UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________________
`
`COMMSCOPE TECHNOLOGIES LLC
`Petitioner
`
`v.
`
`BELDEN CANADA ULC
`Patent Owner
`
`_____________________________
`
`U.S. Patent No. 11,740,423
`______________________________
`
`EXPERT DECLARATION OF DR. STEPHEN RALPH
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`I.
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`Table of Contents
`Introduction .................................................................................................. 1
`A.
`Engagement ....................................................................................... 1
`B.
`Qualifications .................................................................................... 1
`II. Materials Considered ................................................................................... 5
`III. Relevant Legal Principles ............................................................................ 5
`A.
`Person of Ordinary Skill in the Art ................................................... 5
`B.
`Claim Construction Standard ............................................................ 7
`C.
`Anticipation ....................................................................................... 8
`D. Obviousness ....................................................................................... 9
`IV. Technology Background ............................................................................13
`V. Ground 1: The challenged claims are all anticipated by Fukui or obvious
`based on Fukui itself ..................................................................................18
`A.
`Independent Claim 1 .......................................................................19
`B.
`Independent Claim 9 .....................................................................101
`C.
`Independent Claim 17 ...................................................................113
`D. Dependent Claims 2, 10, 18 ..........................................................120
`E.
`Dependent Claims 3, 11, 19 ..........................................................125
`F.
`Dependent Claims 4, 12, 22 ..........................................................125
`G. Dependent Claims 5, 13, 23 ..........................................................141
`H. Dependent Claims 6, 14, 24 ..........................................................146
`I.
`Dependent Claims 7, 15, 25 ..........................................................146
`J.
`Dependent Claims 8, 16, 26, 27 ....................................................160
`K. Dependent Claim 20 ......................................................................163
`L.
`Dependent Claim 21 ......................................................................164
`M. Dependent Claim 28 ......................................................................166
`N. Dependent Claim 29 ......................................................................167
`O. Dependent Claim 30 ......................................................................170
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`In Support of Inter Partes Review
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`VI. Ground 2: The challenged claims are also all obvious based on Fukui plus
`Sauter .......................................................................................................171
`VII. Ground 3: Sauter combined with Dagley renders claims 1-30 obvious. 182
`A.
`Independent Claim 1 .....................................................................182
`B.
`Independent Claim 9 .....................................................................245
`C.
`Independent Claim 17 ...................................................................258
`D. Dependent Claims 2, 10, and 18 ...................................................265
`E.
`Dependent Claims 3, 11, and 19 ...................................................267
`F.
`Dependent Claims 4, 12, and 22 ...................................................269
`G. Dependent Claims 5, 13, 23 ..........................................................281
`H. Dependent Claims 6, 14, 24 ..........................................................293
`I.
`Dependent Claims 7, 15, 25 ..........................................................295
`J.
`Dependent Claims 8, 16, 26, 27 ....................................................299
`K. Dependent Claim 20 ......................................................................302
`L.
`Dependent Claim 21 ......................................................................304
`M. Dependent Claim 28 ......................................................................305
`N. Dependent Claim 29 ......................................................................308
`O. Dependent Claim 30 ......................................................................312
`VIII. Ground 4: Sauter combined with Dagley in further light of Fukui renders
`claims 1-30 obvious .................................................................................315
`A. Dependent Claims 5, 13, 23 “directly adjacent” ...........................315
`B.
`Cassette Size Limitations in Independent Claims 1, 9, 17 ............324
`IX. Ground 5: Either of Grounds 3 or 4 in further light of Laarveld renders
`claims 7, 15, and 25 obvious ...................................................................326
`Claims Listing Appendix ...................................................................................331
`Petitioner’s Exhibit List .....................................................................................343
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`ii
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`I, Stephen E. Ralph, Ph.D., declare as follows.
`
`I.
`
`Introduction
`A. Engagement
`
`1.
`
`I have been retained by CommScope Technologies LLC,
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`(“CommScope”) to provide expert opinions in connection with a petition for inter
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`partes review before the United States Patent and Trademark Office. This
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`declaration involves my expert opinions and expert knowledge related to U.S.
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`Patent No. 11,740,423 (“the ‘423 Patent”) and its field of endeavor.
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`2.
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`I have been asked to provide my independent technical review,
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`analysis, insights, and opinions regarding the ‘423 Patent and the references that
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`form the basis for the grounds for invalidity set forth in the Petition for Inter Partes
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`Review of the ‘423 Patent. The statements made herein are based on my own
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`knowledge and opinions.
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`B. Qualifications
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`3.
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`I am a professor of Electrical Engineering at the Georgia Institute of
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`Technology. I received my Ph.D. (1988) in Electrical Engineering from Cornell
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`University. I received my Bachelor degree (1980) in Electrical Engineering from
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`Georgia Institute of Technology.
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`In Support of Inter Partes Review
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`At Georgia Tech, I hold the Glen Robinson Chair in Electro-Optics
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`
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`4.
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`and I am a Principal Research Scientist at the Georgia Tech Research Institute, the
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`applied research unit of the Georgia Institute of Technology.
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`5.
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`I was a Postdoctoral Member of the Technical Staff at AT&T Bell
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`Laboratories and a Visiting Scientist at IBM T. J. Watson Research Laboratory. I
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`was a founding member of Quellan, Inc., a startup focused on developing
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`electronic signal processing and higher order modulation formats for fiber optic
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`communication systems. Quellan was purchased by Intersil where the
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`technologies are applied to a variety of high-speed links.
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`6.
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`I am currently the Director of the Georgia Electronic Design Center at
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`Georgia Tech. The GEDC is a cross-disciplinary Electronics and Photonics center
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`of the Georgia Institute of Technology focused on the synergistic development of
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`high-speed photonics, electronics, and signal processing. The center includes more
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`than 12 active faculty, over 140 graduate students and an annual research
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`expenditure of ~$8M. The GEDC is one of the world’s largest university-based
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`research centers of its kind.
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`7.
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`I am the Director of a National Science Foundation (NSF) multi–
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`University Center with lead site at Georgia Tech known as EPICA: Electronic and
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`Photonic Integrated Circuits for Aerospace. The center is an NSF Industry
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`University Collaborative Research Center (IUCRC) and is focused on developing
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`and testing integrated photonics and electronics for harsh environments. IUCRCs
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`are unlike most NSF funding efforts in that they are industry driven. EPICA has
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`more than 20 Industry members and affiliates.
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`8.
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`I am actively involved as a reviewer, and committee member of
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`various journals and conferences and have extensive experience with various
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`international standards groups focused on electronic and photonic components and
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`high-capacity fiber optic systems. I am a past Associate Editor for optoelectronic
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`devices for the IEEE Journal Transactions on Electronic Devices and I am now the
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`Treasurer of the IEEE Photonics Society (January 2023 through December 2025),
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`and a Fellow of the OSA (formerly the Optical Society of America).
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`9. My research efforts currently focus on integrated photonics and
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`electronics with application to high capacity communication systems including
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`DWDM fiber networks and optical interconnects, particularly the intersection of
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`electronics, photonics and signal processing; communication component and
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`system design, optimization and simulations for photonic components including
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`lasers, modulators and direct detect and coherent receivers; the integration,
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`assembly and packaging of these components; and impairment identification and
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`mitigation. Fiber systems efforts include; advanced modulation formats including
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`PAM 4 and QAM, demodulation algorithms, equalization, AtoD and DtoAs and
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`optical amplifiers. I am the founder and director of the Georgia Tech Terabit
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`Optical Networking Consortium: An industry-academia collaboration formed to
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`
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`investigate high-capacity optical systems.
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`10.
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`I led a team that developed an open source, density-based topology
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`optimization technique that robustly designs compact, broadband integrated
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`photonic devices for different semiconductor process nodes. These chips have been
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`fabricated on a number of commercial semiconductor foundries.
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`11.
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`I have published more than 360 peer-reviewed papers in journals and
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`conference proceedings and hold 17 patents in the fields of photonic devices,
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`communications and signal processing. Georgia Tech has licensed multiple
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`inventions to Industry.
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`12.
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`I regularly teach undergraduate and graduate level classes on optical
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`communication systems and components. I also regularly make presentations on
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`optical communication technologies, including DWDM systems, modulation,
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`optical transmission, impairment mitigation and signal processing.
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`13. Additional information concerning my background, qualifications,
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`publications, conferences, honors, and awards are described in my Curriculum
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`Vitae, a copy of which is attached with this declaration as Exhibit A.
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`14.
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`I am being compensated for my time spent on this matter at my usual
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`and customary rate of $575/hour, plus reasonable expenses. My rate is $650/hour
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`when travel is involved. My compensation is not related to the outcome of this
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`
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`action, and I have no financial interest in this case.
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`II. Materials Considered
`15. My technical review, analysis, insights, and opinions are based on my
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`experience and other qualifications discussed above, as well as my study of
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`relevant materials.
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`16.
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`I have reviewed and am familiar with the patent specification, claims,
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`and prosecution history for each of the ‘423 patent, ‘422 patent, ’542 patent, and
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`‘107 patent. I have been asked to assume for the purpose of this analysis that the
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`priority date of these patents is October 3, 2017, which is the date of Provisional
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`Application No. 62/567,339.
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`17.
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`I have reviewed and am familiar with each exhibit cited herein (see
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`the chart at the end). I confirm that to the best of my knowledge the accompanying
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`exhibits are true and accurate copies of what they purport to be, and that an expert
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`in the field would reasonably rely on them to formulate opinions such as those set
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`forth in this declaration.
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`III. Relevant Legal Principles
`Person of Ordinary Skill in the Art
`A.
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`18.
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`I have been informed that a person of ordinary skill in the art
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`(“POSITA”) is a person who is presumed to have complete knowledge of the
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`relevant prior art and who would think along the lines of conventional wisdom in
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`that art. The person of ordinary skill in the art has ordinary creativity and does not
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`have extraordinary skill, e.g., is not an expert. I have been informed that factors to
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`consider in determining the level of ordinary skill in the art include the educational
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`level of workers in the field, the types of problems addressed in the art, prior-art
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`solutions to such problems, how quickly innovations are made, and the complexity
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`of the technology.
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`19. The ‘423 patent relates to fiber optic cassette systems. See EX1001
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`Title, Abstract, Field of the Invention, Background of the Invention. In view of the
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`factors mentioned above and the discussion of the technical background herein, it
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`is my opinion that a person of ordinary skill in the art of the ‘423 patent would
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`have a B.S. degree or equivalent in mechanical or electrical engineering or similar
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`fields, in addition to a minimum of two years of professional experience with or
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`graduate studies involving design, development, and/or utilization of optical
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`communication systems. I satisfied this level of ordinary skill in the art, including
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`as Patent Owner’s alleged priority date of 2017.
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`20. Throughout my declaration, even if I discuss my analysis in the
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`present tense, I am always making my determinations based on what a POSITA
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`would have known at the time of the invention.
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`I am aware that during claim construction briefing, Patent Owner has
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`
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`21.
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`produced the testimony of Dr. Charles Eldering in which opines that:
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`In my view, a person of ordinary skill in the art would have had at least
`a B.S. degree or equivalent in mechanical or electrical engineering or
`similar fields, in addition to a minimum of two years of professional
`experience with design, development, and/or utilization of
`communication products.
`I note that my articulation allows for relevant experience to have been gained
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`through graduate studies whereas Dr. Eldering’s articulation does not address
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`whether the “professional experience” could have been gained through
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`graduate studies. Nevertheless, to the extent there is any difference between
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`these two articulations, none of my opinions herein would change if I applied
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`the level of skill as articulated by Dr. Eldering. And I also satisfied Patent
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`Owner’s articulation of the level of ordinary skill in the art, including as Patent
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`Owner’s alleged priority date of 2017.
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`B. Claim Construction Standard
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`22.
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`I have been instructed by counsel on the law regarding claim
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`construction and patent claims, and understand that a patent may include two types
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`of claims—independent claims and dependent claims. An independent claim stands
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`alone and includes only the features it recites. A dependent claim can depend from
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`an independent claim or another dependent claim. I understand that a dependent
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`claim includes all the features that it recites in addition to all the features recited in
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`
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`the claim from which it depends.
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`23.
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`In an inter partes review proceeding such as this, I understand the
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`claim of a patent shall be construed using the same claim construction standard that
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`would be used to construe the claim in a civil action. I understand this includes
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`construing the claim in accordance with the ordinary and customary meaning of
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`such claim as understood by one of ordinary skill in the art and the prosecution
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`history pertaining to the patent. Any prior claim construction determination
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`concerning a term of the claim in a civil action, or a proceeding before the
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`International Trade Commission, that is timely made of record in the inter partes
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`review proceeding will be considered by the PTAB.
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`24.
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`I understand an appropriate dictionary definition may provide
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`evidence explaining the ordinary and customary meaning as would be understood
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`by a person of ordinary skill in the art.
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`25.
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`I understand that if there are specific statements in the specification
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`that define the invention with respect to a term, those statements are strong
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`evidence of a definition for the term.
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`C. Anticipation
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`26.
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`In this declaration I have been instructed by counsel on the law
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`regarding anticipation and obviousness. I understand that a claim is invalid and
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`unpatentable if it is anticipated or obvious. My opinions here relate to both
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`
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`anticipation and obviousness as detailed below.
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`27.
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`I understand that anticipation of a claim requires that every element of
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`a claim is expressly or inherently disclosed in a single prior art reference. I
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`understand that an anticipating reference need not use the exact terms of the
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`claims, but must describe the patented subject matter with sufficient clarity and
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`detail to establish that the claimed subject matter existed in the prior art and that
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`such existence would be recognized by persons of ordinary skill in the field of the
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`purported invention. I also understand that an anticipating reference must enable
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`one of ordinary skill in the art to reduce the purported invention to practice without
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`undue experimentation.
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`D. Obviousness
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`28.
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`I understand that a patent claim is also invalid if the claims would
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`have been obvious to a POSITA at the time of the invention. I understand that the
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`obviousness inquiry should not be done in hindsight but rather from the
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`perspective of a POSITA as of the time of the invention.
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`29.
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`I understand that to obtain a patent, the claims must have been, as of
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`the time of the invention, nonobvious in view of the prior art. I understand that an
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`obviousness analysis involves comparing a claim to the prior art to determine
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`whether the claimed invention would have been obvious to a POSITA at the time
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`of the invention in view of the prior art and in light of the general knowledge in the
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`
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`art as a whole. I also understand that obviousness is ultimately a legal conclusion
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`based on underlying facts of four general types, all of which must be considered:
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`(1) the scope and content of the prior art;
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`(2) the level of ordinary skill in the art;
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`(3) the differences between the claimed invention and the prior art;
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`and
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`(4) any objective indicia of non-obviousness.
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`30.
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`I understand that a claim is obvious when the differences between the
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`subject matter sought to be patented and the prior art are such that the subject
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`matter as a whole would have been obvious to a POSITA at the time of the
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`invention.
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`31.
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`I understand that certain objective indicia can be important evidence
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`regarding whether a patent is obvious. Such indicia include: industry acceptance;
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`commercial success of products covered by the patent claims; long-felt need for
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`the invention; failed attempts by others to make the invention; copying of the
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`invention by others in the field; unexpected results achieved by the invention as
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`compared to the closest prior art; praise of the invention by the infringer or others
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`in the field; taking of licenses under the patent by others; expressions of surprise
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`by experts and those skilled in the art at making the invention; and the patentee
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`proceeded contrary to the accepted wisdom of the prior art. I understand that such
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`
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`evidence must have a nexus, or causal relationship to the elements of the claim. I
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`am unaware of any such objective considerations having a nexus to the claims at
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`issue in this proceeding.
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`32.
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`I understand that obviousness can be established by combining
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`multiple prior art references to meet each and every claim element, or by
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`modifying a single prior art reference. I also understand that to support a
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`combination of multiple prior art references or a modification of a single reference,
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`there must be a rationale explaining why a skilled artisan would combine or
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`modify the references in the manner claimed and how the proposed combination or
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`modification meets each and every claim element. But I also understand that a
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`proposed combination or modification of references can be susceptible to hindsight
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`bias. When it appears hindsight bias is being used, I understand the modification or
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`combination is not considered obvious.
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`33.
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`I understand that exemplary rationales that may support a conclusion
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`of obviousness include: combining or modifying prior art elements according to
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`known methods to yield predictable results; simple substitutions of one known
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`element for another to obtain predictable results; using a known technique to
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`improve similar devices in the same way; applying a known technique to a known
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`device ready for improvement to yield predicable results; choosing from a finite
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`number of identified, predicable solutions, with a reasonable expectation of
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`success; known work in one field of endeavor may prompt variations of it for use
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`in either the same field or a different one based on design incentives or other
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`market forces if the variations are predicable to one of ordinary skill in the art; and
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`some teaching, suggestion, or motivation in the prior art that would have led one of
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`ordinary skill to modify the prior art reference or to combine prior art teachings to
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`arrive at the claimed invention.
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`34.
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`I understand that teaching away, e.g., discouragement from making
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`the proposed modification, is strong evidence that the references are not
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`combinable. I also understand that a disclosure of more than one alternative does
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`not necessarily constitute a teaching away.
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`35.
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`I understand that the combination does not need to result in the most
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`desirable embodiment, but if the proposed combination does not have a reasonable
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`expectation of success at the time of the invention, a POSITA would not have had
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`an adequate teaching, suggestion, or motivation to combine the references.
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`36.
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`I understand that the test for obviousness is not whether the features of
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`a secondary reference may be bodily incorporated or physically combined into the
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`structure of the primary reference, but whether the claimed invention is rendered
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`obvious by the teachings of the references as a whole.
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`I understand that common sense and common knowledge have their
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`
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`37.
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`proper place in the obviousness inquiry if explained with sufficient reasoning. I
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`understand that resorting to common sense and common knowledge cannot be used
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`as a wholesale substitute for reasoned analysis and evidentiary support.
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`IV. Technology Background
`38. The technology in this petition is fiber optic cassette systems. These
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`systems are deployed in data rooms where high-capacity fiber optic cables need to
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`be distributed to many subscriber connections. The conventional elements are
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`cassettes, trays, and a case. The “Sedor” prior art reference, discussed during
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`prosecution, illustrates two conventional cassettes (30) on a tray (120):
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`EX1005, Fig. 8. Each cassette has ports (called adapters) on the front and rear.
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`
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`Cassettes can have different types of adapters, typically, “LC” adapters on the front
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`and “MPO” (multi-fiber push on) adapters on the rear.
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`39. LC adapters often take the form of a “quad” LC adapter with four
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`receptacles to connect four individual LC connectorized fibers:
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`“Quad” LC adapter
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`LC connector on a cable
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`
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`“LC” connectors (Lucent Connector) are a standard connector for a single optical
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`fiber. Connectorized fibers are often paired such that transmitted signals and
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`received signals are managed together. The optical fiber, above, with the LC
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`connector would have one “core” that light propagates down:
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`Optical fiber is comprised of a core and a cladding typically made of glass with the
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`properties such that light is confined in the core. Various coatings are used to
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`protect the fiber and prevent intrusion of water and other elements.
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`40. MPO adapters consists of two opposed multi-fiber connector
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`receiving receptacles that enable the connection of two MPO connectorized fibers
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`with high alignment:
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`MPO adapters
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`In Support of Inter Partes Review
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`MPO connectors on a cable
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`MPO connectors (Multiple-Fiber Push-On) are a standard multi-fiber connector
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`(e.g., 12 fibers) that enables the simultaneous connection of these multiple fibers.
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`The optical fiber with the MPO connectors would contain many optical fibers like
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`this:
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`Ribbon fiber optic cable is formed by first making individual separate fibers and
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`then arranging them tightly together and bonding them into a single structure.
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`Fibers are usually placed side by side to form a flat ribbon.
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`41. The fiber optic cassettes enable the operator to plug a high-capacity
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`fiber optic cable with an MPO connector for multiple fibers (e.g., 12 fibers) into
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`the rear MPO adapter and plug many single fiber optic cables with LC connectors
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`into the LC adapters on the front. Fibers inside the cassette connect the front and
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`rear ports. Thus, the high-capacity cable can serve multiple subscriber connections
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`in the front. Other configurations of LC and MPO connectors on a cassette are
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`feasible.
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`42. The trays of cassettes are stored in a protective case. Sedor illustrates
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`a conventional case:
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`The trays slide in and out of the case to allow the operator to insert change or
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`remove cassettes and plug in or remove fiber cables. The operator typically
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`mounts the case in rack (using the side brackets) and multiple cases can be stacked
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`vertically one on top of the other in the rack. Thus, a single rack may support
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`thousands of connections.
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`V. Ground 1: The challenged claims are all anticipated by Fukui or
`obvious based on Fukui itself
`43. The challenged claims are all anticipated by Fukui or obvious based
`
`on Fukui itself. The challenged claims are Claims 1-30.
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`In Support of Inter Partes Review
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`A.
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`Independent Claim 1
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`1.
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`Preamble
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`44. The preamble of claim 1 recites: “A tray for providing a plurality of
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`different modular fiber optic cassette configurations in a standard U-space fiber
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`optic management system comprising
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`“A tray…”
`45. Fukui discloses the preamble. Fukui’s tray is bottom panel 30e show
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`below in orange:
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`19
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`In Support of Inter Partes Review
`of U.S. Patent No. 11,740,423
`Like the tray in the challenged patent, Fukui’s panel 30e is a flat panel upon which
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`the Fukui’s cassettes (e.g., modules 10, 20) are arranged. EX1004, 8:30-32 (“The
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`plurality of conversion modules 10 are arranged on the bottom panel 30e inside the
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`base member 30 along an X direction (first direction).”). Fukui’s bottom panel has
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`twelve areas (32) for arranging Fukui’s modules. 8:45-51.
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`EX1004, Fig. 9. Figure 8 shows the modules (10) arranged on these areas:
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`20
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`In Support of Inter Partes Review
`of U.S. Patent No. 11,740,423
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`EX1004, Fig. 8.
`46. Fukui’s modules (e.g., 10 and 20) are examples of “fiber optic
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`cassettes” as recited in the preamble and claim. Figures 1 and 4 illustrate Fukui’s
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`module 10:
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`21
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`In Support of Inter Partes Review
`of U.S. Patent No. 11,740,423
`Like the cassettes in the challenged patents, Fukui’s modules have LC adapters
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`(13) on the front and an MPO1 adapter (12) on the rear. EX1004, 5:12-42. Thus,
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`the user of the system can plug a multi-fiber fiber optic cable into the rear and
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`individual fiber cables into the front. Figure 8 shows a multi-core fiber optic cable
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`(F2) going into the rear of each module:
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`Figure 4 shows individual “optical fibers” (F1) going into the front of the module
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`(where an LC connector would connect to the fiber):
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`1 MPO refers to a multi-fiber push on connector.
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`22
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`In Support of Inter Partes Review
`of U.S. Patent No. 11,740,423
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`EX1004, 6:42-48.
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`47. Fukui’s module 10 is a “conversion” module because it converts from
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`multi-core connector in the rear (e.g., MPO connector) to single core connectors in
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`the front (e.g., LC connectors). The “core” here refers to a fiber. A fiber optic
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`cable can have either one fiber (core) or multiple fibers (cores). Here is an
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`example of how the module is used. The user connects a large capacity fiber optic
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`cable with 12 cores (fibers) to the back of the module by plugging the MPO
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`connector on the end of the cable into the MPO adapter on the back of the module
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`10. Each of the twelve fibers is broken out inside the module and is connected to a
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`separate LC adapter on the front of the module. The user can then connect twelve
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`different smaller capacity fiber optic cables each with one core (fiber) to the front
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`of the module by plugging the LC connectors on the end of the cable into the LC
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`adapter on the front of the module.
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`23
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`In Support of Inter Partes Review
`of U.S. Patent No. 11,740,423
`48. Fukui discloses that the modules can have different sizes. For
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`example, Fukui teaches that two modules 10 can be coupled together to form
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`module 20 (i.e., a double size):
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`EX1004, Fig. 5, 7:23-67. Like module 10, module 20 has an MPO adapter (12) in
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`the rear and LC adapters (13) in the front. Id. Module 20 accommodates double
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`the cores/fibers, i.e., it accepts an MPO connector in the rear with 24 cores/fibers
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`and accepts 24 LC connectors in the front. EX1004, 7:65-67 (“24 cores”).
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`49. Fukui also discloses larger sizes of modules. Fukui broadly teaches
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`there can be a “plurality of coupled unit modules,” i.e., two or more modules 10
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`can be coupled together. EX1004, 8:2-3 (“plurality of coupled unit modules”),
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`24
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`In Support of Inter Partes Review
`of U.S. Patent No. 11,740,423
`7:18 (“a plurality thereof coupled to each other”). When more than two modules
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`
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`10 are coupled together, larger sizes result. Fukui explains that one module 10
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`supports 12 cores and two coupled modules 20 support 24 cores. Fukui teaches
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`you can continue this expansion further based on the “number of coupled unit
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`modules” and gives the further examples of expanding to 36 and 48 cores:
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`In other words, in this example, the number of cores of the multi-core
`optical connector 16 can be expanded to 24 cores. Further, the
`expansion can be easily made by the number of the coupled unit
`modules such as 36 cores and 48 cores. Additionally, a plurality of
`coupled unit modules can be dealt with as one body. For this reason, in
`the expansion, it is not necessary to prepare different shape unit
`modules, so long as the required number of the same shape unit
`modules are prepared.
`EX1004, 7:65-8:6. “36 cores” is the result of coupling three of the 12 core
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`modules together into one triple module (i.e., “the number of coupled unit
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`modules” is three). “48 cores” is the result of coupling four of the 12 core modules
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`together into one q