`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`——————————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`——————————
`
`GOOGLE LLC,
`
`Petitioner,
`
`v.
`
`PROXENSE, LLC,
`
`Patent Owner.
`
`——————————
`
`Case No. IPR2024-00784
`U.S. Patent No. 10,073,960
`Filing Date: May 15, 2017
`Issue Date: September 11, 2018
`
`
`
`
`
`DECLARATION OF ANDREW WOLFE IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW OF U.S. PATENT NO. 10,073,960
`
`
`(Exhibit 1003)
`
`
`
`
`
`GOOGLE EXHIBIT 1003
`
`Page 1 of 139
`
`

`

`IPR2024-00784 Dr. Wolfe Declaration
`U.S. Patent No. 10,073,960
`
`TABLE OF CONTENTS
`
`Introduction ...................................................................................................... 1
`
`
`
`
`I.
`
`II.
`
`Education and Work Experience ..................................................................... 2
`
`III. Compensation .................................................................................................. 7
`
`IV. Legal Principles ............................................................................................... 7
`
`A. Anticipation Analysis: 35 U.S.C. § 102 ............................................... 8
`
`B.
`
`Obviousness Analysis: 35 U.S.C. § 103 .............................................. 9
`
`V.
`
`Level of Ordinary Skill .................................................................................. 14
`
`VI. Field of Art and Related Art .......................................................................... 14
`
`VII. Cited Art Prior to the ’289 Patent .................................................................. 15
`
`A. Dua ..................................................................................................... 17
`
`B.
`
`C.
`
`Buer .................................................................................................... 22
`
`Giobbi ’157 ......................................................................................... 26
`
`D.
`
`Lee ...................................................................................................... 28
`
`E.
`
`Nishikawa ........................................................................................... 31
`
`VIII. Overview of the ’960 Patent .......................................................................... 33
`
`A.
`
`Claim Construction............................................................................. 37
`
`IX. Ground 1: Claims 1-6, 8-11, And 14-19 Would Have Been Obvious
`Over Dua In View Of Giobbi ’157 ................................................................ 39
`
`A.
`
`Independent Claims ............................................................................ 39
`
`1.
`
`2.
`
`Independent Claim 14 ...............................................................39
`
`Independent Claim 1 .................................................................53
`
`B.
`
`Dependent Claims .............................................................................. 58
`
`i
`
`Page 2 of 139
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`

`

`
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`8.
`
`IPR2024-00784 Dr. Wolfe Declaration
`U.S. Patent No. 10,073,960
`
`Claim 2: “The device of claim 1, wherein at least one of the
`one or more of the application, the function, and the service
`is enabled, at least in part, on the device.” ................................58
`
`Claim 3: “The device of claim 1, wherein at least one of the
`one or more of the application, the function, and the service
`is enabled, at least in part, external to the device using an
`external, wireless communication interface, the device
`communicatively coupled to wirelessly communicate with
`the external, wireless communication interface.” .....................58
`
`Claim 4: “The hybrid device of claim 1, wherein the local,
`secured information includes biometric information for
`authenticating a user.” ...............................................................59
`
`Claim 5: “The device of claim 1, wherein the local, secured
`information includes biometric information based on a
`biometric scan of a finger, the biometric information for
`authenticating a user.” ...............................................................61
`
`Claim 6: “The device of claim 1, wherein the local, secure
`information includes financial information and at least one
`of the one or more of the application, the function, and the
`service enabled completes a financial transaction based on
`the financial information.” ........................................................61
`
`Claim 8: “The device of claim 1, wherein the local, secure
`information includes financial information and at least one
`of the one or more of the application, the function, and the
`service enabled completes a financial transaction based on
`an authorization of the financial information using an
`external authentication database, the financial information
`transmitted to the external authentication database.” ...............62
`
`Claim 9: “The device of claim 8, wherein the external
`authentication database is separate from a merchant
`providing a sale in the financial transaction.”...........................64
`
`Claim 10: “The device of claim 1, wherein the one or more
`of the application, the function and the service enabled
`based on the local, secured information stored by the
`
`ii
`
`Page 3 of 139
`
`

`

`
`
`IPR2024-00784 Dr. Wolfe Declaration
`U.S. Patent No. 10,073,960
`
`integrated, secure memory includes a first application,
`function or service based on a first subsets of local, secured
`information stored by the integrated, secure memory and a
`second application, function or service based on a second
`subset of local, secured information, the first and second
`subset of local, secured information having different
`accessibility.” ............................................................................64
`
`9.
`
`Claim 11: “The device of claim 1, wherein the device is a
`cell phone.” ...............................................................................66
`
`10. Claim 15: “The method of claim 14, wherein at least one of
`the one or more of the application, the function, and the
`service is enabled at least in part on the device.” .....................67
`
`11. Claim 16: “The method of claim 14 further comprising:
`sending the enablement signal, wherein at least one of the
`one or more of the application, the function, and the service
`is enabled at least in part on a device external to the device
`and communicatively coupled to an external, wireless
`communication interface.” ........................................................67
`
`12. Claim 17: “The method of claim 14, wherein the local,
`secured information includes biometric information for
`authenticating a user.” ...............................................................67
`
`13. Claim 18: “The method of claim 14, wherein the local,
`secured information includes financial information and
`wherein the one or more of the application, the function and
`the service completes a financial transaction.” .........................68
`
`14. Claim 19: “The method of claim 14, wherein the device is a
`cell phone.” ...............................................................................68
`
`X. Ground 2: Claims 1-7, 10-11, and 14-19 Would Have Been Obvious
`Over Buer. ...................................................................................................... 68
`
`A.
`
`Independent Claims ............................................................................ 68
`
`1.
`
`2.
`
`Independent Claim 14 ...............................................................68
`
`Independent Claim 1 .................................................................85
`
`iii
`
`Page 4 of 139
`
`

`

`
`
`B.
`
`Dependent Claims .............................................................................. 90
`
`IPR2024-00784 Dr. Wolfe Declaration
`U.S. Patent No. 10,073,960
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`Claim 2: “The device of claim 1, wherein at least one of the
`one or more of the application, the function, and the service
`is enabled, at least in part, on the device.” ................................90
`
`Claim 3: “The device of claim 1, wherein at least one of the
`one or more of the application, the function, and the service
`is enabled, at least in part, external to the device using an
`external, wireless communication interface, the device
`communicatively coupled to wirelessly communicate with
`the external, wireless communication interface.” .....................90
`
`Claim 4: “The device of claim 1, wherein the local, secured
`information includes biometric information for
`authenticating a user.” ...............................................................95
`
`Claim 5: “The device of claim 1, wherein the local, secured
`information includes biometric information based on a
`biometric scan of a finger, the biometric information for
`authenticating a user.” ...............................................................96
`
`Claim 6: “The device of claim 1, wherein the local, secure
`information includes financial information and at least one
`of the one or more of the application, the function, and the
`service enabled completes a financial transaction based on
`the financial information.” ........................................................96
`
`Claim 7: “The device of claim 1, wherein the local, secure
`information includes financial information and at least one
`of the one or more of the application, the function, and the
`service enabled completes a financial transaction based on a
`signal received from the at least one external device by the
`integrated, wireless communication interface.” ........................97
`
`Claim 10: “The device of claim 1, wherein the one or more
`of the application, the function and the service enabled
`based on the local, secured information stored by the
`integrated, secure memory includes a first application,
`function or service based on a first subsets of local, secured
`information stored by the integrated, secure memory and a
`
`iv
`
`Page 5 of 139
`
`

`

`
`
`IPR2024-00784 Dr. Wolfe Declaration
`U.S. Patent No. 10,073,960
`
`second application, function or service based on a second
`subset of local, secured information, the first and second
`subset of local, secured information having different
`accessibility.” ............................................................................98
`
`Claim 11: “The device of claim 1, wherein the device is a
`cell phone.” ...............................................................................99
`
`Claim 15: “The method of claim 14, wherein at least one of
`the one or more of the application, the function, and the
`service is enabled at least in part on the device.” ...................100
`
`8.
`
`9.
`
`10. Claim 16: “The method of claim 14 further comprising:
`sending the enablement signal, wherein at least one of the
`one or more of the application, the function, and the service
`is enabled at least in part on a device external to the device
`and communicatively coupled to an external, wireless
`communication interface.” ......................................................100
`
`11. Claim 17: “The method of claim 14, wherein the local,
`secured information includes biometric information for
`authenticating a user.” .............................................................100
`
`12. Claim 18: “The method of claim 14, wherein the local,
`secured information includes financial information and
`wherein the one or more of the application, the function and
`the service completes a financial transaction.” .......................101
`
`13. Claim 19: “The method of claim 14, wherein the device is a
`cell phone.” .............................................................................101
`
`XI. Ground 3: Claims 4, 8-10, 12, 13, 17, and 20 Would Have Been
`Rendered Obvious by Buer and Giobbi ’157 .............................................. 101
`
`A.
`
`Claim 4: “The device of claim 1, wherein the local, secured
`information includes biometric information for authenticating a
`user.” Claim 17: “The method of claim 14, wherein the local,
`secured information includes biometric information for
`authenticating a user.” ...................................................................... 102
`
`v
`
`Page 6 of 139
`
`

`

`
`
`B.
`
`C.
`
`D.
`
`E.
`
`F.
`
`G.
`
`IPR2024-00784 Dr. Wolfe Declaration
`U.S. Patent No. 10,073,960
`
`Claim 8: “The device of claim 1, wherein the local, secure
`information includes financial information and at least one of the
`one or more of the application, the function, and the service
`enabled completes a financial transaction based on an
`authorization of the financial information using an external
`authentication database, the financial information transmitted to
`the external authentication database.” .............................................. 103
`
`Claim 9: “The device of claim 8, wherein the external
`authentication database is separate from a merchant providing a
`sale in the financial transaction.” ..................................................... 106
`
`Claim 10: “The device of claim 1, wherein the one or more of the
`application, the function and the service enabled based on the
`local, secured information stored by the integrated, secure
`memory includes a first application, function or service based on a
`first subsets of local, secured information stored by the integrated,
`secure memory and a second application, function or service
`based on a second subset of local, secured information, the first
`and second subset of local, secured information having different
`accessibility.” ................................................................................... 106
`
`Claim 12: “The device of claim 1, wherein external device is
`included in jewelry.” ........................................................................ 109
`
`Claim 13: “The device of claim 1, wherein external device is a
`watch.” .............................................................................................. 110
`
`Claim 20: “The method of claim 14, wherein the external PDK is
`included in a watch.” ........................................................................ 110
`
`XII. Ground 4: Claim 4 Would Have Been Obvious Over Buer and
`Nishikawa .................................................................................................... 114
`
`A.
`
`Claim 4: “The device of claim 1, wherein the local, secured
`information includes biometric information for authenticating a
`user.” ................................................................................................. 114
`
`XIII. Conclusion ................................................................................................... 116
`
`
`
`
`
`vi
`
`Page 7 of 139
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`

`

`
`
`Exhibit
`
`Ex-1001
`
`IPR2024-00784 Dr. Wolfe Declaration
`U.S. Patent No. 10,073,960
`
`TABLE OF EXHIBITS
`
`
`Description
`
`U.S. Patent No. 10,073,960 to David L. Brown (“the ’960
`patent”)
`
`
`
`Ex-1002
`
`
`
` Prosecution history of U.S. Patent No. 10,073,960
`
`Ex-1003
`
`Declaration of Andrew Wolfe, Ph.D., including his Curriculum
`
`Vitae
`
`Ex-1004
`
`U.S. Patent Application Publication No. 2006/0258289 to Dua
`
`(“Dua”)
`
`Ex-1005
`
`European Patent Application Publication No. EP 1536306 to Buer
`
`et al. (“Buer”)
`
`Ex-1006
`
`U.S. Patent Application Publication No. 2007/0245157 to Giobbi
`
`et al. (“Giobbi ’157”)
`
`Ex-1007
`
`U.S. Patent Application Publication No. 2004/0255139 to Giobbi
`
`(“Giobbi ’139”)
`
`Ex-1008
`
`PCT Application Publication No. WO 90/06633 to Lee et al.
`
`(“Lee”)
`
`Ex-1009
`
`Order, Proxense, LLC v. Samsung Elecs. Co., Ltd., No. 6:21-cv-
`
`00210-ADA (W.D. Tex. Jan. 18, 2022)
`
`Ex-1010
`
`Memorandum in Support of Claim Construction Order, Proxense,
`
` LLC v. Samsung Elecs. Co., Ltd., No. 6:21-cv-00210-ADA (W.D.
`Tex. Dec. 28, 2022)
`
`Ex-1011
`
`Scheduling Order, Proxense, LLC v. Google LLC, No. 6:23-cv-
`
`00320-ADA (W.D. Tex. March 18, 2024)
`
`Ex-1012
`
`U.S. Patent Application Publication No. 2005/0116050 to Jei et
`
`al. (“Jei”)
`
`Ex-1013
`
`
`PCT Application Publication No. WO 2005/104584 to Bella et al.
`
`vii
`
`Page 8 of 139
`
`

`

`IPR2024-00784 Dr. Wolfe Declaration
`U.S. Patent No. 10,073,960
`
`(“Bella”)
`
`Ex-1014
`
`European Patent Application Publication No. EP 1600885 to
`
`Nishikawa et al. (“Nishikawa”)
`
`Ex-1015
`
`Google’s Proposed Constructions, Proxense, LLC v. Google LLC,
`
`No. 6:23-cv-00320 (W.D. Tex October 17, 2023)
`
`Ex-1016
`
`Proxense’s Proposed Constructions, Proxense, LLC v. Google
`
`LLC, No. 6:23-cv-00320 (W.D. Tex October 17, 2023)
`
`Ex-1017
`
`U.S. Patent Application Publication No. 2004/0176032 to Kotola
`
`et al. (“Kotola”)
`
`Ex-1018
`
`Preliminary Infringement Contentions Exhibit F, Proxense, LLC
`
`v. Google LLC, No. 6:23-cv-00320 (W.D. Tex)
`
`Ex-1019
`
`U.S. Patent Application Publication No. 2005/0151623 to Von
`
`Hoffmann (“Von Hoffmann”)
`
`Ex-1020
`
`Claim Construction Order, Proxense, LLC v. Google LLC,
`
`No. 6:23-cv-00320-ADA (W.D. Tex. January 23, 2024)
`
`Ex-1021
`
`Bluetooth Specification, Profiles of the Bluetooth System,
`
`Version 1.0 B (December 1999)
`
`Ex-1022
`
`
`
` Comparison of District Courts (December 31, 2023)
`
`
`
`LIST OF APPENDICES
`
`
`
`
`
`
`Appendix A
`
`
`
`Curriculum Vitae of Andrew Wolfe, Ph.D.
`
`
`
`viii
`
`Page 9 of 139
`
`

`

`IPR2024-00784 Dr. Wolfe Declaration
`U.S. Patent No. 10,073,960
`
`LIST OF CHALLENGED CLAIMS
`
`
`
`
`
`[1] Claim 1
`
`[1pre]
`
`A device comprising:
`
`[1a]
`
`[1b]
`
`[1c]
`
`[1d]
`
`Claim 2
`
`[2]
`
`Claim 3
`
`[3]
`
`Claim 4
`
`[4]
`
`a battery;
`
`an integrated, secure memory storing local, secured information;
`and
`
`an integrated, wireless communication interface for communicating
`wirelessly with at least one external device within a proximity zone,
`the integrated, wireless communication interface communicatively
`coupled to the integrated, secure memory and coupled to draw
`power from the battery,
`
`wherein one or more of (a) the integrated, wireless
`communication interface communicating wirelessly with the at
`least one external device within the proximity zone enables one or
`more of an application, a function, and a service and (b) the local,
`secured information stored by the integrated, secure memory
`enables one or more of an application, a function, and a service.
`
`The device of claim 1, wherein at least one of the one or more of
`the application, the function, and the service is enabled, at least in
`part, on the device.
`
`The device of claim 1, wherein at least one of the one or more of
`the application, the function, and the service is enabled, at least in
`part, external to the device using an external, wireless
`communication interface, the device communicatively coupled to
`wirelessly communicate with the external, wireless communication
`interface.
`
`The device of claim 1, wherein the local, secured information
`includes biometric information for authenticating a user.
`
`ix
`
`Page 10 of 139
`
`

`

`
`
`Claim 5
`
`[5]
`
`Claim 6
`
`[6]
`
`Claim 7
`
`[7]
`
`Claim 8
`
`[8]
`
`Claim 9
`
`[9]
`
`Claim 10
`
`[10]
`
`IPR2024-00784 Dr. Wolfe Declaration
`U.S. Patent No. 10,073,960
`
`The device of claim 1, wherein the local, secured information
`includes biometric information based on a biometric scan of a
`finger, the biometric information for authenticating a user.
`
`The device of claim 1, wherein the local, secure information
`includes financial information and at least one of the one or more of
`the application, the function, and the service enabled completes a
`financial transaction based on the financial information.
`
`The device of claim 1, wherein the local, secure information
`includes financial information and at least one of the one or more of
`the application, the function, and the service enabled completes a
`financial transaction based on a signal received from the at least
`one external device by the integrated, wireless communication
`interface.
`
`The device of claim 1, wherein the local, secure information
`includes financial information and at least one of the one or more of
`the application, the function, and the service enabled completes a
`financial transaction based on an authorization of the financial
`information using an external authentication database, the financial
`information transmitted to the external authentication database.
`
`The device of claim 8, wherein the external authentication database
`is separate from a merchant providing a sale in the financial
`transaction.
`
`The device of claim 1, wherein the one or more of the application,
`the function and the service enabled based on the local, secured
`information stored by the integrated, secure memory includes a first
`
`x
`
`Page 11 of 139
`
`

`

`IPR2024-00784 Dr. Wolfe Declaration
`U.S. Patent No. 10,073,960
`
`application, function or service based on a first subsets of local,
`secured information stored by the integrated, secure memory and a
`second application, function or service based on a second subset of
`local, secured information, the first and second subset of local,
`secured information having different accessibility.
`
`
`
`Claim 11
`
`[11]
`
`The device of claim 1, wherein the device is a cell phone.
`
`Claim 12
`
`[12]
`
`Claim 13
`
`[13]
`
`The device of claim 1, wherein the at least one external device is
`included in jewelry.
`
`The device of claim 1, wherein the at least one external device is a
`watch.
`
`[14] Claim 14
`
`[14pre]
`
`A method comprising:
`
`[14a]
`
`[14b]
`
`[14c]
`
`Claim 15
`
`[15]
`
`creating a first wireless link between an integrated, wireless
`communication interface of a device and an external device, the
`device including a battery, an integrated, secure memory, and the
`integrated, wireless communication interface, wherein the
`integrated, secure memory stores local, secured information and the
`integrated, wireless communication interface is powered by the
`battery;
`
`receiving a first signal, at the integrated, wireless communication
`interface, via the first wireless link, from the external device; and
`
`generating an enablement signal enabling one or more of an
`application, a function and a service.
`
`The method of claim 14, wherein at least one of the one or more of
`the application, the function, and the service is enabled at least in
`part on the device.
`
`
`xi
`
`Page 12 of 139
`
`

`

`IPR2024-00784 Dr. Wolfe Declaration
`U.S. Patent No. 10,073,960
`
`
`
`
`
`
`Claim 16
`
`[16]
`
`Claim 17
`
`[17]
`
`Claim 18
`
`[18]
`
`Claim 19
`
`The method of claim 14 further comprising: sending the
`enablement signal, wherein at least one of the one or more of the
`application, the function, and the service is enabled at least in part
`on a device external to the device and communicatively coupled to
`an external, wireless communication interface.
`
`The method of claim 14, wherein the local, secured information
`includes biometric information for authenticating a user.
`
`The method of claim 14, wherein the local, secured information
`includes financial information and wherein the one or more of the
`application, the function and the service completes a financial
`transaction.
`
`[19]
`
`The method of claim 14, wherein the device is a cell phone.
`
`Claim 20
`
`[20]
`
`The method of claim 14, wherein the external PDK is included in a
`watch.
`
`
`
`xii
`
`Page 13 of 139
`
`

`

`IPR2024-00784 Dr. Wolfe Declaration
`U.S. Patent No. 10,073,960
`
`GROUNDS FOR CHALLENGE (37 C.F.R. § 42.204(b)(2))
`
`Ground
`
`Claim(s) Challenged
`
`35 U.S.C. §
`
`Reference(s)
`
`1
`
`2
`
`3
`
`4
`
`1-6, 8-11, and 14-19
`
`1-7, 10-11, and 14-19
`
`4, 8-10, 12, 13, 17, and 20
`
`4
`
`103
`
`103
`
`103
`
`103
`
`Dua, Giobbi ’157
`
`Buer
`
`Buer, Giobbi ’157
`
`Buer, Nishikawa
`
`
`
`
`
`
`
`
`
`xiii
`
`Page 14 of 139
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`

`

`IPR2024-00784 Dr. Wolfe Declaration
`U.S. Patent No. 10,073,960
`
`
`I, Dr. Andrew Wolfe, declare as follows:
`
`I.
`
`Introduction
`
`1. My name is Andrew Wolfe, and I have been retained by Finnegan,
`
`Henderson, Farabow, Garrett & Dunner, LLP, counsel for Google LLC (“Google”),
`
`as an expert witness in the case Google LLC v. Proxense LLC, Case No. IPR2024-
`
`00784 with respect to U.S. Patent No. 10,073,960 (“the ’960 patent”), Ex-1001.1
`
`2. My opinions are based on my years of education, research, and
`
`experience, as well as my investigation and study of relevant materials. The
`
`materials that I have studied for this declaration include the documents identified in
`
`the table of exhibits.
`
`3.
`
`I may rely upon these materials, my knowledge and experience, and/or
`
`additional materials to rebut arguments raised by the patent owner. Further, I may
`
`also consider additional documents and information in forming any necessary
`
`opinions, including documents that may not yet have been provided to me.
`
`4. My analysis of the materials produced in this investigation is ongoing,
`
`and I will continue to review any new material as it is provided. This declaration
`
`represents only those opinions I have formed to date. I reserve the right to revise,
`
`
`1 All references to “Ex” in this declaration refer to the Google Exhibits
`
`concurrently filed with Google’s petition.
`
`Page | 1
`
`Page 15 of 139
`
`

`

`
`supplement, and/or amend my opinions stated herein based on new information and
`
`IPR2024-00784 Dr. Wolfe Declaration
`U.S. Patent No. 10,073,960
`
`my continuing analysis of the materials already provided.
`
`5.
`
`I understand that the Petition for Inter Partes Review involves the ’960
`
`patent, Ex-1001, ’960 patent.
`
`II. Education and Work Experience
`
`6.
`
`I have attached to this declaration a copy of my curriculum vitae that
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`fully sets forth my qualifications. Below is a summary of my education, work
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`experience, and other qualifications.
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`7.
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`In 1985, I earned a Bachelor’s degree in Electrical Engineering and
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`Computer Science from The Johns Hopkins University. In 1987, I received an
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`Master’s degree in Electrical and Computer Engineering from Carnegie Mellon
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`University. In 1992, I received a Ph.D. in Computer Engineering from Carnegie
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`Mellon University. My doctoral dissertation proposed a new approach for the
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`architecture of a computer processor.
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`8.
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`I have more than 35 years of experience as a computer architect,
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`computer system designer, personal computer graphics designer, educator, and
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`executive in the electronics industry.
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`9.
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`In 1983, I began designing touch sensors, microprocessor-based
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`computer systems, and I/O (input/output) cards for personal computers as a senior
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`design engineer for Touch Technology, Inc. During the course of my design projects
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`with Touch Technology, I designed I/O cards for PC- compatible computer systems,
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`IPR2024-00784 Dr. Wolfe Declaration
`U.S. Patent No. 10,073,960
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`including the IBM PC-AT, to interface with interactive touch-based computer
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`terminals that I designed for use in public information systems. I continued
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`designing and developing related technology as a consultant to the Carroll Touch
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`division of AMP, Inc., where in 1986 I designed one of the first custom touch-screen
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`integrated circuits. I designed the touch/pen input system for the Linus WriteTop,
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`which many believe to be the first commercial tablet computer.
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`10.
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` From 1986 through 1987, I designed and built a high- performance
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`computer system as a student at Carnegie Mellon University. From 1986 through
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`early 1988, I also developed the curriculum and supervised the teaching laboratory
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`for processor design courses.
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`11.
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`In the latter part of 1989, I worked as a senior design engineer for ESL-
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`TRW Advanced Technology Division. While at ESL-TRW, I designed and built a
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`bus interface and memory controller for a workstation- based computer system, and
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`also worked on the design of a multiprocessor system.
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`12. At the end of 1989, I (along with some partners) reacquired the rights
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`to the technology I had developed at Touch Technology and at AMP and founded
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`The Graphics Technology Company. Over the next seven years, as an officer and a
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`consultant for The Graphics Technology Company, I managed the company's
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`engineering development activities and personally developed dozens of touch screen
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`IPR2024-00784 Dr. Wolfe Declaration
`U.S. Patent No. 10,073,960
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`sensors, controllers, and interactive touch- based computer systems.
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`13.
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`I have consulted, formally and informally, for a number of fabless
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`semiconductor companies. In particular, I have served on the technical advisory
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`boards for two processor design companies: BOPS, Inc., where I chaired the board;
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`and Siroyan Ltd., where I served in a similar role for three networking chip
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`companies—Intellon, Inc., Comsilica, Inc., and Entridia, Inc.—and one 3D game
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`accelerator company, Ageia, Inc.
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`14.
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`I have also served as a technology advisor to Motorola and to several
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`venture capital funds in the U.S. and Europe. Currently, I am a director of Turtle
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`Beach Corporation, providing guidance in its development of premium audio
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`peripheral devices for a variety of commercial electronic products.
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`15. From 1991 through 1997, I served on the Faculty of Princeton
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`University as an Assistant Professor of Electrical Engineering. At Princeton, I taught
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`undergraduate and graduate-level courses in Computer Architecture, Advanced
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`Computer Architecture, Display Technology, and Microprocessor Systems, and
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`conducted sponsored research in the area of computer systems and related topics. I
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`was also a principal investigator for DOD research in video technology and a
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`principal investigator for the New Jersey Center for Multimedia Research. From
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`1999 through 2002, while a Consulting Professor, I taught a Computer Architecture
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`course to both undergraduate and graduate students at Stanford University. At
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`IPR2024-00784 Dr. Wolfe Declaration
`U.S. Patent No. 10,073,960
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`Princeton, I received several teaching awards, both from students and from the
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`School of Engineering. I have also taught advanced microprocessor architecture to
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`industry professionals in seminars sponsored by the Institute of Electrical and
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`Electronics Engineers (“IEEE”) and the Association for Computing Machinery
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`(“ACM”). I am currently a lecturer at Santa Clara University teaching courses on
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`Microprocessor Systems, Integrated Circuit Design, Real-Time Computing, and
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`Mechatronics and currently serve as Faculty Senate President.
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`16. From 1997 through 2002, I held a variety of executive positions at a
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`publicly-held fabless semiconductor company originally called S3, Inc. and later
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`called SonicBlue Inc. I held the positions of Chief Technology Officer, Vice
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`President of Systems Integration Products, Senior Vice President of Business
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`Development, and Director of Technology, among others. At the time I joined S3,
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`the company supplied graphics accelerators for more than 50% of the PCs sold in
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`the United States. At S3 I supervised the design of several PC graphics accelerators.
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`During my time at SonicBlue we launched more than 30 new consumer electronics
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`products including devices to support copy-protected video and many of the first
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`commercial products to support copy-protected internet audio content. These
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`included some of the first consumer products to support playback of encrypted
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`content using digital rights management (DRM) based security. I also worked with
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`Universal Music Group and Sony Entertainment on the development of systems for
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`IPR2024-00784 Dr. Wolfe Declaration
`U.S. Patent No. 10,073,960
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`distribution and management of secure, encrypted content.
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`17.
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`I have published more than fifty peer-reviewed papers in computer
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`architecture and computer systems and IC design. I also have chaired IEEE and
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`ACM conferences in microarchitecture and integrated circuit design and served as
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`an associate editor for IEEE and ACM journals. I served on the IEEE Computer
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`Society Awards committee. I am an IEEE Fellow, an IEEE Computer Society
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`Distinguished Contributor and a Member of ACM. I am a named inventor on at least
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`fifty-seven U.S. patents and thirty-seven foreign patents, which are listed in my
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`curriculum vitae. Some of these patents relate to encryption systems.
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`18.
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`In 2002, I was the invited keynote speaker at the ACM/IEEE
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`International Symposium on Microarchitecture and at the International Conference
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`on Multimedia. From 1990 through 2005, I have also been an invited speaker on
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`various aspects of technology and the PC industry at numerous industry events
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`including the Intel Developer's Forum, Microsoft Windows Hardware Engineering
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`Conference, Microprocessor Forum, Embedded Systems Conference, Comdex, and
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`Consumer Electronics Show, as well as at the Harvard B