Case 5:19-cv-00036-RWS Document 136-6 Filed 11/18/19 Page 1 of 37 PageID #: 5682
`Case 5:19-cv-00036—RWS Document 136-6 Filed 11/18/19 Page 1 of 37 PageID #: 5682
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`EXHIBIT 6
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`EXHIBIT 6
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`

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`Case 5:19-cv-00036-RWS Document 136-6 Filed 11/18/19 Page 2 of 37 PageID #: 5683
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`
`Plaintiff,
`
`Case No. 5:19-cv-00036-RWS
`
`JURY TRIAL DEMANDED
`
`
`
`
`MAXELL, LTD.,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`
`
`
`DECLARATION OF TIM A. WILLIAMS, Ph.D., REGARDNG
`CLAIM CONSTRUCTION
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`
`
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`

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`Case 5:19-cv-00036-RWS Document 136-6 Filed 11/18/19 Page 3 of 37 PageID #: 5684
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`I.
`
`1.
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`INTRODUCTION
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`My name is Tim A. Williams and I have prepared this declaration at the request of the
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`plaintiff in this case, Maxell, Ltd. (“Maxell”). This declaration provides my opinions with
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`respect to certain claim terms of U.S. Patent No. 7,116,438 (“the ’438 Patent”).
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`2.
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`Specifically, I have been asked to provide my expert opinion regarding the following
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`terms of the ’438 Patent: “an input unit for receiving an input entered by a user”; “display
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`apparatus”; and “means for selecting an object displayed on said display apparatus.”
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`3.
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`I am being compensated for my time spent on this case at my normal consulting rate of
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`$675 per hour and that my compensation is not based on either the content of my opinions or the
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`outcome of this case.
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`II.
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`4.
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`QUALIFICATIONS
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`Included below is a summary of my educational background, career history, publications,
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`and other relevant qualifications.
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`5.
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`I am an expert in wireless communications, telecom technology, and other areas of
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`telecommunications. I am an entrepreneur who has participated in the organization and operation
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`of start up companies that brought wireless Local Area Network (LAN), software for Voice over
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`Internet Protocol (VoIP) Private Branch Exchange (PBX), and 2-way paging technology to the
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`marketplace. I hold numerous patents in wireless and signal processing technology and I have
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`extensive experience as a litigation support consultant in patent infringement matters.
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`6.
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`I received my Ph. D. from the University of Texas at Austin in 1985. The title of my
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`dissertation was “Digital Signal Processing Techniques for Acoustic Log Data.” Prior to that, I
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`received a MSEE from the University of Texas at Austin in 1982 and a BSEE from Michigan
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`Technological University in 1976.
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`7.
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`From 1979 to 1991, I was a senior engineer at Motorola, Inc., where I was responsible for
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`2
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`product development in numerous areas of wireless technology, as set forth in more detail by my
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`CV. Since 1991, I have worked as founder, board member, member, chief executive officer,
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`chief technology officer, or partner in over a dozen wireless technologies as set forth in my CV.
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`8.
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`My primary areas of expertise are in the fields of Wireless LANs; Cellular and Personal
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`Communications Service (PCS) Standards; Cellular Telephone Architecture; Digital Signal
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`Processing; Telecommunications Technology; VoIP Technology; Computer Networking; and
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`Wireless Networks and Protocols.
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`9.
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`Since 2001, I have evaluated hundreds of patents for various clients. These evaluations
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`typically include, for example, analyzing whether products infringed certain patents; analyzing
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`whether certain patents were valid; searching for and reviewing potential prior art; considering
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`the importance of the technological inventions claimed; reviewing and analyzing patent
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`specifications, prosecution histories of patents, and extrinsic evidence relevant to potential claim
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`construction; and considering whether there are available alternatives to the claimed inventions.
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`The cases in which I have consulted are set forth in my CV, attached as exhibit 1.
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`III. LEGAL UNDERSTANDING
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`10.
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`I am not an attorney. I have been informed about legal standards of patent law, which I
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`have used in developing my opinions expressed herein.
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`11.
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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.
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`A dependent claim can depend from an independent claim or another dependent claim and
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`includes all the limitations that it recites in addition to all of the limitations recited in the claim or
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`claims from which it depends.
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`12.
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`I understand that the claim construction exercise begins with the language of the claims
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`themselves, and that the general rule is that claim terms are given their plain and ordinary
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`meaning to a person of ordinary skill in the art, in view of the specification of the patent, at the
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`time of the invention. I also understand that the intrinsic evidence (i.e., the claims, written
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`description, and prosecution history) are the primary sources used in interpreting claim language.
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`13.
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`I understand that if disputed claim language is clear on its face, the intrinsic evidence
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`should be consulted to determine whether some deviation from the ordinary meaning of the
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`claim language is warranted.
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`14. When the disputed claim language is not clear on its face, I understand that the intrinsic
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`evidence should be used to resolve, if possible, the lack of clarity. I also understand that the
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`specification is the best evidence of what the patentee intended the term to mean when there is
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`no clear meaning of a claim term, and that the prosecution history may also shed light on the
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`meaning of ambiguous terms. However, I understand that it is improper to import limitations
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`from the specification into a patent claim through claim construction.
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`15.
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`I have been informed that sometimes the ordinary meaning of claim language as
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`understood by a person of ordinary skill in the art may be readily apparent even to lay persons. I
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`understand that claim construction in such cases involves little more than the application of the
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`widely accepted meaning of commonly understood words.
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`16.
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`I further understand that a patentee may act as his own lexicographer by giving a
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`definition for a particular claim term. I understand that, in order for this principle to apply, the
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`patentee must clearly set forth a definition and clearly express an intent to define that term.
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`Simply disclosing a single embodiment is not sufficient.
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`17.
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`I understand that if the intrinsic evidence fails to clearly disclose the meaning of a claim
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`term, the court may look to extrinsic evidence outside the patent and prosecution history, such as
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`expert testimony, treatises, and dictionaries.
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`4
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`18.
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`I further understand that, under pre-AIA 35 U.S.C. § 112, ¶ 6, a claim element may be
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`expressed as a means or step for performing a specified function without the recital of structure,
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`material, or acts in support thereof, and that such elements are called “means-plus-function”
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`terms. I understand that a patentee’s use of the word “means” in a claim element creates a
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`presumption that the term is a means-plus-function term. I further understand that the lack of the
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`word “means” creates a presumption that a term is not a means-plus-function term.
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`19.
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`I understand that the presumption against means-plus-function interpretation can be
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`overcome. However, I understand that, in order to overcome this presumption, a party must show
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`that a claim term lacks sufficient structure and consists solely of functional terms as understood
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`by one of skill in the art. It is my understanding that a claim term will not be interpreted as a
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`means-plus-function element when that term recites structure that has a sufficiently definite
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`meaning to those of skill in the art. I understand that, in determining whether a claim terms
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`recites sufficiently definite structure, the term may be used in common parlance or by persons of
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`skill in the pertinent art to designate structure, even if the term covers a broad class of structures
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`and even if the term identifies the structures by their function.
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`IV. MATERIALS CONSIDERED
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`20.
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`In providing my opinions, I have considered the documents citing in this declaration,
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`including, for example, the ’438 Patent, the file history of the ’438 Patent, the 1994 IBM
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`Dictionary of Computing, the 2000 IEEE Standards Dictionary, the claim constructions rendered
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`in Maxell Ltd. v. Huawei Device USA Inc. et. al., 297 F.Supp.3d 668 (E.D. Tex. 2018), the
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`parties’ claim construction disclosures, my years of education, research, and experience in the
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`relevant field, and the legal standards provided to me by counsel.
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`V.
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`21.
`
`OVERVIEW OF THE ’438 PATENT
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`The ’438 Patent is entitled “Terminal for Information Processing”; was filed on
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`December 30, 2003, and claims priority to Japanese Patent Publication 2003-144259, which was
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`filed on May 22, 2003.
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`22.
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`The ’438 Patent describes, in general, a system comprising an information-processing
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`terminal and a display apparatus in communication with each other. Various claims are directed
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`to either the information-processing terminal or the display apparatus in such a system.
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`23.
`
` More specifically, the ’438 Patent discloses that an information-processing terminal
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`carries out a processing communication with nearby display apparatus through a first short-
`
`distance communication apparatus in order to start use of the display apparatus, and subsequently
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`exchanges data with the display apparatus by way of a second communication apparatus. ’438
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`Patent at 1:60-65. This arrangement is illustrated in Figure 1, which shows an arrangement of
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`mobile terminals (a type of information-processing terminal) in communication with display
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`terminals (a type of display apparatus). Id. at Fig. 1.
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`Reproduction of Fig. 1 of the ’438 Patent
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`
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`24.
`
`The ’438 Patent discloses that the short-distance communication apparatus is used to
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`authenticate an information-processing terminal that is in a physically close proximity to the
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`6
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`display terminal. Id. at 1:46-50; 6:51-67; 9:65-10:8; Fig. 7. The ’438 Patent discloses that,
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`subsequently, a second communication apparatus is used to exchange data between the
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`information-processing terminal and the display terminal. Id. at 1:63-65; 6:67-7:46; Fig. 7.
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`Reproduction of Fig. 7 of the ’438 Patent
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`VI.
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`LEVEL OF ORDINARY SKILL IN THE ART
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`7
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`25.
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`In my opinion, a person of ordinary skill in the art as of the priority date of the ’438
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`patent had a working knowledge of wireless communications. The person would have gained this
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`knowledge through an undergraduate Bachelor of Science degree in Electrical Engineering and
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`at least one year of experience working in the field of wireless communications. More education
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`(e.g., a Master’s degree) or work experience in a relevant field may compensate for a deficit in
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`one of the other relevant qualifications stated above.
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`VII. CLAIM CONSTRUCTION OPINIONS
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`
`
`A.
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`“an input unit for receiving an input entered by a user” (Claim 1)
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`26.
`
`I understand that the parties have proposed the following constructions for this term:
`
`Maxell’s Construction
`Plain and ordinary meaning
`
`Apple’s Construction
`This claim term should be governed by pre-
`AIA 35 U.S.C. § 112, ¶ 6.
`
`Claimed Function:
`to receive input entered by a user
`
`Disclosed Structure:
`a keyboard; or equivalents thereof
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`
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`27.
`
`I agree with Maxell that “an input unit for receiving an input entered by a user” should be
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`given its plain and ordinary meaning. For at least the reasons discussed below, it is my opinion
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`that a POSITA would have sufficient information, from the written description provided in the
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`’438 Patent and from a knowledge of how this term was used within the art, to understand these
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`terms as used within Claim 1 of the ’438 Patent.
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`28.
`
`Specifically, I note that the ’438 Patent uses the term “input/output unit 103” in a manner
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`consistent with its plain and ordinary meaning:
`
`The input/output unit 103 is a component for displaying information to the user and
`receiving data entered by the user. The input/output unit 103 typically includes a liquid
`crystal display device and a ten-key board. However, the input/output unit 103 is not
`limited to the liquid crystal display device and the ten-key board. That is to say, the
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`input/output unit 103 can be any component as long as the component is capable of
`receiving an input entered by the user and displaying an output to the user. The
`input/output unit 103 can also have a configuration comprising an input unit and an
`output unit physically separated from the input unit.
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`’438 Patent at 3:59-4:3.
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`29.
`
`A POSITA would readily understand this passage, and thus the claimed term, to be
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`discussing a known class of devices, and would confirm to a POSITA that “an input unit for
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`receiving an input entered by a user” should be read in accordance with its plain and ordinary
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`meaning, as this passage is consistent with the plain and ordinary meaning of this term.
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`30.
`
`Indeed, IBM’s 1994 Dictionary of Computing confirms my opinion of a PHOSITA’s
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`understanding with regard to this term. As defined in this dictionary, an “input device” is a
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`defined term, with a definition of: “Synonym for input unit.” Ex. 2 (IBM Dict. of Comp.) at 341.
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`Turning to “input unit,” the definition is “[a] device in a data processing system by means of
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`which data can be entered into the system.” Id. at 343. Such a definition is fully consistent with
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`the usage of “an input unit for receiving an input entered by a user” within the ’438 Patent, and
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`confirms opinion that this term should be given its plain and ordinary meaning.
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`31.
`
`I note that the inventors of the ’438 Patent used clear language to avail themselves of the
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`provisions of pre-AIA 35 U.S.C. § 112, ¶ 6. For example, Claim 3 of the ’438 Patent recites the
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`use of a “means for selecting an object displayed on said display apparatus.” ’438 Patent at cl. 3.
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`This is clear “means for” language, and shows that when the inventors of the ’438 Patent wished
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`to avail themselves of means-plus-function protections, they clearly did so. The disputed term is
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`not a “means for receiving an input entered by a user,” but rather an “input unit for receiving an
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`input entered by a user.” Id. at cl. 1. As discussed above, an “input unit” is a particular
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`component.
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`32.
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`Finally, I have reviewed the claim construction rendered with respect to the ’438 Patent
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`in Maxell Ltd. v. Huawei Device USA Inc. et. al., 297 F.Supp.3d 668, 719-723 (E.D. Tex. 2018). I note
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`that the Court found that the “input/output unit 103” was the structure implicated by the agreed-upon
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`means-plus-function of “means for selecting an object displayed on said display apparatus.” I agree
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`with the Court that the “input/output unit 103” conveys a particular structure, and I find this consistent
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`with my opinion that “an input unit for receiving an input entered by a user” also conveys a
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`particular structure.
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`33.
`
`In my opinion, Apple’s proposed construction is erroneous primarily because (1) it
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`asserts that this term should be governed by the provisions of pre-AIA 35 U.S.C. § 112, ¶ 6, and
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`(2) it attempts to limit the meaning of “an input unit for receiving an input entered by a user”
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`beyond the well-known plain and ordinary meaning by asserting that it is limited to the structure
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`of a keyboard and equivalents thereof. As I have discussed, a POSITA would readily understand
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`the possible range of structures of an input/output unit upon reading the specification of the ’438
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`Patent. Thus, a POSITA would not understand this term to be limited in this way, and would
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`instead understand it to have its plain and ordinary meaning.
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`B.
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`“display apparatus” (all claims)
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`34.
`
`I understand that the parties have proposed the following constructions for this term:
`
`Apple’s Construction
`An electronic notice board
`
`Maxell’s Construction
`A display device comprising a first short-
`distance communication apparatus for
`carrying out a short-distance communication
`with an information-processing terminal and a
`second communication apparatus for carrying
`out a communication with the information-
`processing terminal through a network
`
`35.
`
`I agree with Maxell that “display apparatus” should be construed as “[a] display device
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`comprising a first short-distance communication apparatus for carrying out a short-distance
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`communication with an information-processing terminal and a second communication apparatus
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`10
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`for carrying out a communication with the information-processing terminal through a network.”
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`36.
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`Indeed, I note that the ’438 Patent specifically defines this term in accordance with
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`Maxell’s proposed construction:
`
`[A] display apparatus according to the present invention comprises a first short-
`distance communication apparatus
`for carrying out a
`short-distance
`communication with an
`information-processing
`terminal and a second
`communication apparatus for carrying out a communication with the information-
`processing terminal through a network.
`
`’438 Patent at 2:5-10.
`
`37.
`
`A PHOSITA would also look to Figure 3 of the ’438 Patent to understand this term. The
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`’438 Patent states that:
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`FIG. 3 is a diagram showing details of the display terminal 2. The display terminal 2
`comprises a display unit 212, a processor 106, a
`storage unit 107, a
`transmission/reception unit 104 and a short-distance communication init 102, which are
`connected to each other by an internal bus 105 allowing the display unit 212, the
`processor 106, the storage unit 107, the transmission/reception unit 104 and the short-
`distance communication init 102 to exchange information such as control signals and data
`with each other.
`
`Id. at 4:27-36.
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`11
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`Reproduction of Fig. 7 of the ’438 Patent
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`38.
`
`Turning to component 212, which is the “display unit” of the “display terminal,” the ’438
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`Patent states that “the display unit 212 can be any display device as long as the display device is
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`capable of displaying information.” Id. at 4:50-52. A PHOSITA would readily understand the
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`term “display device.” For example, the IEEE Standards Dictionary from 2000 defines this term
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`as:
`
`In computer graphics, an output device on which display images can be
`(1)
`represented. For example, cathode ray tube display device, plotter, hard copy unit.
`See also: graphical display device.
`(2) An output device that gives a visual representation of data. Note: The
`representation is usually temporary, however arrangements may be made for
`producing a hard copy of the representation. Synonyms: display screen; display
`unit; display monitor; display station. See also: monitor; display surface.
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`The hardware used to provide the display to users. An example is a video
`(3)
`display unit. See also: display.
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`Ex. 3 (IEEE Standards Dict.) at 324.
`
`39.
`
`In my opinion, a POSITA would thus understand that a “display apparatus” should be
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`understood in accordance with the general usage of the term “display device,” and would also
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`understand that the ’438 Patent has specified that this term further “comprises a first short-
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`distance communication apparatus for carrying out a short-distance communication with an
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`information-processing terminal and a second communication apparatus for carrying out a
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`communication with the information-processing terminal through a network.” ’438 Patent at 2:5-
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`10. Thus, my understanding is entirely consistent with Maxell’s proposed construction.
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`40.
`
`I disagree with Apple that a POSITA would understand this term to be “[a]n electronic
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`notice board.” The ’438 Patent is clear that an electronic notice board is a distinct term, and a
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`POSITA would recognize that when the inventors wished to use “electronic notice board” (such
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`as in Claims 6 and 7, which state “wherein said display apparatus is an electronic notice board”),
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`they did so. Indeed, a POSITA would readily recognize that the specification of the ’438 Patent
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`uses the term “electronic notice board” when referring to certain particular embodiments, but
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`uses the term “display apparatus” to connote a more broad component as recited by the claims.
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`See ’438 Patent at 1:46-2:17 (describing “an object of the present invention” as providing “an
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`electronic notice-board system” (emphasis added), but then describing the invention as a whole
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`in more general terms, including the use and definition of the term “display apparatus”). In sum,
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`Apple appears to simply be trying to equate this more generalized term with a particular
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`embodiment, which is not how a PHOSITA would understand the usage of this term.
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`C.
`
`“means for selecting an object displayed on said display apparatus” (Claim
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`I understand that the parties have proposed the following constructions for this term:
`
`3)
`
`41.
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`13
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`Maxell’s Construction
`This claim term should be governed by pre-
`AIA 35 U.S.C. § 112, ¶ 6.
`
`Claimed Function:
`selecting an object displayed on said
`display apparatus
`
`Disclosed Structure:
`input/output unit 103 and associated software
`that allows for the claimed selection function.
`
`
`Apple’s Construction
`This claim term should be governed by pre-
`AIA 35 U.S.C. § 112, ¶ 6.
`
`Claimed Function:
`to select an object displayed on said
`display apparatus
`
`Disclosed Structure:
`input/output unit 103, including a liquid
`crystal display device and a keyboard, and
`associated software; or equivalents thereof
`
`
`
`42.
`
`I agree with Maxell that “means for selecting an object displayed on said display
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`apparatus” should be construed in accordance with pre-AIA 35 U.S.C. § 112, ¶ 6 to refer to a
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`component with a function of “selecting an object displayed on said display apparatus” and a
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`structure of the “input/output unit 103 and associated software that allows for the claimed
`
`selection function” and equivalents thereof.
`
`43.
`
`By my understanding, the language “means for selecting an object displayed on said
`
`display apparatus” clearly invokes pre-AIA 35 U.S.C. § 112, ¶ 6. Moreover the language of the
`
`term makes clear the function: “selecting an object displayed on said display apparatus.” I note
`
`that the parties appear to be in agreement regarding both the applicability of pre-AIA 35 U.S.C. §
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`112, ¶ 6 and the function described by this term.
`
`44.
`
`The structure of this means-plus-function term is made clear by the ’438 Patent. For
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`example, as relayed in one embodiment, “user of the mobile terminal 1 selects an operation to
`
`contribute a content to a notice board by operating the input/output unit 103 to select the
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`display area 1101.” ’438 Patent at 7:52-55 (emphasis added). Thus it is the input/output unit 103
`
`that performs this function. I note that the parties also appear to be in agreement that the
`
`input/output unit 103 is the structure that performs this function.
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`14
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`45.
`
`The ’438 Patent defines the input/output unit 103 as the following:
`
`The input/output unit 103 is a component for displaying information to the user
`and receiving data entered by the user. The input/output unit 103 typically
`includes a liquid crystal display device and a ten-key board. However, the
`input/output unit 103 is not limited to the liquid crystal display device and the ten-
`key board. That is to say, the input/output unit 103 can be any component as long
`as the component is capable of receiving an input entered by the user and
`displaying an output to the user. The input/output unit 103 can also have a
`configuration comprising an input unit and an output unit physically separated
`from the input unit.
`
`Id. at 3:59-4:3.
`
`46.
`
`Reading this passage, a POSITA would recognize that a broader class of structures than
`
`encompassed in Apple’s proposed construction is being invoked. A POSITA would understand
`
`the possible range of structures of an input/output unit, and would understand that a “liquid
`
`crystal display device and a keyboard” (as proposed by Apple) are not required structures.
`
`Indeed, the ’438 Patent specifically states that “the input/output unit 103 is not limited to the
`
`liquid crystal display device and the ten-key board.” Id. at 3:63-64. Thus, Apple’s proposed
`
`construction is unduly narrow and would be contrary to the understanding of a POSITA.
`
`47.
`
`I note that this court has already accepted the construction proposed by Maxell in Maxell
`
`Ltd. v. Huawei Device USA Inc. et. al., 297 F.Supp.3d 668, 719-723 (E.D. Tex. 2018), and found that the
`
`structure for this means-plus-function term is an “input/output unit 103 and associated software that
`
`allows for the claimed selection function.” This is further evidence to me that the structure invoked
`
`by this term is as proposed by Maxell, and that the construction proposed by Apple is unduly narrow.
`
`48.
`
`In addition to the opinions and evidence expressed herein, I reserve the right to rebut any
`
`arguments made or evidence presented in response to this report.
`
`49.
`
`I declare that, to the best of my knowledge, the foregoing is true and correct as the facts
`
`stated and my opinions as expressed.
`
`
`
`15
`
`

`

`Case 5:19-cv-00036-RWS Document 136-6 Filed 11/18/19 Page 17 of 37 PageID #: 5698
`
`Danville, CA
`Executed this 4th day of October, 2019 at _____________.
`
`By:_______________________________
` Dr. Tim A. Williams
`
`16
`
`

`

`Case 5:19-cv-00036-RWS Document 136-6 Filed 11/18/19 Page 18 of 37 PageID #: 5699
`Case 5:19-cv-00036—RWS Document 136-6 Filed 11/18/19 Page 18 of 37 PageID #: 5699
`
`EXHIBIT 1
`
`EXHIBIT 1
`
`

`

`Case 5:19-cv-00036-RWS Document 136-6 Filed 11/18/19 Page 19 of 37 PageID #: 5700
`
`
`
`
`Tim Arthur Williams, Ph.D.
`
`
`
`Curriculum Vitae
`
`
`
`
`
`
`
`
`
`Dr. Williams has 40 years of professional experience in wireless communications and telecom
`technology. He is an entrepreneur who has participated in the organization and
`operation of start up companies that brought wireless LAN, software VoIP PBX,
`and 2-way paging technology to the marketplace. Dr. Williams holds numerous
`patents in wireless and signal processing technology. He is an experienced
`litigation support consultant with experience in patent infringement matters. Dr.
`Williams is also a registered Patent Agent.
`
`
`
`
`
`
`!Wireless LAN
`!Cellular and PCS Standards
`!Cellular Telephone Architecture
`!Digital Signal Processing
`
`
`
`
`
`
`Year University
`1991 University of Texas at Austin
`
`1985 University of Texas at Austin
`
`1982 University of Texas at Austin
`
`1976 Michigan Technological
`University
`
`!Telecommunications Technology
`!VoIP Technology
`!Computer Networking
`!Wireless Networks & Protocols
`
`Degree
`MBA
`
`Ph.D.,
`Dissertation:
`“Digital Signal Processing Techniques for Acoustic
`Log Data”
`
`
`MSEE,
`Thesis:
`“Cepstral Processing of Speech Signals”
`
`BSEE
`
`
`
`
`
`
`
`
`
`
`1 of 7
`
`

`

`Case 5:19-cv-00036-RWS Document 136-6 Filed 11/18/19 Page 20 of 37 PageID #: 5701
`
`Tim Arthur Williams, Ph.D.
`
`Curriculum Vitae
`
`
`
`
`
`Professional Experience
`
`
`
`
`
`
`
`
`2008
`From:
`2010
`To:
`Organization: Expressume, Inc / Montage Inc. – Milwaukee, WI
`Title:
`Board Member
`Summary: This company sells software for human resource recruiting.
`
`
`2008
`From:
`2014
`To:
`Organization: Faculte, Inc. – San Jose, CA
`Title:
`Board Member
`Summary: This company provides SaaS (Software as a Service) web video based
`communication products.
`
`
`
`2008
`From:
`2010
`To:
`Organization: BitRail Networks Inc. – Miami, FL
`Title:
`Founder, Board Member
`Summary: This company sells computer networking solutions.
`
`
`2008
`From:
`Present
`To:
`Organization: Calumet Venture Management – Madison, WI
`Title:
`Member
`Summary: This company provides seed capital and management expertise to small
`companies.
`
`
`
`2006
`From:
`2015
`To:
`Organization: BEEcube Inc. – Fremont, CA
`Title:
`Founder, Board Member, Board Advisor
`Summary: This company builds high speed processing solutions. This company was sold to
`National Instruments, Inc. in Feb 2015.
`
`
`
`
`
`2 of 7
`
`

`

`Case 5:19-cv-00036-RWS Document 136-6 Filed 11/18/19 Page 21 of 37 PageID #: 5702
`
`Tim Arthur Williams, Ph.D.
`
`Curriculum Vitae
`
`
`
`
`
`
`
`
`2006
`From:
`2015
`To:
`Organization: Topaz Equity, LLC – Danville, CA
`Title:
`Founder, Board Member
`Summary: This is a private equity investment company. It owns AtomAMPD which
`develops, markets and sells software based network solutions.
`
`
`
`2004
`From:
`Present
`To:
`Organization: DoceoTech Inc. – Danville, CA
`Title:
`Founder, Chairman
`Summary: This was a training company that provides training for engineers in Wireless,
`Networking, and Telephony technologies. It is currently owned
`by Beach Technologies, LLC.
`
`
`
`2004
`From:
`2006
`To:
`Organization: SiBEAM Inc. – Sunnyvale, CA
`Title:
`Founder, Chief Executive Officer
`Summary: This is a fabless semiconductor company that develops high-speed wireless
`networking ICs. This company was sold to Silicon Image, Inc. in
`Apr 2011.
`
`
`
`2001
`From:
`2004
`To:
`Organization: JetQue, Inc. – Danville, CA
`Title:
`Founder, Chief Executive Officer
`Summary: This company created messaging solutions for the mobile professional.
`
`
`1999
`From:
`2000
`To:
`Organization: Atheros Communications, Palo Alto, CA
`Title:
`Interim CEO, Advisory Board Member
`Summary: This company builds wireless LAN ICs. Atheros became a public company in
`May 2004. (ATHR) This company was sold to QCOM in Jan
`2011.
`
`
`
`
`
`
`3 of 7
`
`
`
`
`

`

`Case 5:19-cv-00036-RWS Document 136-6 Filed 11/18/19 Page 22 of 37 PageID #: 5703
`
`Tim Arthur Williams, Ph.D.
`
`Curriculum Vitae
`
`
`
`
`
`
`
`
`
`
`1998
`From:
`2000
`To:
`Organization: Picazo Communications – San Jose, CA
`Title:
`Chief Technology Officer, Advisory Board Member
`Summary: This company built and sold software PBXs Telephony equipment using VoIP
`and Circuit Switched Technologies. The company was purchased
`by Intel.
`
`
`
`1996
`From:
`Present
`To:
`Organization: Beach Technologies, LLC – Danville, CA
`Title:
`Chief Executive Officer
`Summary: This is a consulting company that provides IP services. It owns DoceoTech LLC
`and Streaming Knowledge LLC, which perform the same
`services.
`
`
`
`1991
`From:
`1998
`To:
`Organization: Wireless Access, Inc. – Santa Clara, CA
`Title:
`Co-Founder, Chief Technical Officer, Vice President of Engineering, Vice
`President of Business Strategy
`This was a startup company focusing on the Narrow Band PCS equipment
`market. The company developed the over the air protocols, the
`subscriber equipment and the ICs to deploy 2-way paging
`services. The company was sold to Glenarye Electronics.
`
`Summary:
`
`
`
`2014
`From:
`Present
`To:
`Organization: Through Technology, LLC. – Chicago, IL
`Title:
`Partner
`Summary:
`This is a private equity investment company. It owns Through Technology
`Group, PTE LTD, which is registered in Singapore.
`
`
`
`1979
`From:
`1991
`To:
`Organization: Motorola, Inc. – Austin, TX – Semiconductor Sector
`
`
`4 of 7
`
`

`

`Case 5:19-cv-00036-RWS Document 136-6 Filed 11/18/19 Page 23 of 37 PageID #: 5704
`
`Tim Arthur Williams, Ph.D.
`
`Curriculum Vitae
`
`
`
`
`
`
`
`
`Title:
`Summary:
`
`Sr. Engineer, Member Technical Staff, Sr. MTS
`Business manager, project leader, and senior technical mem