UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________
`
`APPLE INC.,
`Petitioner
`
`v.
`
`S.M.R INNOVATIONS LTD and Y.M.R TECH LTD
`Patent Owners
`_________________
`
`Inter Partes Review Case Nos. IPR2024-01050, IPR2024-01049
`U.S. Patent Nos. 7,969,990, 8,711,866
`
`DECLARATION OF DR. SAYFE KIAEI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW OF
`U.S. PATENT NOS. 7,969,990 AND 8,711,866
`
`IPR2024-01049
`Apple EX1003 Page 1
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`

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`Declaration of Dr. Sayfe Kiaei
`Patent Nos. 7,969,990 and 8,711,866
`
`
`
`TABLE OF CONTENTS
`
`I.
`
`INTRODUCTION AND QUALIFICATIONS ........................................... 14
`A.
`Educational Background and Professional Experience ............... 14
`II. METHODOLOGY; MATERIALS CONSIDERED .................................. 19
`III. OVERVIEW AND LEGAL STANDARDS ................................................ 21
`A.
`Person of Ordinary Skill in the Art ................................................ 22
`B. Obviousness ...................................................................................... 23
`C. Analogous Art ................................................................................... 28
`D. Claim Construction .......................................................................... 29
`IV. LEVEL OF A PERSON OF ORDINARY SKILL ..................................... 29
`V.
`OVERVIEW OF THE TECHNOLOGY .................................................... 30
`A. Wireless Networking ........................................................................ 30
`B.
`Cellular Networks ............................................................................ 35
`C. Device Discovery and Service Discovery ........................................ 35
`D. Media Streaming .............................................................................. 39
`E.
`Streaming Protocols ......................................................................... 42
`F. Graphical User Interfaces (GUIs) and Touch Screens ................. 44
`G. Mobile Device Hardware ................................................................. 46
`H. Auxiliary Rendering Devices (aka Helper Servers/Helper
`Devices) ............................................................................................. 48
`Codecs ............................................................................................... 51
`I.
`Bidirectional Communication Link ................................................ 52
`J.
`K. Media Type Requirements .............................................................. 53
`L. Media Transformation .................................................................... 53
`M. Media Cloner .................................................................................... 54
`VI. OVERVIEW OF THE ’990 AND ’866 PATENTS .................................... 55
`A.
`The ’990 and ’866 Patents’ Alleged Invention .............................. 55
`
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`Declaration of Dr. Sayfe Kiaei
`Patent Nos. 7,969,990 and 8,711,866
`B.
`The ’990 Patent’s Prosecution ........................................................ 57
`The ’866 Patent’s Prosecution ........................................................ 58
`C.
`VII. PROPOSED GROUNDS OF UNPATENTABILITY ................................ 58
`VIII. OVERVIEW OF THE PRIOR ART ........................................................... 59
`A. Overview of Chihara ........................................................................ 59
`B. Overview of BluetoothSpec ............................................................. 60
`C. Overview of Everett ......................................................................... 63
`D. Overview of Chang .......................................................................... 64
`IX. OPINIONS REGARDING GROUND 1 (’990 PATENT): CLAIMS
`1-3, 9, AND 24 ARE OBVIOUS OVER CHIHARA,
`BLUETOOTHSPEC, EVERETT, AND CHANG ..................................... 65
`A. Claim 1(Pre) - Apparatus for rerouting communication
`data, comprising: .............................................................................. 65
`Claim 1(a) - a mobile communication device comprising: ........... 70
`B.
`C. Claim 1(a)(i): an announcer device associated with said
`mobile communication device, and configured for indicating
`to surrounding equipment that said mobile communication
`device is available to receive rerouting, thereby to enable
`receipt of rerouted data from said surrounding equipment,
`and ..................................................................................................... 72
`Announcing Availability to Receive Rerouted Data From
`1.
`Surrounding Equipment ........................................................... 72
`Chihara Teaches an Announcer Device and Rerouting
`Data .......................................................................................... 75
`BluetoothSpec Teaches Announcing Availability –
`Inquiry Substate ....................................................................... 81
`4. Motivation to Combine Chihara and BluetoothSpec ............... 84
`D. Claim 1(a)(ii): a scout device associated with said mobile
`communication device, configured for scanning
`surroundings of said associated mobile communication
`device to identify and determine availability of compatible
`equipment in the vicinity, thereby to reroute data from said
`mobile communication device to a selected one of said
`surrounding equipment, wherein said rerouting comprises
`
`3.
`
`2.
`
`
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`2.
`
`Declaration of Dr. Sayfe Kiaei
`Patent Nos. 7,969,990 and 8,711,866
`setting up a bidirectional communication link between said
`mobile communication device and said selected surrounding
`equipment, said bidirectional link having a first link
`direction from said mobile communication device to said
`selected surrounding equipment and a second link direction
`from said selected surrounding equipment to said mobile
`communication device, said bidirectional link carrying
`streaming data over both directions of said first link
`direction and said second link direction, and wherein said
`scout device is operable to determine media type
`requirements of said compatible equipment; ................................ 89
`Chihara Teaches a Scout Device and Bidirectional
`1.
`Communication Link ............................................................... 89
`BluetoothSpec Teaches Scanning Surroundings to
`Identify and Determine Availability of Compatible
`Equipment ................................................................................ 92
`Chihara Teaches Bidirectional Communication Link ........... 100
`3.
`Chihara Teaches Media Type Requirements ......................... 104
`4.
`5. Motivation to Combine Chihara and BluetoothSpec ............. 105
`Claim 1(a)(iii): a media transformer, associated with said
`scout device, for transforming media into a form that
`accords with said determined media type requirements,
`wherein a plurality of types correspond to said media type
`requirements, and further comprising a user interface for
`allowing a user to select one of said media type
`requirements for transforming at said media transformer
`and ................................................................................................... 107
`1.
`Chihara-Everett’s Media Transformer ................................... 107
`2. Motivation to Combine Chihara with Everett ....................... 112
`3.
`Chihara’s Plurality of Media Type Requirements ................. 116
`4.
`Chihara’s User Interface for Selecting a Media Type
`Requirement ........................................................................... 118
`Chang’s User Interface for Selecting a Media Type
`Requirement ........................................................................... 123
`6. Motivation to Combine Chihara, BluetoothSpec, Everett,
`and Chang .............................................................................. 127
`
`5.
`
`E.
`
`
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`F.
`
`Declaration of Dr. Sayfe Kiaei
`Patent Nos. 7,969,990 and 8,711,866
`Claim 1(a)(iv): a media cloner, associated with said media
`transformer, for making multiple copies of a single
`incoming data stream, thereby to enable said apparatus to
`redirect said single incoming data stream to a plurality of
`locations, at least some of said multiple copies being
`redirected via said media transformer. ........................................ 132
`1.
`’990 Patent’s Media Cloner Description ............................... 132
`2.
`Chihara-Everett Teaches a Media Cloner .............................. 132
`3. Motivation to Combine Chihara and Everett ......................... 136
`G. Claim 2: Apparatus according to claim 1, further
`comprising a user interface associated with said scout
`device for allowing a user to select between available
`compatible equipment to reroute data thereto. ........................... 137
`H. Claim 3: Apparatus according to claim 1, wherein said
`announcer is an active device, operable to transmit at least
`status information to respective surroundings. ........................... 139
`Claim 9: Apparatus according to claim 1, further
`comprising control functionality operable to carry out said
`rerouting through locally available network infrastructure. ..... 140
`Claim 24 - A cellular telephone comprising the apparatus of
`claim 1. ............................................................................................ 140
`OPINIONS REGARDING GROUND 1 (’866 PATENT): CLAIMS
`22-24 ARE OBVIOUS OVER CHIHARA, BLUETOOTHSPEC,
`EVERETT, AND CHANG ........................................................................ 144
`A. Claim 22(Pre) - Apparatus for routing and rerouting
`streaming data, the apparatus being mobile and
`comprising: ..................................................................................... 144
`Chihara Teaches a Mobile Apparatus for Routing and
`1.
`Rerouting Streaming Data ..................................................... 144
`Claim 22(a) - a streaming device comprising: ............................. 148
`B.
`C. Claim 22(a)(i) - an announcer device configured to indicate
`to surrounding media handling devices that said streaming
`device is available to receive streaming data, thereby to
`enable receipt of rerouted data from said surrounding
`media handling devices, and ......................................................... 148
`
`I.
`
`J.
`
`X.
`
`
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`E.
`
`F.
`
`Declaration of Dr. Sayfe Kiaei
`Patent Nos. 7,969,990 and 8,711,866
`D. Claim 22(a)(ii) - a scout device configured to scan
`surroundings of said streaming device to identify
`surrounding media handling devices as being compatible to
`handle given media, and determine availability of said
`identified compatible media handling devices, thereby to
`reroute streaming data between said streaming device and a
`selected one of said surrounding media handling devices,
`said scout device further being configured to determine
`media type requirements of said compatible media handling
`devices, said apparatus configured to set up a bidirectional
`wireless communication link between said streaming device
`and a respective one of said media handling devices, said
`bidirectional link carrying streaming data over either
`direction as required of said bidirectional link; .......................... 149
`Claim 22(a)(iii) - a media transformer, configured to
`transform media into forms that accord with respective
`determined media type requirements, wherein there are a
`plurality of said types; ................................................................... 149
`Claim 22(a)(iv) - a user interface for allowing a user to
`select one of said media type requirements for transforming
`at said media transformer, and ..................................................... 149
`G. Claim 22(b) - a media cloner, associated with said media
`transformer, for making multiple copies of a single
`incoming data stream, thereby to enable said apparatus to
`redirect said single incoming data stream to a plurality of
`locations, at least some of said multiple copies being
`transformed via said media transformer. .................................... 149
`H. Claim 23(Pre) - Apparatus for routing'and rerouting media
`data, the apparatus being mobile and comprising: ..................... 150
`Claim 23(a) - a media data transfer device comprising: ............ 150
`Claim 23(a)(i) - an announcer device configured for
`indicating to surrounding media handling devices that said
`media data transfer device is available to receive media
`data, thereby to enable receipt of rerouted data from said
`surrounding media handling evices, and ..................................... 150
`K. Claim 23(a)(ii) - a scout device configured for scanning
`surroundings to identify surrounding media handling
`
`I.
`J.
`
`
`
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`L.
`
`Declaration of Dr. Sayfe Kiaei
`Patent Nos. 7,969,990 and 8,711,866
`devices as being compatible with given media and
`determine availability of said identified compatible media
`handling devices, thereby to reroute edia data from said
`media data transfer device to a selected one of said
`surrounding media handling devices, said scout device
`further being configured to determine media type
`requirements of said media handling devices; ............................ 150
`Claim 23(a)(iii) - a media transformer, configured to
`transform media into a form that accords with respective
`determined media type requirements, there being a
`plurality of said media type requirements; ................................. 150
`M. Claim 23(a)(iv) - a user interface for allowing a user to
`select one of said plurality of media type requirements for
`transforming at said media transformer, and ............................. 151
`N. Claim 23(a)(v) - a media cloner, associated with said media
`transformer, for making multiple copies of said media data,
`thereby to enable said apparatus to redirect said media data
`to a plurality of locations, at least some of said multiple
`copies being ransformed at said media transformer. ................. 151
`O. Claim 24 - The apparatus of claim 23, wherein said media
`type requirements comprise a screen capability. ........................ 151
`XI. CONCLUSION .......................................................................................... 154
`
`
`
`
`
`
`
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`Declaration of Dr. Sayfe Kiaei
`Patent Nos. 7,969,990 and 8,711,866
`CLAIM LISTING ’990 PATENT
`
`Claim 1:
`
`Claim 1[Pre]: Apparatus for rerouting communication data, comprising:
`
`Claim 1(a): a mobile communication device comprising:
`
`Claim 1(a)(i): an announcer device associated with said mobile
`
`communication device, and configured for indicating to surrounding equipment that
`
`said mobile communication device is available to receive rerouting, thereby to
`
`enable receipt of routed data from said surrounding equipment, and
`
`Claim 1(a)(ii): a scout device associated with said mobile communication
`
`device, configured for scanning surroundings of said associated mobile
`
`communication device to identify and determine availability of compatible
`
`equipment in the vicinity, thereby to reroute data from said mobile communication
`
`device to a selected one of said surrounding equipment, wherein said rerouting
`
`comprises setting up a bidirectional communication link between said mobile
`
`communication device and said selected surrounding equipment, said bidirectional
`
`link having a first link direction from said mobile communication device to said
`
`selected surrounding equipment and a second link direction from said selected
`
`surrounding equipment to said mobile communication device, said bidirectional link
`
`carrying streaming data over both directions of said first link direction and said
`
`
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`Declaration of Dr. Sayfe Kiaei
`Patent Nos. 7,969,990 and 8,711,866
`second link direction, and wherein said scout device is operable to determine media
`
`type requirements of said compatible equipment;
`
`Claim 1(a)(iii): a media transformer, associated with said scout device, for
`
`transforming media into a form that accords with said determined media type
`
`requirements, wherein a plurality of types correspond to said media type
`
`requirements, and further comprising a user interface for allowing a user to select
`
`one of said media type requirements for transforming at said media transformer and
`
`Claim 1(a)(iv): a media cloner, associated with said media transformer, for
`
`making multiple copies of a single incoming data stream, thereby to enable said
`
`apparatus to redirect said single incoming data stream to a plurality of locations, at
`
`least some of said multiple copies being redirected via said media transformer.
`
`Claim 2:
`
`Apparatus according to claim 1, further comprising a user interface associated
`
`with said scout device for allowing a user to select between available compatible
`
`equipment to reroute data thereto.
`
`Claim 3:
`
`Apparatus according to claim 1, wherein said announcer is an active device,
`
`operable to transmit at least status information to respective surroundings.
`
`
`
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`Declaration of Dr. Sayfe Kiaei
`Patent Nos. 7,969,990 and 8,711,866
`
`Claim 9:
`
`Apparatus according to claim 1, further comprising control functionality
`
`operable to carry out said rerouting through locally available network infrastructure.
`
`Claim 24:
`
`A cellular telephone comprising the apparatus of claim 1.
`
`
`
`
`
`
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`Declaration of Dr. Sayfe Kiaei
`Patent Nos. 7,969,990 and 8,711,866
`CLAIM LISTING ’866 PATENT
`
`Claim 22:
`
`Claim 22[Pre]: Apparatus for routing and rerouting streaming data, the
`
`apparatus being mobile and comprising:
`
`Claim 22(a): a streaming device comprising:
`
`Claim 22(a)(i): an announcer device configured to indicate to surrounding
`
`media handling devices that said streaming device is available to receive streaming
`
`data, thereby to enable receipt of rerouted data from said surrounding media
`
`handling devices, and
`
`Claim 22(a)(ii): a scout device configured to scan surroundings of said
`
`streaming device to identify surrounding media handling devices as being
`
`compatible to handle given media, and determine availability of said identified
`
`compatible media handling devices, thereby to reroute streaming data between said
`
`streaming device and a selected one of said surrounding media handling devices,
`
`said scout device further being configured to determine media type requirements of
`
`said compatible media handling devices, said apparatus configured to set up a
`
`bidirectional wireless communication link between said streaming device and a
`
`respective one of said media handling devices, said bidirectional link carrying
`
`streaming data over either direction as required of said bidirectional link;
`
`
`
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`Declaration of Dr. Sayfe Kiaei
`Patent Nos. 7,969,990 and 8,711,866
`Claim 22(a)(iii): a media transformer, configured to transform media into
`
`forms that accord with respective determined media type requirements, wherein
`
`there are a plurality of said types;
`
`Claim 22(a)(iv): a user interface for allowing a user to select one of said
`
`media type requirements for transforming at said media transformer, and
`
`Claim 22(b): a media cloner, associated with said media transformer, for
`
`making multiple copies of a single incoming data stream, thereby to enable said
`
`apparatus to redirect said single incoming data stream to a plurality of locations, at
`
`least some of said multiple copies being transformed via said media transformer.
`
`Claim 23:
`
`Claim 23[Pre]: Apparatus for routing'and rerouting media data, the apparatus
`
`being mobile and comprising:
`
`Claim 23(a): a media data transfer device comprising:
`
`Claim 23(a)(i): an announcer device configured for indicating to surrounding
`
`media handling devices that said media data transfer device is available to receive
`
`media data, thereby to enable receipt of rerouted data from said surrounding media
`
`handling devices, and
`
`Claim 23(a)(ii): a scout device configured for scanning surroundings to
`
`identify surrounding media handling devices as being compatible with given media
`
`and determine availability of said identified compatible media handling devices,
`
`
`
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`Declaration of Dr. Sayfe Kiaei
`Patent Nos. 7,969,990 and 8,711,866
`thereby to reroute media data from said media data transfer device to a selected one
`
`of said surrounding media handling devices, said scout device further being
`
`configured to determine media type requirements of said media handling devices;
`
`Claim 23(a)(iii): a media transformer, configured to transform media into a
`
`form that accords with respective determined media type requirements, there being
`
`a plurality of said media type requirements;
`
`Claim 23(a)(iv): a user interface for allowing a user to select one of said
`
`plurality of media type requirements for transforming at said media transformer, and
`
`Claim 23(a)(v): a media cloner, associated with said media transformer, for
`
`making multiple copies of said media data, thereby to enable said apparatus to
`
`redirect said media data to a plurality of locations, at least some of said multiple
`
`copies being transformed at said media transformer.
`
`Claim 24:
`
`The apparatus of claim 23, wherein said media type requirements comprise a
`
`screen capability.
`
`
`
`
`
`
`
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`Declaration of Dr. Sayfe Kiaei
`Patent Nos. 7,969,990 and 8,711,866
`
`
`
`I.
`
`I, Sayfe Kiaei, declare as follows:
`
`INTRODUCTION AND QUALIFICATIONS
`1.
`I am over the age of 21 and am competent to make this declaration. I
`
`make this declaration based on facts and matters within my own knowledge and on
`
`information provided to me by others, and, if called as a witness, I could and would
`
`competently testify to the matters set forth herein.
`
`A. Educational Background and Professional Experience
`2. My qualifications are stated more fully in my curriculum vitae, which
`
`is attached as Exhibit A. Below is a summary of my education, work experience, and
`
`other qualifications.
`
`3.
`
`I earned a Ph.D. in 1987 from Washington State University in
`
`Electrical, Computer, and Energy Engineering. From 1985 through 1987, while
`
`working toward my Ph.D., I worked with Boeing on the development of signal
`
`processing and control systems.
`
`4.
`
`From 1987 through 1993, I was a tenured Professor at Oregon State
`
`University in the Electrical and Computer Engineering Department.
`
`5.
`
`From 1993 to 2002, I was a Senior Member of Technical Staff with the
`
`Wireless Technology Center and Broadband Operations at Motorola Inc. With the
`
`Wireless Integrated Technology Center (WITC) group of Motorola, I was
`
`responsible for the development of wireless system for cellular system, 2-way
`
`
`
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`Declaration of Dr. Sayfe Kiaei
`Patent Nos. 7,969,990 and 8,711,866
`Radios, RF integrated circuits, GPS, and Bluetooth. I represented Motorola at the
`
`Bluetooth (BT) SIG group forming the first BT standard. I was also responsible for
`
`the development of BT and GPS IC solutions for Motorola’s Cellular phones. With
`
`the Broadband Operation, I worked with the team on the development of Single-
`
`Chip COPPERGOLD ™ Motorola Digital Subscriber Lines (DSL) transceivers. I
`
`worked on the development of broadband transceivers for MODEMS including
`
`DSL, SDSL, VDSL, and Optical communication systems. I also represented
`
`Motorola in the T`1E1 and ETSI, and cable MODEM DOCIS standards.
`
`6.
`
`Since 2001 I have held the position of Motorola Endowed Chair
`
`Professor in Analog and Radio Frequency Integrated Circuitry at the School of
`
`Electrical, Computer, and Energy Engineering at Arizona State University in Tempe,
`
`Arizona. I am also the Director of the National Science Foundation Center,
`
`Connection One. Connection One is an industry/university cooperative research
`
`center with focus on communication systems. The center has over thirty industrial
`
`members and five university members focused on developing communication
`
`systems, sensors, electronics, bio-electronics, and networking technologies.
`
`7.
`
`At Arizona State University, I have developed and taught courses on
`
`Communications, Broadband Wirelines and Wireless Transceivers, Electronics,
`
`VLSI, Analog IC design, RFIC, communications, and related areas. In my over thirty
`
`years of academic experience, I have taught university courses and done research in
`
`
`
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`Declaration of Dr. Sayfe Kiaei
`Patent Nos. 7,969,990 and 8,711,866
`electronics, RF and wireless system, bio-electronics, networking, communication
`
`systems, and sensors. I have graduated over 100 M.S. and Ph.D. students working
`
`under my supervision on their thesis, and many of them are professors in academia,
`
`or have senior positions in the industry. Currently, I have 8 M.S., Ph.D., and postdoc
`
`students working with me in my lab on research related to communication and
`
`networking systems, wireless systems, RF, and integrated circuits. My research is
`
`funded by various sources, including industry, federal agencies including NSF,
`
`DARPA, ONR, DOE, and other, with an average total research funding of $1M per
`
`year.
`
`8.
`
`I have been conducting research, publishing papers, and supervising
`
`graduate students working on communication system, signal process, audio
`
`processing, GPS, BT, DSL, RFIC, and communication transceivers for the past 40
`
`years. I have published over two hundred journal and conference papers covering
`
`topics such as wireless systems, power management, low-power electronics, sensors,
`
`radio frequency, integrated circuits (IC), filter design, and related areas. A list of my
`
`publications can be found in my CV, attached as Exhibit A. I also have over 10
`
`patents and patent applications in electronics, RF, and low-power bio-electronics.
`
`9.
`
`I am an IEEE Fellow, a distinction and the highest level of IEEE
`
`membership awarded by the IEEE directors to recognize a high level of
`
`demonstrated extraordinary accomplishments. The IEEE is the Institute of Electrical
`
`
`
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`Declaration of Dr. Sayfe Kiaei
`Patent Nos. 7,969,990 and 8,711,866
`and Electronics Engineers, the world’s largest association of technical professionals
`
`whose objectives include the educational and technical advancement of electrical
`
`and electronic engineering, telecommunications, computer engineering, and related
`
`disciplines. I am a member of the IEEE Circuits and Systems Society, IEEE Solid
`
`State Circuits Society, and IEEE Communication Society, IEEE RF and Microwave
`
`committees, IEEE International Symposium on Low Power Electronics and Design
`
`(ISLPED), IEEE Signal Processing Society, IEEE Fellow Selection Committee, and
`
`many other International Electrical Engineering societies. I was one of the key
`
`organizers to establish the IEEE Radio Frequency Integrated Circuits (RFIC)
`
`symposium in 1995, and IEEE International Symposium on Low Power Electronics
`
`and Design (ISLPED) in 1997. I have been on the executive committee, and
`
`technical committee of RFIC and ISLPED for the last 16 years. The RFIC and
`
`ISLPED Symposia have grown and is now the premier international symposium in
`
`the world where the latest RF, low-power electronics, wireless, and bio-electronic
`
`circuits and components are presented.
`
`10.
`
`I have received several awards including the Carter Best Teacher
`
`Award, the IEEE Darlington Award (which is given for the best technical paper on
`
`circuits and systems in the IEEE Circuits and Systems Society), and the Motorola
`
`10X Rapid Design Cycle Reduction Award.
`
`
`
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`Declaration of Dr. Sayfe Kiaei
`Patent Nos. 7,969,990 and 8,711,866
`I have been one of the key organizers of the IEEE International
`
`11.
`
`Symposium on Low Power Electronics and Design (ISLPED) since 1997. I have
`
`published papers and organized sessions on techniques for low-power cellular
`
`phones at ISLPED. I have published a number of papers on the design and
`
`development of low-power RF, wireless transceivers, sensors, and low-power
`
`bioelectronics.
`
`12.
`
`I have also been a consultant on various projects with Motorola, Intel
`
`(designing 2G, 3G mobile telephone transceivers, Internet-of-Things (IOT), and
`
`sensors), Texas Instrument (developing 3G cellular and Bluetooth technologies),
`
`Sony Wireless (developing GPS technologies), Tektronics (designing wireless
`
`systems), and various other consultancies. During my work in industry, I have
`
`designed and contributed to the design of many wireless systems for commercial
`
`products. Many of my designs are still in use today in products manufactured by the
`
`companies I have worked for, including Motorola, Intel, Sony, and more.
`
`13. My compensation is not dependent on the outcome of these proceedings
`
`or the content of my opinions. To the best of my knowledge, I have no financial
`
`interest in either party or in the outcome of this proceeding.
`
`
`
`IPR2024-01049
`Apple EX1003 Page 18
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`

`

`Declaration of Dr. Sayfe Kiaei
`Patent Nos. 7,969,990 and 8,711,866
`II. METHODOLOGY; MATERIALS CONSIDERED
`14.
`I have relied upon my education, knowledge, and experience with the
`
`technology of communication networks, as well as the other materials as discussed
`
`in this declaration in forming my opinions.
`
`15. For this work, I have been asked to review U.S. Patent Nos. 7,969,990
`
`and 8,711,866 (“the ’990 Patent”) (Ex. 1001) (“the ’866 Patent”) (Ex. 1038)
`
`including the specification and claims, and the ’990 and ’866 Patents’ prosecution
`
`histories (“’990 File History”) (Ex. 1002), (“’866 File History”) (Ex. 1039). In
`
`developing my opinions relating to the ’990 and ’866 Patents, I have considered the
`
`materials cited or discussed herein, including those listed below.
`
`• U.S. Patent No. 7,969,990 (“’990 Patent”) (Ex. 1001)
`• Prosecution History for the ’990 Patent (“’990 FH”) (Ex. 1002)
`• U.S. Patent App. Pub. No. 2002/0068600 to Chihara et al. (“Chihara”)
`(Ex. 1004)
`• Specification of the Bluetooth System Version 1.1. February 22, 2001.
`(“BluetoothSpec”) (Ex. 1005)
`• U.S. Patent No. 6,701,162 to Everett (“Everett”) (Ex. 1006)
`• U.S. Patent App. Pub. No. 2002/0062406 to Chang et al. (“Chang”)
`(Ex. 1007)
`• U.S. Patent No. 7,580,005 to Palin (“Palin”) (Ex. 1008)
`• U.S. Patent No. 6,307,921 to Engelke et al. (“Engelke”) (Ex. 1009)
`• U.S. Patent App. Pub. No. 2002/0178279 to Janik et al. (“Janik”) (Ex.
`1010)
`• International Publication No. WO 01/74024 to Hartmaier et al.
`(“Hartmaier”) (Ex. 1011)
`• European Patent Application No. EP1132847 to Han et al. (“Han”) (Ex.
`1012)
`• U.S. Patent App. Pub. 2002/0102998 to Lin (“Lin”) (Ex. 1013)
`• U.S. Patent No. 7,580,005 to Palin (“Palin”) (Ex. 1014)
`
`
`
`IPR2024-01049
`Apple EX1003 Page 19
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`

`

`Declaration of Dr. Sayfe Kiaei
`Patent Nos. 7,969,990 and 8,711,866
`• U.S. Patent App. Pub. No. 2003/0110234 to Egli et al. (“Egli”) (Ex.
`1015)
`• U.S. Patent No. 6,910,068 to Zintel et al. (“Zintel”) (Ex. 1016)
`• U.S. Patent No. 6,901,273 to Lutnaes (“Lutnaes”) (Ex. 1018)
`• U.S. Patent App. Pub. No. 2002/0141548 to Boda (“Boda”) (Ex. 1019)
`• International Publication No. WO 02/19152 to Bergman et al.
`(“Bergman”) (Ex. 1020)
`• Matthew S. Gast. 802.11 Wireless Networks The Definitive Guide.
`O’Reilly & Associates. April 2002. (“Gast”) (Ex. 1021)
`• U.S. Patent No. 6,925,108 to Miller et al. (“Miller”) (Ex. 1022)
`• Jim Geier. Wireless LANs. 2nd Edition. Sams Publishing. July 2001.
`(“Geier”) (Ex. 1023)
`• U.S. Patent No. 6,212,282 to Mershon (“Mershon”) (Ex. 1024)
`• U.S. Patent No. 6,526,287 to Lee (“Lee”) (Ex. 1025)
`• U.S. Patent App. Pub. No. 2002/0101367 to Geiger et al. (“Geiger”)
`(Ex. 1026)
`• U.S. Patent App. Pub. No. 2002/0186770 to Jawerth et al. (“Jawerth”)
`(Ex. 1027)
`• U.S. Patent App. Pub. No. 2003/0013438 to Darby (“Darby”) (Ex.
`1028)
`• U.S. Patent App. Pub. No. 2003/0139966 to Sirota et al. (“Sirota”) (Ex.
`1029)
`• U.S. Patent No. 5,781,192 to Kodimer (“Kodimer”) (Ex. 1030)
`• U.S. Patent No. 6,297,737 to Irvin (“Irvin”) (Ex. 1031)
`• U.S. Patent No. 6,309,305 to Kraft (“Kraft”) (Ex. 1032)
`• U.S. Patent No. 7,676,372 to Oba (“Oba”) (Ex. 1033)
`• U.S.