETSI)
`
`published the ETSI document on its July 24, 2003 (see Attachment 2a). A history
`
`of the development of ETSI TS 101 270-2, Version 1.2.1 indicates that the
`
`document was approved for publication on June 19, 2003 (see Attachment 2b).
`
`Given that the ETSI website was accessible to the public prior to or on July 24,
`
`2003, I understand that persons interested and ordinarily skilled in the subject
`
`matter or art exercising reasonable diligence could have located the ETSI
`
`document on the ETSI website using the common search terms discussed above
`
`and/or reasonable diligence.
`
`28.
`
`Indeed, an interested researcher could have accessed the ETSI website
`
`and selected the “Standards” tab. This search engine on the ETSI website is a
`
`13
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`promotional tool that allows information seekers to download individual copies of
`
`ETSI Publications free of charge and access the complete range of ETSI
`
`Publications, including European Standards in the telecommunications series (EN,
`
`ETS, I-ETS, EG, ES, ETR, GTS, TBR, TR, TS).
`
`29.
`
`This search engine permitted individuals to search for documents
`
`based on various criteria including title, scope, technical body name, standard type,
`
`and subject. Archived webpages to this search engine were present in at least the
`
`three captures indicated above. The ETSI document indicates that it could be
`
`searched using a variety of information including the standard type (“TS”) and the
`
`keywords “Digital Subscriber Line” and “Very High Speed Digital Subscriber Line
`
`(VDSL).” These are reliable indicators that copies of the ETSI document were
`
`available on the ETSI.org website on at least the dates indicated above to persons
`
`interested in searching for this information.
`
`30.
`
`Furthermore, the ETSI document is dated July 2003, has a header
`
`“ETSI TS 101 270-2 V1.2.1 (2003-07),” and includes a copyright date on the
`
`second page indicating “© European Telecommunications Standards Institute
`
`2003.” I understand that persons of at least ordinary skill in the art researching
`
`documents would rely on these dates as indications of when this document was
`
`published.
`
`14
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`31.
`
`For the foregoing reasons, it is my opinion that Exhibit 1007 was
`
`publicly accessible to persons interested in and ordinarily skilled in the art
`
`exercising reasonable diligence no later than July 24, 2003 (if not sooner).
`
`VI.
`
`SUMMARY OF OPINIONS
`32.
`In view of the foregoing, it is my opinion that the publication
`
`described above were publicly available no later than the corresponding date listed
`
`in the table below:
`
`Exhibit
`
`Publication
`
`1007 European Telecommunications Standards
`Institute. Technical Specification. Transmission
`and Multiplexing (TM); Access Transmission
`Systems on Metallic Access Cables; Very High
`Speed Digital Subscriber Line (VDSL); Part 2:
`Transceiver Specification. ETSI TS 101 270-2,
`v1.2.1, July 2003. Sophia Antipolis Cedex,
`France: ETSI, 2003.
`
`Publicly Available
`No Later Than
`July 24, 2003
`
`33.
`
`In signing this declaration, I recognize that the declaration will be
`
`filed as evidence in a contested case before the Patent Trial and Appeal Board of
`
`the United States Patent and Trademark Office. I also recognize that I may be
`
`subject to cross-examination in the case and that cross-examination will take place
`
`within the United States. If cross-examination is required of me, I will appear for
`
`cross-examination within the United States during the time allotted for cross
`
`examination.
`
`34.
`
`I declare that all statements made herein of my knowledge are true,
`
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`and that all statements made on information and belief are believed to be true, and
`
`that these statements were made with the knowledge that willful false statements
`
`and the like so made are punishable by fine or imprisonment, or both, under
`
`Section 1001 of Title 18 of the United States Code.
`
`Executed this CJ-!£ day of March 2022.
`
`~L~-~
`7
`Sylvia D. Hall-Ellis, Ph.D.
`
`7
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`ATTACHMENT 1
`ATTACHMENT1
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`CommScope, Inc.
`IPR2023-00066, Ex. 1033
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`
`
`Sylvia D. Hall-Ellis, Ph.D.
`
`CURRICULUM VITAE SYLVIA D. HALL-ELLIS
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`EDUCATION
`Ph.D., University of Pittsburgh, Pittsburgh, Pennsylvania, 1985
`M.P.S., University of Denver, Denver, Colorado, 2014
`Post Graduate Studies, University of Texas – San Antonio, Texas, 1975-1976
`M.L.S., University of North Texas, Denton, Texas, 1972 B.A.,
`Rockford University, Rockford, Illinois, 1971
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`PROFESSIONAL EXPERIENCE
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`Consultant for higher education, non-profit organizations, and corporations.
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`Adjunct Professor, School of Information, San José State University, San José,
`California. Serve as part-time faculty member teaching graduate students in technical services
`(cataloging, bibliographic control, classification), “core courses,” and special topics.
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`Director, Grants and Resource Development, Colorado Community College System.
`Provided leadership and vision to foster the continued growth of rigorous scholarship,
`innovative projects, and creative work for statewide system, 13 campuses, and 50 teaching
`sites serving 155,000 students. Responsible for leadership and ensured efficient functioning of
`contract and grants in compliance with state & federal requirements and successful
`implementation and management. Served as a subject matter expert and liaison for college
`Grant Directors for all issues relating to grants and subcontracts.
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`Senior Grant Administrator, Morgridge College of Education, University of Denver
`(Colorado). Provided leadership and vision to foster continued growth of rigorous scholarship,
`innovative research, and creative work in the Morgridge College of Education. Ensure that
`contract and grants processes function effectively and efficiently for 60 faculty and researchers
`with a focus on the successful progression and efficient management of grants totaling $13M.
`Worked effectively and collegially with Department Chairs and Program Coordinators on
`operational grant-related management activities and with a broad range of internal and external
`constituencies. Supported the dissemination and promotion of faculty research and scholarship
`to outside constituents at conferences and through publications. Assisted Principal
`Investigators and grant project teams by coaching, mentoring, and financial management.
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`Interim Director & Assistant Dean, Westminster Law Library, Sturm College of Law,
`University of Denver. Planned, organized, and directed all administrative activities for the
`library serving students, faculty, and alumni; oversaw the employment, retention, promotion,
`transfer and termination of library personnel; represented the library at professional
`conferences and public meetings; created and promoted a climate and culture of acceptance for
`new programs and services, a positive high-quality image of the law library, and that reflect
`the organization’s values, encourage excellent performance, and reward high productivity and
`innovation; provided leadership and set strategic direction of the organization; ensured that the
`library provided excellent customer service through solution-oriented staff response to patron
`needs and by responsiveness and continuous improvement of the organization; promoted,
`developed, and maintained positive working relationships with colleagues and customers
`including key stakeholders and groups, higher education institutions, the legal community,
`other regional libraries and districts statewide, and national library organizations.
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`1981-
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`2002-
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`2014-2016
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`2010-2014
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`2011-2013
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`CommScope, Inc.
`IPR2023-00066, Ex. 1033
`Page 19 of 233
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`2007-2014
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`Sylvia D. Hall-Ellis, Ph.D.
`Page 2 of 52
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`Associate Professor, Library & Information Science, Morgridge College of Education,
`University of Denver (Colorado). Served in leadership role and worked collaboratively in
`program, college, campus and community environments. Advised and supervised students,
`taught core and specialized courses at the graduate level in an integrative, student-centered
`learning environment. Served on LIS, College, and University committees, and maintained
`working relationships with colleagues in other academic units and information professionals in
`the Rocky Mountain region and beyond. Served on and chair doctoral student dissertation
`committees. Oversaw and facilitated the College and LIS graduate student association.
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`2002-2007 Assistant Professor, Library & Information Science, College of Education, University of
`Denver (Colorado). Served as tenure-track faculty member teaching graduate students in
`“core courses,” resource description and access, service learning, and independent studies.
`Advised graduate students, participate on LIS and College committees, and serve on doctoral
`student dissertation committees. Oversaw and facilitated the LIS graduate student association
`and alumni association.
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`2000-2002
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`2000-2001
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`Affiliate Faculty, Library & Information Science, College of Education, University of
`Denver (Colorado). Served as part-time faculty member teaching graduate students in
`technical services (cataloging, bibliographic control, classification), “core courses,” and
`special topics. Oversaw and facilitated the LIS graduate student association and alumni
`association.
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`Special Assistant to the Secretary’s Regional Representative, U.S. Department of
`Education, Region VIII, Denver, Colorado. Served as the principal advisor and
`representative of the U. S. Secretary of Education’s Regional Representative (SRR). Ensured
`the implementation of major goals of the SRR and the Secretary. Provided leadership on
`behalf of the SRR in contacts with high-level officials in Region VIII requiring sensitive
`policy interpretation in communication with senior Department officials to solve problems and
`resolve issues raised by State and local education officials. Served as the primary contact for
`School-to-Work/Career, Children’s Health Insurance Program, and Safe and Drug-Free
`Schools. Delivered technical assistance to local education agencies and institutions of higher
`education in technology, professional development, and school construction.
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`1999-2000
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`Catalog Librarian, Jefferson County Public Library, Lakewood, Colorado. Performed
`original, copy cataloging and classification of library materials (English and Spanish) using
`standard library protocols; completed original descriptive cataloging and subject analysis;
`enhanced brief catalog and authority records in III.
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`1997-1999 Development Officer, McREL International, Aurora, Colorado. Served as senior member
`of corporate management team in strategic planning, development of proposals and contracts,
`implementation, and evaluation of new services, products, and programs for educational
`agencies. Provided creative leadership to corporate committees to solicit ideas, identify goals
`and objectives, plan, develop, present, and evaluate professional development opportunities.
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`1995-1997 Education Specialist, Education Service Center, Region One, Edinburg, Texas. Served as
`member of Administrative Cabinet team in strategic planning, development of proposals and
`contracts, implementation, and evaluation of telecommunications capabilities, services,
`products, and programs for 40 school districts serving 283,000 students in 7 counties. Provided
`creative leadership to regional and state committees to solicit ideas, identify strategic goals and
`objectives, plan, develop, present, and evaluate funding opportunities and professional
`development for 400 librarians.
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`CommScope, Inc.
`IPR2023-00066, Ex. 1033
`Page 20 of 233
`
`

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`Sylvia D. Hall-Ellis, Ph.D.
`Page 3 of 52
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`Assistant Professor of Library Science, Sam Houston State University, Huntsville, Texas.
`Served a faculty member teaching 400 graduate students in technical services (cataloging,
`bibliographic control, classification), automation, and networking. Participated in distance
`education program and coordinated annual conference. Conducted university and Texas
`Library Association-funded field research focused on library collection development and
`academic achievement.
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`Head Librarian, Rocky Mountain College of Art & Design, Denver, Colorado.
`Responsible for the daily operation, selection and acquisition of materials, formulation of
`policies for library operations, media center, and photography/slides archives. Designed and
`implemented library automation and delivery of elec