Case 2:17-cv-00140-RWS-RSP Document 66-3 Filed 02/23/18 Page 1 of 63 PageID #: 1608
`Case 2:17-cv-00140-RWS—RSP Document 66-3 Filed 02/23/18 Page 1 of 63 PageID #: 1608
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`EXHIBIT C
`EXHIBIT C
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`Case 2:17-cv-00140-RWS-RSP Document 66-3 Filed 02/23/18 Page 2 of 63 PageID #: 1609
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`CYWEE GROUP LTD.,
`
`Plaintiff
`
`v.
`
`SAMSUNG ELECTRONICS CO. LTD.
`AND SAMSUNG ELECTRONICS
`AMERICA, INC.,
`
`Defendants.
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
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`
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`NO. 2:17-CV-00140-RWS-RSP
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`I.
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`
`
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`DECLARATION OF M. RAY MERCER, PH.D.
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`INTRODUCTION
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`I, M. Ray Mercer, Ph.D. hereby declare as follows:
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`1.
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`My name is Melvin Ray Mercer. I am at least eighteen years of age. I reside in Dallas
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`in the State of Texas. I have personal knowledge of and am competent to testify as to the facts and
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`opinions herein.
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`2.
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`I have been retained by counsel for Defendants Samsung Electronics Corporation
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`Ltd. and Samsung Electronics America, Inc. (collectively “Samsung”) as an expert to analyze and
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`explain what certain claim terms in U.S. Patent Nos. 8,441,438 (“’438 Patent”) and 8,552,978 (“’978
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`Patent”) (collectively, “patents-in-suit”) would mean to a person of ordinary skill in the art
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`(“POSA”) at the time of the alleged inventions.
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`3.
`
`I have been informed that CyWee Group Ltd. (“CyWee”) is currently asserting
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`certain claims of the ’438 and ’978 Patents against Samsung in a litigation pending in the
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`United States District Court for the Eastern District of Texas.
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`4.
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`I am being compensated at my normal consulting rate of $650 per hour. I am being
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`separately reimbursed for any out-of-pocket expenses. My compensation does not depend in any
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`way on the outcome of this case, my particular testimony, or the opinions that I express.
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`5.
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`In rendering my opinions, I considered the items listed in Exhibit A, the items
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`discussed or listed herein, as well as my own experiences in the field.
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`II.
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`QUALIFICATIONS
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`6.
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`In this section of my declaration, I provide a brief summary of my qualifications to
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`act as an expert in this matter. A copy of my current Curriculum Vitae is attached as Exhibit B,
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`which contains a listing of my education and experience.
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`7.
`
`I have more than 47 years of dual industrial and academic experience in Electrical
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`Engineering and Computer Engineering. I received a B.S. in Electrical Engineering from Texas Tech
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`University in 1968, a Master of Science in Electrical Engineering from Stanford University in 1971,
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`and a Doctor of Philosophy in Electrical Engineering from The University of Texas at Austin in
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`1980. Further, I have authored dozens of published technical papers and delivered many lectures
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`addressing various aspects of Electrical and Computer Engineering.
`
`8.
`
`From 1968 to 1973, I was a Research/Development Engineer at General Telephone
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`and Electronics Sylvania in Mountain View, California. I completed my M.S. in Electrical
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`Engineering from Stanford University in 1971. At Stanford, I worked on techniques that were
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`unique in that they involved adaptive linear optimizations for monitoring non-stationary signals.
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`During this period, much of my work related to communications, computer control of data
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`collection, and analysis systems used by organizations in the United States government. Leading-
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`edge sensing techniques were a key aspect of much of this work.
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`9.
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`From 1973 to 1977, I was a Member of Technical Staff at Hewlett-Packard’s Santa
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`Clara Division and subsequently at Hewlett-Packard Laboratories in Palo Alto, California. During
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`2
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`that time, I continued to develop application programs. I also designed interface hardware to
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`interact with computer software and accomplish various tasks. One major project I was responsible
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`for was the real-time control of environmental test systems for satellites and satellite components.
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`Applications for these analysis and control tools utilized Fourier Transforms for tasks best
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`performed in the frequency domain. For example, these tools allowed automated analysis of
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`communication systems. Key concepts in this work are related to this case because they involved
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`digital data communications, motion control, motion analysis, and data collection based upon
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`sensors including accelerometers. During this period, I also used variations of these tools to
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`monitor and analyze motions of rigid and semi-rigid objects – particularly with respect to vibration
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`mode analysis. The same tools also found application in the automated diagnosis of communication
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`systems such as telephone systems.
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`10.
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`At HP Laboratories, among other projects, I developed hardware and software to
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`provide real-time control of manufacturing systems for solid state devices. This work related directly
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`to the issues in this case because the tools I developed involved sensor systems and control systems
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`for displacement, rotation, temperature control, etc. I also did some of the earliest research on the
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`dominant sources for the degradation of liquid crystal displays.
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`11.
`
`From 1977 to 1980, I was a Lecturer in the Division of Mathematics, Statistics, and
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`Computer Science at the University of Texas at San Antonio. As the director of a laboratory for
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`teaching students to program and build hardware interfaces and control systems using small
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`computers, my students and I purchased, built, and operated some of the earliest personal
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`computers. Additionally, I taught courses in the design of digital systems. During this period, I also
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`completed my Ph.D. in Electrical Engineering at the University of Texas at Austin in 1980. I also
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`did my first consulting work at this time involving the control, sensing, and evaluation of human
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`motion control capabilities under adverse environmental conditions.
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`3
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`12.
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`From 1980 to 1983, I was a Member of Technical Staff at Bell Laboratories in
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`Murray Hill, New Jersey. My work involved the programming of computers and the design of
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`hardware components for communication systems. I was part of a three-person team that designed,
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`tested, and directed the manufacture of an integrated circuit that was a key component in a digital
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`telephone modem. I also actively worked with designers of large scale digital telephone switching
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`systems. This work relates generally to the topics in this case because modems obviously sense and
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`produce sound. The manufacture testing of this product involved extensive investigation of the
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`external sensing aspects of this product and associated conclusions about aspects of the device that
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`were only indirectly determinable.
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`13.
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`In 1983, I was appointed Assistant Professor of Electrical and Computer
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`Engineering at the University of Texas at Austin. In 1987, I was promoted to Associate Professor
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`and Professor in 1991. During this period, I taught Computer Engineering courses at the
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`undergraduate and graduate level, directed the research of graduate students, and consulted with
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`numerous organizations. One consulting project I did at this time involved the study of early printed
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`circuit board surface mount techniques where component placement was automated using pick-and-
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`robotic systems. As part of this work I interface with more than a dozen of the largest printed circuit
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`manufacturers in the United States at that time. Aspects of this work relate to issues in this case
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`since the manufacturing systems made extensive use of sensors and controllers.
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`14.
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`In 1995, I was appointed Professor of Electrical and Computer Engineering, Leader
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`of the Computer Engineering Group, and Holder of the Computer Engineering Chair in Electrical
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`Engineering at Texas A&M University in College Station, Texas. My teaching, my research, my
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`technical publications, and my supervision of graduate students during that period included the areas
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`of the modeling, design, and fabrication of digital hardware and software systems. As with my
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`previous work (at The University of Texas at Austin), during this period, I taught courses at the
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`undergraduate and graduate level, directed the research of graduate students, and consulted with
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`numerous organizations on a variety of topics. I was also responsible for monitoring controlled
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`experiments to optimize and quantify the use of tester time to detect defects in electrical products,
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`and I was part of a team that used analytical techniques to predict the expected growth of quiescent
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`currents in MOS transistors as a function of the reduction in integrated circuit feature sizes.
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`15.
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`In September 2005, I retired from my teaching position, and the Regents of the
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`Texas A&M University System appointed me as Professor Emeritus of Electrical and Computer
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`Engineering at Texas A&M University.
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`16.
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`In 1984, I formed Mercer and Associates, an independent consulting firm that I have
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`owned and directed to this day. Since 1979, I have provided private consultation and advice in
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`Electrical and Computer Engineering to numerous entities, including IBM Corp., Rockwell
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`International, Motorola Semiconductor, AT&T, Inc., and SigmaTel.
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`17.
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`I first served as an expert witness at the request of the Office of the State Attorney
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`General of Texas in 1984. Since then, I have been hired by numerous law firms to provide them and
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`their clients with expert consultation and expert testimony, often in the areas of patent infringement
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`litigation related to electrical and computer engineering. Among other topics, I have opined with
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`respect to communications systems including telephony, cell phone networks and devices, and
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`particular characteristics of private and public network communications networks, including the
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`Internet. I have testified regarding standalone and Internet-based online gaming systems. I have
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`testified regarding home entertainment systems that use wireless communications. I have testified
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`with respect to online educational institutions and technical aspects of their media distribution
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`systems. I have testified with respect to media and entertainment systems for mobile vehicles as well
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`as special aspects of display equipment similar to the equipment at issue in the current case. I have
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`testified in a case involving delta-sigma modulation for high performance analog-to-digital and
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`5
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`digital-to-analog converters—such as those commonly utilized in personal computers. Many of the
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`technical issues and topics in this work relate directly to the key technical issues in this current case.
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`18.
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`Throughout my career, I have been actively involved in numerous professional
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`organizations, including the Institute of Electrical and Electronics Engineers (“IEEE”) and was
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`recognized as an IEEE Fellow in 1994. I was the Program Chairman for the 1989 International Test
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`Conference, which is an IEEE sponsored annual conference with (at that time) more than one
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`thousand attendees and over one hundred presented papers. I won the Best Paper Award at the
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`1982 International Test Conference.
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`19.
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`I also won a Best Paper Award at the 1991 Design Automation Conference, an
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`annual conference with (at that time) more than ten thousand attendees and five hundred submitted
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`papers, many of which related to the design of integrated circuit-based systems.
`
`20.
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`I also won a Best Paper Award at the 1999 VLSI Test Symposium. This paper was
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`focused on manufacturing techniques to optimize the quality of manufactured digital systems. I am
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`the inventor of two United States patents that relate to the design of integrated circuits and digital
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`systems. I was selected as a National Science Foundation Presidential Young Investigator in 1986.
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`This award included $500,000 for support of my research.
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`III.
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`LEGAL STANDARD
`21.
`
`I am not an attorney. I have been informed on the law regarding claim construction
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`and patent claims, and my understanding is as follows.
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`22.
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`I understand that a patent may include two types of claims, independent claims and
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`dependent claims. An independent claim stands alone and includes only the limitations it recites. A
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`dependent claim can depend from an independent claim or another dependent claim. I understand
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`that a dependent claim includes all the limitations that it recites in addition to all of the limitations
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`recited in the claim or claims from which it depends.
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`6
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`23.
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`I understand that the claims of a patent are presumed to be valid, and that, in the
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`venue for this case, invalidity of a claim must be proven by clear and convincing evidence.
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`24.
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`I am informed that claim construction is a matter of law for the Court to decide.
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`Claim terms should be given their ordinary and customary meaning within the context of the patent
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`in which the terms are used, i.e., the meaning that the term would have to a person of ordinary skill
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`in the art in question at the time of the invention in light of what the patent teaches.
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`25.
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`I am informed that to determine how a POSA would understand a claim term, one
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`should look to those sources available that show what a POSA would have understood disputed
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`claim language to mean. Such sources include the words of the claims themselves, the remainder of
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`the patent’s specification, the prosecution history of the patent and the cited references (all
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`considered “intrinsic” evidence), and “extrinsic” evidence, such as dictionary definitions and learned
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`treatises and the opinions of qualified experts concerning relevant scientific principles, the meaning
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`of technical terms, and the state of the art.
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`26.
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`I understand that, in construing a claim term, one looks primarily to the intrinsic
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`patent evidence, including the words of the claims themselves, the remainder of the patent
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`specification, and the prosecution history.
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`27.
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`I understand that extrinsic evidence, which is evidence external to the patent and the
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`prosecution history, may also be useful in interpreting patent claims when the intrinsic evidence
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`itself is insufficient.
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`28.
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`I understand that words or terms should be given their ordinary and accepted
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`meaning unless it appears that the inventors were using them to mean something else. In making
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`this determination, the claims, the patent specification, and the prosecution history are of paramount
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`importance. Additionally, the specification and prosecution history must be consulted to confirm
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`whether the patentee has acted as its own lexicographer (i.e., provided its own special meaning to
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`any disputed terms), or intentionally disclaimed, disavowed, or surrendered any claim scope.
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`29.
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`I understand that the claims of a patent define the scope of the rights conferred by
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`the patent. The claims must particularly point out and distinctly claim the subject matter which the
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`patentee regards as his invention. Because the patentee is required to define precisely what he claims
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`his invention to be, it is improper to construe claims in a manner different from the plain meaning
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`of the terms used consistent with the specification. Accordingly, a claim construction analysis must
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`center on the claim language itself. Additionally, the context in which a term is used in the asserted
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`claim can be highly instructive. Likewise, other claims of the patent in question, both asserted and
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`unasserted, can inform the meaning of a claim term. For example, because claim terms are normally
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`used consistently throughout the patent, the usage of a term in one claim can often illuminate the
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`meaning of the same term in other claims. Differences among claims can also be a useful guide in
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`understanding the meaning of particular claim terms.
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`30.
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`I understand that a POSA is deemed to read a claim term not only in the context of
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`the particular claim in which the disputed term appears, but in the context of the entire patent,
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`including the specification. For this reason, the words of the claim must be interpreted in view of
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`the entire specification. The specification is the primary basis for construing the claims and provides
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`a safeguard such that correct constructions closely align with the specification. Ultimately, the
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`interpretation to be given a term can only be determined and confirmed with a full understanding of
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`what the inventors actually invented and intended to envelop with the claim as set forth in the
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`patent itself.
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`31.
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`I understand that it is improper to place too much emphasis on the ordinary
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`meaning of the claim term without adequate grounding of that term within the context of the
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`specification of the asserted patent. Hence, claim terms should not be broadly construed to
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`encompass subject matter that, although technically within the broadest reading of the term, is not
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`supported when the claims are read in light of the invention described in the specification. Prior art
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`incorporated by reference or otherwise cited during the prosecution history is also highly relevant in
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`ascertaining the breadth of claim terms and is considered intrinsic evidence.
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`32.
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`I understand that the role of the specification is to describe and enable the invention.
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`In turn, the claims cannot be of broader scope than the invention that is set forth in the
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`specification. Care must be taken because word-by-word definition, removed from the context of
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`the patent, leads to an overall result that departs significantly from the patented invention.
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`33.
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`I understand that claim terms must be construed in a manner consistent with the
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`context of the intrinsic record. In addition to consulting the specification, one should also consider
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`the patent’s prosecution history, if available. The file history provides evidence of how both the
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`Patent Office and the inventors understood the terms of the patent, particularly in light of what was
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`known in the prior art. Further, where the specification describes a claim term broadly, arguments
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`and amendments made during prosecution may require a more narrow interpretation.
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`34.
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`I understand that while intrinsic evidence is of primary importance, extrinsic
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`evidence, e.g., all evidence external to the patent and prosecution history, including expert and
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`inventor testimony, dictionaries, and learned treatises, can also be considered. For example, technical
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`dictionaries may help one better understand the underlying technology and the way in which one of
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`skill in the art might use the claim terms. Extrinsic evidence should not be considered, however,
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`divorced from the context of the intrinsic evidence. Evidence beyond the patent specification,
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`prosecution history, and other claims in the patent should not be relied upon unless the claim
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`language is ambiguous in light of these intrinsic sources. Furthermore, while extrinsic evidence can
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`shed useful light on the relevant art, it is less significant than the intrinsic record in determining the
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`legally operative meaning of claim language.
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`35.
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`I understand that a claim limitation is indefinite if the claim, when read in light of the
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`specification and the prosecution history, fails to inform with reasonable certainty persons of
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`ordinary skill in the art about the scope of the invention.
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`36.
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`I am informed that the specification of a patent must satisfy a definiteness
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`requirement, which requires that it conclude with one or more claims particularly pointing out and
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`distinctly claiming the subject matter which the applicant regards as the invention.
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`37.
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`I am also informed that definiteness requires that a patent’s claims, viewed in light of
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`the specification and file history from the perspective of a person skilled in the relevant art at the
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`time the patent was filed, inform those skilled in the art about the scope of the invention with
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`reasonable certainty.
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`38.
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`I understand that a patent must be precise enough to afford clear notice of what is
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`claimed and apprise the public of what subject matter is still open to them in a manner that avoids a
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`zone of uncertainty.
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`IV. OPINIONS ON UNDERSTANDING OF ONE OF ORDINARY SKILL AND
`SELECTED CLAIM TERMS
`A.
`39.
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`I have been asked to provide an opinion as to a person of ordinary skill in the art at
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`Level of Ordinary Skill in the Art
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`the time of the purported invention of the ’438 and ’978 Patents, which I have been asked to initially
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`assume is January 6, 2010, the filing date of Provisional Application No. 61/292,558. My opinions
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`below would not change if the time of the invention was July 29, 2009, September 25, 2009,
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`November 11, 2010, March 28, 2011, or July 6, 2011.
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`40.
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`It is my opinion that one of ordinary skill in the art relevant to the technology of the
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`’438 and ’978 Patents is someone who has a computer science, electrical engineering, mechanical
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`engineering, or other related technical degree at the undergraduate level, and knowledge of sensor
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`systems. Superior experience in one of these areas could compensate for lesser experience in the
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`other.
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`41.
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`I understand that CyWee has asserted that a POSA typically would have had at least
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`a Bachelor’s Degree in Computer Science, Electrical Engineering, Mechanical Engineering, or
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`Physics, or equivalent work experience, along with knowledge of sensors (such as accelerometers,
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`gyroscopes, and magnetometers), and mobile computing technologies. My opinions below would
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`not substantively change if the level of a person of ordinary skill in the art were based on CyWee’s
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`assertion of a POSA, although I reserve my right to consider and respond to any other opinions or
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`findings as to such a level.
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`B.
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`42.
`
`Summary of Opinions
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`In summary, it is my opinion that the following claim terms and phrases, read in light
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`of the specification and the prosecution history of the respective patent, fail to inform, with
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`reasonable certainty, those skilled in the art about the scope of the claim in which the terms or
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`phrases appear:
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`
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`
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`
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`“utilizing a comparison to compare the first signal set with the second signal set”
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`(’438 Patent, claim 1)
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`“comparing the second quaternion in relation to the measured angular velocities ωx,
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`ωy, ωz of the current state at current time T with the measured axial accelerations
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`Ax, Ay, Az and the predicted axial accelerations Ax', Ay', Az' also at current time T”
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`(’438 Patent, claims 14 and 19)
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`“generating the orientation output based on the first signal set, the second signal set
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`and the rotation output or based on the first signal set and the second signal set”
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`(’978 Patent, claim 10)
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`43. My detailed opinions are set forth below.
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`C.
`44.
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`The Physical Frame of Reference for the Asserted Claims
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`Neither of the patents-in-suit specifically describes the physical frame of reference
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`for their purported inventions. Therefore, a POSA would have assumed an inertial frame of
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`reference where a given object could experience at least one or more of the following three
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`accelerations:
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`
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`Gravitational acceleration due to the gravity of the Earth;
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`Linear acceleration due to an external applied force; and
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`Centrifugal acceleration due to an external applied force.
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`The patents-in-suit also do not discuss limitations of the domain of application for
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`
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` 
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`45.
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`
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`the purported inventions they claim. For example, it is not clear if the motions of interest are
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`restricted to rigid bodies or if the domain of the applications is broader.
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`46.
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`A rigid body is an idealized model of a solid object in which any changes in the shape
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`or size of an object are assumed to be zero. In this way, the distance between any two given points
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`between the object remain constant in time regardless of external forces, i.e., the body does not
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`deform as it moves.
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`47.
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`In non-rigid bodies, external forces may change the shape and/or size of the body as
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`it moves. Without guidance, a POSA would assume the domain of the patents-in-suit to be
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`unrestricted so that it applies to both rigid and non-rigid bodies.
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`Types of Acceleration
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`48.
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`Gravitational acceleration measures the acceleration of an object caused by
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`gravitational force.
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`49.
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`For example, when two spheres of different weight fall from the same height, both
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`are accelerated by gravity at the same rate and hit the ground at the same time.
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`50.
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`Similarly, when a person steps onto a bathroom scale, the acceleration of gravity
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`deforms a structure similar to a spring, and the amount of the deformation is read as the person’s
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`weight.
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`51.
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`Although the magnitude of acceleration due to gravity is almost constant everywhere
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`on the Earth’s surface, its direction with respect to an object’s frame of reference changes
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`depending on the object’s orientation, because gravitational acceleration is always directed towards
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`the center of the Earth.
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`52.
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`Linear acceleration measures the rate of change of linear velocity with respect to
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`time. Linear velocity is the rate of change of the position of an object traveling along a straight
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`path.
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`53.
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`Humans may produce simple linear acceleration. For example, when a person throws
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`a dart toward a bull’s eye, his arm attempts to linearly accelerate the dart from an initial velocity of
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`zero to the correct velocity so that, after its release, the trajectory of the dart terminates within the
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`bull’s eye.
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`54. Machines can also produce simple linear acceleration. A gun linearly accelerates a
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`bullet from an initial velocity (normally zero) to the very high velocity at which it leaves the gun
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`barrel.
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`55.
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`Centrifugal acceleration results when a rotating body (such as a weight held by a
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`string) rotates about a point (such as the center of the circle of motion).
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`56.
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`Rotational motion may be simple or compound. For example, rotational motion
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`induced by a single rigid body motion is simple because the radius of rotation remains constant.
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`Rotational motion induced by multiple rigid bodies or non-rigid bodies may produce more
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`complex motions.
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`57.
`
`Centrifugal accelerations can be either simple or compound (if the motions are not
`
`induced by a single rigid object.).
`
`58.
`
`As one example, the centrifugal force experienced by a baseball when it is thrown by
`
`a mechanical pitching machine is simple because there is a fixed radius of rotation and a fixed center
`
`of rotation. In the case of this motion, both of these values are constant.
`
`59.
`
`In contrast, when the ball is thrown by a human, the centrifugal force experienced by
`
`the baseball is compound. This is because the angle of the pitcher’s arm at his elbow changes during
`
`the pitch, and therefore, the radius of curvature changes when the pitcher moves. Further, the
`
`pitcher’s shoulder and wrist also move so that many complex motions are combined—and each of
`
`these anatomical parts induces different radial motions, each with a different radius that may be a
`
`constant or variable value.
`
`D.
`
`60.
`
`61.
`
`“utilizing a comparison to compare the first signal set with the second signal
`set” (’438 Patent, claim 1)
`
`This element appears in claim 1 of the ’438 Patent and its dependents.
`
`Claim 1 of the ’438 Patent recites (emphasis added):
`
`1. A three-dimensional (3D) pointing device subject to movements
`and rotations in dynamic environments, comprising:
`
` a
`
` housing associated with said movements and rotations of the 3D
`pointing device in a spatial pointer reference frame;
`
` a
`
` printed circuit board (PCB) enclosed by the housing;
`
` a
`
` six-axis motion sensor module attached to the PCB, comprising a
`rotation sensor for detecting and generating a first signal set
`comprising angular velocities ωx, ωy, ωz associated with said
`movements and rotations of the 3D pointing device in the spatial
`pointer reference frame, an accelerometer for detecting and
`generating a second signal set comprising axial accelerations Ax, Ay,
`Az associated with said movements and rotations of the 3D pointing
`device in the spatial pointer reference frame; and
`
` a
`
` processing and transmitting module, comprising a data transmitting
`unit electrically connected to the six-axis motion sensor module for
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` 1623
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`transmitting said first and second signal sets thereof and a computing
`processor for receiving and calculating said first and second signal
`sets from the data transmitting unit, communicating with the six-axis
`motion sensor module to calculate a resulting deviation comprising
`resultant angles in said spatial pointer reference frame by utilizing a
`comparison to compare the first signal set with the second
`signal set whereby said resultant angles in the spatial pointer
`reference frame of the resulting deviation of the six-axis motion
`sensor module of the 3D pointing device are obtained under said
`dynamic environments, wherein the comparison utilized by the
`processing and transmitting module further comprises an update
`program to obtain an updated state based on a previous state
`associated with said first signal set and a measured state associated
`with said second signal set; wherein the measured state includes a
`measurement of said second signal set and a predicted measurement
`obtained based on the first signal set without using any derivatives of
`the first signal set.
`
`As set forth above, claim 1 recites “utilizing a comparison to compare the first signal
`
`
`62.
`
`set with the second signal set.” I have considered the meaning of this claim element in the context
`
`of the ’438 Patent.
`
`63.
`
`Claim 1 further recites that the “first signal set” comprises “angular velocities ωx, ωy,
`
`ωz associated with said movements and rotations of the 3D pointing device in the spatial pointer
`
`reference frame.” Claim 1 recites that this first signal set is detected and generated by a rotation
`
`sensor.
`
`64.
`
`Claim 1 recites that the “second signal set” comprises “axial accelerations Ax, Ay, Az
`
`associated with said movements and rotations of the 3D pointing device in the spatial pointer
`
`reference frame.” Claim 1 recites that this second signal set is detected and generated by an
`
`accelerometer.
`
`65.
`
`In my opinion, a POSA would not have understood the meaning of this element
`
`with reasonable certainty for at least three reasons.
`
`66.
`
`First, a POSA would have understood that the term “axial accelerations” could have
`
`multiple possible interpretations. Specifically, an “axial acceleration” could connote the combination
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` 1624
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`of one or multiple possible acceleration components resulting from: (i) the force of gravity; (ii)
`
`external forces that impose linear accelerations, and (iii) centrifugal forces producing non-straight
`
`line motion that impose one or more centrifugal accelerations (since the structures imposing the
`
`centrifugal accelerations are not necessarily a single rigid body).
`
`67.
`
`Second, a POSA would have understood that it would be impossible to correctly
`
`decompose a given reading from an accelerometer in order to determine the individual values of
`
`each of the components of acceleration induced by the f