throbber
Defendants’
`Defendants’
`Exhibit P
`Exhibit P
`
`CommScopeEx. 1043
`
`

`

`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`BELDEN CANADA ULC,
`
`Plaintiff,
`
`v.
`
`COMMSCOPE, INC., COMMSCOPE, INC.
`OF NORTH CAROLINA, and
`COMMSCOPE TECHNOLOGIES, LLC,
`
`Defendants.
`
`
`
`
`
`
`
`C.A. No. 1:23-CV-00810-RGA
`
`
`
`
`Expert Declaration of Dr. Stephen Ralph
`
`
`
`
`
`
`
`
`
`
`

`

`I, Stephen E. Ralph, Ph.D., declare as follows.
`
`I.
`
`Introduction
`
`A.
`
`1.
`
`Engagement
`
`I have been retained by CommScope to provide expert opinions in connection
`
`Belden’s U.S. Patent Nos. (i) 10,795,107, (ii) 11,435,542, (iii) 11,656,422, (iv) 11,740,423.
`
`2.
`
`I have been asked to provide my independent review, analysis, insights, and
`
`opinions regarding the meaning of certain phrases in these patents. The statements made herein
`
`are based on my own knowledge and opinions.
`
`B.
`
`3.
`
`Qualifications
`
`I am a professor of Electrical Engineering at the Georgia Institute of Technology. I
`
`received my Ph.D. (1988) in Electrical Engineering from Cornell University. I received my
`
`Bachelor degree (1980) in Electrical Engineering from Georgia Institute of Technology.
`
`4.
`
`At Georgia Tech, I hold the Glen Robinson Chair in Electro-Optics and I am a
`
`Principal Research Scientist at the Georgia Tech Research Institute, the applied research unit of
`
`the Georgia Institute of Technology.
`
`5.
`
`I was a Postdoctoral Member of the Technical Staff at AT&T Bell Laboratories
`
`and a Visiting Scientist at IBM T. J. Watson Research Laboratory. I was a founding member of
`
`Quellan, Inc., a startup focused on developing electronic signal processing and higher order
`
`modulation formats for fiber optic communication systems. Quellan was purchased by Intersil
`
`where the technologies are applied to a variety of high-speed links.
`
`6.
`
`I am currently the Director of the Georgia Electronic Design Center at Georgia
`
`Tech. The GEDC is a cross-disciplinary Electronics and Photonics center of the Georgia
`
`Institute of Technology focused on the synergistic development of high-speed photonics,
`
`1
`
`
`

`

`
`
`electronics, and signal processing. The center includes more than 10 active faculty, over 140
`
`graduate students and an annual research expenditure of ~$8M. The GEDC is one of the world’s
`
`largest university-based research centers of its kind.
`
`7.
`
`I am the Director of a National Science Foundation (NSF) multi–University
`
`Center with lead site at Georgia Tech known as EPICA: Electronic and Photonic Integrated
`
`Circuits for Aerospace. The center is an NSF Industry University Collaborative Research Center
`
`(IUCRC) and is focused on developing and testing integrated photonics and electronics for harsh
`
`environments. IUCRCs are unlike most NSF funding efforts in that they are industry driven.
`
`EPICA has more than 20 Industry members and affiliates.
`
`8.
`
`I am actively involved as a reviewer, and committee member of various journals
`
`and conferences and have extensive experience with various international standards groups
`
`focused on electronic and photonic components and high-capacity fiber optic systems. I am a
`
`past Associate Editor for optoelectronic devices for the IEEE Journal Transactions on Electronic
`
`Devices and I am now the Treasurer of the IEEE Photonics Society (January 2023 through
`
`December 2025), and a Fellow of the OSA (formerly the Optical Society of America).
`
`9.
`
`My research efforts currently focus on integrated photonics and electronics with
`
`application to high capacity communication systems including DWDM fiber networks and
`
`optical interconnects, particularly the intersection of electronics, photonics and signal processing;
`
`communication component and system design, optimization and simulations for photonic
`
`components including lasers, modulators and direct detect and coherent receivers; the
`
`integration, assembly and packaging of these components; and impairment identification and
`
`mitigation. Fiber systems efforts include; advanced modulation formats including PAM 4 and
`
`QAM, demodulation algorithms, equalization, AtoD and DtoAs and optical amplifiers. I am the
`
`2
`
`

`

`
`
`founder and director of the Georgia Tech Terabit Optical Networking Consortium: An industry-
`
`academia collaboration formed to investigate high-capacity optical systems.
`
`10.
`
`I led a team that developed an open source, density-based topology optimization
`
`technique that robustly designs compact, broadband integrated photonic devices for different
`
`semiconductor process nodes. These chips have been fabricated on a number of commercial
`
`semiconductor foundries.
`
`11.
`
`I have published more than 360 peer-reviewed papers in journals and conference
`
`proceedings and hold 17 patents in the fields of photonic devices, communications and signal
`
`processing. Georgia Tech has licensed multiple inventions to Industry.
`
`12.
`
`I regularly teach undergraduate and graduate level classes on optical
`
`communication systems and components. I also regularly make presentations on optical
`
`communication technologies, including DWDM systems, modulation, optical transmission,
`
`impairment mitigation and signal processing.
`
`13.
`
`Additional information concerning my background, qualifications, publications,
`
`conferences, honors, and awards are described in my Curriculum Vitae, a copy of which is
`
`attached with this declaration as Exhibit A.
`
`14.
`
`I am being compensated for my time spent on this matter at my usual and
`
`customary rate of $575/hour, plus reasonable expenses. My rate is $650/hour when travel is
`
`involved. My compensation is not related to the outcome of this action, and I have no financial
`
`interest in this case.
`
`II.
`
`Materials Considered
`
`15. My technical review, analysis, insights, and opinions are based on my experience
`
`and other qualifications discussed above, as well as my study of relevant materials.
`
`3
`
`

`

`
`
`16.
`
`I have reviewed and am familiar with the patent specification, claims, and
`
`prosecution history for each of the ‘423 patent, ‘422 patent, ’542 patent, and ‘107 patent. I have
`
`been asked to assume for the purpose of this analysis that the priority date of these patents is
`
`October 3, 2017, which is the date of Provisional Application No. 62/567,339. I have reviewed
`
`and am familiar with the other materials discussed and cited herein.
`
`III.
`
`Relevant Legal Principles
`
`A.
`
`17.
`
`Person of Ordinary Skill in the Art
`
`I have been informed that a person of ordinary skill in the art (“POSITA”) is a
`
`person who is presumed to have complete knowledge of the relevant prior art and who would
`
`think along the lines of conventional wisdom in that art. The person of ordinary skill in the art
`
`has ordinary creativity and does not have extraordinary skill, e.g., is not an expert. I have been
`
`informed that factors to consider in determining the level of ordinary skill in the art include the
`
`educational level of workers in the field, the types of problems addressed in the art, prior-art
`
`solutions to such problems, how quickly innovations are made, and the complexity of the
`
`technology.
`
`18.
`
`The patents-in-suit all relate to fiber optic cassette systems. See, e.g., ‘107 patent
`
`at Title, Abstract, Field of the Invention, Background of the Invention. In view of the factors
`
`mentioned above and the discussion of the technical background herein, it is my opinion that a
`
`person of ordinary skill in the art of the patents-in-suit would have 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 or graduate studies involving design, development, and/or
`
`utilization of optical communication systems. I satisfied this level of ordinary skill in the art,
`
`including as to Belden’s alleged priority date of 2017.
`
`4
`
`

`

`
`
`19.
`
`Throughout my declaration, even if I discuss my analysis in the present tense, I
`
`am always making my determinations based on what a POSITA would have known at the time of
`
`the invention.
`
`20.
`
`I am aware that during claim construction briefing, Belden has produced the
`
`testimony of Dr. Charles Eldering in which he opines that:
`
`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 through
`
`graduate studies whereas Dr. Eldering’s articulation does not address whether the
`
`“professional experience” could have been gained through graduate studies. Nevertheless,
`
`to the extent there is any difference between these two articulations, none of my opinions
`
`herein would change if I applied the level of skill as articulated by Dr. Eldering. And I also
`
`satisfied Belden’s articulation of the level of ordinary skill in the art, including as Belden’s
`
`alleged priority date of 2017.
`
`B.
`
`21.
`
`Claim Construction Standard
`
`I have been instructed by counsel on the law regarding claim construction and
`
`patent claims, and understand that a patent may include two types of claims—independent claims
`
`and dependent claims. An independent claim stands alone and includes only the features it
`
`recites. A dependent claim can depend from an independent claim or another dependent claim. I
`
`understand that a dependent claim includes all the features that it recites in addition to all the
`
`features recited in the claim from which it depends.
`
`5
`
`

`

`
`
`22.
`
`In a district court proceeding such as this, I understand the claim of a patent
`
`should be generally given their ordinary and customary meaning to a POSITA at the time of the
`
`invention when read in the context of the intrinsic record.
`
`23.
`
`I understand that the intrinsic record includes the claim language, specification,
`
`and prosecution history.
`
`24.
`
`I understand an appropriate dictionary definition may provide evidence explaining
`
`the ordinary and customary meaning as would be understood by a person of ordinary skill in the
`
`art.
`
`25.
`
`I understand that if there are specific statements in the specification that define the
`
`invention with respect to a term, those statements are strong evidence of a definition for the term.
`
`C.
`
`26.
`
`27.
`
`Indefiniteness
`
`I understand that each claim in an issued patent is presumed valid.
`
`I understand, however, that a claim can be invalid for a number of reasons,
`
`including because it is “indefinite.”
`
`28.
`
`Because a patent is presumed valid, I understand the burden is on the challenger
`
`to show the claim is invalid as indefinite. I understand the standard of proof is “clear and
`
`convincing” evidence.
`
`29.
`
`I understand the test for indefiniteness is as follows. I understand that a claim is
`
`invalid as “indefinite” if the claim, read in light of the specification delineating the patent, and
`
`the prosecution history, fails to inform, with “reasonable certainty,” those skilled in the art about
`
`the scope of the invention. I understand it can also be proper to consider the background
`
`knowledge of a POSITA.
`
`6
`
`

`

`
`
`IV.
`
`Disputed Terms
`
`A.
`
`30.
`
`“standard width unit” and “standard one width (1W) unit”
`
`The claims of the ‘107, ‘542, and ‘422 patents recite a “standard width unit” and
`
`the claims of the ‘423 patent recite a “standard one width (1W) unit.”
`
`31.
`
`The term “standard” for a value has a well-known meaning in this art. It refers to
`
`a value that is standardized in the industry. Interoperability is important. By this I mean that it is
`
`important that components from different manufacturers are able to be used together in
`
`combination. The telecommunications industry long ago recognized, for example, that it is
`
`highly desirable for a panel from one manufacturer will fit into a rack made by a different
`
`manufacturer. Likewise, it is highly desirable for a connector from one manufacturer to fit and
`
`mate with an adapter made by a different manufacturer. Interoperability is, therefore, a major
`
`motivation for the industry to agree upon standardized dimensions and features of
`
`communications components and equipment. Standards are generated and typically published so
`
`as to be available to multiple manufacturers. As a result, there are a large number of published
`
`standards that define agreed upon standardized dimensions (e.g., the width, height) of
`
`components and other features for numerous components and systems within the telecom
`
`equipment industry.
`
`32.
`
`As one example, the Electronic Components Industry Association (EIA)
`
`published the EIA/ECA-310-E standard that standardized certain dimensions (e.g., the width,
`
`height) of cabinets, racks, and panels that are used, for example, for the fiber optic cassette
`
`systems discussed in the patents-in-suit. The EIA/ECA-310-E defines a unit (called U):
`
`7
`
`

`

`
`
`EIA/ECA-310-E at 2. Note that the unit is an actual specific value (44.45 millimeters).
`
`Panels are made and described as being multiples of this unit such as a 1U, 2U, or 3U panel:
`
`EIA/ECA-310-E at 5. The EIA/ECA-310-E also defines a number of other specific dimensions
`
`such as the inner width of the rack opening:
`
`8
`
`
`
`
`
`

`

`
`
`
`
`EIA/ECA-310-E at 4. The standard allows for three different actual values for this particular
`
`width dimension (450, 577, or 730 millimeters).
`
`33.
`
`As another example, the International Electrotechnical Commission (IEC)
`
`published an international standard IEC 61754-20 that standardized certain dimensions (e.g., the
`
`width, height) of LC connector components. For example, the standard describes the width of a
`
`quad LC adapter (see “GC”):
`
`
`
`9
`
`

`

`
`
`
`
`IEC 61754-20 at 25. Note that the value of GC is an actual specific width in the range of 25.6 –
`
`25.9 millimeters. The IEC also defines the technology footprint for the SC Duplex and MPO
`
`adapters as actual widths.
`
`B.
`
`“a width of the front edge is substantially evenly divisible by said standard
`width unit”
`
`34.
`
`The ‘107 and ‘542 patents both recite the limitation that “a width of the front edge
`
`is substantially evenly divisible by said standard width unit.” In my opinion, the scope of the
`
`phrase lacks reasonable certainty and lacks an objective boundary. Therefore, in my opinion, the
`
`claims that recite this limitation are invalid as indefinite.
`
`Background
`
`35.
`
`The term “divisible” refers to division, which is a mathematical operation (e.g., 12
`
`/ 4).
`
`36.
`
`The term “evenly divisible” refers to a division operation where there is no
`
`remainder. For example, 12 / 4 = 3 with no remainder. Thus, 12 is “evenly divisible” by four.
`
`By contrast, 13 / 4 = 3 with a remainder of 1. Thus, 13 is not “evenly divisible” by four.
`
`10
`
`

`

`
`
`37.
`
`The term “substantially evenly divisible” suggests some remainder is permissible.
`
`But the immediate question to a POSITA is: how much remainder is permissible? Said another
`
`way, when is the remainder small enough such that the result is considered “substantially evenly
`
`divisible” and when is the remainder large enough that that result is no longer “substantially
`
`evenly divisible.” A POSITA would wonder what the boundary is between substantially evenly
`
`divisible and not substantially evenly divisible.
`
`Claim language
`
`38.
`
`The claim language itself does not provide reasonable certainty or an objective
`
`boundary for the scope of the phrase “a width of the front edge is substantially evenly divisible
`
`by said standard width unit.”
`
`39.
`
`The recited phrase appears first in claim 8 of the ‘107 and ‘542 patents. Here is
`
`the full claim language for claim 8 of both patents:
`
`Claim 8 of the ‘107 patent
`8. A method for organising a tray comprising a front edge in a fiber optic interconnect system,
`the method comprising:
`
`defining a standard width unit wherein a width of the front edge is substantially evenly
`divisible by said standard width unit;
`
`selecting a plurality of cassettes for installation on the tray from a set of cassettes having a
`plurality of different widths, wherein each of said different widths is evenly divisible by said
`standard width unit; and
`
`releasably securing said selected cassettes along the front edge of the tray;
`
`wherein when arranged on the tray each of said selected cassettes touches at least one other
`selected cassette.
`
`Claim 8 of the ‘542 patent
`8. A method for organising a tray comprising a front edge in a fiber optic interconnect system,
`the method comprising:
`
`defining a standard width unit wherein a width of the front edge is substantially evenly
`divisible by said standard width unit;
`
`11
`
`

`

`
`
`
`selecting a plurality of cassettes for installation on the tray from a set of cassettes having a
`plurality of different widths as measured between respective outer side edges thereof, wherein
`each of said different widths is evenly divisible by said standard width unit; and
`
`releasably securing said selected cassettes along the front edge of the tray;
`
`wherein when arranged on the tray an outer side edge of each of said selected cassettes is
`directly adjacent an outer side edge of at least one other selected cassette.
`The ‘107 and ‘542 patents also recite the phrase in dependent claims.
`40.
`
`Claim 8 of the ‘107 patent
`12. The method for organising a tray of claim 8, wherein the width of the front edge is
`substantially evenly divisible by a maximum of twelve (12) of said standard width units.
`
`Claim 8 of the ‘542 patent
`13. The method for organising a tray of claim 8, wherein the width of the front edge is
`substantially evenly divisible by a maximum of twelve (12) of said standard width units.
`
`
`41.
`
`If you read the surrounding claim language, the claim does not explain what
`
`amount of remainder is permissible. The claim language does not provide a quantitative
`
`boundary for the scope of permissible remainders. For example, the claim language does not
`
`recite substantially evenly divisible such that the remainder is less than… The claim language
`
`also does not provide a qualitative boundary for the scope of permissible remainders. For
`
`example, the claim language does not recite substantially evenly divisible such that the front
`
`edge achieves a certain result, property, function, or benefit.
`
`Specification
`
`42.
`
`The specification does not provide reasonable certainty or an objective boundary
`
`for the scope of the phrase “a width of the front edge is substantially evenly divisible by said
`
`standard width unit.”
`
`43.
`
`The specification (a) never recites (much less explains) the phrase “substantially
`
`evenly divisible and (b) does not recite (much less explain) any division operation for the front
`
`12
`
`

`

`
`
`edge of the tray compared to the standard width unit, other than when simply quoting the claim
`
`language in the summary section.
`
`44.
`
`There is no discussion in the specification of the scope of permissible remainders.
`
`There is no discussion of remainders being small enough vs. too big. There is no compare-and-
`
`contrast example in the specification. For example, there is no example in the specification that
`
`explains (a) this exemplary front edge is substantially evenly divisible because the remainder is
`
`this amount and (b) this exemplary front edge is not substantially evenly divisible because the
`
`remainder is this amount.
`
`Prosecution history
`
`45.
`
`The prosecution history does not provide reasonable certainty or an objective
`
`boundary for the scope of the phrase “a width of the front edge is substantially evenly divisible
`
`by said standard width unit.” Belden did not further explain the scope of this phrase during the
`
`prosecution. There is no discussion in the prosecution history of the scope of permissible
`
`remainders. There is no discussion of remainders being small enough vs. too big.
`
`General knowledge in the art
`
`46.
`
`The general knowledge in the art also does not provide reasonable certainty or an
`
`objective boundary for the scope of the phrase “a width of the front edge is substantially evenly
`
`divisible by said standard width unit.” Outside these patents, I have never encountered this
`
`phrase.
`
`47.
`
`I did a general patent search for the phrase “substantially evenly divisible” in this
`
`art and did not locate any other patent explaining the scope of this term outside the patents-in-
`
`suit. None of the prior art listed on the patents-in-suit recite or explain the scope of the phrase
`
`“substantially evenly divisible.”
`
`13
`
`

`

`
`
`48.
`
`I also considered industry standards. I am not aware, however, of any standard in
`
`the art that explains how to judge whether a remainder is “substantially evenly divisible.” There
`
`are many standards in the art, but none of them discuss the claimed phrase or the scope of phrase
`
`substantially evenly divisible to my knowledge. As one example, there is an industry standard
`
`for the racks (EIA/ECA-310-E). But the standard never uses the phrase substantially evenly
`
`divisible or contains any discussion whether a remainder in this art from a division operation is
`
`or is not “substantial.” As another example, there is industry standard for the LC connectors and
`
`adapters (IEC 61754-20). But, again, the standard never uses the phrase substantially evenly
`
`divisible or contains any discussion whether a remainder in this art from a division operation is
`
`or is not “substantial.”
`
`49.
`
`I also considered technical and general purpose definitions. I am not aware,
`
`however, of any dictionary definition that provides certainty or an objective boundary for the
`
`phrase “substantially evenly divisible.”
`
`50.
`
`The general knowledge in the art also does not provide a known objective
`
`boundary for the scope of permissible remainders for the phrase “a width of the front edge is
`
`substantially evenly divisible by said standard width unit” or “substantially evenly divisible” by
`
`itself).
`
`Belden’s construction
`
`51.
`
`I understand that Belden has proposed a construction for the disputed term as
`
`follows:
`
`Belden’s proposed construction
`Not indefinite –
`“a width of the front edge of the tray is evenly divisible by the unit of width that
`accommodates a single receptacle module, such as a LC Quad (SC Duplex) technology
`footprint comprising four connectors.
`
`
`14
`
`

`

`
`
`‘Substantially,’ in this context, means that there may be some excess space between a cassette
`and an end of the front edge of the tray.”
`
`
`52.
`
`First, even under Belden’s own construction, the scope of claim term still lacks
`
`reasonable certainty and an objective boundary. Belden’s construction vaguely states that there
`
`may be “some” excess space between a cassette and an end of the front edge of the tray. The
`
`ordinary meaning of “some” is an indeterminate amount. It leaves unanswered the follow-up
`
`question of how much excess space? What is the objective boundary for when the excess is
`
`small enough to count as “some” without reading on any and all remainder amounts? Belden’s
`
`recitation of “some” excess space lacks reasonable certainty and an objective boundary.
`
`53.
`
`Second, Belden’s construction is not supported by the intrinsic record. Claim
`
`language. The claim never recites “excess space” or focuses on a measurement “between a
`
`cassette and an end of the front edge.” Prosecution history. The prosecution history also never
`
`discusses a measurement “between a cassette and an end of the front edge” or whether there is
`
`excess space there. Specification. Belden apparently extrapolates its construction from figures
`
`of the preferred embodiment in the specification. But the specification never discusses a
`
`measurement “between a cassette and an end of the front edge” much less indicates this is the
`
`measurement to understand the scope of “substantially evenly divisible.”
`
`54.
`
`Third, Belden’s construction also cannot be right because it leads to inconsistent
`
`results. Consider the two examples:
`
`15
`
`

`

`
`
`
`
`“some” excess space at end
`
`“some” excess space at end
`
`4st
`a
`ae
`example Ieee Eee Ee
`
`
`
`VA,
`
`rs
`oS
`be
`See) (ee ee ee 9
`
`
`
`same excess space but in the middle
`
`The red lines represent the front edge of two trays, and the black boxes represent cassettes
`
`arranged on the trays. Under Belden’s construction, the first example infringes but the second
`
`example does not even though the width of the front edge (red) remains exactly the same and the
`
`“substantially evenly divisible” remainder is the same. That makes no sense to me.
`
`cmmion
`
`£8 fg B02 Agha Tape
`
`
`
`Dr. Stephen E. Ralph
`
`16
`
`
`
`
`
`

`

`
`
`
`
`Exhibit A
`Exhibit A
`
`Page 19
`
`CommScopeEx. 1043
`
`Exhibit A
`
`

`

`
`S T E P H E N E . R A L P H
`
`Georgia Institute of Technology
`Professor
`School of Electrical and Computer Engineering
`July 2024
`
`
`I. Earned Degrees
`
`
` Graduate
`
`
`
` Undergraduate
`
`
`
`
`Cornell University, Ithaca, NY
`School of Electrical Engineering
`Ph.D.; minor: Physics
`
`Georgia Institute of Technology, Atlanta, GA
`Bachelor of Electrical Engineering
`With highest honor
`
`1981-1988
`
`1976-1980
`
`II. Employment
`
`Full Professor, Glen Robinson Chair in Electro-Optics, Georgia Institute of Technology 2020-present
`Principal Research Scientist, Georgia Tech Research Institute
`2020-present
`Director, Georgia Electronic Design Center
`2011-present
`Full Professor, Georgia Institute of Technology
`2007-2020
`Director, Optical Technologies, Quellan Inc.
`2001-2004
`Associate Professor, Georgia Institute of Technology, GA
`1998-2007
`Assistant Professor, Emory University, GA
`1992-1998
`Visiting Scientist, IBM Watson Research Center, Yorktown Heights, NY
`1990-1992
`Post-Doctoral Research, AT&T Bell Laboratories, Murray Hill, NJ
`1987-1990
`Graduate Research Assistant, Cornell University, Ithaca, NY
`1981-1987
`Design Engineer, Harris Corporation, Melbourne, FL
`1980-1981
`
`
`III. Honors and Awards
`
`
`Glen Robinson Chair in Electro-Optics, January 2020, “in recognition of your significant
`contributions to photonics technologies ... and demonstrated skills working across institutional
`boundaries.” Glen Robinson was a pioneer in satellite technology and a founder of Scientific Atlanta
`now part of Cisco.
`
`Principal Research Scientist and Joint Appointment at the Georgia Tech Research Institute,
`January 2020. GTRI is the applied research division of the Georgia Institute of Technology.
`
`Elected to IEEE Photonics Society Board of Governors (term 2019 to 2022)
`
`
`
`
`

`

`
`Fellow of the Optical Society of America (OSA)
`
`Plenary Talk “Short Reach Optical Interconnects,” “IEEE Components Packaging and
`Manufacturing Society symposium,” Kyoto University, Kyoto Japan, November 20-22, 2017.
`
`Best Student Paper Award, SAIC Inc., 2000
`Todd Ulmer and S. E. Ralph “Resonant-cavity-enhanced surface-emitted second-harmonic generation
`for all-optical time division demultiplexing," April 26, 2000.
`
`21st International Conference on VLSI Design 2008, Best Paper: Arun K. Choudhury, S.
`Bandyopadhyay, P. Mandal (IIT, Kharagpur), S. E. Ralph (Georgia Tech) K. Pedrotti (UCSC)
`“Integrated TIA-Equalizer for High-Speed Optical Link,” Hyderabad, India, 4-8 January 2008.
`
`Finalist, Corning Outstanding Student Paper, Optical Fiber Conference 2011
`A. J. Stark, Y. Hsueh, S. Searcy, T. Detwiler, M. Filer, S. Tibuleac, G. Chang, and S. E. Ralph,
`"Scaling 112 Gb/s PDM-QPSK Hybrid Optical Networks," Optical Fiber Comm. Conf. (OFC), 6-10
`Mar. 2011.
`
`Finalist, Corning Outstanding Student Paper, Optical Fiber Conference 2016
`J. Lavrencik, S. Kota Pavan, A. Melgar and S. E. Ralph, “Direct Measurement of Transverse Mode
`Correlation and Fiber-Enhanced RIN through MMF using 850nm VCSELs,” Optical Fiber
`Communication Conference (OFC), Anaheim, CA, March 20-24, 2016.
`
`Finalist, Corning Outstanding Student Paper, Optical Fiber Conference 2020
`J. Lavrencik, A. Melgar and S. E. Ralph, “168Gbps PAM-4 Multimode Fiber Transmission through
`50m using 28GHz 850nm Multimode VCSELs,” Optical Fiber Communication Conference (OFC),
`San Diego, CA, March 8-12, 2020.
`
`
`
`IV. Research, Scholarship, and Creative Activities
`
`
`A. Areas of Current Research:
`
`
`
`.
`
`
`High-capacity optical systems, particularly the intersection of electronics, photonics and signal
`processing/machine learning and where integrated photonics is a key area of innovation. Dr. Ralph is
`a leading innovator in the use of Machine learning for performance monitoring and transceiver
`assessment and in the use of signal processing in power efficient optical interconnects. He has recently
`been awarded 5 patents in these areas.
`Dr. Ralph is the Director of the Georgia Electronic (and Photonic) Design Center a cross-disciplinary
`center of the Georgia Institute of Technology focused on the development of photonics, electronics, and
`the innovative use of machine learning to achieve breakthrough system performance. The primary
`mission is the rapid transition of GEDC innovations to deployed systems by the creation of strong
`industrial partnerships and consortia. With more than 12 active faculty, over 120 graduate students and
`annual research expenditure of ~$10M, the GEDC is one of the world’s largest university-based research
`centers of its kind.
`Dr. Ralph is PI on the recently awarded NSF IUCRC (Industry University Collaborative Research
`Centers). The effort is “Electronic-Photonic Integrated Circuits for Aerospace” (EPICA). EPICA’s
`objective is to enable the next wave of communications and sensing technologies for aerospace and
`space-borne platforms by designing architectures and validating the performance and reliability of
`advanced electronic-photonic integrated circuits, systems and packaging technologies. The center is
`now comprised of more than 12 companies and national labs.
` Page 2 of 40
`
`Stephen E. Ralph, July 2024
`
`

`

`Dr. Ralph has collaborated for many years with the Georgia Tech Research Institute in an effort to
`transition his innovations to DoD customers. He was a key contributor to the development of an
`integrated photonics effort within the Electro-Optical Systems Lab.
`
`B. Recent Principal Related Scientific/Technical Accomplishments:
`Dr. Ralph has widely published in peer-reviewed journals and at conferences and holds 16 patents in
`the fields of photonic devices and communications. He is actively involved as a reviewer, and
`committee member of various journals and conferences. He is an elected member of the Board of
`Governors for the IEEE Photonics Society and was recently a member of the technical advisory
`council for the IEEE Photonics Society. Dr. Ralph is a Fellow of the Optical Society of America.
`Dr. Ralph is founder and director of the Georgia Tech Terabit Optical Networking Consortium: An
`industry-academia collaboration formed to investigate deployment issues related to high-capacity
`optical systems. Dr. Ralph vision recognized that improvements in electronic processing speeds and
`photonic components are enabling the use of sophisticated signal processing. These modulation,
`equalization, forward error correction and impairment mitigation strategies transcend the optical and
`electronic components, influencing the entire signal path; hence systems must be jointly optimized
`across multiple technologies.
`
` 
`
`
`
`Integrated Photonics: Initiated comprehensive efforts to integrate signal processing and device
`efforts (photonic and electronic) and establish GaTech and GEDC as a leader in integrated
`photonics research; established multiple integrated photonics efforts; with GlobalFoundries, AIM
`photonics, Sandia National Labs, Harvard University, GTRI and IHP to design, fabricate and test
`high-speed optical systems. These efforts directly enabled GaTech’s successful NSF IUCRC
`program.
`- Developed an open source, density-based topology optimization framework that robustly
`designs compact, broadband photonic devices for different semiconductor process nodes.
`This effort is key to the GlobalFoundries partnership enabling Georgia Tech access to multiple
`MPW runs annually.
`- Dr. Ralph initiated GaTech’s efforts with AIM Photonics; a US Federally funded (USAF)
`Institute for Manufacturing Innovation focusing on integrated photonics. The “Analog RF
`Photonics” program team includes Raytheon, H

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