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`DECLARATION OF NABIL J. SARHAN, PH.D.,
`UNDER 37 C.F.R. § 42.100 REGARDING
`U.S. PATENT NOS. 7,593,034; 8,692,882; 9,485,471; AND 9,912,914
`
`
`
`
`Declaration
`I declare that all statements made herein on my own knowledge are true and
`that all statements made on information and belief are believed to be true, and further,
`that these statements were made with the knowledge that willful false statements and
`the like so made are punishable by fine or imprisonment, or both, under Section 1001
`of Title 18 of the United States Code.
`
`
`
`
`Date: July 22, 2024
`
` By: ___________________________
`
`
`
`
`
`
`
`
`
`
`
`
`
` Nabil J. Sarhan, Ph.D.
`
`
`
`
`
`Motorola v. Stellar
`Motorola Exhibit 1003
`
`

`

`4.
`5.
`
`Table of Contents
`Qualifications .................................................................................................. 1
`I.
`Relevant Legal Standards ............................................................................... 6
`II.
`III. Person Of Ordinary Skill In The Art .............................................................. 9
`IV. Technology Background ............................................................................... 12
`A.
`Introduction ........................................................................................ 12
`B.
`State Of The Art And Admitted Prior Art .......................................... 13
`1.
`Admissions In The Stellar Patents ........................................... 14
`2.
`Admissions In The Stellar Patents’ File Histories ................... 21
`3.
`Pre-Event Recording Or Record-After-The-Fact Was
`Well Known In The Art ........................................................... 34
`Body-Worn Cameras Were Known In The Art ....................... 56
`Various Memory Options For Storing Events Were
`Known In The Art .................................................................... 60
`6. Wireless Transmission Of Files To A Remote Memory
`Was Known In The Art ............................................................ 63
`Remote Memory On Mobile Phone Was Known In The
`Art ............................................................................................ 79
`Treating A Circular Buffer As A Single File Was Known
`In The Art ................................................................................. 93
`Indexing Write-Protected Portions As A Second, Distinct
`File In The Circular Buffer Was Known In The Art ............. 100
`The Alleged Invention Of The ’034, ’882, ’471, And ’914 Patents .......... 116
`V.
`VI. Claim Construction ..................................................................................... 120
`A.
`“a local memory functionally coupled to the [camera/sensor]” ....... 120
`“file” ................................................................................................. 121
`B.
`VII. Summary Of The Prior Art ......................................................................... 124
`A. Yerazunis .......................................................................................... 124
`B.
`Ely ..................................................................................................... 130
`C.
`Fiore .................................................................................................. 134
`
`8.
`
`9.
`
`
`
`
`
`7.
`
`

`

`
`
`Lewellen ........................................................................................... 143
`D.
`E. Mann ................................................................................................. 148
`F.
`Fiedler ............................................................................................... 150
`VIII. ’034 Patent: Claims 1-20 ............................................................................ 152
`A.
`Summary Of The ’034 Patent File History ...................................... 153
`B. Ground 1a: Claims 1-6, 9, And 11-18 Of The ’034 Patent
`Would Have Been Obvious Over Yerazunis Alone Or As
`Combined With Fiore ....................................................................... 154
`1. Motivation To Combine ......................................................... 154
`2.
`Independent Claim 1 .............................................................. 158
`3.
`Dependent Claims 2-6, 9, and 11 ........................................... 172
`4.
`Independent Claim 12 ............................................................ 178
`5.
`Dependent Claims 13-18 ........................................................ 183
`C. Ground 1b: Claims 7 And 8 Of The ’034 Patent Would Have
`Been Obvious Over Yerazunis Alone Or As Combined With
`Fiore, In Further View Of Lewellen ................................................ 188
`1. Motivation To Combine ......................................................... 188
`2.
`Dependent Claims 7 and 8 ..................................................... 191
`D. Ground 1c: Claim 10 Of The ’034 Patent Would Have Been
`Obvious Over Yerazunis Alone Or As Combined With Fiore, In
`Further View Of Mann ..................................................................... 193
`1. Motivation to Combine ........................................................... 193
`2.
`Dependent Claim 10 ............................................................... 193
`Ground 1d: Claims 19 And 20 Of The ’034 Patent Would Have
`Been Obvious Over Yerazunis Alone Or As Combined With
`Fiore, In Further View Of Fiedler .................................................... 194
`1. Motivation To Combine ......................................................... 194
`2.
`Dependent Claims 19 and 20 ................................................. 195
`Ground 2a: Claims 1-9 And 11-18 Of The ’034 Patent Would
`Have Been Obvious Over Ely Alone Or As Combined With
`Fiore, In Further View Of Lewellen ................................................ 197
`1. Motivation To Combine ......................................................... 197
`
`E.
`
`F.
`
`
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`-ii-
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`
`
`IX.
`
`Independent Claim 1 .............................................................. 201
`2.
`Dependent Claims 2-9, 11 ...................................................... 209
`3.
`Independent Claim 12 ............................................................ 215
`4.
`Dependent Claims 13-18 ........................................................ 219
`5.
`G. Ground 2b: Claim 10 Of The ’034 Patent Would Have Been
`Obvious Over Ely Alone Or As Combined With Fiore, In
`Further View Of Lewellen And Mann ............................................. 222
`H. Ground 2c: Claims 19 And 20 Of The ’034 Patent Would Have
`Been Obvious Over Ely Alone Or As Combined With Fiore, In
`Further View Of Lewellen And Fiedler ........................................... 223
`1. Motivation to Combine .......................................................... 223
`2.
`Dependent Claims 19 and 20 ................................................. 223
`’882 Patent: Claims 1-22 ............................................................................ 225
`A.
`Summary Of The ’882 Patent File History ...................................... 227
`B. Ground 1a: Claims 1-6, 9, 11-18, 21, And 22 Of The ’882
`Patent Would Have Been Obvious Over Yerazunis Alone Or As
`Combined With Fiore ....................................................................... 227
`1. Motivation To Combine ......................................................... 227
`2.
`Independent Claims 1 and 12 ................................................. 227
`3.
`Dependent Claims 2-6, 9, 11, 13-18, 21-22 ........................... 243
`C. Ground 1b: Claims 7 And 8 Of The ’882 Patent Would Have
`Been Obvious Over Yerazunis Alone Or As Combined With
`Fiore, In Further View Of Lewellen ................................................ 254
`1. Motivation To Combine ......................................................... 254
`2.
`Dependent Claims 7 and 8 ..................................................... 254
`D. Ground 1c: Claim 10 Of The ’882 Patent Would Have Been
`Obvious Over Yerazunis Alone Or As Combined With Fiore, In
`Further View Of Mann ..................................................................... 256
`Ground 1d: Claims 19 And 20 Of The ’882 Patent Would Have
`Been Obvious Over Yerazunis Alone Or As Combined With
`Fiore, In Further View Of Fiedler .................................................... 256
`1. Motivation To Combine ......................................................... 256
`
`E.
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`-iii-
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`
`
`X.
`
`I.
`
`F.
`
`Dependent Claims 19 and 20 ................................................. 256
`2.
`Ground 2a: Claims 1, 2, 4-6, 9, 11-18, And 21 Of The ’882
`Patent Would Have Been Obvious Over Ely Alone Or As
`Combined With Fiore ....................................................................... 259
`1. Motivation To Combine ......................................................... 259
`2.
`Independent Claims 1 and 12 ................................................. 259
`3.
`Dependent Claims 2, 4-6, 9, 11, 13-18, and 22 ..................... 270
`G. Ground 2b: Claims 3, 7, 8, And 22 Of The ’882 Patent Would
`Have Been Obvious Over Ely Alone Or As Combined With
`Fiore, In Further View Of Lewellen ................................................ 277
`1. Motivation To Combine ......................................................... 277
`2.
`Dependent Claims 3, 7, 8 and 22 ........................................... 278
`H. Ground 2c: Claim 10 Of The ’882 Patent Would Have Been
`Obvious Over Ely Alone Or As Combined With Fiore, In
`Further View Of Mann ..................................................................... 280
`Ground 2d: Claims 19 And 20 Of The ’882 Patent Would Have
`Been Obvious Over Ely Alone Or As Combined With Fiore, In
`Further View Of Fiedler ................................................................... 280
`1. Motivation To Combine ......................................................... 280
`2.
`Claims 19 and 20.................................................................... 280
`’471 Patent: Claims 1-13 ............................................................................ 282
`A.
`Summary Of The ’471 Patent File History ...................................... 283
`B. Ground 1a: Claims 1, 2, 4-7, 10, 12, And 13 Of The ’471 Patent
`Would Have Been Obvious Over Yerazunis Alone Or As
`Combined With Fiore ....................................................................... 284
`1. Motivation To Combine ......................................................... 284
`2.
`Claim 1 ................................................................................... 285
`3.
`Dependent Claims 2, 4-7, 10, 12, and 13 ............................... 297
`C. Ground 1b: Claims 3, 8, And 9 Of The ’471 Patent Would Have
`Been Obvious Over Yerazunis Alone Or As Combined With
`Fiore, In Further View of Lewellen ................................................. 308
`1. Motivation To Combine ......................................................... 308
`
`
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`-iv-
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`

`
`
`XI.
`
`F.
`
`E.
`
`Dependent Claims 3, 8, and 9 ................................................. 308
`2.
`D. Ground 1c: Claim 11 Of The ’471 Patent Would Have Been
`Obvious Over Yerazunis Alone Or As Combined With Fiore, In
`Further View Of Mann ..................................................................... 311
`1. Motivation To Combine ......................................................... 311
`2.
`Dependent Claim 11 ............................................................... 312
`Ground 2a: Claims 1, 2, 4-7, 10, 12, And 13 Of The ’471 Patent
`Would Have Been Obvious Over Ely Alone Or As Combined
`With Fiore ......................................................................................... 313
`1. Motivation To Combine ......................................................... 313
`2.
`Claim 1 ................................................................................... 313
`3.
`Dependent Claims 2, 4-7, 10, 12, and 13 ................................ 320
`Ground 2b: Claims 3, 8, And 9 Of The ’471 Patent Would Have
`Been Obvious Over Ely Alone Or As Combined With Fiore, In
`Further View Of Lewellen ............................................................... 330
`1. Motivation To Combine ......................................................... 330
`2.
`Dependent Claims 3, 8, and 9 ................................................. 330
`G. Ground 2c: Claim 11 Of The ’471 Patent Would Have Been
`Obvious Over Ely Alone Or As Combined With Fiore, In
`Further View Of Mann ..................................................................... 331
`1. Motivation To Combine ......................................................... 331
`2.
`Dependent Claim 11 ............................................................... 332
`’914 Patent: Claims 1-23 ............................................................................ 332
`A.
`Summary Of The ’914 Patent File History ...................................... 333
`B. Ground 1a: Claims 1-10, 13-16, And 18-23 Of The ’914 Patent
`Would Have Been Obvious Over Yerazunis Alone Or As
`Combined With Fiore ....................................................................... 334
`1. Motivation To Combine ......................................................... 334
`2.
`Claim 1 ................................................................................... 335
`3.
`Dependent Claims 2-10, 13-16, 18-23 .................................. 346
`
`
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`-v-
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`

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`
`
`
`C. Ground 1b: Claims 11, 12, And 17 Of The ’914 Patent Would
`Have Been Obvious Over Yerazunis Alone Or As Combined
`With Fiore, In Further View of Lewellen ........................................ 363
`1. Motivation To Combine ......................................................... 363
`2.
`Dependent Claims 11, 12, and 17 .......................................... 363
`D. Ground 2a: Claims 1-10, 13-16, And 18-23 Of The ’914 Patent
`Would Have Been Obvious Over Ely Alone Or As Combined
`With Fiore ......................................................................................... 365
`1. Motivation To Combine ......................................................... 365
`2.
`Claim 1 ................................................................................... 365
`3.
`Dependent Claims 2-10, 13-16, 18-23 ................................... 374
`Ground 2b: Claims 11, 12, And 17 Of The ’914 Patent Would
`Have Been Obvious Over Ely Alone Or As Combined With
`Fiore, In Further View Of Lewellen ................................................ 392
`1. Motivation To Combine ......................................................... 392
`2.
`Dependent Claims 11, 12, and 17 .......................................... 392
`
`E.
`
`-vi-
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`
`
`I, Nabil Sarhan, do hereby declare:
`
`
`
`I am making this declaration at the request of Motorola Solutions, Inc.
`
`(“Motorola”) and Watchguard Video, Inc. (“Watchguard”) in the matter of the Inter
`
`Partes Reviews (“IPRs”) of U.S. Patent Nos. 7,593,034 (the ’034 patent); 8,692,882
`
`(the ’882 patent); 9,485,471 (the ’471 patent); and 9,912,914 (the ’914 patent).
`
`
`
`I am being compensated for my work in this matter at my standard hourly
`
`rate of $390 for such consulting services. My compensation in no way depends on the
`
`outcome of this proceeding.
`
`I.
`
`Qualifications
`
` My qualifications generally are set forth in my curriculum vitae, which is
`
`submitted as Appendix A. All appendices cited herein are found in Exhibit 1041.
`
`
`
`I received my Ph.D. and M.S. degrees in Computer Science and
`
`Engineering from the Pennsylvania State University (Penn State) in 2003 and a B.S.
`
`degree in Electrical Engineering from Jordan University of Science and Technology in
`
`1995. Both my M.S. thesis and Ph.D. dissertation considered the design of computer
`
`systems for supporting multimedia. In particular, my Ph.D. dissertation dealt with the
`
`design of high-bandwidth I/O systems for multimedia applications, specifically video
`
`streaming. In this dissertation, titled “On the design of scalable and high-performance
`
`multimedia servers”, I proposed new methods to design multimedia systems in a way
`
`that maximizes the number of users that can stream videos at the same time.
`
`
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`
`
`I am an Associate Professor of Electrical and Computer Engineering
`
`(ECE) at Wayne State University and the Director of Wayne State Computer Systems
`
`and Deep Learning Research Laboratory, formerly known as the Multimedia Systems
`
`and Networking Lab Research Lab. I am the Coordinator of the Interdisciplinary
`
`College of Engineering M.S. in AI Program and the Director of the Hardware and
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`System Track. I served as the Graduate Program Director of Electrical and Computer
`
`Engineering and the Chair of the College of Engineering Faculty Assembly. I also
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`served as the Director of the Wayne State Multimedia Computing and Networking
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`Research Laboratory in the ECE department for approximately fifteen years. I am
`
`chairing the Computer Engineering Area in the ECE department, and I regularly teach
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`undergraduate and graduate courses in computer architecture and computer networks
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`and supervise Ph.D. and M.S. students.
`
`
`
`I have been regularly teaching the senior-level Computer Architecture
`
`course (previously called Computer Organization and Design) since 2003. The course
`
`covers microprocessor design, memory hierarchy, and I/O. I have also been teaching
`
`the Computer Networks and Network Programming course, which includes coverage
`
`of all network layers (including the physical layer) and different network protocols.
`
`Additionally, I taught multiple times the Advanced Computer Architecture course,
`
`which focuses on the design of parallel computer systems and covers microprocessor
`
`design, memory hierarchy, and I/O. I have recently developed a new mandatory course
`
`titled “Object-Oriented Programming for Electrical and Computer Engineering” and
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`led the efforts to modernize the Introduction to Microcomputers course and lab by using
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`ARM-based microcontrollers and the instruction set. Additionally, I taught the
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`following advanced graduate courses: Scalable and Secure Internet Services and
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`Architectures, Special Topics on Multimedia, Special Topics on Multimedia
`
`Networking, and Special Topics on Multimedia Systems and Networks. Furthermore, I
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`taught
`
`the
`
`following undergraduate courses: “Microcomputer Systems and
`
`Programming”, and “Microprocessor Interfacing Lab”.
`
`
`
`I am an internationally recognized expert on computer systems,
`
`particularly those for multimedia applications.
`
`
`
`I supervised eight Ph.D. dissertations and four master theses related to
`
`computer systems. Seven of these Ph.D. dissertations and all four M.S. theses were
`
`focused on multimedia systems, with research areas including video streaming and
`
`automated video surveillance. Additionally, I am currently supervising three Ph.D.
`
`dissertations in computer systems. Furthermore, I served on 25 other Ph.D. dissertation
`
`committees and 10 other M.S. thesis committees.
`
`
`
`I authored more than 55 refereed papers, including those in top journals
`
`and conferences in various areas including computer systems, multimedia, networking,
`
`deep learning, and I/O. I was awarded (with a collaborator) a grant from the National
`
`Science Foundation (NSF) to develop a reconfigurable hardware accelerator chip and
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`system for deep learning and artificial intelligence. The project includes the design of
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`inference-engine chips that are interconnected through PCI Express to build a scalable
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`system supporting large neural models. Three of my other research projects were also
`
`sponsored by the NSF. One of these projects was on video streaming while another
`
`was on the design of a video camera security system, specifically an automated video
`
`surveillance system, for automatic detection of
`
`threats, utilizing cross-layer
`
`optimization.
`
` Another NSF-sponsored project was on reconfigurable high-
`
`performance cluster computing and medical engineering applications. Other research
`
`projects were sponsored by Silicon Mechanics and Sun Microsystems. These projects
`
`include “High Performance Computing Cluster” and “Sun’s Center of Excellence in
`
`Open Source Computing and Applications”. I published a book chapter: “Streaming
`
`Multimedia”, The Handbook of Computer Networks, John Wiley & Sons, Inc.,
`
`November 2007.
`
`
`
`I am the named inventor on U.S. Patent No. 9,313,463 related to the design
`
`of automated video surveillance systems. The system optimally controls a plurality of
`
`security cameras to achieve the best threat detection accuracy.
`
`
`
`I served as the Chair of the Interest Group on Media Streaming of the
`
`Institute of Electrical and Electronics Engineering (IEEE) Multimedia Communication
`
`Technical Committee and as the Co-Director of the IEEE Multimedia Communication
`
`Technical Committee Review Board. I have been an Editor of the ERTI journal since
`
`2017. I served as an Associate Editor of the IEEE Transactions on Circuits and Systems
`
`for Video Technology. I served as a Guest Editor and Reviewer for prestigious journals
`
`and magazines. I have been involved in the organization of numerous international
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`
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`conferences in various capacities, including General Chair, Chair, Technical Program
`
`Committee Co-Chair, Publicity Chair, Track Chair, Session Chair, and Technical
`
`Program Committee Member. For example, I served as Co-Chair of the Technical
`
`Program Committee of ACM SIGMM Workshop on Network and Operating Systems
`
`Support for Digital Audio and Video (NOSSDAV) in 2018. I participated as a Panelist
`
`in major international conferences.
`
`
`
`I served as a Panelist for the National Science Foundation and the National
`
`Institute of Health and as a Site Review Panelist for the Natural Sciences and
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`Engineering Research Council of Canada.
`
`
`
`I have been extensively involved in internal and international educational
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`reform, review, and accreditation activities. I also served as an external expert in
`
`reviewing and reforming computer science and computer engineering programs and
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`courses. I served as the chair of more than 20 international panels and as a member of
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`seven international panels for the review and accreditation of institutions and
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`undergraduate and graduate programs, including “electrical engineering”, “electrical
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`and computer engineering”, “software engineering”, “computer and network
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`engineering”, “computer science”, and “information technology”. I am also a Program
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`Evaluator for ABET Accreditation Board for Engineering and Technology.
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`
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`I received the IEEE SEM Outstanding Professional of the Year Award,
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`the Wayne State University President’s Award for Excellence in Teaching, and the
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`College of Engineering Excellence in Teaching Award. I was elevated to a Senior
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`Member of the Institute of Electrical and Electronics Engineering (IEEE) in 2016.
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`
`
`I have recently been inducted into the WSU Academy of Teachers for
`
`having “a significant impact on the WSU undergraduate learning experience”,
`
`practicing “innovative pedagogy”, and demonstrating “instructional excellence.”
`
`II. Relevant Legal Standards
`
`
`
`I have been asked to provide my opinion as to whether the claims of
`
`the ’034, ’882, ’471, and ’914 patents would have been obvious to a person of ordinary
`
`skill in the art at the time of the invention, in view of the prior art.
`
`
`
`I am an engineer by training and profession. The opinions I am expressing
`
`in this declaration involve the application of my knowledge and experience to the
`
`evaluation of certain prior art with respect to the ’034, ’882, ’471, and ’914 patents. My
`
`formal knowledge of patent law is no different than that of any lay person. Therefore,
`
`I have requested the attorneys from Jones Day, who represent Motorola and
`
`Watchguard, to provide me with guidance as to the applicable patent law in this matter.
`
`The paragraphs below express my understanding of how I must apply current principles
`
`related to patent validity to my analysis.
`
`
`
`It is my understanding that in determining whether a patent claim is
`
`obvious in view of the prior art, the Patent Office must apply the Phillips standard to
`
`construe the claim by giving the claim its plain and ordinary meaning, consistent with
`
`the specification and prosecution history. For the purposes of this review, I have
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`construed each claim term in accordance with its plain and ordinary meaning under the
`
`Phillips standard, unless otherwise indicated.
`
`
`
`It is my understanding that a claim is unpatentable under 35 U.S.C. § 103
`
`if the claimed subject matter as a whole would have been obvious to a person of
`
`ordinary skill in the art at the time of the invention. I understand that a person of
`
`ordinary skill in the art is a person with a level of experience, education, or training
`
`generally possessed by those individuals who work in the area or field of the invention
`
`at the time of the invention. A person of ordinary skill is also a person of ordinary
`
`creativity that can use common sense to solve problems. I also understand that an
`
`obviousness analysis takes into account the scope and content of the prior art, the
`
`differences between the claimed subject matter and the prior art, and the level of
`
`ordinary skill in the art at the time of the invention.
`
`
`
`In determining the scope and content of the prior art, it is my
`
`understanding that a reference is considered analogous prior art if it falls within the field
`
`of the inventor’s endeavor. In addition, a reference is analogous prior art if it is
`
`reasonably pertinent to the particular problem with which the inventor was involved. A
`
`reference is reasonably pertinent if it logically would have commended itself to an
`
`inventor’s attention in considering his problem. If a reference relates to the same
`
`problem as the claimed invention, that supports use of the reference as prior art in an
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`obviousness analysis.
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`-7-
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` To assess the differences between prior art and the claimed subject matter,
`
`it is my understanding that 35 U.S.C. § 103 requires the claimed invention to be
`
`considered as a whole. This “as a whole” assessment requires showing that one of
`
`ordinary skill in the art at the time of invention, confronted by the same problems as the
`
`inventor and with no knowledge of the claimed invention, would have selected the
`
`elements from the prior art and combined them in the claimed manner.
`
`
`
`It is my further understanding that the Supreme Court has recognized
`
`several rationales for combining references or modifying a reference to show
`
`obviousness of claimed subject matter. Some of these rationales include: combining
`
`prior art elements according to known methods to yield predictable results; simple
`
`substitution of one known element for another to obtain predictable results; a
`
`predictable use of prior art elements according to their established functions; applying
`
`a known technique to a known device (method or product) ready for improvement to
`
`yield predictable results; choosing from a finite number of identified, predictable
`
`solutions, with a reasonable expectation of success; and some teaching, suggestion, or
`
`motivation in the prior art that would have led one of ordinary skill in the art to modify
`
`the prior art reference or to combine prior art reference teachings to arrive at the claimed
`
`invention. As part of an obviousness analysis, I understand that I am to consider
`
`whether a reason existed at the relevant time that would have motivated a person of
`
`ordinary skill in the art in the relevant field to combine the known elements in the way
`
`the claimed invention does. The reason could come from the prior art, the background
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`knowledge of one of ordinary skill in the art, the nature of the problem to be solved,
`
`market demand, or common sense, for instance.
`
`III. Person Of Ordinary Skill In The Art
`
`
`
`It is my understanding that when interpreting the claims of the ’034, ’882,
`
`’471, and ’914 patents, I must do so based on the perspective of one of ordinary skill in
`
`the art (a “POSITA”) as of the relevant priority date. I understand that
`
`the ’034, ’882, ’471, and ’914 patents are part of a patent family assigned to the Patent
`
`Owner:
`
`
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`-9-
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`
` As indicated above, it is my understanding that the ’034, ’882, ’471,
`
`and ’914 patents are related to each other as continuation applications, meaning that
`
`these patents share a common specification. The earliest-filed of these four patent
`
`applications was the application for the ’034 patent filed on November 10, 2008. As
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`indicated above, it is my understanding that the ’034 patent claims priority as a
`
`continuation-in-part to two (2) previous applications filed in 2007: (i) App. No.
`
`11/770,920 (the ’920 application), filed June 29, 2007, issued as U.S. Patent No.
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`8,310,540, and (ii) App. No. 11/846,217 (the ’217 application), filed August 28, 2007,
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`issued as U.S. Patent No. 8,928,752. The ’920 application claims priority to U.S.
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`Provisional App. No. 60/824,097, filed on August 31, 2006. The ’217 application
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`claims priority to U.S. Provisional App. No. 60/824,095, filed on August 31, 2006.
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` For the purposes of this IPR proceeding, I have been asked to apply
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`June 29, 2007, as the priority date for the challenged claims of the ’034, ’882, ’471,
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`and ’914 patents.
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`In my opinion, a person of ordinary skill in the art for the ’034, ’882, ’471,
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`and ’914 patents as of June 29, 2007 would have been a person having at least a
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`Bachelor’s Degree in electrical engineering, computer science, or computer engineering,
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`or undergraduate training in an equivalent field and at least two years of relevant
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`experience in electronics technology. Additional graduate education could substitute
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`for professional experience, and significant work experience could substitute for formal
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`education.
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` Further, I note that my opinion on the level of skill of the POSITA is the
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`same for the other, later priority dates to which the ’034, ’882, ’471, and ’914 patents
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`could potentially be entitled: the August 28, 2007 filing date of the ’217 application,
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`and the November 10, 2008 filing date of the ’034 patent application. On all of these
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`dates, it is my opinion that the POSITA would have been a person having at least a
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`Bachelor’s Degree in electrical engineering, computer science, or computer engineering,
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`or undergraduate training in an equivalent field and at least two years of relevant
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`experience in electronics technology. Additional graduate education could substitute
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`for professional experience, and significant work experience could substitute for formal
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`education.
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` As described in detail above in the “Qualifications” section, my own
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`training and experience exceeded that of one of ordinary skill in the art at the assumed
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`priority date of June 29, 2007.
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`IV. Technology Background
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`A.
`Introduction
` The ’034, ’882, ’471, and ’914 patents are directed generally to “video
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`camera recording technology” (see, e.g., ’034 patent at 1:19-20), and more specifically
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`to systems and apparatuses that “continuously record[] imaged data from a camera into
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`a circular buffer in a local memory.” Id. at Abstract. “The circular buffer is preferably
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`organized into a series of memory segments that loops back on itself.” Id. at 2:21-24.
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`Receipt of a “record signal” causes “a segment of the circular buffer to be write-
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`protected to prevent that segment from being overwritten during the next recording
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`loop.” Id. at Abstract, 4:34-37. “Part of the write-protected portion could be a pre-
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`recorded subset that is recorded before the signal is received, while part of the write-
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`protected portion could be a post-recorded subset that is recorded after the signal is
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`received.” Id. at 2:38-41. In embodiments, “the entire circular buffer is treated and
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`stored as a single file,” and “the write-protected portions are preferably stored as
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`separate files in the [circular buffer]. Id. at 2:45-48, 6:3-7. Further, in embodiments,
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`write-protected portions are “sent to a remote memory via a wireless connection to free
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`up local memory for future recording sessions.” Id. at Ab