UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`MOTOROLA SOLUTIONS, INC.,
`
`Petitioner,
`
`v.
`
`STA GROUP LLC,
`Patent Owner.
`
`
`
`IPR2023-01292
`U.S. Patent No.: 7,324,802 B2
`
`
`
`DECLARATION OF DAVID HILLIARD WILLIAMS IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW OF CLAIMS 1-21 OF U.S. PATENT
`NO. 7,324,802 B2
`
`
`
`
`
`
`
`
`
`Motorola Solutions, Inc., Ex1002, p. 1
`
`

`

`Declaration of David H. Williams
`IPR of USP 7,324,802
`
`TABLE OF CONTENTS
`
`Page
`INTRODUCTION ......................................................................................... 1 
`I. 
`PROFESSIONAL BACKGROUND AND QUALIFICATIONS ............. 2 
`II. 
`III.  MATERIALS CONSIDERED ................................................................... 11 
`IV.  LEGAL STANDARDS ................................................................................ 16 
`A. 
`Claim Construction ............................................................................. 16 
`B. 
`Obviousness ......................................................................................... 18 
`LEVEL OF ORDINARY SKILL IN THE ART ...................................... 22 
`V. 
`VI.  OVERVIEW OF THE ’802 PATENT ....................................................... 23 
`A. 
`Priority Date ........................................................................................ 23 
`B. 
`The Subject Matter of the Challenged Patent ..................................... 24 
`C. 
`The Challenged Claims of the ’802 Patent ......................................... 26 
`D. 
`Prosecution History ............................................................................. 31 
`E. 
`Level of Ordinary Skill in the Art ....................................................... 35 
`F. 
`Claim Construction of Terms in the Challenged Claims .................... 37 
`1. 
`Terms Governed By 35 U.S.C. § 112, ¶6 ................................. 38 
`VII.  TECHNOLOGY BACKGROUND AND STATE OF THE ART .......... 41 
`A. 
`Communication Management Centers ................................................ 41 
`B. 
`Receiving Overlapping Messages ....................................................... 43 
`C. 
`Prioritizing Messages .......................................................................... 46 
`D. 
`Storing Messages ................................................................................. 49 
`E. 
`Playing Messages in Priority Order .................................................... 51 
`
`i
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`Motorola Solutions, Inc., Ex1002, p. 2
`
`

`

`B. 
`
`Declaration of David H. Williams
`IPR of USP 7,324,802
`VIII.  SUMMARY OF PRIOR ART .................................................................... 53 
`A.  Ohel (Ex[1004]) .................................................................................. 53 
`1. 
`Status of Ohel ............................................................................ 53 
`2. 
`Overview of the Disclosure of Ohel ......................................... 53 
`Nigawara (Ex[1007]) ........................................................................... 58 
`1. 
`Status of Nigawara .................................................................... 58 
`2. 
`Overview of the Disclosure of Nigawara ................................. 58 
`Doolin (Ex[1008]) ............................................................................... 61 
`1. 
`Status of Doolin ........................................................................ 61 
`2. 
`Doolin’s Priority Date ............................................................... 62 
`3. 
`Overview of the Disclosure of Doolin ...................................... 64 
`IX.  APPLICATION OF THE PRIOR ART TO THE CHALLENGED
`CLAIMS ....................................................................................................... 66 
`A.  Grounds of Unpatentability ................................................................. 67 
`B. 
`Ground 1: Claims 1-21 are obvious over Ohel. .................................. 67 
`1. 
`Claim 1 ...................................................................................... 67 
`
`C. 
`
`a.  1[Pre]: A method of managing communication in a communication
`system, the communication system receiving messages from a plurality of
`channels, the method comprising: ............................................................. 68 
`
`b.  1[a]: receiving a first message on a first dedicated channel from
`amongst the plurality of channels at the communication system, the
`plurality of channels being dedicated to different entities, the first
`dedicated channel being dedicated to receiving messages from a first
`entity; ........................................................................................................ 69 
`
`c.  1[b]: receiving a second message on a second dedicated channel being
`dedicated to receiving messages from a second entity from amongst the
`plurality of channels at the communication system, the second message
`overlapping with the first message in time; .............................................. 73 
`
`ii
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`Motorola Solutions, Inc., Ex1002, p. 3
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`

`

`Declaration of David H. Williams
`IPR of USP 7,324,802
`
`d.  1[c]: determining one or more priorities for the first message received
`on the first dedicated channel from the first entity and the second message
`received on the second dedicated channel from the second entity based on
`at least one pre-defined parameter; ........................................................... 76 
`
`e.  1[d]: determining which message out of the first message and the
`second message should be stored and subsequently played based on the
`second message overlapping with the first message in time and one or
`more priorities assigned to the first and the second message; .................. 80 
`
`f.  1[e]: playing the message having a higher priority between the first
`and the second message; ........................................................................... 82 
`
`g.  1[f]: storing at least one message having a lower priority between the
`first and the second message based on the determination; and ................. 83 
`
`h.  1[g]: playing the stored message subsequent to completing playing of
`the message having higher priority. .......................................................... 85 
`Claim 2 ...................................................................................... 87 
`
`a.  2[pre] .................................................................................................. 87 
`
`b.  2[a]: calculating the priorities of the received messages; and ............ 87 
`
`c.  2[b]: comparing the priorities of the received messages. ................... 90 
`Claim 3: The method of claim 1, wherein the predefined
`parameter comprises a bandwidth requirement of the received
`messages. ................................................................................... 92 
`Claim 4: The method of claim 1, wherein the predefined
`parameter comprises a type of the received messages. ............. 94 
`Claim 5: The method of claim 4, wherein the type of received
`messages being one of a group comprising audio, video, text, and
`image. ........................................................................................ 95 
`Claim 6: The method of claim 1, wherein determining the
`priority comprises assigning priorities to the first message and
`the second message based on inputs from a user. ..................... 95 
`Claim 7: The method of claim 1, further comprising informing
`an operator the time of receipt of a message while playing the
`first message and the second message. ..................................... 97 
`
`iii
`
`2. 
`
`3. 
`
`4. 
`
`5. 
`
`6. 
`
`7. 
`
`Motorola Solutions, Inc., Ex1002, p. 4
`
`

`

`8. 
`
`9. 
`
`Declaration of David H. Williams
`IPR of USP 7,324,802
`Claim 8: The method of claim 1, wherein a message includes
`voice over internet protocol communications. .......................... 99 
`Claim 9: The method of claim 1, wherein a message includes
`mobile phone communications. ..............................................100 
`10.  Claim 10: The method of claim 1, wherein a message includes
`radio communications. ............................................................101 
`11.  Claim 11: A method of managing communication in a
`communication system, the communication system receiving
`messages from a plurality of channels, the method comprising:
`receiving a first message on a first dedicated channel from
`amongst the plurality of channels at the communication system,
`the plurality of channels being dedicated to different entities, the
`first dedicated channel being dedicated to receiving messages
`from a first entity; receiving a second message on a second
`dedicated channel being dedicated to receiving messages from a
`second entity from amongst the plurality of channels at the
`communication system, the second message overlapping with
`the first message in time; prioritizing the first and second
`messages based on at
`least one predefined parameter;
`determining which message out of the first message and the
`second message should be stored and subsequently played based
`on the second message overlapping with the first message in time
`and one or more priorities assigned to the first and the second
`message; playing the message having the highest priority; storing
`the message having lower priority in a queue on the basis of the
`determination and the prioritization; checking periodically the
`status of the message being played; and playing the stored
`message having the highest priority. .......................................103 
`12.  Claim 12: The method of claim 11 further comprising informing
`a user the time of receipt of a message while plying the message.
` .................................................................................................105 
`13.  Claim 13: A
`communication
`system
`for managing
`communication, the communication system receiving messages
`from a plurality of channels, the communication system
`comprising: means for receiving a plurality of messages on the
`plurality of channels, the plurality of messages received
`including a first message received from a first dedicated channel
`
`iv
`
`Motorola Solutions, Inc., Ex1002, p. 5
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`

`

`Declaration of David H. Williams
`IPR of USP 7,324,802
`dedicated to receiving messages from a first entity and a second
`message received from a second dedicated channel dedicated to
`receiving messages from a second entity; means for playing a
`received messages having the highest priority, the plurality of
`received messages being prioritized based on at least one
`predefined parameter; a central conferencing system comprising:
`means for prioritizing the received plurality of messages
`including the first message from the first dedicated channel and
`the second message from the second dedicated channel based on
`the predefined parameter; means for determining which
`messages out of the received messages should be stored and
`subsequently played based on messages overlap-ping in time and
`one or more priorities assigned to the first and the second
`message; means for sending the messages for playing based on
`the associate priority; and means for storing the messages other
`than the one sent for playing in a queue based upon the associated
`priority. ....................................................................................106 
`14.  Claim 14: A
`communication
`system
`for managing
`communication, the communication system receiving messages
`from a plurality of channels, the communication system
`comprising: a receiver module configured to receive a plurality
`of messages on the plurality of channels, the plurality of
`messages received including a first message received from a first
`dedicated channel dedicated to receiving messages from a first
`entity and a second message received from a second dedicated
`channel dedicated to receiving messages from a second entity; a
`player module for playing a received message having the highest
`priority, the plurality of received messages being prioritized
`based on at
`least one predefined parameter; a central
`conferencing system comprising: a prioritizing module
`configured to prioritize of messages including the first message
`received on the first dedicated channel and the second message
`received on the second dedicated channel based on the pre-
`defined parameter; a determiner configured to determine which
`messages out of the received messages should be stored and
`subsequently played based on the second message overlapping
`with the first message in time and one or more priorities assigned
`to the first and the second message; a sender module to send a
`message for playing based on the associated priority; and a
`
`v
`
`Motorola Solutions, Inc., Ex1002, p. 6
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`

`

`Declaration of David H. Williams
`IPR of USP 7,324,802
`storage medium configured to store the messages in a queue
`based upon the associated priority and the determination. .....110 
`15.  Claims 15-16 ...........................................................................111 
`16.  Claim 17: A central conferencing system for managing a
`plurality of messages received by a communication system, the
`central conferencing system comprising: a receiver module
`configured to receive a plurality of messages on the plurality of
`channels, the plurality of messages received including a first
`message received from a first dedicated channel dedicated to
`receiving messages from a first entity and a second message
`received from a second dedicated channel dedicated to receiving
`message from a second entity; a prioritizing module for
`prioritizing the received messages based on at least one
`predefined parameter, the prioritizing module comprises: a
`priority calculator for calculating the priority of the received
`messages including the first message received on the first
`dedicated channel and the second message received on the
`second dedicated channel; and a comparison module for
`comparing the priorities of the plurality of received messages; a
`sender module for sending the messages with the highest priority
`to the player module for playing; a determiner configured to
`determine which messages out of the received messages should
`be stored and subsequently played based on the second message
`overlapping with the first message in time and one or more
`priorities assigned to the first and the second message; a storage
`module for storing the messages from amongst the plurality of
`messages that are not being played; and an alert module for
`informing a user the time of receipt of a message while playing
`the message. ............................................................................113 
`17.  Claim 18: An apparatus for managing communication in a
`communication system, the communication system receiving
`messages on a plurality of channels, the apparatus comprising: a
`processing system including a processor coupled to a display and
`us-er input device; and a machine-readable medium including
`instructions executable by the processor comprising: one or more
`instructions for receiving a plurality of messages on the plurality
`of channels, the plurality of messages received including a first
`message received from a first dedicated channel to receiving
`
`vi
`
`Motorola Solutions, Inc., Ex1002, p. 7
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`

`

`Declaration of David H. Williams
`IPR of USP 7,324,802
`messages from a first entity and a second message received from
`a second dedicated channel dedicated to receiving messages from
`a second entity; one or more instructions for playing the message
`having the highest priority, the priority of the received messages
`including the first message and the second message being
`determined based on at least one predefined parameter; one or
`more instructions for determining which messages out of the
`received m messages should be stored and subsequently played
`based on messages overlapping in time and one or more priorities
`assigned to the first and the second message; one or more
`instructions for playing the stored messages subsequent to
`completing playing of the message having higher priority. ...115 
`18.  Claim 19: A machine-readable medium including instructions
`executable by the processor comprising: one or more instructions
`for receiving a plurality of messages on the plurality of channels,
`the plurality of messages received including a first message
`received from a first dedicated channel dedicated to receiving
`messages from a first entity and a second message received from
`a second dedicated channel dedicated to receiving messages from
`a second entity; one or more instructions for playing the message
`having the highest priority, the priority of the received messages
`being including the first message and the second message being
`determined based on at least one pre-defined parameter; one or
`more instructions for determining which messages out of the
`received messages should be stored and subsequently played
`based on message overlapping in time and one or more priorities
`assigned to the first and the second message; one or more
`instructions for storing at least one message having a low-er
`priority; and one or more instructions for playing the stored
`messages subsequent to completing playing of the message
`having higher priority. ............................................................118 
`19.  Claim 20: The method of claim 1, wherein playing the message
`comprises playing the message having a higher priority between
`the first and second message without storing the message having
`the higher priority if no other message is being played. .........120 
`20.  Claim 21: The method of claim 1, wherein determining the
`priority comprises determining the priority based on the
`
`vii
`
`Motorola Solutions, Inc., Ex1002, p. 8
`
`

`

`Declaration of David H. Williams
`IPR of USP 7,324,802
`dedicated channel the first message and/or the second message is
`received on. .............................................................................122 
`Ground 2: Claims 1-7 and 11-21 are obvious over Nigawara. ......... 122 
`1. 
`Nigawara is Analogous Art to the ’802 Patent .......................122 
`2. 
`Claim 1 ....................................................................................126 
`
`C. 
`
`a.  1[Pre]: A method of managing communication in a communication
`system, the communication system receiving messages from a plurality of
`channels, the method comprising: ........................................................... 127 
`
`b.  1[a]: receiving a first message on a first dedicated channel from
`amongst the plurality of channels at the communication system, the
`plurality of channels being dedicated to different entities, the first
`dedicated channel being dedicated to receiving messages from a first
`entity; ...................................................................................................... 127 
`
`c.  1[b]: receiving a second message on a second dedicated channel being
`dedicated to receiving messages from a second entity from amongst the
`plurality of channels at the communication system, the second message
`overlapping with the first message in time; ............................................ 130 
`
`d.  1[c]: determining one or more priorities for the first message received
`on the first dedicated channel from the first entity and the second message
`received on the second dedicated channel from the second entity based on
`at least one pre-defined parameter; ......................................................... 134 
`
`e.  1[d]: determining which message out of the first message and the
`second message should be stored and subsequently played based on the
`second message overlapping with the first message in time and one or
`more priorities assigned to the first and the second message; ................ 138 
`
`f.  1[e]: playing the message having a higher priority between the first
`and the second message; ......................................................................... 143 
`
`g.  1[f]: storing at least one message having a lower priority between the
`first and the second message based on the determination; and ............... 144 
`
`h.  1[g]: playing the stored message subsequent to completing playing of
`the message having higher priority. ........................................................ 146 
`Claim 2 ....................................................................................148 
`
`3. 
`
`a.  2[pre]: The method of claim 1, wherein determining which message
`out of the first message and the second message should be stored and
`subsequently played comprises: .............................................................. 148 
`
`viii
`
`Motorola Solutions, Inc., Ex1002, p. 9
`
`

`

`4. 
`
`5. 
`
`6. 
`
`7. 
`
`8. 
`
`9. 
`
`Declaration of David H. Williams
`IPR of USP 7,324,802
`
`b.  2[a]: calculating the priorities of the received messages; and .......... 149 
`
`c.  2[b]: comparing the priorities of the received messages. ................. 150 
`Claim 3: The method of claim 1, wherein the predefined
`parameter comprises a bandwidth requirement of the received
`messages. .................................................................................152 
`Claim 4: The method of claim 1, wherein the predefined
`parameter comprises a type of the received messages. ...........153 
`Claim 5: The method of claim 4, wherein the type of received
`messages being one of a group comprising audio, video, text, and
`image. ......................................................................................156 
`Claim 6: The method of claim 1, wherein determining the
`priority comprises assigning priorities to the first message and
`the second message based on inputs from a user. ...................158 
`Claim 7: The method of claim 1, further comprising informing
`an operator the time of receipt of a message while playing the
`first message and the second message. ...................................159 
`Claim 11: A method of managing communication in a
`communication system, the communication system receiving
`messages from a plurality of channels, the method comprising:
`receiving a first message on a first dedicated channel from
`amongst the plurality of channels at the communication system,
`the plurality of channels being dedicated to different entities, the
`first dedicated channel being dedicated to receiving messages
`from a first entity; receiving a second message on a second
`dedicated channel being dedicated to receiving messages from a
`second entity from amongst the plurality of channels at the
`communication system, the second message overlapping with
`the first message in time; prioritizing the first and second
`messages based on at
`least one predefined parameter;
`determining which message out of the first message and the
`second message should be stored and subsequently played based
`on the second message overlapping with the first message in time
`and one or more priorities assigned to the first and the second
`message; playing the message having the highest priority; storing
`the message having lower priority in a queue on the basis of the
`
`ix
`
`Motorola Solutions, Inc., Ex1002, p. 10
`
`

`

`Declaration of David H. Williams
`IPR of USP 7,324,802
`determination and the prioritization; checking periodically the
`status of the message being played; and playing the stored
`message having the highest priority. .......................................161 
`10.  Claim 12: The method of claim 11 further comprising informing
`a user the time of receipt of a message while plying the message.
` .................................................................................................164 
`11.  Claim 13: A
`communication
`system
`for managing
`communication, the communication system receiving messages
`from a plurality of channels, the communication system
`comprising: means for receiving a plurality of messages on the
`plurality of channels, the plurality of messages received
`including a first message received from a first dedicated channel
`dedicated to receiving messages from a first entity and a second
`message received from a second dedicated channel dedicated to
`receiving messages from a second entity; means for playing a
`received messages having the highest priority, the plurality of
`received messages being prioritized based on at least one
`predefined parameter; a central conferencing system comprising:
`means for prioritizing the received plurality of messages
`including the first message from the first dedicated channel and
`the second message from the second dedicated channel based on
`the predefined parameter; means for determining which
`messages out of the received messages should be stored and
`subsequently played based on messages overlap-ping in time and
`one or more priorities assigned to the first and the second
`message; means for sending the messages for playing based on
`the associate priority; and means for storing the messages other
`than the one sent for playing in a queue based upon the associated
`priority. ....................................................................................164 
`12.  Claim 14: A
`communication
`system
`for managing
`communication, the communication system receiving messages
`from a plurality of channels, the communication system
`comprising: a receiver module configured to receive a plurality
`of messages on the plurality of channels, the plurality of
`messages received including a first message received from a first
`dedicated channel dedicated to receiving messages from a first
`entity and a second message received from a second dedicated
`channel dedicated to receiving messages from a second entity; a
`
`x
`
`Motorola Solutions, Inc., Ex1002, p. 11
`
`

`

`Declaration of David H. Williams
`IPR of USP 7,324,802
`player module for playing a received message having the highest
`priority, the plurality of received messages being prioritized
`based on at
`least one predefined parameter; a central
`conferencing system comprising: a prioritizing module
`configured to prioritize of messages including the first message
`received on the first dedicated channel and the second message
`received on the second dedicated channel based on the pre-
`defined parameter; a determiner configured to determine which
`messages out of the received messages should be stored and
`subsequently played based on the second message overlapping
`with the first message in time and one or more priorities assigned
`to the first and the second message; a sender module to send a
`message for playing based on the associated priority; and a
`storage medium configured to store the messages in a queue
`based upon the associated priority and the determination. .....168 
`13.  Claims 15-16 ...........................................................................169 
`14.  Claim 17: A central conferencing system for managing a
`plurality of messages received by a communication system, the
`central conferencing system comprising: a receiver module
`configured to receive a plurality of messages on the plurality of
`channels, the plurality of messages received including a first
`message received from a first dedicated channel dedicated to
`receiving messages from a first entity and a second message
`received from a second dedicated channel dedicated to receiving
`message from a second entity; a prioritizing module for
`prioritizing the received messages based on at least one
`predefined parameter, the prioritizing module comprises: a
`priority calculator for calculating the priority of the received
`messages including the first message received on the first
`dedicated channel and the second message received on the
`second dedicated channel; and a comparison module for
`comparing the priorities of the plurality of received messages; a
`sender module for sending the messages with the highest priority
`to the player module for playing: a determiner configured to
`determine which messages out of the received messages should
`be stored and subsequently played based on the second message
`overlapping with the first message in time and one or more
`priorities assigned to the first and the second message; a storage
`module for storing the messages from amongst the plurality of
`
`xi
`
`Motorola Solutions, Inc., Ex1002, p. 12
`
`

`

`Declaration of David H. Williams
`IPR of USP 7,324,802
`messages that are not being played; and an alert module for
`informing a user the time of receipt of a message while playing
`the message. ............................................................................172 
`15.  Claim 18: An apparatus for managing communication in a
`communication system, the communication system receiving
`messages on a plurality of channels, the apparatus comprising: a
`processing system including a processor coupled to a display and
`us-er input device; and a machine-readable medium including
`instructions executable by the processor comprising: one or more
`instructions for receiving a plurality of messages on the plurality
`of channels, the plurality of messages received including a first
`message received from a first dedicated channel to receiving
`messages from a first entity and a second message received from
`a second dedicated channel dedicated to receiving messages from
`a second entity; one or more instructions for playing the message
`having the highest priority, the priority of the received messages
`including the first message and the second message being
`determined based on at least one predefined parameter; one or
`more instructions for determining which messages out of the
`received m messages should be stored and subsequently played
`based on messages overlapping in time and one or more priorities
`assigned to the first and the second message; one or more
`instructions for playing the stored messages subsequent to
`completing playing of the message having higher priority. ...174 
`16.  Claim 19: A machine-readable medium including instructions
`executable by the processor comprising: one or more instructions
`for receiving a plurality of messages on the plurality of channels,
`the plurality of messages received including a first message
`received from a first dedicated channel dedicated to receiving
`messages from a first entity and a second message received from
`a second dedicated channel dedicated to receiving messages from
`a second entity; one or more instructions for playing the message
`having the highest priority, the priority of the received messages
`being including the first message and the second message being
`determined based on at least one pre-defined parameter; one or
`more instructions for determining which messages out of the
`received messages should be stored and subsequently played
`based on message overlapping in time and one or more priorities
`assigned to the first and the second message; one or more
`
`xii
`
`Motorola Solutions, Inc., Ex1002, p. 13
`
`

`

`Declaration of David H. Williams
`IPR of USP 7,324,802
`instructions for storing at least one message having a low-er
`priority; and one or more instructions for playing the stored
`messages subsequent to completing playing of the message
`having higher priority. ............................................................178 
`17.  Claim 20: The method of claim 1, wherein playing the message
`comprises playing the message having a higher priority between
`the first and second message without storing the message having
`the higher priority if no other message is being played. .........180 
`18.  Claim 21: The method of claim 1, wherein determining the
`priority comprises determining the priority based on the
`dedicated channel the first message and/or the second message is
`received on. .............................................................................181 
`D.  Ground 3: Claims 3, and 8-10 are obvious over Nigawara in view of
`Doolin. ............................................................................................... 182 
`1. 
`Doolin is also Analogous Art to the ’802 Patent ....................182 
`2. 
`A POSITA Would Have Combined Nigawara with Doolin ...183 
`3. 
`Claim 8: The method of claim 1, wherein a message includes
`voice over internet protocol communications. ........................187 
`Claim 9: The method of claim 1, wherein a message includes
`mobile phone communications. ..............................................188 
`Claim 10: The method of claim 1, wherein a message includes
`radio communications. ............................................................189 
`Claim 3: The method of claim 1, wherein the predefined
`parameter comprises a bandwidth requi