UNITED STATES PATENT AND TRADEMARK OFFICE
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`NETFLIX, INC.,
`NETFLIX, INC.,
`PETITIONER,
`PETITIONER,
`
`v.
`Vv.
`
`GOTV STREAMING, LLC,
`GOTV STREAMING,LLC,
`PATENT OWNER.
`PATENT OWNER.
`
`CASE IPR2023-00757
`CASE IPR2023-00757
`PATENT 8,989,715
`PATENT 8,989,715
`
`DECLARATION OF MR. STUART LIPOFF
`DECLARATION OF MR. STUART LIPOFF
`
`EXHIBIT
`
`2022
`2022
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`IPR2023-00757
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`Patent No. 8,989,715
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`TABLE OF CONTENTS
`
`CURRENT EXHIBIT LIST ...................................................................................... 6
`CLAIM LISTING .................................................................................................... 10
`I.
`INTRODUCTION .......................................................................................... 13
`II.
`PROFESSIONAL BACKGROUND AND QUALIFICATIONS .................. 14
`III. PATENT FAMILY ......................................................................................... 23
`IV. RELEVANT TIME ......................................................................................... 23
`V. LEVEL OF ORDINARY SKILL IN THE ART ............................................ 23
`VI. GOVERNING LAW ....................................................................................... 25
`
`A. Claim Construction Generally ...................................................................... 25
`B. Enablement ................................................................................................... 27
`C. Means Plus Function Terms ......................................................................... 28
`D. Obviousness .................................................................................................. 30
`
`VII. MATERIALS CONSIDERED ....................................................................... 33
`VIII. OVERVIEW OF THE PATENT-AT-ISSUE ................................................. 33
`
`A. Historical Context ......................................................................................... 33
`B. Subject Matter ............................................................................................... 36
`C. Invention as Illustrated through Embodiments ............................................. 38
`
`1. Applications ............................................................................................ 38
`2. Compiled Content and Rendering Blocks .............................................. 40
`3. Custom Configuration ............................................................................. 43
`4. Client ....................................................................................................... 44
`
`IX.
`
`INTERPRETATION OF TERMS .................................................................. 45
`
`A. District Court Constructions ......................................................................... 45
`B. All Claims Require the Recited “Application” to Run Remotely ................ 45
`
`1[c]/9[c]/17[c] [transmitting, to said wireless device, / . . .
`transmits compiled content to said wireless device,
`said] compiled content comprising (i) first compiled
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`content specific to a first page of said application and
`(ii) second compiled content specific to a second page
`of said application ............................................................................. 45
`1[d]/9[d]/17[d] wherein said compiled content is generated
`in part from execution of said application [by said
`server] ............................................................................................... 45
`
`C. The Pages of Compiled Content Must Be in Part Generated by
`the Executing Remote Application ............................................................. 53
`
`1[d]/9[d]/17[d] wherein said compiled content is generated
`in part from execution of said application [by said
`server] ............................................................................................... 53
`
`D. “Customized to Said Application” Means “Created For” the
`Application Program ................................................................................... 56
`
`1[b]/9[b] wherein said custom configuration . . .
`configures said plurality of rendering blocks to render
`content in a manner customized to said application ......................... 56
`17[b] . . . custom configuration that configures a plurality
`of rendering blocks of said wireless device to render
`content in a manner customized to an application . . . ...................... 56
`
`E. “Layout Sover” Connotes Understood Class of Structure ............................ 57
`
`X. OVERVIEW OF THE CITED REFERENCES ............................................. 59
`
`A. Hariki ............................................................................................................ 59
`B. Harris ............................................................................................................. 61
`
`XI. CITED ART DOES NOT RENDER THE ’715 PATENT
`UNPATENTABLE AS OBVIOUS ................................................................ 63
`
`A. No Single Application Petitioner Identifies Renders Any
`Independent Claim Obvious ........................................................................ 63
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`1. The UI Skin Does Not Configure a Plurality of Rendering
`Blocks to Render Content in a Manner Customized to a
`Web Server .......................................................................................... 65
`
`1[b]/9[b] wherein said custom configuration . . .
`configures said plurality of rendering blocks to render
`content in a manner customized to said application ......................... 65
`17[b] . . . custom configuration that configures a plurality
`of rendering blocks of said wireless device to render
`content in a manner customized to an application . . . ...................... 65
`
`2. The Web Browser Does Not Transmit HTML Files to a
`Wireless Device ................................................................................... 68
`
`1[c]/9[c]/17[c] [transmitting, to said wireless device, / . . .
`transmits compiled content to said wireless device,
`said] compiled content comprising (i) first compiled
`content specific to a first page of said application and
`(ii) second compiled content specific to a second page
`of said application ............................................................................. 68
`
`3. The Web Browser Is Not Running Remotely from the
`Wireless Device ................................................................................... 70
`
`1[c]/9[c]/17[c] [transmitting, to said wireless device, / . . .
`transmits compiled content to said wireless device,
`said] compiled content comprising (i) first compiled
`content specific to a first page of said application and
`(ii) second compiled content specific to a second page
`of said application ............................................................................. 70
`1[d]/9[d]/17[d] wherein said compiled content is generated
`in part from execution of said application [by said
`server] ............................................................................................... 70
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`4. The Web Browser Does Not Generate in Part from Its
`Execution HTML Files ........................................................................ 70
`
`1[d]/9[d]/17[d] wherein said compiled content is generated
`in part from execution of said application [by said
`server] ............................................................................................... 70
`
`B. Hariki’s UI Skin Is Not “Applicable” to the Received HTML
`Files ............................................................................................................. 71
`
`1[f]/9[f]/17[f] wherein said custom configuration is
`applicable to said first and second compiled content ....................... 71
`
`C. Hariki in View of Harris Does Not Teach the “Library”
`Limitations .................................................................................................. 73
`
`17[a] a library of applications; ............................................................... 73
`17[b] a library of custom configuration data comprising a
`custom configuration that configures a plurality of
`rendering blocks of said wireless device to render
`content in a manner customized to an application from
`said library of applications requested by said wireless
`device ................................................................................................ 73
`
`D. Hariki in View of Harris Does Not Teach the “Layout Solver”
`Limitation .................................................................................................... 74
`
`17[c] a layout solver that transmits compiled content to
`said wireless device, said compiled content comprising
`(i) first compiled content specific to a first page of said
`application and (ii) second compiled content specific to
`a second page of said application ..................................................... 74
`
`E. Harris and Hariki Further Do not Teach Limitations in
`Dependent Claim 3 and 11 .......................................................................... 75
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`3. A method as described in claim 1 wherein said compiled
`content is partially resultant from said application
`operating on a remote server............................................................. 75
`11. A non-transitory computer readable medium as
`described in claim 9 wherein said compiled content is
`partially resultant from said application operating on a
`remote server. .................................................................................... 75
`
`XII. CONCLUSION ............................................................................................... 75
`XIII. DECLARATION ............................................................................................ 76
`APPENDIX A (RESUME) ...................................................................................... 77
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`CURRENT EXHIBIT LIST
`
`No. Brief Description
`1001 U.S. Patent No. 8,989,715
`1002 Expert Declaration of Ben Bederson (“Bederson”)
`1003 Curriculum Vitae of Benjamin B. Bederson, Ph.D.
`1004 File History of U.S. Patent No. 8,989,715
`1005 File History of U.S. Patent No. 8,478,245
`1006 U.S. Patent Application Publication No. 2007/0150617 (“Hariki”)
`1007 U.S. Patent Application Publication No. 2003/0023755 (“Harris”)
`1008 U.S. Patent No. 7,447,486 (“Tamura”)
`1009 U.S. Patent No. 6,996,627 (“Carden”)
`1010 U.S. Patent No. 6,669,564 (“Young”)
`1011 U.S. Patent No. 6,732,183 (“Graham”)
`1012 U.S. Patent No. 6,507,727 (“Henrick”)
`1013 Webpage excerpt from Computer History Museum at
`https://www.computerhistory.org/tdih/april/6/ (last accessed
`March 29, 2023)
`https://www.webdesignerdepot.com/2009/05/the-evolution-of-cell-
`phone-design-between-1983-2009/
`1015 Excerpts from Dan R. Olsen, Jr., Developing user interfaces (1998)
`1016 Alok Sinha, Client-server computing, in Communications of the ACM,
`35, 7 (1992)
`1017 Tim Berners-Lee, Robert Cailliau, Ari Luotonen, Henrik Frystyk
`Nielsen, and Arthur Secret, The World-Wide Web,
`Communications
`1018 Eric Kasten, HTML: A Gentle Introduction, Linux Journal (July 1995),
`available at https://www.linuxjournal.com/article/1081
`1019 U.S. Patent Application Publication No. 2013/0124961 (“Linburn ”)
`1020 U.S. Patent No. 8,111,326 (“Talwar”)
`1021 Order re Scheduling Conference, GoTV Streaming, LLC v. Netflix, Inc.,
`2:22-cv-07556 (C.D. Cal. issued Feb. 13, 2023) (Doc. 61)
`1022 Complaint in GoTV Streaming, LLC v. Netflix, Inc., No. 2:22-cv-
`07556-RGK-SHK (C.D. Cal. October 17, 2022)
`
`1014
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`No. Brief Description
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`2001 CAMPBELL-KELLY ET AL., Mainframes to Smartphones: A History of
`the International Computer Industry, Ch. 11 (Harvard Univ.
`Press 2015)
`2002 GALAZZO, Timeline from 1G to 5G: A Brief History on Cell Phones
`(Sept. 21, 2020), available at https://www.cengn.ca/information-
`centre/innovation/timeline-from-1g-to-5g-a-brief-history-on-cell-
`phones/
`2003 Cingular MEdia Mall Games and Motorola Page (March 23, 2006),
`available at
`https://web.archive.org/web/20060323054853/http://www-
`xl.cingularextras.com/fuel/enduser/portal/endUserHTMLDir?c1=
`3&dc=0 and
`https://web.archive.org/web/20060323054841/http://www-
`xl.cingularextras.com/fuel/enduser/portal/endUserHTMLSelectP
`hone?makeName=motorola&dc=0
`2004 Suite, Definition & Meaning - Merriam-Webster, available at
`https://www.merriam-webster.com/dictionary/suite
`2005 U.S. Patent No. 7,380,205 to Bezrukov et al. (filed Oct. 28, 2003)
`2006 TUTENEL ET AL., Rule-Based Layout Solving and Its Application to
`Procedural Interior Generation, Netherlands Organization for
`Scientific Research and the Netherlands ICT Research and
`Innovation Authority (2009)
`2007 KRÖNER, Adaptive Layout of Dynamic Web Pages, Deutsches
`Forschungszentrum fur Künstliche Intelligenz GmH (2000)
`2008 Scheduling Order, GoTV Streaming, LLC v. Netflix, Inc., 2:22-cv-
`07556 (C.D. Cal. issued Feb 14, 2023) (Doc. 62)
`2009 Klausner Decisions re Motions to Stay Pending IPR, Docket Navigator
`(generated June 8, 2023)
`2010 Order Granting Stipulated Stay Pending IPR, Flexstent, LLC v. Abbott
`Labs., No. 5-18-cv-02479 (C.D. Cal. Oct. 18, 2019) (Doc.77)
`2011 Order Denying Renewed Stipulated Stay Pending IPR, Shenzhen
`Gooloo E-Commerce Co., Ltd. v. Pilot, Inc., No. 2-22-cv-02219
`(C.D. Cal. Jan. 12, 2023) (Doc. 95)
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`No. Brief Description
`2012 Renewed Joint Stipulation to Stay Case Pending Resolution of Inter
`Partes Reviews of ’653 Patent, Shenzhen Gooloo E-Commerce
`Co., Ltd. v. Pilot, Inc., No. 2-22-cv-02219 (C.D. Cal. Jan. 11,
`2023) (Doc. 94)
`2013 Klausner Time to Trial in Patent Cases, Docket Navigator (generated
`June 8, 2023)
`2014 U.S. District Court—Judicial Caseload Profile for Central California
`from Federal Court Management Statistics–Profiles
`(Mar. 31, 2023), available at
`https://www.uscourts.gov/sites/default/files/data_tables/fcms_na
`_distprofile0331.2023.pdf
`2015 Order Denying Netflix’s Motions, including for Invalidity under § 101,
`GoTV Streaming, LLC v. Netflix, Inc., 2:22-cv-07556 (C.D. Cal.
`issued May 24, 2023) (Doc. 109)
`2016 Order re Scheduling Conference, GoTV Streaming, LLC v. Netflix, Inc.,
`2:22-cv-07556 (C.D. Cal. issued Feb. 13, 2023) (Doc. 61)
`2017 Excerpts from Redacted and De-designated Corrected Declaration of
`Dr. John Villasenor Regarding Invalidity of U.S. Patent Nos.
`8,989,715; 8,478,245; and 8,103,865, GoTV Streaming, LLC v.
`Netflix, Inc., 2:22-cv-07556 (C.D. Cal. served June 23, 2023)
`2018 Declaration of Joshua S. Wyde regarding authentication of exhibits
`(Aug. 10, 2023)
`2019 Excerpts from Trial Transcript Day 2, GoTV Streaming, LLC v. Netflix,
`Inc., No. 2:22-cv-07556 (C.D. Cal. Oct. 18, 2023)
`2020 Excerpts from Trial Transcript Day 3, GoTV Streaming, LLC v. Netflix,
`Inc., No. 2:22-cv-07556 (C.D. Cal. Oct. 19, 2023)
`2021 Defendant Netflix, Inc.’s Notice of Motion and Rule 50(a) Motion for
`Judgment as a Matter of Law, GoTV Streaming, LLC v. Netflix,
`Inc., No. 2:22-cv-07556 (C.D. Cal. Oct. 19, 2023) (Dkt. 389)
`Intentionally Left Blank
`2022
`2023 Generate, Free On-Line Dictionary of Computing, available at
`https://foldoc.org/generate (last updated June 15, 1995).
`2024 Output, TechTerms.com; The Computer Dictionary, available at
`https://techterms.com/definition/output (last updated December
`12, 2006)
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`No. Brief Description
`2025 From, Merriam-Webster.com Dictionary, available at
`https://www.merriam-webster.com/dictionary/from (last visited
`December 12, 2023)
`2026 Customized, Merriam-Webster.com Dictionary, available at
`https://www.merriam-webster.com/dictionary/customized (last
`visited December 29, 2023)
`2027 Application-Specific, Wiktionary, available at
`https://en.wiktionary.org/wiki/application-specific (last visited
`Dec. 15, 2023)
`2028 Excerpt from 10-K statement filed by Netflix with the Securities and
`Exchange Commission (Jan. 26, 2023)
`2029 Excerpt from Netflix Women In Tech Event - UI Engineering - August
`2018, Jessica Berglund, Netflix UI engineer, 22:43–23:02,
`available at https://www.youtube.com/watch?v=YpIGejJiaBo
`2030 Ethan Kao Deposition Designations Video, GoTV Streaming, LLC v.
`Netflix, Inc., No. 2:22-cv-07556 (C.D. Cal. Oct. 19, 2023)
`(Dkt. 413-13)
`2031 Deposition of Dr. Benjamin Bederson (Jan. 10, 2024)1
`2032 Second Declaration of Joshua S. Wyde regarding authentication of
`exhibits (Jan. 29, 2024)
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`1 Per Party agreement, Dr. Bederson conducted a consolidated deposition
`
`regarding U.S. Patent Number 8,989,715 in IPR No. IPR2023-00757; Patent
`
`No. 8,478,245 in IPR No. IPR2023-00758; and U.S. Patent No. 8,103,865 in IPR
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`No. IPR2023-00759. See Ex. 2031, 5:21–6:11.
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`1[pre]
`
`1[a]
`
`1[b]
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`1[c]
`
`1[d]
`
`1[e]
`
`1[f]
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`1[g]
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`2
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`3
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`4
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`5
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`6
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`7
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`8
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`CLAIM LISTING
`
`Limitation
`1. A method of generating content that is renderable by a wireless
`device, said method comprising:
`transmitting, to said wireless device, an identification of a custom
`configuration of a plurality of rendering blocks of said wireless device,
`wherein said custom configuration is associated with an application and
`configures said plurality of rendering blocks to render content in a
`manner customized to said application; and
`transmitting, to said wireless device, compiled content comprising (i)
`first compiled content specific to a first page of said application and (ii)
`second compiled content specific to a second page of said application,
`wherein said compiled content is generated in part from execution of
`said application,
`wherein said compiled content comprises render commands expressed
`in a syntax that is generic to said wireless device, and
`wherein said custom configuration is applicable to said first and second
`compiled content,
`wherein said compiled content and said custom configuration are
`usable by a graphical user interface comprising said plurality of
`rendering blocks to generate renderable content based on said compiled
`content and said custom configuration.
`2. A method as described in claim 1 wherein said renderable content
`comprises audio content and display content.
`3. A method as described in claim 1 wherein said compiled content is
`partially resultant from said application operating on a remote server.
`4. A method as described in claim 1 wherein said compiled content is
`specific to the rendering capabilities of said wireless device.
`5. A method as described in claim 1 wherein each of said plurality of
`rendering blocks operates specific to a wireless device type of said
`wireless device and each is instructed using a syntax that is generic to
`said wireless device type.
`6. A method as described in claim 5 wherein said custom configuration
`comprises a syntax that is generic regarding said wireless device type.
`7. A method as described in claim 1 wherein said custom configuration
`comprises configuration information and content specific to said
`application.
`8. A method as described in claim 1 wherein said custom configuration
`is one of a plurality of memory-stored custom configurations stored by
`said wireless device, and wherein said method further comprises
`transmitting an identifier that identifies said custom configuration.
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`9[pre]
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`9[a]
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`9[b]
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`9[c]
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`9[d]
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`9[e]
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`9[f]
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`9[g]
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`10
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`11
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`12
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`13
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`14
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`15
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`Limitation
`9. A non-transitory computer readable medium comprising instructions
`therein that when executed by a processor implement a method of
`generating content that is renderable by a wireless device, said method
`comprising:
`transmitting, to said wireless device, an identification of a custom
`configuration of a plurality of rendering blocks of said wireless device,
` wherein said custom configuration is associated with an application
`and configures said plurality of rendering blocks to render content in a
`manner customized to said application; and
`transmitting, to said wireless device, compiled content comprising (i)
`first compiled content specific to a first page of said application and (ii)
`second compiled content specific to a second page of said application,
` wherein said compiled content is generated in part from execution of
`said application,
`wherein said compiled content comprises render commands expressed
`in a syntax that is generic to said wireless device, and
`wherein said custom configuration is applicable to said first and second
`compiled content,
`wherein said compiled content and said custom configuration are
`usable by a graphical user interface comprising said plurality of
`rendering blocks to generate renderable content based on said compiled
`content and said custom configuration.
`10. A non-transitory computer readable medium as described in claim 9
`wherein said renderable content comprises audio content and display
`content.
`11. A non-transitory computer readable medium as described in claim 9
`wherein said compiled content is partially resultant from said
`application operating on a remote server.
`12. A non-transitory computer readable medium as described in claim 9
`wherein said compiled content is specific to the rendering capabilities
`of said wireless device.
`13. A non-transitory computer readable medium as described in claim 9
`wherein each of said plurality of rendering blocks operates specific to
`a wireless device type of said wireless device and each is instructed
`using a syntax that is generic to said wireless device type.
`14. A non-transitory computer readable medium as described in
`claim 13 wherein said custom configuration comprises a syntax that is
`generic regarding said wireless device type.
`15. A non-transitory computer readable medium as described in claim 9
`wherein
`said custom
`configuration
`comprises
`configuration
`information and content specific to said application.
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`16
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`17[a]
`17[b]
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`17[c]
`
`Limitation
`16. A non-transitory computer readable medium as described in claim 9
`wherein said method further comprises transmitting an identifier that
`identifies said custom configuration.
`17[pre] 17. A server that is programmed to generate content that is renderable
`by a wireless device, comprising:
`a library of applications;
`a
`library of custom configuration data comprising a custom
`configuration that configures a plurality of rendering blocks of said
`wireless device to render content in a manner customized to an
`application from said library of applications requested by said wireless
`device; and
`a layout solver that transmits compiled content to said wireless device,
`said compiled content comprising (i) first compiled content specific to
`a first page of said application and (ii) second compiled content specific
`to a second page of said application,
`17[d] wherein said compiled content is generated in part from execution of
`said application by said server,
`17[e] wherein said compiled content comprises render commands expressed
`in a syntax that is generic to said wireless device, and
`17[f] wherein said custom configuration is applicable to said first and second
`compiled content,
`17[g] wherein said compiled content and said custom configuration are
`usable by a graphical user interface comprising said plurality of
`rendering blocks to generate renderable content based on said compiled
`content and said custom configuration.
`18. A server as described in claim 17 wherein said renderable content
`comprises audio content and display content.
`19. A server as described in claim 17 wherein said compiled content is
`specific to the rendering capabilities of said wireless device.
`20. A server as described in claim 17 wherein said custom
`configuration comprises configuration information and content specific
`to said application.
`
`18
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`19
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`20
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`Patent No. 8,989,715
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`I.
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`INTRODUCTION2
`
`¶1. My name is Mr. Stuart Lipoff. I have been retained by GoTV
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`Streaming, LLC, (“Patent Owner” or “GoTV”) to provide my expert assessment and
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`technical opinions in connection with the above captioned inter partes review
`
`(“IPR”) of U.S. Patent No. 8,989,715 (“’715 Patent” or “Patent-at-Issue”), Ex. 1001.
`
`¶2. Specifically, I will provide my opinion regarding Claims 1–20
`
`(“Challenged Claims”) over U.S. Patent Application Publication No. 2007/0150617
`
`(“Hariki”) in view of U.S. Patent Application Publication No. 2003/0023755
`
`(“Harris”).
`
`¶3. This declaration is based on information currently available to me. I
`
`reserve the right to expand, modify, or supplement my opinions if I become aware
`
`of evidence or information that was not available for review at the time I drafted this
`
`declaration.
`
`¶4. GoTV is paying me at a rate of $375 per hour plus expenses for my
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`study and testimony in this case. This compensation is not contingent upon my
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`performance, the outcome of this IPR, or any issues involved in or related to this
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`IPR.
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`2 All emphasis is added in this report unless otherwise noted.
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`II.
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`PROFESSIONAL BACKGROUND AND QUALIFICATIONS
`
`¶5.
`
`I have attached my resume as Appendix A to this declaration. While
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`my resume summarizes my educational background and work history, I will now
`
`expound upon my qualifications and professional background related to the field of
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`wireless communication systems for rendering applications on a wireless device,
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`distributed software applications that have a graphical user interface, and related
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`applications and technology.
`
`¶6.
`
`I have bachelor’s degrees in electrical engineering and in engineering
`
`physics, both from Lehigh University. I also have a master’s degree in electrical
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`engineering from Northeastern University, and an MBA degree from Suffolk
`
`University.
`
`¶7.
`
`I was employed for 25 years by Arthur D Little, Inc. as VP and Director
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`of Communications, Information Technology, and Electronics (“CIE”), where I was
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`responsible for the firm’s global CIE practice in laboratory-based contract
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`engineering, product development, and technology-based consulting.
`
`¶8.
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`I was employed by Bell & Howell Communications Company for four
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`years as a Section Manager.
`
`¶9.
`
`I was employed by Motorola’s Communications Division for three
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`years as a Project Engineer.
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`IPR2023-00757
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`Patent No. 8,989,715
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`¶10. At both Bell & Howell and Motorola, I had project-design
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`responsibility for wireless communications devices with graphical user interfaces
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`controlled by remote terminal servers.
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`¶11. I have extensive experience—over a 50-year period—working on
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`legacy and modern applications that relate to the subject matter of the challenged
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`patents involving the delivery of remote information and multimedia content to be
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`rendered on intelligent devices.
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`¶12. For Comcast Corporation, I supported a number of their initiatives in
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`public network wireless services. This support included identifying applications and
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`the supporting technologies to add value beyond basic voice services.
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`¶13. For Securus, a provider of pay per call alternate operator services to
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`prison inmates, I evaluated their technology and assets with an emphasis on their
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`ability to associate calling and calling party phone numbers with databases combined
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`with their employees with multiple language skills. Following this evaluation, I
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`worked with the client to identify and plan for offering services to clients other than
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`prison inmates. Examples of such clients included government operated call centers,
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`hospitals, police departments, and telephone catalog sales call centers making use of
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`intelligent rendering engines in cellphones.
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`¶14. For International Mobile Machines (“IMM”), a firm that licenses
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`patents to cellphone OEMs, I developed a roadmap of future services, architectures,
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`Patent No. 8,989,715
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`and technology to support alternative visions of the development of cellular. I then
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`worked with the firm to generate R&D projects designed to increase the base of
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`patents for IMM to license in the future. The service concepts I generated employed
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`technologies that supported distributed software applications that have a graphical
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`user interface.
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`¶15. For International Finance Corporation (the venture capital group of The
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`UN’s World Bank), I evaluated an investment opportunity in Cellon Inc, a PRC
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`based cellphone design house. This project included inspection of Cellon’s facilities
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`in the PRC and France as well as detailed review of Cellon’s facility assets,
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`technology strengths, and intellectual property. Of particular focus was Cellon’s
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`technology to support enhanced services with graphic user interfaces.
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`¶16. For the patent and licensing division of The General Electric Company,
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`I evaluated a number of patent portfolios in the wireless telecommunications space
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`and provided feedback to the client on the application and value of these patents.
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`¶17. For Tele2 (a pan European cellular and wireline telephone company), I
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`supported Tele2’s efforts to procure an advanced cordless telephone from contract
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`manufacturers in China (“PRC”). This involved development of detailed technical
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`specifications, coordination of a request for information, (“RFI”), and evaluation of
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`the responses. The devices were all enhanced to provide non-voice services.
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`Patent No. 8,989,715
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`¶18. For Millicom International (a cellular provider in several developing
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`nations), I studied capital spending and developed best practice benchmarks. The
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`work products were then employed in forward planning and to develop strategies for
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`improvement of their financial performance. The project involved the collection of
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`data from over 25 systems in 12 countries and developing capital efficiency metrics
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`that were normalized to the specific geographic and demographic specifics of each
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`system. The project not only provided a measure of present and historical capital
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`efficiency but also provided a management system for future deployment.
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`¶19. For the banks providing financing to The Iridium Mobile Satellite
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`Service, I served as a technical advisor and assisted in developing the contracts
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`between the banks and Motorola in which Motorola secured the loan. As a technical
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`advisor, I had extensive day-to-day interactions with Motorola’s manufacturing and
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`product design organizations. The interactions included examination of the
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`manufacturing cost, methods, and processes of Motorola’s Subscriber Products
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`Group including voice and data applications of cellphones, pagers, and related
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`portable wireless data communications devices.
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`¶20. For Sony USA, I supported a feasibility analysis of a planned
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`investment by Sony into a wireless PCS carrier in the USA. This involved the
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`development of advanced concepts employing distributed software applications that
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`have a graphical user interface and exploring alternative business models, financial
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`Patent No. 8,989,715
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`analysis, and technical analysis in order to determine financial attractiveness and risk
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`of proceeding with the venture.
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`¶21. For Samsung Electronics Global Marketing, I developed a strategic
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`framework for a line of portable and personal multimedia products to be introduced
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`in the USA. The project included developing a common theme for a set of products
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`that ranged from cellphones, MP3 music players, electronic books, PDAs, to hand-
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`held games. One common theme was developed, product features and capabilities
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`were detailed, and market adoption models were developed to forecast demand.
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`¶22. For Korea Mobile Telephone (“KMT”), I supported the project that
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`developed a strategic plan to position KMT relative to Korea Telecom by enhancing
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`their service offerings to support distributed software applica