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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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`VOLKSWAGEN GROUP OF AMERICA, INC.,
`Petitioner
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`v.
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`YECHEZKAL EVAN SPERO,
`Patent Owner
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`Case IPR2023-00318
`U.S. Patent No. 9,955,551 C1
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`DECLARATION OF JIANZHONG JIAO, PH.D., IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,955,551
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`VWGoA EX1003
`U.S. Patent No. 9,955,551
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`

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`Case IPR2023-00318
`U.S. Patent No. 9,955,551
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`TABLE OF CONTENTS
`
`
`INTRODUCTION ............................................................................................. 1
`I.
`SUMMARY OF GROUNDS ............................................................................ 2
`II.
`SUMMARY OF OPINIONS ............................................................................. 2
`III.
`IV. QUALIFICATIONS .......................................................................................... 3
`V. MATERIALS CONSIDERED .......................................................................... 7
`VI. LEGAL STANDARDS ..................................................................................... 9
`A. My Understanding of Claim Construction ............................................ 10
`B.
`A Person of Ordinary Skill in the Art ................................................... 11
`C. My Understanding of Obviousness ....................................................... 12
`VII. LEVEL OF ORDINARY SKILL IN THE ART ............................................. 17
`VIII. OVERVIEW OF THE ’551 PATENT CLAIMS ............................................ 18
`A.
`Technology Overview of the Patent Claims ......................................... 18
`B.
`Independent Claims 56, 64, 72, and 80 ................................................. 27
`C.
`Prosecution History Summary .............................................................. 32
`D.
`Level of Ordinary Skill in the Art ......................................................... 33
`E.
`Claim Construction ............................................................................... 33
`“electronic circuitry apparatus for the controlled powering of the
`
`LEDs” .......................................................................................... 33
`IX. OVERVIEW OF APPLIED REFERENCES .................................................. 34
`A. Ground 1 – Beam and Satonaka ............................................................ 34
`U.S. Patent No. 6,144,158 to Beam ............................................ 34
`
`Japanese Patent Publication No. H7-101291 to Satonaka .......... 38
`
`Ground 2 – U.S. Patent No. 6,049,749 to Kobayashi with Beam-
`Satonaka ................................................................................................ 40
`Ground 3 – Karlsson and Nakamura ..................................................... 45
` WIPO Patent Publication No. 1998/054030 to Karlsson ........... 45
`Japanese Patent Publication No. JPH07-65603 to Nakamura .... 49
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`D. Ground 4 - Gotou with Karlsson-Nakamura ......................................... 53
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`B.
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`C.
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`B.
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`Case IPR2023-00318
`U.S. Patent No. 9,955,551
`X. GROUND 1: BEAM AND SATONAKA RENDER OBVIOUS
`CLAIMS 56, 57, 62-65, 70-73, 78-81 , AND 86-87 ....................................... 55
`A. A POSA would have been motivated to combine Beam and
`Satonaka with a reasonable expectation of success. ............................. 56
`Independent Claim Structural Elements ................................................ 61
`[56.P]/[64.P]/[72.P]/[80.P] “An
`illuminating device having
`
`automatic control of light provided to an illuminated area
`comprising” ................................................................................. 62
`[56.1]/[64.1]/[72.1]/[80.1]
`“a
`structure
`for
`incorporating
`illuminating device elements, wherein the structure comprises a
`motor vehicle” ............................................................................. 63
`[56.2]/[64.2]/[72.2]/[80.2] “a plurality of individually controllable
`LEDs incorporated in the structure via at least one headlamp
`mounted to the structure, each headlamp including at least one of
`the LEDs, the LEDs in communication with a power source” ... 64
`[56.3]/[64.3]/[72.3]/[80.3] “electronic circuitry apparatus for the
`controlled powering of the LEDs and other of the illuminating
`device elements” ......................................................................... 66
`[56.4]/[64.4]/[72.4]/[80.4] “one or more processors” ................. 69
`[56.5]/[64.5]/[72.5]/[80.5] “one or more sensors, including one or
`more cameras, placed on the structure for detecting coordinate-
`specific information about the illuminated area, at least one of said
`cameras in communication with power, and in communication
`with at least one of the one or more processors” ........................ 69
`(a) Beam discloses this element. .......................................... 69
`(b)
`Satonaka also discloses this element. ............................. 71
`(c)
`It would have been obvious to modify Beam in view of
`Satonaka with a reasonable expectation of success. ....... 72
`[56.6]/[64.6]/[72.6]/[80.6] “a controller, including at least one of
`the one or more processors, integrated with the structure via
`mounting, in communication with the LED controlling power
`electronic circuitry apparatus, said controller arranged to process
`the
`information communicated from
`the cameras and
`to
`automatically control the light provided to the illuminated area”
` ..................................................................................................... 75
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`[56.7]/[64.7]/[72.7]/[80.7] “memory storing instructions that,
`when executed by one or more processors of the controller, enable
`the controller to:” ........................................................................ 76
`Independent Claim 56 Instructions ....................................................... 77
`[56.8] “determine, based on data from one or more of the sensors,
`
`a vertical and horizontal position associated with the at least one
`other vehicle;” ............................................................................. 77
`[56.9] “select a first cluster of the LEDs based at least in part on
`at least one of the vertical and horizontal position compared to
`known aimings of light associated with the first cluster; and” ... 80
`[56.10] “reduce
`intensity of
`illumination
`to non-glaring
`illumination of a first area associated with the at least one other
`vehicle, relative intensity of illumination on both sides of the first
`area at elevations common with the first area illuminated by a
`second cluster of the LEDs, by control of emission from the first
`cluster.” ....................................................................................... 82
`Claim 57 “The illuminating device of claim 56, wherein: the data
`includes image data; the control of emission of the first cluster
`includes a change of at least one of color or intensity or control
`of at least one LED of the first cluster into a nonemitting state; at
`least one of the first cluster second cluster includes a plurality of
`the LEDs and at least one of the first cluster or the second cluster
`includes non-contiguous LEDs; and the known light aimings
`associated with the first cluster is based at least on art on known
`directionality of light emitted by LEDs of the first cluster exiting
`from the at least one headlamp.” ........................................................... 83
`Claims 62/70/78/86 “The illuminating device of claim 56, further
`including one or more optical control elements to control light
`emitted from one or more of the LEDs.” .............................................. 87
`Claims 63/71/79/87 “The illuminating device of claim 62,
`wherein the optical control elements include at least one of one
`or more reflectors, refractors or lenses.” ............................................... 87
`Independent Claim 64 Instructions ....................................................... 89
`[64.8] “select a first cluster of the LEDs having light associated
`
`there that is directed towards the other vehicle based at least in
`part on first data from one or more of the sensors indicating a first
`position associated with the other vehicle;” ............................... 89
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`U.S. Patent No. 9,955,551
`[64.9] “control a first change to one or more characteristics of the
`light associated with the first cluster of the LEDs that is directed
`towards the other vehicle, that diminishes glare to a driver of the
`other vehicle when the other vehicle is at the first position;” .... 91
`[64.10] “select a second, different cluster of the LEDs having light
`associated therewith that is directed towards the other vehicle
`based at least in part on second, subsequent data from one or more
`of the sensors indicating a second, subsequent position associated
`with the other vehicle; and” ........................................................ 93
`[64.11] “control a second, subsequent change, to one or more
`characteristics of the light that is subsequently directed towards
`the other vehicle, that diminishes glare to the driver of the other
`vehicle when the other vehicle is at the second position.” ......... 94
`Claim 65 “The illuminating device of claim 64, wherein: the first
`data or second data includes image data; at least one of the first
`or second change to characteristics of light associated with at
`least one of the first or second cluster of LEDs includes at least
`one of a change to color, to intensity, or a change of at least one
`LED respective cluster to a non-emitting state; at least one of the
`first cluster or the second cluster includes a plurality of the LEDs
`and at least one of the first cluster or the second cluster includes
`non-contiguous LEDs; and the light that is directed or
`subsequently directed towards the other vehicle is determined
`based at least in part on known directionality of light emitted by
`the respective first or second cluster exiting the at least one
`headlamp.” ............................................................................................. 96
`Independent Claim 72 Instructions ....................................................... 99
`[72.8] “determine a target based on first data from one or more of
`
`the sensors;” ................................................................................ 99
`[72.9] “determine a first target location based on the first data;
`from one or more of the LEDs” ................................................ 100
`[72.10] “select a cluster of the LEDs having light associated
`therewith that is directed at the target, determined based on the
`first target location;” ................................................................. 100
`[72.11] “vary illumination provided to the target by the selected
`cluster, relative to illumination provided to areas laterally adjacent
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`U.S. Patent No. 9,955,551
`to the target and provided by at least one LED different from LEDs
`in the selected cluster; ............................................................... 102
`[72.12] “maintain a variance of illumination provided to the target
`relative to the laterally adjacent areas, when subsequent data from
`one or more of the cameras indicates a change in position of the
`target relative to the motor vehicle, by repeating the determination
`of target location, selection of the cluster and variance to
`illumination provided to the target, relative to the laterally
`adjacent areas, based on the subsequent data.” ......................... 104
`Claim 73 “The illuminating device of claim. 72, wherein: the
`variation of illumination provided to the target includes variation
`in at least one of color or intensity at least a change of at least
`one LED of the selected cluster to a non-emitting state; the
`cluster includes a plurality of the LEDs and the cluster includes
`non-contiguous LEDs; the light directed at the target is
`determined based at least in part on known directionality of light
`emitted by the first cluster exiting/ram the at least one headlamp;
`and at least one of the first data or the subsequent data includes
`image data.” .........................................................................................104
`Independent Claim 80 Instructions .....................................................108
`[80.8] “identify, based on data received from one or more of the
`
`sensors, a plurality of positions associated with the target as the
`target move relative to the motor vehicle; and” ........................ 108
`[80.9] “change, responsive to the positions associated with the
`target, first light associated with one or more LEDs aimed toward
`at least a portion of the target, relative to second light associated
`with other one or more of the LEDs aimed laterally adjacent the
`target on either side, as the target moves relative to the motor
`vehicle.” .................................................................................... 110
`Claim 81 “The illuminating device of claim 80, wherein: the data
`includes image data; the memory further stores instructions that
`when executed by one or more processors of the controller,
`enable the controller to select a first cluster of LEDs, associated
`with the first light, for the change, based at least in part on
`known aimings of the first light associated with the first cluster
`having a correlation to the at least the portion, the known
`aimings based at least in part on at least one of known
`directionality of light emitted by the first cluster or known
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`Case IPR2023-00318
`U.S. Patent No. 9,955,551
`directionality of light emitted by the first cluster exiting the
`headlamp; and the change to emission of one or more LEDs
`aimed to towards the at least the portion includes a change to
`intensity or color or a chance of a least one of the LEDs to a non-
`emitting state.” .....................................................................................112
`XI. GROUND 2: BEAM, SATONAKA, AND KOBAYASHI RENDER
`OBVIOUS CLAIMS 58–61, 66–69, 74–77, AND 82–85. ........................... 115
`A. A POSA would have been motivated to combine Beam,
`Satonaka, and Kobayashi with a reasonable expectation of
`success. ................................................................................................115
`Claims 58/66/74/82 “The illuminating device of claim 56,
`wherein the memory further stores instructions that when
`executed by one or more processors of the controller, enable the
`controller to: identify an upcoming road curvature along a road
`on which the motor vehicle is traveling; and accommodate the
`upcoming road curvature by adaptation of a light pattern of at
`least one of the at least one headlamps.” .............................................126
`Claims 59/67/75/83 “The illuminating device of claim 58,
`wherein: the change to emission of the one or more LEDs aimed
`towards the at least the portion includes a change to intensity or
`color or a change of at least one of the LEDs to a non-emitting
`state; the memory further stores instructions that when executed
`by one or more processors of the controller, enable the controller
`to select a first cluster of LEDs, associated with the first light, for
`the change, based at least in part on known aimings of the first
`light associated with the first cluster having a correlation to the at
`least the portion, the known aimings based at least in part on at
`least one of known directionality of light emitted by the first
`cluster or known directionality of light emitted by the first cluster
`exiting the headlamp; and the memory further stores instructions
`that when executed by one or more processors of the controller,
`enable the controller to accommodate the road curvature by
`changing illumination in at least a direction of the road curvature
`by adaptation of the light pattern in at least one of color, intensity
`or spatial distribution by modification of light associated with
`one or more of the LEDs.” ..................................................................128
`Claims 60/68/76/84 “The illuminating device claim 58, wherein
`identification of the upcoming road curvature is based at least in
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`E.
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`U.S. Patent No. 9,955,551
`part on map data and wherein the adaptation of the light pattern
`is based at least in part on the map data.” ...........................................134
`Claim 61/69/77/85 “The illuminating device of claim 58,
`wherein the identification of the upcoming road curvature is
`based at least in part on sensor data provided by one or more of
`the sensors of the vehicle and wherein the adaptation of the light
`pattern is based in part on map data.” .................................................134
`XII. GROUND 3: KARLSSON AND NAKAMURA RENDER OBVIOUS
`CLAIMS 56, 57, 62–65, 70–73, 78–81, AND 86–87 ................................... 135
`A. A POSA would have been motivated to combine Karlsson and
`Nakamura with a reasonable expectation of success. .........................138
`Independent Claim Structural Elements ..............................................143
`[56.P]/[64.P]/[72.P]/[80.P] “An
`illuminating device having
`
`automatic control of light provided to an illuminated area
`comprising” ............................................................................... 143
`[56.1]/[64.1]/[72.1]/[80.1]
`“a
`structure
`for
`incorporating
`illuminating device elements, wherein the structure comprises a
`motor vehicle” ........................................................................... 144
`[56.2]/[64.2]/[72.2]/[80.2] “a plurality of individually controllable
`LEDs incorporated in the structure via at least one headlamp
`mounted to the structure, each headlamp including at least one of
`the LEDs, the LEDs in communication with a power source” . 145
`[56.3]/[64.3]/[72.3]/[80.3] “electronic circuitry apparatus for the
`controlled powering of the LEDs and other of the illuminating
`device elements” ....................................................................... 145
`[56.4]/[64.4]/[72.4]/[80.4] “one or more processors” ............... 146
`[56.5]/[64.5]/[72.5]/[80.5] “one or more sensors, including one or
`more cameras, placed on the structure for detecting coordinate-
`specific information about the illuminated area, at least one of said
`cameras in communication with power, and in communication
`with at least one of the one or more processors” ...................... 147
`(a) Karlsson discloses this element. ...................................147
`(b) Nakamura discloses this element. .................................149
`(c)
`It would have been obvious to modify Karlsson in view of
`Nakamura with a reasonable expectation of success. ...149
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`Case IPR2023-00318
`U.S. Patent No. 9,955,551
`[56.6]/[64.6]/[72.6]/[80.6] “a controller, including at least one of
`the one or more processors, integrated with the structure via
`mounting, in communication with the controlling power electronic
`circuitry apparatus, said controller arranged to process the
`information communicated from the cameras and to automatically
`control the light provided to the illuminated area” ................... 150
`[56.7]/[64.7]/[72.7]/[80.7] “memory storing instructions that,
`when executed by one or more processors of the controller, enable
`the controller to:” ...................................................................... 151
`Independent Claim 56 instructions ......................................................152
`[56.8] “determine, based on data from one or more of the sensors,
`
`a vertical and horizontal position associated with the at least one
`other vehicle;” ........................................................................... 152
`[56.9] “select a first cluster of the LEDs based at least in part on
`at least one of the vertical and horizontal position compared to
`known aimings of light associated with the first cluster; and” . 154
`[56.10] “reduce
`intensity of
`illumination
`to non-glaring
`illumination of a first area associated with the at least one other
`vehicle, relative intensity of illumination on both sides of the first
`area at elevations common with the first area illuminated by a
`second cluster of the LEDs, by control of emission from the first
`cluster.” ..................................................................................... 156
`Claim 57 “The illuminating device of claim 56, wherein: the data
`includes image data; the control of emission of the first cluster
`includes a change of at least one of color or intensity or control
`of at least one LED of the first cluster into a nonemitting state; at
`least one of the first cluster second cluster includes a plurality of
`the LEDs and at least one of the first cluster or the second cluster
`includes non-contiguous LEDs; and the known light aimings
`associated with the first cluster is based at least on art on known
`directionality of light emitted by LEDs of the first cluster exiting
`from the at least one headlamp.” .........................................................158
`Claims 62/70/78/86 “The illuminating device of claim 56, further
`including one or more optical control elements to control light
`emitted from one or more of the LEDs.” ............................................160
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`U.S. Patent No. 9,955,551
`Claims 63/71/79/87 “The illuminating device of claim 62,
`wherein the optical control elements include at least one of one
`or more reflectors, refractors or lenses.” .............................................161
`Independent Claim 64 instructions ......................................................162
`[64.8] “select a first cluster of the LEDs having light associated
`
`there that is directed towards the other vehicle based at least in
`part on first data from one or more of the sensors indicating a first
`position associated with the other vehicle;” ............................. 162
`[64.9] “control a first change to one or more characteristics of the
`light associated with the first cluster of the LEDs that is directed
`towards the other vehicle, that diminishes glare to a driver of the
`other vehicle when the other vehicle is at the first position;” .. 164
`[64.10] “select a second, different cluster of the LEDs having light
`associated therewith that is directed towards the other vehicle
`based at least in part on second, subsequent data from one or more
`of the sensors indicating a second, subsequent position associated
`with the other vehicle; and.” ..................................................... 165
`[64.11] “control a second, subsequent change, to one or more
`characteristics of the light that is subsequently directed towards
`the other vehicle, that diminishes glare to the driver of the other
`vehicle when the other vehicle is at the second position.” ....... 166
`Claim 65 “The illuminating device of claim 64, wherein: the first
`data or second data includes image data; at least one of the first
`or second change to characteristics of light associated with at
`least one of the first or second cluster of LEDs includes at least
`one of a change to color, to intensity, or a change of at least one
`LED respective cluster to a non-emitting state; at least one of the
`first cluster or the second cluster includes a plurality of the LEDs
`and at least one of the first cluster or the second cluster includes
`non-contiguous LEDs; and the light that is directed or
`subsequently directed towards the other vehicle is determined
`based at least in part on known directionality of light emitted by
`the respective first or second cluster exiting the at least one
`headlamp.” ...........................................................................................167
`Independent Claim 72 instructions ......................................................169
`[72.8] “determine a target based on first data from one or more of
`
`the sensors;” .............................................................................. 169
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`Case IPR2023-00318
`U.S. Patent No. 9,955,551
`[72.9] “determine a first target location based on the first data;
`from one or more of the LEDs” ................................................ 170
`[72.10] “select a cluster of the LEDs having light associated
`therewith that is directed at the target, determined based on the
`first target location;” ................................................................. 171
`[72.11] “vary illumination provided to the target by the selected
`cluster, relative to illumination provided to areas laterally adjacent
`to the target and provided by at least one LED different from LEDs
`in the selected cluster; ............................................................... 172
`[72.12] “maintain a variance of illumination provided to the target
`relative to the laterally adjacent areas, when subsequent data from
`one or more of the cameras indicates a change in position of the
`target relative to the motor vehicle, by repeating the determination
`of target location, selection of the cluster and variance to
`illumination provided to the target, relative to the laterally
`adjacent areas, based on the subsequent data.” ......................... 174
`Claim 73 “The illuminating device of claim. 72, wherein: the
`variation of illumination provided to the target includes variation
`in at least one of color or intensity at least a change of at least
`one LED of the selected cluster to a non-emitting state; the
`cluster includes a plurality of the LEDs and the cluster includes
`non-contiguous LEDs; the light directed at the target is
`determined based at least in part on known directionality of light
`emitted by the first cluster exiting/ram the at least one headlamp;
`and at least one of the first data or the subsequent data includes
`image data.” .........................................................................................175
`Independent Claim 80 instructions ......................................................177
`[80.8]“identify, based on data received from one or more of the
`
`sensors, a plurality of positions associated with the target as the
`target move relative to the motor vehicle; and” ........................ 177
`[80.9] “change, responsive to the positions associated with the
`target, first light associated with one or more LEDs aimed toward
`at least a portion of the target, relative to second light associated
`with other one or more of the LEDs aimed laterally adjacent the
`target on either side, as the target moves relative to the motor
`vehicle.” .................................................................................... 179
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`U.S. Patent No. 9,955,551
`Claim 81 “The illuminating device of claim 80, wherein: the data
`includes image data; the memory further stores instructions that
`when executed by one or more processors of the controller,
`enable the controller to select a first cluster of LEDs, associated
`with the first light, for the change, based at least in part on
`known aimings of the first light associated with the first cluster
`having a correlation to the at least the portion, the known
`aimings based at least in part on at least one of known
`directionality of light emitted by the first cluster or known
`directionality of light emitted by the first cluster exiting the
`headlamp; and the change to emission of one or more LEDs
`aimed to towards the at least the portion includes a change to
`intensity or color or a chance of a least one of the LEDs to a non-
`emitting state.” .....................................................................................180
`XIII. GROUND 4: KARLSSON, NAKAMURA, AND GOTOU RENDER
`OBVIOUS CLAIMS 58–61, 66–69, 74–77, AND 82–85. ........................... 182
`A. A POSA would have been motivated to combine Karlsson,
`Nakamura, and Gotou with a reasonable expectation of success. ......182
`Claims 58/66/74/82 “The illuminating device of claim 56,
`wherein the memory further stores instructions that when
`executed by one or more processors of the controller, enable the
`controller to: identify an upcoming road curvature along a road
`on which the motor vehicle is traveling; and accommodate the
`upcoming road curvature by adaptation of a light pattern of at
`least one of the at least one headlamps.” .............................................185
`Claims 59/67/75/83 “The illuminating device of claim 58,
`wherein: the changed emission includes a change to at least one
`of intensity or color or a change of at least one LED of the
`cluster to a non-emitting state; the cluster includes a plurality of
`the LEDS and the cluster includes non-contiguous LEDs; and the
`memory further stores instructions that, when executed one or
`more processors of the controller, enable the controller to
`accommodate the road curvature by changing illumination in at
`least a direction of the road curvature by adaptation of the light
`pattern in at least one of color, intensity or spatial distribution by
`LEDs.” .................................................................................................186
`Claims 60/68/76/84 “The illuminating device claim 58, wherein
`identification of the upcoming road curvature is based at least in
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`E.
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`Case IPR2023-00318
`U.S. Patent No. 9,955,551
`part on map data and wherein the adaptation of the light pattern
`is based at least in part on the map data.” ...........................................187
`Claim 61/69/77/85 “The illuminating device of claim 58,
`wherein the identification of the upcoming road curvature is
`based at least in part on sensor data provided by one or more of
`the sensors of the vehicle and wherein the adaptation of the light
`pattern is based in part on map data.” .................................................188
`XIV. THE ALLEGED SECONDARY CONSIDERATIONS DO NOT
`DEMONSTRATE NONOBVIOUSNESS .................................................... 189
`CONCLUSION ........................................................................................................ 191
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`- xii -
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`I.
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`INTRODUCTION
`I, Dr. Jianzhong Jiao, declare as follows:
`
`Case IPR2023-00318
`U.S. Patent No. 9,955,551
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`1.
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`I have been retained on behalf of Volkswagen Group of America,
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`Inc. (“VWGoA” or “Petitioner”) for the above-captioned inter partes review
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`proceeding to provide my expert opinions and expert knowledge. I understand
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`that this proceeding involves U.S. Patent No. 9,955,551 (“the ’551 patent”)
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`titled “Detector Controlled Illuminating System,” to Yechezkal Evan Spero, and
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`that Torchlight Technologies, LLC has purported to be the exclusive licensee of
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`the ’551 patent. I understand that the Petition submitted by Petitioner challenges
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`claims 56-87 of the ’551 patent.
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`2.
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`The ’551 patent describes, generally, adaptive headlamp systems
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`and methods. I am familiar with the technology described in the ’551 patent as
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`of its earliest possible priority date, July 12, 2002.
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`3.
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`I have been asked to provide my independent technical review,
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`analysis, insights, and opinions regarding the ’551 patent and the references that
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`form the basis for the grounds of unpatentability set forth in the Petition for inter
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`partes review of the ’551 patent filed by Petitioner.
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`4.
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`In preparing this declaration, I have reviewed and am familiar with
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`all the documents cited in this declaration. I have reviewed and am familiar with
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`the ’551 patent and its file history, including the history of the reexamination
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`
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`- 1 -
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`Case IPR2023-00318
`U.S. Patent No. 9,955,551
`proceeding that resulted in the challenged claims. I confirm that to the best of
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`my knowledge, the accompanying exhibits are true and accurate copies of what
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`they purport to be, and that an expert in the field would reasonably rely on them
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`to formulate opinions such as those set forth in this de