UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`GOOGLE LLC,
`Petitioner,
`
`v.
`
`PARUS HOLDINGS INC.,
`Patent Owner.
`_____________
`
`Case No. TBD
`Patent No. 9,769,314
`_____________
`
`DECLARATION OF STUART J. LIPOFF IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW
`UNDER 35 U.S.C. §§ 311-319 AND 37 C.F.R. § 42.1 et seq
`
`EX. 1002
`APPLE INC. / Page 1 of 109
`
`

`

`TABLE OF CONTENTS
`
`MANDATORY NOTICES
`
`I.
`
`II.
`
`INTRODUCTION ........................................................................................... 1
`
`BACKGROUND AND QUALIFICATIONS ................................................. 1
`
`III.
`
`INFORMATION CONSIDERED ................................................................. 11
`
`IV. RELEVANT LEGAL STANDARDS ........................................................... 12
`
`A.
`
`Claim Interpretation ....................................................................................... 12
`
`B. Written Description ....................................................................................... 12
`
`C.
`
`D.
`
`V.
`
`Perspective of One of Ordinary Skill in the Art ............................................ 13
`
`Obviousness ................................................................................................... 13
`
`SUMMARY OF OPINIONs ......................................................................... 16
`
`VI.
`
`’314 PATENT ................................................................................................ 16
`
`A. Specification ......................................................................................... 16
`
`B.
`
`C.
`
`Prosecution History .............................................................................. 20
`
`Priority Date ......................................................................................... 21
`
`VII. TECHNOLOGY BACKGROUND ............................................................... 22
`
`A. Storing electronic documents in a magnetic medium was well
`known in the art .................................................................................... 22
`
`B. Voice Recognition was well known. .................................................... 23
`
`C.
`
`Storing personal recognition relating to web information was
`well known. .......................................................................................... 24
`
`D. A polling mechanism to poll web sites was well known. .................... 26
`
`E. Ranking agent was well known. ........................................................... 29
`
`VIII. LEVEL OF ORDINARY SKILL IN THE ART ........................................... 32
`
`IX. CLAIM CONSTRUCTION .......................................................................... 32
`
`X.
`
`BRIEF DESCRIPTION OF THE PRIOR ART REFERENCES .................. 32
`
`A. Wise (Ex-1007) .................................................................................... 32
`
`B. Woods (Ex-1012) ................................................................................. 35
`
`C. Dasan (Ex-1013) ................................................................................... 36
`
`– 1 –
`
`EX. 1002
`APPLE INC. / Page 2 of 109
`
`

`

`
`
`D. Uppaluru (Ex-1014) ............................................................................. 37
`
`XI. DETAILED EXPLANATION OF THE UNPATENTABILITY GROUNDS
` ....................................................................................................................... 38
`
`A. Ground 1: Claims 1-26 Would Have Been Obvious over Wise in
`View of Woods ..................................................................................... 38
`
`1. A POSITA would have been motivated to combine the
`teachings of Wise and Woods and would have had a
`reasonable expectation of success in doing so. ............................. 38
`
`2.
`
`Independent Claims 1, 6, 11 and 19 .............................................. 39
`
`a.
`
`b.
`
`c.
`
`d.
`
`1[Pre(i)]/6[Pre(i)]/11[Pre(i)]/19[Pre(i)]: A[n]
`[method/system/information-retrieval system] for
`retrieving [desired] information from an information
`source [of a plurality of information sources], the
`information source being periodically updated with
`current information, [comprising:] ...................................... 39
`
`1[Pre(ii)]/6[Pre(ii)]/11[Pre(ii)]: over a network, by
`speech commands received from a particular user of a
`plurality of users[, provided by the particular user via
`an electronic-communication device, and] .......................... 40
`
`1[Pre(iii)]/6[Pre(iii)]/11[Pre(iii)]/19[A(i)(b)]: wherein
`each of the plurality of users has a respective
`electronic-communication device[, said
`[method/system] comprising:] ............................................. 41
`
`1(a)[(i)(A)]/11(a)[(i)(A)]: receiving a speech
`command[,] from each of the plurality of users
`provided via the respective electronic-communication
`device, 6(a)[(i)(B)]/19(a)[(i)(B)]: [the speech-
`recognition engine] adapted to receive a speech
`command from [each/a particular user] of [the/a]
`plurality of users [provided] via [the/an] [respective]
`electronic-communication device [to access desired
`information], ........................................................................ 42
`
`e.
`
`1(a)[(i)(B)]/11(a)[(i)(B)]: [by] [a/the] speech-
`recognition engine coupled to a media server,
`6(a)[(i)(A)]/19(a)[(i)(A)]: a speech-recognition engine
`
`
`
`– 2 –
`
`EX. 1002
`APPLE INC. / Page 3 of 109
`
`

`

`
`
`
`
`f.
`
`g.
`
`h.
`
`i.
`
`j.
`
`[including/coupled to] a processor and [coupled to] a
`media server, ........................................................................ 42
`
`1(a)[(ii)]/6(a)[(ii)]/11(a)[(ii)]/19(a)[(ii)]: the media
`server configured to identify and access [an/the]
`information source [from the plurality of information
`sources] via the network, ..................................................... 44
`
`1(a)[(iii)]/6(a)[(iii)]/11(a)[(iii)]/19(a)[(iii)]: the speech-
`recognition engine adapted to select speech-
`recognition grammar established to correspond to the
`speech commands received[,] [from [certain of] the
`plurality of users and assigned to a desired search] [the
`speech-recognition grammar associated with the
`desired information]; ............................................................ 47
`
`1(b)[(i)]/6(b)[(i)]/11(b)[(i)]/19(b)[(i)]: [selecting, by]
`the media server[,] [further configured to/adapted to]
`[select] at least one information-source-retrieval
`instruction corresponding to the speech-recognition
`grammar established for a particular speech command, ...... 48
`
`1(b)[(ii)]/6(b)[(ii)]/11(b)[(ii)]/19(b)[(ii)]: the at least
`one [appropriate] information-source-retrieval
`instruction stored in a database associated with the
`media server and adapted to retrieve information [from
`a particular one of the information sources that has the
`desired information]; ............................................................ 50
`
`1(c)/6(c): [accessing, by] a web-browsing server[,]
`[coupled to the media server and adapted to access] a
`portion of the information source to retrieve
`information of interest requested by the particular user,
`by using a processor of the web-browsing server,
`which processor 11(c)/19(c): [providing access, by the
`speech command, via] a web-browsing server,
`[adapted to provide access, by the speech command,]
`to a portion of the information source to retrieve the
`desired information[,] [for the particular user,] by
`using a processor of the web-browsing server, which
`process[or] ............................................................................ 52
`
`– 3 –
`
`EX. 1002
`APPLE INC. / Page 4 of 109
`
`

`

`
`
`
`
`k.
`
`l.
`
`1(c)[(i)]/6(c)[(i)]/11(c)[(i)]/19(c)[(i)]: performs an
`instruction that requests information from an identified
`webpage, and ........................................................................ 54
`
`1(c)[(ii)]/6(c)[(ii)]/11(c)[(ii)]/19(c)[(ii)]: utilizes a
`content extractor within the web-browsing server to
`separate a portion of the information from other
`information, the information [is] derived from only a
`portion of [the/a] webpage containing information of
`interest to [the/a] particular user, ......................................... 54
`
`m. 1(c)[(iii)]/6(c)[(iii)]/11(c)[(iii)]/19(c)[(iii)]: wherein
`the content extractor uses a content-descriptor file
`containing a description of the portion of information
`and wherein the content-descriptor file indicates a
`location of the portion of the information within the
`information source[;/,] [and] ................................................ 57
`
`n.
`
`o.
`
`p.
`
`1(d)/6(c)[(iv)]/11(d)/19(c)[(iv)]: [and] selecting[,] by
`the web-browsing server[,] the [desired] information
`[of interest] from the [appropriate] information source
`and retrieving only the portion of the information [of
`interest requested/desired] by the particular user
`according to the at least one information-source-
`retrieval instruction; [and] ................................................... 59
`
`1(e)/11(e): converting the information retrieved from
`the information source into an audio message by a
`speech-synthesis engine, the speech-synthesis engine
`coupled to the media server; [and] 6(d)[(i)]/19(d)[(i)]:
`a speech-synthesis engine [including a processor and]
`coupled to the media server, [the speech-synthesis
`engine/and] adapted to convert the [portion of the]
`information [retrieved] from the information source
`into an audio message [and/for the particular user of
`the plurality of users] ........................................................... 60
`
`1(f)/6(d)[(ii)]: transmit[ting] the audio message [to/by]
`the electronic-communication device of the particular
`user requesting information of interest to the particular
`user. 11(f)/19(d)[(ii)]: [and] conveying the audio
`message through the electronic-communication device
`to the [respective electronic-communication device of
`
`– 4 –
`
`EX. 1002
`APPLE INC. / Page 5 of 109
`
`

`

`
`
`
`
`the particular user requesting the desired information/
`particular user of the plurality of users]; and ....................... 62
`
`q.
`
`11(g)/19(e): [providing] a graphical display [interface
`coupled to the media server] and adapted to [provide
`for] display the desired information retrieved from the
`information source to the particular user on [the
`respective electronic-communication device of the
`particular user/certain others of the plurality of users]. ....... 63
`
`3. Dependent Claims 2-5, 7-10, 12-18, and 20-26 ............................ 64
`
`a.
`
`b.
`
`c.
`
`d.
`
`e.
`
`2: The method of claim 1, further comprising:
`searching, by the media server, an associated website
`to locate requested information. .......................................... 64
`
`3[A]/8[A]/13[A]/21: The [method/system] of claim
`[1/6/11/19], wherein the respective electronic-
`communication device is at least one of a landline
`telephone, a wireless telephone, [and] [an internet
`protocol telephone][.] ........................................................... 66
`
`3[B]/8[B]: and [wherein] the media server is
`operatively connected to [the network, which is] at
`least one of a local-area network, a wide-area network,
`and the internet. 13[B]/22: [The system of claim 19,]
`[and] wherein the media server is operatively
`connected to the network, which is at least one of a
`local-area network, a wide area network, and the
`internet. ................................................................................ 67
`
`4/9/17: The [method/system] of claim [1/6/11],
`wherein the media server functions as a user-interface
`system adapted to provide access to a voice-browsing
`system. ................................................................................. 67
`
`5: The method of claim 1, further comprising: clipping
`engine adapted to initially generate the content-
`descriptor file that indicates the location of the portion
`of the information within the information source.
`10[A]/18[A]: The method of claim [6/11], further
`comprising: clipping engine [adapted to
`generate/coupled to] the content-descriptor file, …
`wherein the information is only the portion of the
`
`– 5 –
`
`EX. 1002
`APPLE INC. / Page 6 of 109
`
`

`

`
`
`
`
`f.
`
`g.
`
`h.
`
`i.
`
`j.
`
`k.
`
`webpage containing information of interest to the
`particular user. ...................................................................... 68
`
`10[B]/18[B]: by which, [an/the] instruction [is used by
`the web-browsing server to] request[s] information
`from the identified website and the information is
`displayed on the respective electronic-communication
`device, .................................................................................. 71
`
`7/12/20: The [system/method] [of] claim [6/11/19],
`further comprising: an interface to [a plurality of/an]
`associated website[s] [of the information source] by
`the network to locate [requested/the desired]
`information. .......................................................................... 72
`
`14/23: The [method/system] of claim [11/19],
`[wherein the web-browsing server further comprises
`the content-descriptor file, which is stored within the
`web-browsing server,] wherein the content-descriptor
`file relates to obtaining the desired information from a
`website. ................................................................................ 73
`
`15/24: The [method/system] of claim [11/19], wherein
`the speech command includes a phrase provided by the
`[certain users/particular user], the phrase associated
`with an identified website and information [available
`at the website]. ..................................................................... 73
`
`16/25: The [method/system] of claim [11/19], wherein
`a command for executing [a/the] content-extraction
`agent [are/is] stored in a database associated with the
`media server and used for voice browsing. ......................... 74
`
`26: The system of claim 19, further comprising: a
`database wherein a personal-recognition grammar is
`stored in the database and relates to web information. ........ 75
`
`B. Ground 2: Claims 1-25 Would Have Been Obvious over Wise in
`View of Dasan ...................................................................................... 77
`
`1. A POSITA would have been motivated to combine the
`teachings of Wise and Woods and would have had a
`reasonable expectation of success in doing so. ............................. 77
`
`2.
`
`Independent Claims 1, 6, 11 and 19 .............................................. 77
`
`– 6 –
`
`EX. 1002
`APPLE INC. / Page 7 of 109
`
`

`

`
`
`
`
`a.
`
`b.
`
`c.
`
`d.
`
`e.
`
`f.
`
`1[Pre(i)]/6[Pre(i)]/11[Pre(i)]/19[Pre(i)]: A[n]
`[method/system/information-retrieval
`system]…[comprising:] ....................................................... 77
`
`1[Pre(ii)]/6[Pre(ii)]/11[Pre(ii)] through
`1(b)[(i)]/6(b)[(i)]/11(b)[(i)]/19(b)[(i)],
`1(c)/6(c)/11(c)/19(c) through
`1(c)[(i)]/6(c)[(i)]/11(c)[(i)]/19(c)[(i)], and 1(e)/11(e)/
`6(d)[(i)]/19(d)[(i)] through 1(f)/6(d)[(ii)]/
`11(f)/19(d)[(ii)] .................................................................... 78
`
`1(b)[(ii)]/6(b)[(ii)]/11(b)[(ii)]/19(b)[(ii)]: the at least
`one [appropriate] information-source-retrieval
`instruction stored in a database…; ....................................... 78
`
`1(c)[(ii)]/6(c)[(ii)]/11(c)[(ii)]/19(c)[(ii)]: utilizes a
`content extractor…, ............................................................. 79
`
`1(c)[(iii)]/6(c)[(iii)]/11(c)[(iii)]/19(c)[(iii)]: wherein
`the content extractor uses a content-descriptor
`file…[;][,] ............................................................................. 81
`
`1(d)/6(c)[(iv)]/11(d)/19(c)[(iv)]: [and] selecting[,] by
`the web-browsing server[,] the [desired] information
`[of interest]…[;][and] .......................................................... 81
`
`g.
`
`11(g)/19(e): [providing] a graphical display... .................... 83
`
`3. Dependent Claims 2-5, 7-10, 12-18, and 20-26 ............................ 86
`
`a.
`
`2: The method of claim 1, further comprising:
`searching, by the media server, an associated website
`to locate requested information. .......................................... 86
`
`b. Claims 3, 4, 8, 9, 13-17, and 21-25 ...................................... 87
`
`c.
`
`d.
`
`e.
`
`5: The method of claim 1, further comprising: clipping
`engine... 10[A]/18[A]: The method of claim [6/11],
`further comprising: clipping engine... .................................. 87
`
`10[B]/18[B]: by which, [an/the] instruction [is used by
`the web-browsing server to] request[s] information…........ 90
`
`7/12/20: The [system/method] [of] claim [6/11/19],
`further comprising: an interface... ........................................ 92
`
`C. Ground 3: Claim 26 Would Have Been Obvious over Wise and
`Dasan in View of Uppaluru .................................................................. 92
`
`– 7 –
`
`EX. 1002
`APPLE INC. / Page 8 of 109
`
`

`

`
`
`1. A POSITA would have been motivated to combine the
`teachings of Wise and Woods and would have had a
`reasonable expectation of success in doing so. ............................. 92
`
`2. Dependent Claim 26 ...................................................................... 93
`
`a.
`
`26: The system of claim 19, further comprising: a
`database wherein a personal-recognition grammar is
`stored... ................................................................................. 93
`
`XII. SECONDARY CONSIDERATIONS ........................................................... 95
`
`XIII. CONCLUSION .............................................................................................. 95
`
`
`
`
`
`
`
`
`
`– 8 –
`
`EX. 1002
`APPLE INC. / Page 9 of 109
`
`

`

`
`
`
`
`LISTING OF EXHIBITS
`
`Exhibit Description
`
`1001
`
`1002
`
`1003
`
`1004
`
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`1012
`
`1013
`
`1014
`
`1015
`
`1016
`
`1017
`
`1018
`
`1019
`
`1020
`
`1021
`
`1022
`
`1023
`
`1024
`
`U.S. Patent No. 9,769,314
`
`Declaration of Stuart J. Lipoff
`
`Curriculum Vitae of Stuart J. Lipoff
`
`INTENTIONALLY LEFT BLANK
`
`INTENTIONALLY LEFT BLANK
`
`U.S. Patent No. 5,765,149 (“Burrows”)
`
`U.S. Patent No. 5,884,262 (“Wise”)
`
`INTENTIONALLY LEFT BLANK
`
`INTENTIONALLY LEFT BLANK
`
`INTENTIONALLY LEFT BLANK
`
`INTENTIONALLY LEFT BLANK
`
`U.S. Patent No. 6,510,417 (“Woods”)
`
`U.S. Patent No. 5,761,662 (“Dasan”)
`
`U.S. Patent No. 5,915,001 (“Uppaluru”)
`
`U.S. Patent No. 6,587,822 (“Brown”)
`
`INTENTIONALLY LEFT BLANK
`
`INTENTIONALLY LEFT BLANK
`
`INTENTIONALLY LEFT BLANK
`
`INTENTIONALLY LEFT BLANK
`
`Claim Mapping Table
`
`Prosecution History of U.S. Patent Application 15/193,517 (U.S.
`Patent 9,769,314)
`
`U.S. Patent 5,855,020
`
`U.S. Patent 6,085,160
`
`U.S. Patent 6,434,524
`
`– 9 –
`
`EX. 1002
`APPLE INC. / Page 10 of 109
`
`

`

`
`
`
`
`1025
`
`1026
`
`1027
`
`1028
`
`1029
`
`1030
`
`1031
`
`1032
`
`1033
`
`1034
`
`1035
`
`1036
`
`1037
`
`1038
`
`1039
`
`McGraw-Hill Electronics Dictionary (6th ed. 1997) (“McGraw-Hill”)
`
`INTENTIONALLY LEFT BLANK
`
`INTENTIONALLY LEFT BLANK
`
`INTENTIONALLY LEFT BLANK
`
`Petitioner’s Stipulation Letter to Patent Owner, dated April 4, 2022
`
`INTENTIONALLY LEFT BLANK
`
`INTENTIONALLY LEFT BLANK
`
`U.S. Patent 6,418,433 (“Chakrabarti”)
`
`Evolution of Magnetic Storage by L.D. Stevens (1981)
`
`U.S. Patent No. 6,285,999
`
`Scientific American: Feature Article: “Hypersearching the Web”: June
`1999 by Members of the Clever Project
`(https://www.cs.cornell.edu/home/kleinber/sciam99.html)
`
`“NLP Meets the Jabberwocky: Natural Language Processing in
`Information Retrieval” by Susan Feldman, May 1999
`
`“Information Retrieval on the Web” by MEI KOBAYASHI and
`KOICHI TAKEDA, IBM Research, ACM Computing Surveys, Vol.
`32, No. 2, June 2000
`
`INFORMATION RETRIEVAL USING STATISTICAL
`CLASSIFICATION by Hull – 1994
`
`Search Engines for the World Wide Web: A Comparative Study and
`Evaluation Methodology, by Heting Chu and Marilyn Rosenthal, 1996
`
`1040
`
`INTENTIONALLY LEFT BLANK
`
`1041
`
`1042
`
`1043
`
`1044
`
`1045
`
`1046
`
`INTENTIONALLY LEFT BLANK
`
`INTENTIONALLY LEFT BLANK
`
`INTENTIONALLY LEFT BLANK
`
`INTENTIONALLY LEFT BLANK
`
`INTENTIONALLY LEFT BLANK
`
`INTENTIONALLY LEFT BLANK
`
`– 10 –
`
`EX. 1002
`APPLE INC. / Page 11 of 109
`
`

`

`
`
`
`
`
`
`
`1047
`
`1048
`
`Provisional Application No. 60/180,343
`
`Comparison of Provisional Application No. 60/180,343 and
`Application No. 09/777,406
`
`– 11 –
`
`EX. 1002
`APPLE INC. / Page 12 of 109
`
`

`

`
`
`I.
`
`INTRODUCTION
`
`1.
`
`I have been retained by Google LLC (“Google” or “Petitioner”) as an
`
`independent expert consultant in this inter partes review (“IPR”) proceeding
`
`before the United States Patent and Trademark Office (“PTO”).
`
`2.
`
`I have been asked by Google Counsel (“Counsel”) to consider
`
`whether certain references teach or suggest the features recited in Claims 1-26 (the
`
`“challenged claims”) of U.S. Patent No. 9,769,314 (“the ’314 patent”) (Ex-1001).
`
`My opinions and the bases for my opinions are set forth below.
`
`3.
`
`I am being compensated at my ordinary and customary consulting rate
`
`for my work, which is $375 per hour. My compensation is in no way contingent on
`
`the nature of my findings, the presentation of my findings in testimony, or the
`
`outcome of this or any other proceeding. I have no other financial interest in this
`
`proceeding.
`
`II. BACKGROUND AND QUALIFICATIONS
`
`4.
`
`All of my opinions stated in this declaration are based on my own
`
`personal knowledge and professional judgment. In forming my opinions, I have
`
`relied on my knowledge and experience in designing, developing, researching, and
`
`teaching the technology referenced in this declaration.
`
`5.
`
`I am over 18 years of age and, if I am called upon to do so, I would be
`
`competent to testify as to the matters set forth herein. I understand that a copy of
`
`1
`
`
`EX. 1002
`APPLE INC. / Page 13 of 109
`
`

`

`
`
`my current curriculum vitae, which details my education and professional and
`
`academic experience, is being submitted as Ex-1003. The following provides a
`
`brief overview of some of my experience that is relevant to the matters set forth in
`
`this declaration.
`
`6.
`
`I am currently president of IP Action Partners Inc., a consulting
`
`practice that serves the telecommunications, information technology, media,
`
`electronics, and e-business industries.
`
`7.
`
`I earned a Bachelor of Science degree in Electrical Engineering in
`
`1968 and a second Bachelor of Science degree in Engineering Physics in 1969,
`
`both from Lehigh University. I earned a Master of Science degree in Electrical
`
`Engineering from Northeastern University in 1974, and then a Master of Business
`
`Administration degree from Suffolk University in 1983.
`
`8.
`
`I hold a Federal Communications Commission (“FCC”) General
`
`Radiotelephone License. I also hold a Certificate in Data Processing from the
`
`Institute for the Certification of Computing Professionals (“ICCP”), which is
`
`supported by the Association for Computing Machinery (“ACM”).
`
`9.
`
`I am also a registered professional engineer (PE) in the
`
`Commonwealth of Massachusetts and in the State of Nevada.
`
`10.
`
`I am a fellow of the Institute of Electrical and Electronics Engineers
`
`(“IEEE”) Consumer Electronics, Communications, Computer, Circuits, and
`
`2
`
`
`EX. 1002
`APPLE INC. / Page 14 of 109
`
`

`

`
`
`Vehicular Technology Groups. I have been a member of the IEEE Consumer
`
`Electronics Society National Board of Governors (formerly known as the
`
`Administrative Committee) since 1981, and I was Boston Chapter Chairman of the
`
`IEEE Vehicular Technology Society from 1974 to 1976. I served as the 1996-1997
`
`President of the IEEE Consumer Electronics Society, and from 1999 to 2018 I
`
`served as Chairman of the Society’s Technical Activities and Standards Committee
`
`and as Vice President of Publications for the Society. Since 2018 I have served as
`
`Vice President of Standards and Industry Activities for the Society. I have also
`
`served as an Ibuka Award committee member for the IEEE’s Award in the field of
`
`consumer electronics.
`
`11.
`
`I have prepared and presented numerous papers at the IEEE and at
`
`other professional meetings. For example, in fall 2000, I served as general program
`
`chair for IEEE’s Vehicular Technology Conference on advanced wireless
`
`communication technology. I have organized sessions at The International
`
`Conference on Consumer Electronics, and I was the 1984 program chairman. I
`
`conducted an eight-week IEEE-sponsored short course on Fiber Optics System
`
`Design. I received IEEE’s Centennial Medal in 1984, and I received IEEE’s
`
`Millennium Medal in 2000.
`
`12. As Vice President and Standards Group Chairman for the Association
`
`of Computer Users (“ACU”) from 1980 to 1983, I served as the ACU
`
`3
`
`
`EX. 1002
`APPLE INC. / Page 15 of 109
`
`

`

`
`
`representative to the ANSI X3 Standards Group. From 1976 to 1978, I served as
`
`Chairman of the task group on user rule compliance for the FCC’s Citizens
`
`Advisory Committee on Citizen’s Band Radio.
`
`13. Over the last 25 years, I have been a member of the Society of Cable
`
`Television Engineers, the Association for Computing Machinery, and The Society
`
`of Motion Picture and Television Engineers. From 2001 to 2004, I served as a
`
`member of the USA advisory board to the National Science Museum of Israel. In
`
`1998, I presented a short course on international product development strategies as
`
`a faculty member for Technion Institute of Management in Israel. From 2001 to
`
`2003, I served as a member of the board or directors of The Massachusetts Future
`
`Problem Solving Program.
`
`14.
`
`I am a named inventor on seven United States patents and have
`
`several publications on data communications in publications, including Electronics
`
`Design, Microwaves, EDN, the Proceedings of the Frequency Control Symposium,
`
`Optical Spectra, and IEEE publications.
`
`15. During my professional career dating from 1969 to the present, I have
`
`been heavily engaged in the study, analysis, evaluation, design, and
`
`implementation of products and technology associated with consumer electronics
`
`and electronic appliances. A particular focus of my professional activities has been
`
`improving the man-machine interface including voice, speech, and speaker
`
`4
`
`
`EX. 1002
`APPLE INC. / Page 16 of 109
`
`

`

`
`
`recognition for man-machine interactions. I also have extensive experience in
`
`studying foundation technologies and the applications supporting home
`
`automation, home appliance control, residential energy management, and home
`
`security and monitoring.
`
`16. For approximately three years, from 1969 to 1972, I served as Project
`
`Engineer for Motorola’s Communications Division, where I had project design
`
`responsibilities for paging and wireless communication products. Projects I worked
`
`on while employed at Motorola included work on paging systems that included
`
`digital voice storage, voice compression, and voice synthesis. I also worked on
`
`projects that interfaced wireless data communications terminals to public safety
`
`computer systems for mobile data retrieval and data entry.
`
`17. For approximately four years, from 1972 to 1976, I served as Section
`
`Manager for Bell & Howell Communications Company, where I also had project
`
`design responsibilities for paging and wireless communication products. The
`
`projects I supported included covert audio intelligence systems that recognized
`
`speech and activated digital voice compression recording systems. I also led
`
`projects for voice-based radio paging systems that recorded speech input,
`
`processed the speech to remove silence, processed the speech to digitally compress
`
`the speech, and store and forward the speech upon demand from DTMF or
`
`computer keyboard retrieval from the servers.
`
`5
`
`
`EX. 1002
`APPLE INC. / Page 17 of 109
`
`

`

`
`
`18. For 25 years from 1976 to 2001, I worked for Arthur D. Little, Inc.
`
`(ADL), where I became the Vice President and Director of Communications,
`
`Information Technology, and Electronics (CIE) and served in that role for 10
`
`years, from 1991 to 2001. At ADL, I was responsible for the firm’s global CIE
`
`practice in laboratory-based contract engineering, product development, and
`
`technology-based consulting. I was also involved in multiple pioneering efforts to
`
`identify and explore customer-to-business and business-to-business electronic
`
`commerce and transactions information processing opportunities (e-commerce).
`
`These projects involved technology assessment and analysis as well as developing
`
`architectures and systems to support multiple applications, and typically involved
`
`an information retrieval component.
`
`19. While at ADL, I worked on several projects involving the
`
`combination of voice interfaces (including speech recognition and voice audio
`
`output) and information retrieval as well as working on projects for utilities,
`
`service providers, and consumer electronics OEMs for home automation and
`
`energy management. For example, over the course of three years in the early-
`
`1990s, I worked on a project for Bolt Beranek and Newman (BB&N), where I
`
`evaluated and benchmarked technology for a voice input/output application that
`
`allowed end users (e.g., travel agents) to use speech inputs to interact with airline
`
`reservation databases to retrieve information about travel reservation options,
`
`6
`
`
`EX. 1002
`APPLE INC. / Page 18 of 109
`
`

`

`
`
`where the results were returned to the user in an audible message. This system
`
`included a natural language front-end speech-interface module with speech
`
`recognition that used pre-defined recognition grammars to convert the end user’s
`
`speech into structured commands supported by an airline reservation system. As
`
`another example, over the course of three years in the mid-1990s, I worked on a
`
`project for Texas Instruments that applied a speech-recognition interface for a
`
`variety of applications that retrieved information from database servers. My work
`
`for electric, gas, and water utilities included a focus on remote and automatic meter
`
`reading and energy management of appliances and residential HVAC systems.
`
`20. Other projects that I worked on at various points in my 25 years at
`
`ADL and afterwards that involved speech recognition technologies included the
`
`following.
`
`21. Over the course of three years in the early 1990s, I worked on a voice-
`
`interface project developing spoken digit telephone number recognition and
`
`voiceprint matching for Sprint’s long distance alternative access telephone
`
`services.
`
`22. Over the course of a year in the late 1980s, I worked on a voice
`
`interface project evaluating the processing power needed to perform various voice
`
`recognition applications by Rockwell Semiconductor’s signal processing
`
`technology.
`
`7
`
`
`EX. 1002
`APPLE INC. / Page 19 of 109
`
`

`

`
`
`23. Other projects that I worked on at various points in my 25 years at
`
`ADL that involved information-retrieval technologies included the following.
`
`24. Over the course of 15 years starting in the early 1980s, I worked on a
`
`project for the United States Postal Service (USPS), where we developed a real-
`
`time automated postal teller system that served as an interface between end-users
`
`and the USPS’s information systems. This system included voice prompts for the
`
`vision impaired.
`
`25. Over the course of two years in the early 1990s, I worked on a project
`
`for the grocery industry consortium of The Food Marketing Institute and The
`
`Grocery Manufacturers Association, where I developed standards used by the
`
`industry for direct exchange electronic data interchange (DEX/UCS EDI). This
`
`project involved developing a business model for vendors who make direct store
`
`delivery of merchandise to retail stores (e.g., fast-moving goods that do not come
`
`via a warehouse such as soda, meat, bread) so that legacy paper receipts and
`
`signature could be captured on hand-held portable computers and then uploaded to
`
`the vendors’ billing computers at some later time to generate invoices.
`
`26. Over the course of two years in the early 1990s, I worked on a project
`
`for MasterCard and Visa, where I supported a project exploring the applications
`
`and security issues associated with the use of smart cards in eCommerce. This
`
`project explored both physical security properties of the card media as well as
`
`8
`
`
`EX. 1002
`APPLE INC. / Page 20 of 109
`
`

`

`
`
`issues associated with the back-end information processing servers. For example, I
`
`explored electronic watermarks resident on a credit card where the watermark
`
`digital content was captured at point of sale and then uploaded to the back-end
`
`credit card processor so that the card media