UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`Microsoft Corporation, Dell Inc., and Dell Technologies Inc.,
`Petitioners
`
`v.
`
`Ozmo Licensing LLC
`Patent Owner
`
`U.S. Patent No. 8,599,814
`Filing Date: July 27, 2012
`Issue Date: December 3, 2013
`
`Title: Apparatus and Method for Integrating Short-Range Wireless Personal Area
`Networks for a Wireless Local Area Network Infrastructure
`
`
`DECLARATION OF JAMES PROCTOR
`U.S. PATENT NO. 8,599,814
`
`
`
`
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`TABLE OF CONTENTS
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`TABLE OF CONTENTS .......................................................................................... ii
`
`LIST OF EXHIBITS ................................................................................................ iii
`
`I.
`
`Introduction ......................................................................................................... 1
`
`I. BACKGROUND AND QUALIFICATIONS .................................................... 1
`
`II. UNDERSTANDING OF THE LAW ................................................................. 6
`
`III. THE ’814 PATENT ......................................................................................... 7
`
`IV. Printed Publications ......................................................................................... 8
`
`A. Bluetooth Specification v1.1 (EX1006) (“Bluetooth Specification”) ............. 8
`
`B. 802.11-1999 (“802.11”; EX1017), 802.11b-1999 (“802.11b”; EX1018), and
`
`802.11g-2003 (“802.11g”; EX1019) ....................................................................10
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`V. CONCLUSION .................................................................................................12
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`
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`LIST OF EXHIBITS
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`Exhibit No.
`
`Description
`
`1001
`
`1006
`
`1010
`
`1017
`
`1018
`
`1019
`
`1021
`
`U.S. Patent No. 8,599,814 (“the 814 patent”)
`
`Specification of the Bluetooth System, Version 1.1, February 22,
`2001 (“Bluetooth Specification”)
`
`U.S. Pat. Pub. No. 2005/0174962 (“Gurevich”)
`
`802.11-1999
`
`802.11b-1999
`
`802.11g-2003
`
`802.15.1-2002
`
`1025
`
`U.S. Patent No. 6,255,800
`
`1026
`
`1027
`
`1028
`
`1029
`
`1030
`
`1031
`
`1032
`
`1033
`
`
`
`April 1, 2002 WaybackMachine Archive of www.Bluetooth.com
`(visited June 20, 2023)
`
`April 7, 2002 WaybackMachine Archive of
`http://Bluetooth.com/dev/specifications.asp (visited June 13,
`2023)
`
`IEEE Xplore, 802.11-1999 (reaffirmed 2003) Specification,
`https://ieeexplore.ieee.org/document/1389197 (visited June 13,
`2023)
`
`IEEE Xplore, 802.11b-1999 Specification,
`https://ieeexplore.ieee.org/document/817038 (visited June 13,
`2023)
`
`IEEE Xplore, 802.11g-2003 Specification,
`https://ieeexplore.ieee.org/document/1210624 (visited June 13,
`2023)
`
`Feb. 12, 2004 WaybackMachine Archive of
`http://standards.ieee.org/getiee802/802.11.html
`
`Declaration of James Proctor (“Proctor Decl.”)
`
`U.S. Patent No. 7,990,904
`
`iii
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`I, James A. Proctor, Jr., hereby declare as follows:
`
`I.
`
`INTRODUCTION
`
`1.
`
`I have been retained by Petitioner at my normal hourly rate of $500
`
`per hour. No part of my compensation is dependent upon the outcome of the
`
`petition for inter partes review or the specifics of my testimony.
`
`2.
`
`I am over 21 years old and otherwise competent to make this
`
`Declaration. I make this Declaration based on facts and matters within my own
`
`knowledge and, if called as a witness, I could and would competently testify to the
`
`matters set forth herein.
`
`I.
`
`BACKGROUND AND QUALIFICATIONS
`
`3. My background and expertise that qualify me as an expert are
`
`described in detail in my Curriculum Vitae attached as Attachment A, which
`
`further includes an accurate list of all publications authored by me in the previous
`
`10 years and a list of all cases in which I testified as an expert at trial or by
`
`deposition during the previous 4 years.
`
`4. My educational background includes a Bachelor of Science in
`
`Electrical Engineering (BSEE) from the University of Florida in 1991 and Master
`
`of Science in Electrical Engineering (MSEE) from the Georgia Institute of
`
`Technology (“Georgia Tech”) in 1992 focusing on digital signal processing.
`
`1
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`5.
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`I have worked as an engineer and entrepreneur in the field of wireless
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`communications for over 25 years and have been involved with various aspects of
`
`wireless communications for the duration of my career.
`
`6.
`
`From 1986 to 1991, while at the University of Florida, I interned with
`
`Harris Corporation in various roles including mechanical design, software
`
`development, and digital design. From 1991 to 1992, while at Georgia Tech, I
`
`worked at the Georgia Tech Research Institute (GTRI) as a graduate research
`
`assistant, performing software development on classified government programs.
`
`7.
`
`From 1993 to 1995, while working for Harris Corporation, I designed
`
`various cellular communication systems for voice, data, and tracking/location.
`
`Many of these systems I designed utilized advanced communications technologies,
`
`such as those utilized in the then-developing and future telecommunications (such
`
`as IS95, W-CDMA, and aspects of LTE).
`
`8.
`
`From 1995 to 1998, I worked at Spectran in advanced development
`
`and technical marketing. At Spectrian, I interfaced with Nortel’s and Qualcomm’s
`
`product management and performed advanced technology development and
`
`systems analysis. In this role, I designed IS-95 CDMA and GSM base station
`
`power amplifiers and control electronics, and received several patents associated
`
`with advanced linearization techniques for the reduction of transmitted distortion. I
`
`note that the peak to average ratio of various waveforms was of particular concern
`
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`in the design of the power amplifiers and associated linearization techniques with
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`the designs I was involved with during my work at Spectrian.
`
`9.
`
`From 1998 to 2002, I served as the Director of Strategic and
`
`Technical Marketing at Tantivy Communications, a venture capital-funded 3G
`
`cellular data and chip set company. At Tantivy, I helped to architect and
`
`standardize the I-CDMA Spread Spectrum Systems Air Interface Standard
`
`(T1P1.4). I also developed both wireless access terminals and base stations that
`
`complied with the standard. The base stations utilized various IP protocols, and
`
`interfaced with the wire line network utilizing IP over Ethernet. Additionally, I
`
`participated in and provided technical contributions to 3GPP/3GPP2
`
`standardization efforts related to the development of CDMA2000 and 1xEV-DO.
`
`This work resulted in me being a named inventor on more than 150 pending or
`
`issued U.S. patents or applications.
`
`10. From 2002 to 2007, as co-founder of WiDeFi, Inc., I served in various
`
`roles including President, CEO, CTO, and board member. As the CEO, my
`
`responsibilities included advanced development of platform technologies. I was a
`
`named inventor of wireless technology components, including a frequency
`
`translating TDD repeater, a same frequency repeater architecture for TDD/FDD-
`
`based systems, and physical layer multi-stream MIMO repeater technology.
`
`WiDeFi invented and provided wireless home networking products based on WiFi
`
`3
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`and cellular technologies. While at WiDeFi, I was a named inventor on over 25
`
`issued U.S. patents or patent applications.
`
`11. From 2007 to 2009, I consulted as a principal engineer for Qualcomm
`
`Inc. as part of the acquisition of WiDeFi’s technology. While at Qualcomm, I
`
`worked with its corporate R&D division and developed consumer 3G and 4G
`
`cellular coverage enhancement systems utilizing WiDeFi’s baseband interference
`
`cancellation technologies. My responsibilities included working with international
`
`cellular operators on product requirements, detailed W-CDMA simulations, Long
`
`Term Evolution (“LTE”) systems analysis, and participation in prototype product
`
`realization. I am currently a named inventor on roughly 45 issued U.S. patents or
`
`patent applications assigned to Qualcomm.
`
`12. From 2010 to the present, I have served as managing director and co-
`
`founder of Proxicom Wireless, LLC, which has developed and continues to
`
`develop cloud-based, mobile social networking and mobile payments technology
`
`based upon the proximity and location of mobile devices. Proxicom currently holds
`
`twelve issued U.S. patents and multiple pending patent applications, of which I am
`
`a named inventor. Significant aspects of Proxicom’s technology involve a mobile
`
`device’s use of short range wireless technologies (802.11, near field
`
`communications, Bluetooth) in combination with cellular data links (3G/WCDMA
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`or 4G/LTE, for example) to facilitate frictionless interactions via a wireless
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`networked central cloud server.
`
`13. Since 2007, I have also been the principal of Proctor Consulting, LLC.
`
`In this role, I have been a consultant relating to wired, wireless, and cellular
`
`communication and technologies, start-up companies and intellectual property. I
`
`have also been involved with numerous patent infringement, patent validity, and
`
`patent analysis assignments for public and private companies in the wired,
`
`wireless, and cellular networking industries.
`
`14. Additionally, I have worked and consulted for both cellular
`
`infrastructure and device focused companies (Spectrian, Qualcomm, Fastback
`
`Networks), and defense contractors (Harris Corporation), where I developed
`
`covert-tracking and location technologies involving CDMA and smart-antenna
`
`technologies.
`
`15.
`
`In various of the above-detailed roles, I have been responsible for the
`
`development of business plans, product development plans, product development
`
`budgets, and product bill of materials estimations. I have been responsible for
`
`numerous product development teams, including schedule and costs of the
`
`development process at various stages of my career. For example, at Tantivy
`
`Communications, I ran a joint development of I-CDMA cellular base stations in
`
`Seoul, Korea that were used in a field trial in that country. Additionally, as founder
`
`5
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`and CEO of WiDeFi, Inc., I was responsible for similar such activities, as required
`
`to raise venture capital funding and reporting to the board of directors.
`
`16.
`
`I am currently a named inventor on more than 320 issued U.S. patents,
`
`and more than 700 international patent publications in total. A substantial portion
`
`of my work has focused on wireless communication systems and products. A
`
`number of these patents and patent applications corroborate the statements
`
`provided in this declaration.
`
`17.
`
`I am personally familiar with the content and public availability of the
`
`802.11-1999, 802.11b, 802.11g, and Bluetooth standards. For example, I am a
`
`named inventor on each of the patents listed below, each of which was filed prior
`
`to 2004, and each of which discusses those standards.
`
`U.S. Patent No.
`7,990,904
`8,060,009
`
`Title
`“Wireless network repeater”
`“Wireless local area network repeater with automatic gain
`control for extending network coverage”
`“Wireless local area network repeater with detection”
`“Reducing loop effects in a wireless local area network
`repeater”
`II. UNDERSTANDING OF THE LAW
`
`8,111,645
`8,122,134
`
`18.
`
`I am not a legal expert and therefore I offer no opinions on the law.
`
`However, I have been informed and am aware of legal standards that are relevant
`
`to my analysis, as summarized below.
`
`19.
`
`It has been explained to me that an electronic publication, including
`
`an online data base or Internet publication, is considered to be a “printed
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`publication” provided persons interested and of ordinary skill in the art to which
`
`the publication relates had access to the publication or otherwise could have, by
`
`exercising reasonable diligence, located the publication.
`
`20.
`
`I understand that while an indexed publications may be relevant in
`
`determining whether a publication is considered “printed,” it is not determinative.
`
`For example, I understand additional factors to consider when determining whether
`
`Internet material is considered a “printed publication” are (a) the website which
`
`published the material was known to the interested public; (b) the published
`
`material was treated by the community as being public and could be copied; and
`
`(c) the website had an internal search tool that could be used to locate the article.
`
`21.
`
`I have also been informed that the date of availability for such printed
`
`publications is considered to be the date the document was publicly posted.
`
`22.
`
`I understand that to be considered prior art, a printed publication must
`
`have been publicly available more than one year prior to the earliest priority date
`
`of the asserted patent (the critical date).
`
`III. THE ’814 PATENT
`
`23. The ’814 patent is generally directed to wireless communications.
`
`More particularly, the invention relates to seamlessly integrating short-range
`
`wireless personal area networks (“WPANs”) into longer-range wireless local area
`
`networks. (“WLANs”). EX1001, 1:25-29. With respect to the wireless networks,
`
`7
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`the ’814 patent discloses various wireless protocols such as, for example, 802.11b,
`
`802.11g, and Bluetooth (based on the IEEE 802.15.1 standard). Id. 1:54-2:44.
`
`24. The earliest priority date listed on the face of the asserted patents is
`
`March 14, 2005 (based on U.S. Provisional Patent App. No. 60/661,763) and,
`
`therefore, I am informed that anything published prior to March 14, 2004 is prior
`
`art to the ’814 patent.
`
`IV. PRINTED PUBLICATIONS
`
`A. Bluetooth Specification v1.1 (EX1006) (“Bluetooth Specification”)
`
`25. EX1006 is a true and correct copy of The Bluetooth Specification
`
`(v1.1). The Bluetooth Specification is entitled “Specification of the Bluetooth
`
`System” and further provides that it is a “Core” document. EX1006, Cover. The
`
`Bluetooth Specification was a well-known specification in the wireless industry at
`
`least as early as its publication on February 22, 2001 but by no later than 2002.
`
`Indeed, the Bluetooth Specification provides copyright years of 1999, 2000, and
`
`2001. Id. at pp. 3. In addition, the Bluetooth Specification (v1.1) was also well-
`
`known as IEEE 802.15.1-2002 (EX1021). See EX1021 at pp. 3 (explaining
`
`802.15.1 is “based on the Bluetooth core specification (version 1.1)” with minimal
`
`to no alterations to the text of the Bluetooth specifications); see also id. (providing
`
`a 2002 copyright, print ISBN and PDF ISBN).
`
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`26.
`
`I recall the Bluetooth Specification being published via
`
`www.Bluetooth.com in 2001. The Bluetooth Specification was also known to those
`
`working in the field of wireless networks to be indexed on, and readily accessible
`
`at the that website. My recollection is confirmed by contemporaneous prior art,
`
`such as U.S. Patent No. 6,255,800 (filed on January 3, 2000). EX1025 (U.S. Patent
`
`No. 6,255,800) at 6:26-29 (Bluetooth specifications “can be found at
`
`www.Bluetooth.com or www.Bluetooth.net).
`
`27. Further confirming my recollection, on June 13, 2023, I accessed an
`
`April 1, 2002 archival of www.Bluetooth.com through the Wayback Machine
`
`(web.archive.org/web/20020401234331mp_/http://www.bluetooth.com/index.asp).
`
`A true and correct copy of the April 1, 2002 archive is provided as EX1026. At
`
`that time, www.Bluetooth.com (the Bluetooth website) stated that it is “The
`
`Official Bluetooth Website.” EX1026. After selecting the “developer information”
`
`hyperlink (which is one of four options on the main webpage), I was directed to an
`
`April 7, 2002 archived page of the Bluetooth website entitled “the specification”
`
`(web.archive.org/web/20020407225138mp_/http://bluetooth.com/dev/specification
`
`s.asp). A true and correct copy of the April 7, 2002 archive is provided as EX1027.
`
`“The specification” page explained that the “Bluetooth Specification contains the
`
`information necessary to ensure that diverse devices supporting the Bluetooth
`
`wireless technology can communicate with each other worldwide” and further
`
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`provided a hyperlink to “v.1.1 core.” Id. Upon clicking the “v.1.1 core” hyperlink,
`
`I was directed to the December 17, 2001 downloadable archival of the February
`
`22, 2001 Core “Specification of the Bluetooth System,” version 1.1
`
`(https://web.archive.org/web/20011February%2022,%202001217222220/http://ww
`
`w.bluetooth.com/pdf/Bluetooth_11_Specifications_Book.pdf).
`
`28.
`
`In or around 2002-2003, I recall reviewing the Bluetooth specification
`
`(v1.1) and I subsequently reviewed it numerous times thereafter. My recollection is
`
`confirmed by my patent, U.S. Patent No. 8,122,134 having a priority date of
`
`October 11, 2002, which discusses Bluetooth. EX1033 at 7:4-6. I have also
`
`reviewed EX1006, and it is a true and accurate copy of the Bluetooth specification
`
`I reviewed in or around 2002.
`
`B.
`
`802.11-1999 (“802.11”; EX1017), 802.11b-1999 (“802.11b”;
`EX1018), and 802.11g-2003 (“802.11g”; EX1019)
`
`29. EX1017 is a true and correct copy of 802.11-1999. EX1018 is a true
`
`and correct copy of 802.11b. EX1019 is a true and correct copy of 802.11g.
`
`30. The Institute of Electrical and Electronics Engineers (IEEE) is a
`
`known and reputable organization which published the well-known family of
`
`802.11 standards directed to WLANs.
`
`31.
`
`I recall that the IEEE published 802.11-1999 originally in 1999—and
`
`subsequently in 2003 (reaffirmed 2003), 802.11b in 2000, and 802.11g in 2003. I
`
`was personally familiar with those standards and obtained them from the IEEE
`
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`website for use in my work prior to 2004. For example, I was familiar with these
`
`standards and discussed them in my patent, U.S. Patent No. 7,990,904 (EX1033)
`
`(filed on December 16, 2003). See EX1033 at 1:25-2:50 (disclosing 802.11), 3:36-
`
`39 (“as is well known to those of ordinary skill in the art, 802.11b and 802.11g are
`
`standards specifying transmission protocols for the 2.4 GHz systems.”), page 3-4
`
`(identifying 802.11-1999, 802.11b, and 802.11g as cited publications).
`
`32. The current IEEE Xplore website provides the publication date and
`
`ISBN of each of 802.11-1999, 802.11b, and 802.11g. See EX1028-EX1030,
`
`respectively.
`
`33.
`
`In addition, these standards were well-known to those working in the
`
`field of wireless networks prior to 2004 to be indexed and accessible on the IEEE
`
`website. For example, U.S. Patent Pub. No. 2005/0174962 (EX1010) (filed on
`
`December 16, 2004), provides the URL to access the specifications. EX1010 (“The
`
`IEEE 802.11 WiFi specification is located at
`
`http://standards.ieee.org/getieee802/802.11.html and is herein incorporated by
`
`reference”).
`
`34. Further confirming the above, on June 13, 2023, I accessed a February
`
`12, 2004 archival of “http://standards.ieee.org/getieee802/802.11.html” through the
`
`Wayback Machine
`
`(https://web.archive.org/web/20040212055445/http://standards.ieee.org/getieee802
`
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`/802.11.html). A true and correct copy of the April 1, 2002 archive is provided as
`
`EX1031. The February 12, 2004 archive demonstrates that 802.11-1999, 802.11b-
`
`1999, and 802.11g-2003 were available and accessible at that time. Id.
`
`35.
`
`Prior to March 14, 2004, I recall reviewing each of the 802.11-1999,
`
`802.11b, and 802.11g specifications. As part of developing wireless platform
`
`technologies for my company Wi-DeFi, Inc. (see supra Paragraph 9) from 2003-
`
`2004, I recall locating, reviewing, and using the published 802.11-1999, 802.11b,
`
`802.11g specifications to develop standard-compliant devices. See also EX1033 at
`
`page 3-4. I have also reviewed EX1017 (802.11-1999). EX1018 (802.11b) and
`
`EX1019 (802.11g), and each is a true and correct copy of the respective standard
`
`that I reviewed prior to March 14, 2004.
`
`V.
`
`CONCLUSION
`
`36.
`
`I hereby declare under penalty of perjury under the laws of the United
`
`States of America that the foregoing is true and correct.
`
`Date: June ____, 2023
`
`By: __________________________
`James A. Proctor, Jr.
`
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`ATTACHMENT A
`ATTACHMENT A
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`

`James A. Proctor Jr.
`1680 North Riverside Drive, Indialantic, FL 32903 - (321) 271-8411 - jproctor@ieee.org
`
`
`
`EDUCATION
`
`M.S. Electrical Engineering
`
`
`Georgia Institute of Technology, Atlanta, Georgia
`Graduated:
`
`September 1992
`Interests:
`
`Digital Signal Processing, Communications, Optics
`
`The University of Florida, Gainesville, Florida
`
`
`B.S. Electrical Engineering
`Graduated:
`
`May 1991
`Minor Studies:
`Business
`Honors & Activities:
`PI ETA SIGMA Honor Society
`
`
`
`ALPHA LAMBDA DELTA Freshman Honor Society
`ETA KAPPA NU National Electrical Engineering Fraternity
`
`
`Skills & Achievements
`
`
`- Successfully led Qualcomm / WiDeFi integration efforts resulting in a new product effort within
`Qualcomm related to the 3G/4G Market
`- Co-founded WiDeFi and successfully raised >$14M of venture funding
`- Generated intellectual property and product strategy leading to the acquisition of two companies
`(WiDeFi, and Tantivy Communications), contributing to > $100M of revenue
`- Performed extensive customer and industry business development to provide support for innovative
`product definition, requirement definition, and customer support for business plan and forecasts
`(Qualcomm, WiDeFi, and Tantivy Communications)
`Led and coached many R&D teams to refine and de-risk innovative wireless concepts
`-
`Led cross functional product teams to deliver high volume ready prototypes
`-
`- Ability to balance market, programmatic, and technical concerns and refine clear strategy and
`actionable plans
`- Generated >320 issued US Patents Currently and >700 international patent publications
`- Have spoken at numerous public events: industry, venture, and technical
`- Strong communication and technical skills
`
`
`Work Experience
`
`
`
`
`Proctor Consulting, LLC
`
`December 2008 - Present
`- Early stage market and technology strategy
`o
`Interim CTO/Team Member, business development/validation
`o Roadmap / IP development
`o Advisory Board Member
`- Technical / Market Consultant
`o Fastback Networks, Audigence, Peregrine Semiconductor
`Intellectual property portfolio analysis within the communications market space
`o Market / Product Applicability, Claims Chart Development and Analysis, Valuation
`o Expert Witness Consulting in Wireless Communications (WiFi, 2G-GSM, 3G-C2K/WCDMA,
`4G/LTE and associated networks)
`
`-
`
`
`November 2011 – Present
`
`Proxicom Wireless. Co-Founder, Managing Director
`- Proximity based mobile technology utilizing a centralized trusted third party
`- Development of foundational Intellectual Property (12+ US Patents)
`- Enabling technology applicable to a variety of proximity based applications including highly secure:
`Mobile Payments, Electronic Coupons and Loyalty, Rating and Reviews, Social Commerce
`
`
`
`
`
`1
`
`
`
`Proctor CV
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`EXHIBIT 1032 - PAGE 17
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`-
`
`-
`
` October 2007 - October 2009
`
`
`Qualcomm Inc., Principal Engineer (Consulting)
`Technical and Business development leadership of a consumer level 3G wireless repeater product
`-
`concept based upon WiDeFi’s technology during the integration
`Provided technical leadership in architecture development
`o Defined initial architecture approach for the wireless repeater concept based upon WiDeFi’s
`technology
`o Worked with technical team to refine approach and achieve “key proof points”
`Performed Business Development with International Wireless Operators
`o Worked closely with business development from ESG and QCT divisions
`o Developed bottoms up forecast with the top international wireless operators for consumer
`repeater products.
`o Refined product features to meet carrier’s requirements
`- Market Analysis to estimate Market Size and Competitive Landscape
`- Named inventor on 44+ Issued or pending patents for Qualcomm on wireless repeater concepts
`
`August 2005 - October 2007
`
`
`WiDeFi, Inc., EVP/CTO, and Co-Founder, Director
`- Focused on aligning WiDeFi’s technology and product roadmaps to customer and market drivers
`o Strategic and Technical Marketing, Product Definition
`o Market Analysis to estimate Market Size and Competitive Landscape
`o Collaborated with customers and internal team to define and pursue product/customer
`opportunities (Retail Wi-Fi, Mesh Repeater, VoiP over Wi-Fi Repeater, Cellular Repeaters, Wi-
`Max Repeaters, In-Building Distribution Systems)
`o Customer Development from initial contact, joint testing, first purchase order, to new product
`introduction
`o Contributed to and managed WiDeFi’s IP portfolio
`o Pursued fund raising from corporate and venture capital communities
`
`July 2002 - August 2005
`
`WiDeFi, Inc., President, CEO, and Co-Founder, Director
`Led WiDeFi from inception to the recruitment of an expansion-stage CEO.
`-
`Principal duties:
`-
`o Direct Fundraising of initial seed and Series A Venture Capital
`o General Management (Finance, Business Administration, Legal/Contracts and Organizational
`Development/Recruiting)
`o Coordination of Board of Directors and Investors
`o Sales (WiDeFi was Cash Flow positive prior to venture investment)
`
`
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`
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`April 1998 - June 2002
`
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`
`
`Tantivy Communications
`Director of Strategic and Technical Marketing
`- Business Development/Technical Due Diligence
`- Represented Tantivy in a wide range of Wireless Broad Band Industry Conferences
`Intellectual Property Management and Strategy
`-
`o Represented Tantivy’s Patents and their value to External Companies
`o Performed Validity, Infringement, and Value Analysis of Tantivy Patents for non-Tantivy products
`Industry Standards Representation for 3G Technologies
`o TIA/3GPP2, Over 15 Technical Contributions/Papers
`o T1P1 (3GPP Member)
`- Project Management of an International Technology Transfer Team (S Korea)
`- Performed System Architecture and Analysis
`
`Spectrian, Advanced Development and Technical Marketing
`Interfaced with NORTEL/Qualcomm’s Product Management
`-
`- Performed Advanced Technology Development/Systems Analysis
`
`-
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`1995 - April 1998
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`Proctor CV
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`DELL
`EXHIBIT 1032 - PAGE 18
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`September 1992 - 1995
`
`June 1991 - August 1992
`May 1990 - August 1990
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`
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`
`
`Harris Corp. GCSD,
`Senior Engineer Signal Processing Section, Modems Group
`
`Georgia Tech Research Institute, CSITL
`
`Harris Corp.. ISD, Electro-optics, Co-op
`- Acousto-optic signal processing
`
`
`
`
` Standards Development
`- Participated in architecting “Internet CDMA” (I-CDMA)
`Jointly led establishment of the Committee T1, working group T1P1.4 “WWINA” standardization
`-
`effort, which stands for “Wireless Wideband Internet Access”
`o T1 Approved this system as the T1.723-2002 standard
`- ATIS approved as ATIS0700723-2002 I-CDMA Spread Spectrum Systems Air Interface Standard
`- Participated in 3GPP2 Standards Developments (including 15+ technical contributions)
`
`Intellectual Property
`- More than 320 Issued U.S. Patents
`- More than 700 Issued or Pending International Patent Applications (WIPO)
`- Patents Cited at the USPTO more than 6000 times
`55+ Patents Assigned to Intel
`-
`45+ Patents Assigned to Qualcomm
`-
`16+ Patents designated as “Standards Essential” for UMTS (WCDMA)
`-
`6+ Patents designated as “Standards Essential” for LTE
`-
`
`
`
`Testifying Expert Experience
`
`SPH Am., LLC v. Acer, Inc., 09CV02535-CAB MDD, 2012 WL 1344515 (S.D. Cal. Apr. 18, 2012).
`Testifying Expert offering opinions on validity for the defense. The technology related to WCDMA
`modulation techniques. Resulted in settlement prior to trial.
`
`WI-LAN USA, INC. and WI-LAN INC. v. ELEFONAKTIEBOLAGET LM ERICSSON and ERICSSON INC.,
`Case No. l:12-23569-Civ (S.D. FL)
`Testifying expert offering opinions on infringement for the defense. The technology involved LTE
`“contention free” handover (CFRA), and Media Access Control (MAC) layer messaging for Quality of
`Service (QOS). Resulted in a summary judgement finding of non-infringement for the defense, and
`settlement after appeal.
`
`U.S. ETHERNET INNOVATIONS, LLC. V. STMICROELECTRONICS, INC.,
`Civil Action No. 6:12-cv-4181-MHS-JDL
`Testifying expert offering opinions on both validity and infringement for the defense. The
`technology related to Ethernet devices. Resulted in settlement prior to trial.
`
`UNWIRED PLANET. V. SQUARE, INC.,
`Case No. 3:13-CV-00579-RCJ-WGC, DISTRICT OF NEVADA,
`Case CBM2014-00156, Case IPR2014-01164, Case IPR2014-01165, UNITED STATES PATENT TRIAL
`AND APPEAL BOARD,
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`Proctor CV
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`DELL
`EXHIBIT 1032 - PAGE 19
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`Provided testimony related to claim construction, and validity for the defense. The technology
`was related to location based services (LBS). The case resulted in a finding by the Patent Trial and
`Appeal Board of unpatentability of all asserted claims.
`
`PRISM TECHNOLOGIES LLC. V. T-MOBILE USA, INC., Case No. 12-CV-124
`Testifying expert at trial, and deposition offering opinions on both validity and infringement for the
`defense. The technology was related to SIM/USIM/ISIM based authentication in UMTS, LTE, and IMS
`networks. The case resulted in a jury verdict of non-infringement.
`
`FASTVDO LLC. V. AT&T Mobility LLC, AT&T Services, Inc., and Apple Inc.,
`Case No. 3:16-cv-00385-H-WVG
`Engaged by Apple as the testifying expert offering opinions on infringement for the defense. The
`technology was related to Forward Error Correction (FEC) and voice codecs in GSM and WCDMA
`standards, including detailed FEC performance simulations. The case was concluded based upon an
`IPR outcome finding unpatentable subject matter by the PTAB.
`
`BLACKBERRY LIMITED V. BLU PRODUCTS, INC.,
`Case No.: 16-23535-CIV-MORENO
`Engaged by Blackberry as the testifying expert offering opinions on infringement for the plaintiff.
`The technology involved WCDMA and battery saving techniques in Radio Resource Control (RRC)
`states. The case was settled between the parties prior to trial.
`
`CELLULAR COMMUNICATIONS EQUIPMENT LLC V. AT&T Inc., and Apple Inc.
`Case No.: 2:15-cv-00576-RWS-RSP
`Engaged engaged by Apple as the testifying expert offering opinions on validity and benefits of
`the alleged inventions for the defense. The technology involved Media Access Control (MAC) messaging
`for LTE (Power Headroom Reporting) and LTE Advanced (CSI reporting for Carrier Aggregation). The
`case resulted in summary judgement for the defense.
`
`GENERAL ACCESS SOLUTIONS, LTD. v. Sprint Corporation et al.
`Civil Action No. 2:16-cv- 00465 (E.D. Tex.) and PTAB Proceedings (IPR2017-01885 (Patent 7,173,916
`B2) IPR2017-01887 (Patent 6,891,810 B2) IPR2017-01889 (Patent 7,230,931 B2),
`
`Engaged by Sprint to provide expert testimony relating to claim construction, and validity for the
`defense before the Patent Trial and Appeal Board (PTAB) relating to an Inter Partes Review petition,
`providing multiple expert declarations, and deposition testimony. The technology related to Adaptive
`Modulation and Coding (AMC) in a wireless system; Adaptive Beamforming, Sectorization, and Multi-
`Input Multi-Output (MIMO). All trials were instituted by the PTAB Board, with a finding of all petitioned
`claims unpatentable for two of the three patents.
`
`TC TECHNOLOGY LLC. V., Sprint Corporation and Sprint Spectrum, L.P
`Case 1:16-cv-00153-RGA
`
`Engaged by Sprint to provide expert testimony relating to validity and infringement by the
`defense, in the district of Delaware. The technology related to OFDMA and SC-FDMA use in the LTE
`uplink, for multiplexing transmissions from different UEs utilizing mutually exclusive OFDM subcarriers.
`The matter is currently pending.
`
`Mobility Workx, LLC v T-Mobile US, Inc.
`Civil Action No. 4:17-cv-00567-ALM
`Retained by the defendant, and provided declarations and deposition for claim construction, engaged for
`both invalidity and non-infringement analysis and testimony. This matter relates to LTE handover, and
`Mobile IP. The case was settled between the parties prior to trial.
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`Proctor CV
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`DELL
`EXHIBIT 1032 - PAGE 20
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`Mobility Workx, LLC v Cellco Partnership d/b/a Verizon Wireless
`Case No. 4:17-cv