Case 5:19-cv-00036-RWS Document 161-5 Filed 12/09/19 Page 1 of 90 PageID #: 6605
`Case 5:19-cv-00036—RWS Document 161-5 Filed 12/09/19 Page 1 of 90 PageID #: 6605
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`EXHIBIT D
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`EXHIBIT D
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`Case 5:19-cv-00036-RWS Document 161-5 Filed 12/09/19 Page 2 of 90 PageID #: 6606
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
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`MAXELL, LTD.,
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`Plaintiff,
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`vs.
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`APPLE INC.,
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` Civil Action No. 5:19-cv-00036-RWS
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`Defendant.
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`DECLARATION OF DR. JOSEPH A. PARADISO IN SUPPORT OF
`APPLE INC.’S PROPOSED CLAIM CONSTRUCTIONS
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`Case 5:19-cv-00036-RWS Document 161-5 Filed 12/09/19 Page 3 of 90 PageID #: 6607
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`I, Joseph A. Paradiso, declare and state as follows:
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`I.
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`INTRODUCTION
`1.
`My name is Dr. Joseph A. Paradiso. I am Professor and Associate Academic
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`Head, Program in Media Arts and Sciences, at the Media Lab of the Massachusetts Institute of
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`Technology. I am over the age of eighteen, and I am a citizen of the United States.
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`2.
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`I have been retained by defendant Apple Inc. (“Apple” or “Defendant”) in
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`connection with civil action Maxell, Ltd. v. Apple Inc., Case No. 5:19-cv-00036-RWS (E.D.
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`Texas), to provide my opinions regarding technical background, level of ordinary skill in the art,
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`and other subject-matter relevant to interpretation of certain disputed claim terms in the asserted
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`claims of U.S. Patent Nos. 6,748,317 (the “’317 patent”), 6,580,999 (the “’999 patent”),
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`6,430,498 (the “’498 patent”) (collectively, the “Asserted Navigation Patents”).
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`3.
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`I have been asked to provide my opinions on the following topics: (1) the
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`technology relevant to the Asserted Navigation Patents; (2) the state of the art at the time the
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`relevant patent applications were filed; (3) the level of ordinary skill in that field as of the filing
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`date of the application that yielded the Asserted Navigation Patents; (4) how those of ordinary
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`skill in the art at the time of the invention would have understood statements made by the
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`patentee during prosecution of the applications; and (5) how those of ordinary skill in the art at
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`the time of the invention would understand certain terms used in the claims of the Asserted
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`Navigation Patents.
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`4.
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`My opinions expressed in this declaration rely on my own personal knowledge
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`and experience. However, where I also considered specific documents or other information in
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`formulating the opinions expressed in this declaration, such items are referred to in this
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`declaration. This includes, but is not limited to, the Asserted Navigation Patents, their
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`prosecution histories (including, if applicable, inter partes review proceedings before the Patent
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`1
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`Trial and Appeal Board), prior art references cited during prosecution, certain extrinsic evidence
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`cited by Apple and/or Maxell as part of their claim construction disclosures, and Maxell Ltd. v.
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`Huawei Device USA Inc. et al., Case No. 5:16-cv-00178-RWS, Dkt. No. 175, Claim
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`Construction Memorandum and Order (January 31, 2018).
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`II.
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`QUALIFICATIONS
`5.
`I received a B.S. in electrical engineering and physics from Tufts University in
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`1977 and a Ph.D. in physics from the Massachusetts Institute of Technology (MIT) in 1981.
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`Currently, I am the Alexander W. Dreyfoos (1954) Professor and Associate Academic Head in
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`the Program in Media Arts and Sciences at the MIT Media Laboratory.
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`6.
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`For over three decades, I have been involved with the research and development
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`of sensor technology in a variety of applications. For example, after receiving my Ph.D., I was a
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`post-doctoral researcher at the Swiss Federal Institute of Technology (ETH) in Zurich from 1981
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`to 1983, where I worked on sensor technology for high-energy particle physics. Following my
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`post-doctoral position at ETH, I was a physicist at the Draper Laboratory until 1994, where I was
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`a member of the Control and Decision Systems Directorate and Sensor and Signal Processing
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`Directorate. There, my research encompassed spacecraft control systems, image processing
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`algorithms, underwater sonar, and precision alignment sensors for large high-energy physics
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`detectors.
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`7.
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`In 1994, I joined the MIT Media Lab, a research laboratory, founded in 1985, that
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`promotes a unique, Interdisciplinary culture and focuses on highly-collaborative research that
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`joins seemingly disparate technological and academic fields. Researchers at the MIT Media Lab
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`have pioneered areas such as wearable computing, tangible interfaces, and affective computing,
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`which has led to numerous products and platforms that have become a ubiquitous part of
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`consumer life today. Examples of technologies that have spun off from the Media Lab’s
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`research include e-readers, such as the Amazon Kindle and Barnes & Noble Nook, the popular
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`video game Guitar Hero, the MPEG-4 structured audio format, the first bionic lower-leg system
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`for amputees, wireless mesh networks developed by Nortel, and the Mercury RFID Reader,
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`commercialized by spin-off ThingMagic. Today, the Lab is supported by more than 80
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`members, including some of the world’s leading corporations that represent the fields of
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`electronics, entertainment, fashion, health care, toys, and telecommunications, among others.
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`Currently, faculty members, research staff, and students work in over 25 research groups and
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`initiatives on more than 450 projects that range from digital approaches for treating neurological
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`disorders, to advancing imaging technologies that can “see around a corner,” to the word’s first
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`“smart” powered ankle-foot prosthesis.
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`8.
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`When I joined the Media Lab, I focused on developing new sensing modalities for
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`human-computer interaction, which, by 1997, evolved into wearable and non-wearable wireless
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`sensing and distributed sensor networks to measure movement activity. This work anticipated
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`and influenced transformative products and industries that have blossomed in recent years.
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`9.
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`For example, in 1997, I developed a shoe with wireless sensors for measuring
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`dynamic movement of the human foot during, for example, interactive dance and other physical
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`activities. The shoe was intended to capture motion data, which were mapped into different
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`information representations to facilitate interactivity. The design of this sensor-laden wireless
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`shoe is now recognized as a watershed in the field of wireless sensing for activity tracking and
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`was an inspiration for the Nike+, one of the very first activity trackers and the first commercial
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`product to integrate dynamic music with monitored exercise. My team went on to pioneer on-
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`shoe sensor architecture for clinical gait analysis in collaboration with the Massachusetts General
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`Hospital (MGH) in 2002. We then worked in sports medicine with another MGH collaboration
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`that developed an attachable, ultra-wide-range, wireless inertial measurement unit system for
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`evaluating professional baseball pitchers and batters in 2007.
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`10.
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`Leading to over 300 publications, 17 issued patents, and a string of awards in the
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`Pervasive Computing, Human-Computer Interaction, and sensor network communities, my
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`research has become the basis for widely established curricula. Many of these publications are
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`directed to fixed, wearable, or portable sensor devices. I have also advised over 55 graduate
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`(M.S. and Ph.D) theses for students who have done their work in my research group, and served
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`as a reader for roughly 100 M.S. and Ph.D. students in other groups and at other universities.
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`11.
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`I have given over 300 invited talks, panel appearances, and seminars worldwide,
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`recently keynoting on topics relating to ubiquitous sensing and the Internet of Things (IoT) for
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`prestigious venues ranging from the Sensors Expo (the main industrial sensors conference) to the
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`World Economic Forum. I am frequently asked to address industrial groups on sensing systems
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`and IoT. For example, I recently gave the opening keynote at IoT Solutions World Congress in
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`Barcelona, the leading Industrial IoT event, and I have been on the Editorial Board (and have
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`served as Associate Editor in Chief) of IEEE Pervasive Computing Magazine (the original
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`flagship publication in this area) since 2006. I often engage with the Media Lab’s extensive list
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`of industrial partners in strategizing these areas.
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`12.
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`I also belong to and participate in numerous professional organizations. I am a
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`senior member of the Institute of Electrical and Electronics Engineers (IEEE), and also belong to
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`the Association for Computer Machinery (ACM). I also belong to the American Physical Society
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`(the major professional society in physics), and am a senior member in the American Institute of
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`Aeronautics and Astronautics (AIAA). Within the IEEE, I belong to the Signal Processing
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`Society, the Controls Society, and the Computer Society. I have served on many Technical
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`Program Committees (which solicit, review, and select papers for academic conferences) and
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`journal editorial boards. I have also organized academic conferences in areas such as wireless
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`sensor networks, wearable computing and wearable sensing, human-computer interfaces,
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`ubiquitous computing, and the like.
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`13.
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`Further details of my relevant work history, awards, honors, publications, and
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`other background are found in my current curriculum vitae (“CV”), attached as Exhibit A. The
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`list of litigation matters in which I have been engaged can be found in my CV.
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`14.
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`I am being compensated at my usual rate of $600 per hour, plus reimbursement
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`for expenses, for my analysis. My compensation does not depend on the content of my opinions
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`or the outcome of this proceeding.
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`III. LEGAL STANDARDS
`15.
`I have been informed that the words of a claim are generally given the ordinary
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`and customary meaning that the term would have to a person of ordinary skill in the art at the
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`time of the invention. I understand that there are exceptions to this general rule if: (1) the
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`patentee, in the specification or prosecution history, defined a claim term to have a meaning
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`different from its ordinary meaning, or (2) the patentee disclaimed or disavowed patent scope in
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`the specification or prosecution history.
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`16.
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`I have been informed that to determine how a person of ordinary skill would
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`understand a claim term, courts may consider both “intrinsic” and “extrinsic” evidence. I
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`understand that courts look first to the intrinsic evidence of record, which includes the patent
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`itself (including the claims, specification, and drawings) and its prosecution history. I also
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`understand that courts may consider extrinsic evidence, such as expert and inventor testimony,
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`dictionaries, and learned treatises.
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`17.
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`I have been informed that a person of ordinary skill in the art is deemed to read
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`the claim term not only in the context of the particular claim in which it appears but also in the
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`context of the entire patent, including the specification, drawings, and prosecution history.
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`18.
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`I have been informed that a term must be interpreted with a full understanding of
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`what the inventors actually invented and intended to include within the scope of the claim as set
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`forth in the patent itself. Thus, claim terms should not be broadly construed to encompass
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`subject matter that is technically within the broadest reading of the term but is not supported
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`when the claims are viewed in light of the invention described in the specification. I have also
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`been informed that when a patent specification repeatedly and consistently characterizes the
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`claimed invention in a particular way, it is proper to construe the relevant claim terms in
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`accordance with that characterization.
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`19.
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`I have been informed that the prosecution file history of the patent provides
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`additional evidence of how both the Patent Office and the inventors understood the terms of the
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`patent, particularly in light of what was known in the prior art. I understand that arguments and
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`amendments made during prosecution may further require a narrow interpretation of a claim
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`term, even if that term is used more broadly in the specification.
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`20.
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`I have been informed that a patent must be precise enough to afford clear notice
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`of what is claimed and apprise the public of what subject matter is still open to them in a manner
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`that avoids uncertainty. I understand that a claim term is indefinite if, when the term is viewed in
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`light of the specification and prosecution history, it fails to inform one skilled in the art about the
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`scope of the invention with reasonable certainty. The definiteness requirement must take into
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`account the inherent limitations of language; reasonable certainty in light of the subject matter,
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`and not absolute precision, is required.
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`21.
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`I have been informed that the proper construction of a “means-plus-function”
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`claim limitation is governed by pre-AIA 35 U.S.C. § 112, ¶ 6, which provides:
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`An element in a claim for a combination may be expressed as a means or step
`for performing a specified function without the recital of structure, material,
`or acts in support thereof, and such claim shall be construed to cover the
`corresponding structure, material, or acts described in the specification and
`equivalents thereof.
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`22.
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`I have been informed that if a claim element contains the word “means” and
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`recites a function, that element is presumed to be a “means-plus-function” limitation. Further, I
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`also understand that when a claim element fails to sufficiently definite structure or recites
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`function without reciting sufficient structure for performing that function, that claim element
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`should be construed as a “means-plus-function” limitation.
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`IV.
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`LEVEL OF ORDINARY SKILL IN THE ART
`23.
`Based on my review of the patents and their prosecution histories, and based on
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`my years of experience working, researching, and teaching in the field of human-computer
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`interfaces, my opinion is that a person of ordinary skill in the art around the filing of the Asserted
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`Navigation Patents would have had a Bachelor of Science Degree in Electrical/Computer
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`Engineering or Computer Science (or equivalent degree), and at least one year of experience
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`working in the field of location- or sensor-based human-computer interaction.
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`24.
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`Around the filing of the Asserted Navigation Patents, I would have qualified as a
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`person of ordinary skill in the art under the definition I provided above. As stated above, I hold a
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`Bachelor of Science Degree in electrical engineering, and I have performed research and
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`development of sensor technology in a variety of applications, including underwater sonar,
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`wearable movement detection, and wireless sensor networks, among many others. The opinions
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`expressed in this declaration would not change if the level of experience varied by a few years.
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`7
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`V.
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`THE ASSERTED NAVIGATION PATENTS
`25.
`The Asserted Navigation Patents relate generally to navigation systems and more
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`specifically to portable terminals suitable for “walking navigation.” The Abstract of the ’317
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`Patent recites, for example:
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`A portable terminal has a function of walking navigation. The
`direction of a destination is displayed by an indicating arrow that
`always points in the direction of the destination. In the navigation
`processing, the user enters data to select a menu and/or set
`retrieving conditions on the setup screen. At first, the user gets the
`location information of the portable terminal, represented by a
`latitude/longitude or coordinates and an altitude, for example.
`Then, the user gets the direction information of the portable
`terminal, which is the direction of the tip of the portable terminal
`as determined by a compass, a gyro, or a clinometer. The location
`information and the direction information are set as terminal
`information for the retrieving conditions. The system controls
`retrieving of the database and retrieves the information
`corresponding to the selected menu, such as route guidance.
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`’317 Patent at Abstract.1 Specifically, the ’317 Patent describes a portable terminal, which does
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`not require a user to input their current location and that presents navigational information on a
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`narrow screen of the portable terminal in a manner easily understood by the user/walker. Id. at
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`2:51-61. The portable terminal includes devices for obtaining a location and direction of the
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`user’s present place, so that the user does not have to input such information. Id. at 2:62-3:8.
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`The portable terminal may also compress the location and direction information, so as to display
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`a direction of movement from the user’s present place with an arrow. This enables the
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`navigation information to be displayed on a small-sized screen in a manner easily understood to
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`the user/walker. Id. at 3:18-26.
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`VI.
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`THE DISPUTED CLAIM TERMS
`A.
`“a device for getting location information …” terms (’498, Claims 1, 5, 10;
`’999, Claims 1, 5, 6; ’317, Claims 1, 6, 10)
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`1 The specifications of all three Asserted Navigation Patents are substantially identical.
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`26.
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`I am informed that the parties propose the following constructions:
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`Claim Term
`“a device for
`getting location
`information …”
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`“a device for
`getting location
`information
`denoting a
`present place of
`said portable
`terminal”
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`Apple’s Proposal
`This claim term should be governed
`by pre-AIA 35 U.S.C. § 112, ¶ 6.
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`Claimed Function: getting
`location information [denoting a
`present place of said portable
`terminal]
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`Disclosed Structure: a wireless or
`cellular antenna, or a GPS, or a
`Personal Handyphone System
`(PHS); and an infrared ray sensor;
`and a control unit for analyzing
`received data, with the control unit
`calculating location information as
`disclosed in ’498 at 5:48-56 and
`Fig. 2; or equivalents thereof
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`Maxell’s Proposal
`Function: getting location
`information denoting a present
`place of said portable terminal
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`Structure: a wireless or cellular
`antenna, a GPS, a PHS, or the like;
`such a data receiver as an infrared
`ray sensor, or the like; and a CPU
`for analyzing received data; or
`equivalents thereof. See ’317,
`9:51-56
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`27.
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`The terms “a device for getting location information” and “a device for getting
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`location information denoting a present place of said portable terminal” have no accepted
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`meaning in the art that I am aware of. In my view, these terms do not connote any specific
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`structure, and the word “device” is no more specific to me than a generic term such as “means.”
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`28.
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`I understand that both Apple and Maxell agree that this claim term is a means-
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`plus-function term. Therefore, I have analyzed the specification to identify the structure
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`disclosed to perform the recited function. The specifications of the Asserted Navigation Patents,
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`however, describe the structure required to carry out the function of “getting location
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`information.” For example, Figure 10 of the ’498 Patent depicts a “device for getting location
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`information” 77 and a “device for getting direction information” 78. See below:
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`The ’498 specification describes the structures of these two devices as follows:
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`• “For example, such a wireless antenna as a GPS, a [Personal Handyphone System, or
`“PHS”], etc., as well as an infrared ray sensor is used to measure location information.”
`’498 patent at 4:9-11.
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`• “The device for getting location information 77 is provided with such a wireless antenna,
`a GPS, a PHS, or the like; such a data receiver as an infrared ray sensor, or the like; and a
`control unit for analyzing received data, thereby calculating location information.” Id. at
`9:39-44.
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`• “The device for getting direction information 78 is provided with a compass, a gyro, such
`a sensor as a clinometer, and a control unit for analyzing sensor-measured data, thereby
`calculating direction information.” Id. at 9:44-47.
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`The “device for getting location information,” according to the ’498 specification, therefore
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`requires a wireless receiver (such as a wireless antenna, a GPS, or PHS, etc.), and an infrared ray
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`sensor, and a control unit “for analyzing received data, thereby calculating location
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`information.” Id.
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`10
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`29.
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`The goal of the Asserted Navigation Patents is to facilitate walking navigation,
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`i.e., providing location information to a walking user. See ’498 Patent at 1:10-13. To achieve
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`this, a POSITA would understand that the experience of the walking user would be improved by
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`providing functional location determination for both open/outdoor areas and in obstructed/indoor
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`areas. Especially at or around the time of the alleged invention, 1999, GPS/wireless signals
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`worked well in outdoor or otherwise unobstructed areas, but were not ideal for providing
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`location information indoors or in environments where signals are obstructed. See, e.g. Abowd,
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`et al. “Cyberguide: A Mobile Context-Aware Tour Guide,” Baltzer Journals (Sept. 23, 1996)
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`(“Abowd”) at 8 (APL-MAXELL_00713087) (“Indoors, however, GPS signals are weak or not
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`available”); Starner, et al., “The Locust Swarm: An environmentally-powered, networkless
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`location and messaging system,” IEEE (1997) (“Starner”) at 1 (“Unfortunately, the radio
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`frequencies used [by GPS] prevent the system from being effective indoors.”)
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`30.
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`At around the time of the alleged invention, I am aware that combinations of
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`infrared sensors and beacons were often used to provide location information in places where
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`GPS was unavailable, such as indoors. For example, I have launched and run several projects in
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`my own research team that leveraged and developed localization technology of various sorts,
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`have put together classes at MIT involving indoor localization (e.g., MAS.S61, ‘Emerging
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`Technologies in Location-Aware Computing’), and have advised students in my own group and
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`across the Media Lab and MIT in this area. Several of my projects have used IR and/or RF to
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`locate users within a building or relative to one another. See, e.g., UberBadge, a wearable
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`computer platform with multiple processors, including RF and IR communication
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`(https://resenv.media.mit.edu/#Projects#the-uberbadge).
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`31.
`
`Therefore, to achieve the goal of walking navigation, a POSITA would have
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`understood, consistent with the disclosures in the specification, that a combination of GPS and
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`some means of indoor location determination, likely an infrared sensor, would be required to
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`cover as many potential use scenarios as possible. Extrinsic evidence confirms that a POSITA at
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`the time of the alleged invention would have known that an infrared ray sensor was commonly
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`used, in conjunction with GPS, to obtain location information. Specifically, those skilled in the
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`art understood that infrared ray sensors were especially adept at determining location when a
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`walking user is indoors. See, e.g.:
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`• Starner at 1-2 (noting that radio frequencies used for GPS at that time prevented GPS
`from being effective indoors and proposing a solution that incorporates the use of a
`system of infrared receivers and transmitters);
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`• Abowd at 8-9 (noting the same problem and proposing as a solution the use of infrared
`receivers tuned to the same frequency as intermittently placed infrared beacons); and
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`• Marmasse, “comMotion: a context-aware communication system,” Mass. Inst. of Tech.
`(Sept. 1999) (noting the use of infrared receivers and transmitters for “interior location
`sensing”).
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`32.
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`I have also been informed that the Patent Trial and Appeal Board adopted in
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`IPR2019-00071 (ASUSTek Computer Inc., et al. v. Maxell, Ltd.) the construction that Apple now
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`proposes. There, the Petitioner ASUSTek proposed the same construction offered by Apple
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`here, and Maxell did not dispute it. The PTAB noted that the construction was “supported by the
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`cited portions of the Specification of the ’498 patent” (IPR2019-00071, Paper No. 7 at 9) which
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`were also excerpted above.
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`33.
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`I therefore agree with Apple’s proposed construction because it reflects the
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`understanding of a POSITA as of the priority date of the Asserted Navigation Patents: July 12,
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`1999.
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`34.
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`I am further informed that Maxell agrees that this term should be construed in
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`means-plus-function format, but contends that the function should be “getting location
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`information denoting a present place of said portable terminal” and that the corresponding
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`structure is “a wireless or cellular antenna, a GPS, a PHS, or the like; such a data receiver as an
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`infrared ray sensor, or the like; and a CPU for analyzing received data: or equivalents thereof.” 1
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`disagree with Maxell that the way it has phrased its proposed corresponding structure is how a
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`POSITA would have understood the invention. Particularly. it appears that Maxell contends that
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`any of the following list ofindividual components: (1) GPS, (2) antenna, or (3) PHS could each
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`individually be combined with both a CPU and a “data receiver” to perform the function of
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`“getting location information denoting a present place of said portable terminal.” This is
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`incorrect as, for example, an antenna could not be combined with a CPU to get location
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`information. This is further incorrect because, under Maxell’s proposed construction, any “data
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`receiver" could be used in place of an infrared ray sensor, and not all “data receivers” were
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`capable of obtaining location information in the manner that infrared ray sensors were. For
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`example, a POSl’l‘A would consider a USB port to be a “data receiver," and a USB port was
`
`never used, by itself, for location determination. Moreover, the only example of a data receiver
`
`disclosed by the Asserted Navigation Patents’ specification is an infrared ray sensor.
`
`35.
`
`l declare under the penalty of perjury under the laws of the United States of
`
`America that the foregoing is true and correct.
`
`Executed on 4th day ofOctober, 2019, M
`
`
`
`Joseph A. Paradise
`
`l3
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`

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`Case 5:19-cv-00036-RWS Document 161-5 Filed 12/09/19 Page 16 of 90 PageID #: 6620
`Case 5:19-cv-00036—RWS Document 161-5 Filed 12/09/19 Page 16 of 90 PageID #: 6620
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`EXHIBIT A
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`EXHIBIT A
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`

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`Case 5:19-cv-00036-RWS Document 161-5 Filed 12/09/19 Page 17 of 90 PageID #: 6621
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`
`MASSACHUSETTS INSTITUTE OF TECHNOLOGY
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`School of Architecture and Planning Faculty Personnel Record
`
`Joseph A. Paradiso
` Full Name:
`
` Department: Program in Media Arts and Sciences
`
`
`
`
`Date: January 2017
`
`
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`
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`1.
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`2.
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`3.
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`4.
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`5.
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`6.
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`7.
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`8.
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`Date of Birth:
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`December 20, 1955
`
`Citizenship:
`USA
`
`Immigration Status: N/A
`
`Education:
`
`
`School
`
`MIT
`
`Tufts University
`
` Degree
`
`
`
`
` Ph.D. in Physics
`
`
`
`BS in Electrical Engineering and Physics
`
`
`
`
`
`Date
`May, 1981
`May, 1977
`
`Title of Thesis for Most Advanced Degree:
`Characteristics of Muon Pair Production in P-P Collisions at Very High Energies as a
`Probe of Proton Constituents
`
`Principal Fields of Interest:
`Sensor Networks
`Ubiquitous Computing
`Energy Management in the Built Environment
`Human-Computer Interaction (HCI)
`
`Name and Rank of Other Departmental Faculty in Same Field: None
`Name and Rank of Faculty of Other Departments in Similar Fields:
`Non-MIT Experience (including military service):
`
`Employer
`
`
`
`
`Position
`Draper Laboratory
`
`
`
`Technical Staff
`Sensor and Signal Processing Directorate
`
`
`
`Swiss Federal Institute of Technology
`Visiting Scientist
`
`(ETH Zurich) Lab for High Energy Physics
`Swiss Federal Institute of Technology
`Visiting Scientist
`(ETH Zurich) Lab for High Energy Physics
`
`Draper Laboratory
`
`
`
`Technical Staff
`Control and Decision Systems Directorate
`
`Swiss Federal Institute of Technology
`Postdoc
`(ETH Zurich) Lab for Nuclear Physics
`
`
`Brookhaven National Laboratory
`
`Consulting Physicist 7/81
`
`Instrumentation Laboratory
`
`
`
`Beginning
`4/89
`
`
`8/92
`
`
`
`10/91
`
`Ending
`7/94
`
`10/92
`
`12/91
`
`2/84
`
`
`
`4/89
`
`
`
`11/81
`
`12/83
`
`10/81
`
`
`
`

`

`Case 5:19-cv-00036-RWS Document 161-5 Filed 12/09/19 Page 18 of 90 PageID #: 6622
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`
`
`
`Draper Laboratory
`
`
`
`
`
`History of MIT Appointments:
`Department
`
`
`
`Media Arts and Sciences
`
`Media Arts and Sciences
`
`Media Arts and Sciences
`
`Media Arts and Sciences
`
`Media Arts and Sciences
`
`Media Arts and Sciences
`
`Physics Department
`
`
`
`
`
`
`Engineering Aide,
`Summer Staff
`
`6/74
`
`
`
`9/77
`
`Beginning
`
`
`Rank
`7/15
`
`
`
`Professor
`7/07
`
`Associate Prof. w. Tenure
`7/02
`
`Associate Professor
`
`Principal Research Scientist 7/98
`
`Research Scientist
`
`7/94
`
`Research Affiliate
`
`1/93
`
`Compton Fellow
`
`9/77
`
`
`Ending
`present
`7/15
`7/07
`7/02
`7/98
`7/94
`9/80
`
`
`9.
`
`
`
`
`
`
`
`
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`10.
`
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`
`
`
`
`
`
`Consulting Record:
`Firm
`
`
`
`
`Morrison & Foerster LLP (Technical Expert)
`
`Gibson, Dunn & Crutcher LLP (Technical Expert)
`
`Banner & Witcoff, Ltd (Technical Expert)
`
`
`Weil, Gotshal & Manges LLP (Technical Expert)
`Moog Music Inc. (organized daylong seminar on research
`in electronic music at MoogFest 2014)
`
`
`
`Durie Tangri LLP (Technical Expert)
`
`
`Samsung Electronics (SRFC Expert Reviewer)
`
`Transitio Mexico City (electronic music seminar series)
`Nokia Research (visiting researcher at NRC Santa Monica)
`Swedish Foundation for Strategic Research (expert reviewer)
`Microsoft (visiting researcher at MSR Cambridge UK)
`
`Nokia Research Center Activity Review Panel
`
`
`UPF Barcelona (invited week-long seminar series)
`
`
`Microsoft Corp. (Distinguished ALT-TAB for Mobility)
`
`Swedish Foundation for Strategic Research (expert reviewer)
`A.I.E.P. Milano (Seminar series on computer music)
`
`Hermann Miller, Inc.
`
`
`
`
`
`Senera Corporation (Technology Advisory Board)
`
`
`Synectics, Inc.
`
`
`
`
`
`
`Swedish Foundation for Strategic Research (onsite evaluation)
`MediaLabEurope, Dublin
`
`
`
`
`
`Diller and Scofidio (architects)
`
`
`
`
`University of Limerick (Ireland), External Examiner for
`Graduate Program in Interactive Media
`
`
`IBM T.J. Watson Research Center
`
`
`
`British Telecom
`
`
`
`
`
`Fibersense, Inc. (Technology Board Member)
`
`Takata Inc., Automotive Systems Laboratory
`
`Boston University Photonics Center
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Beginning
`
`Ending
`
`10/16
`7/15
`
`8/14
`
`7/14
`
`4/14
`
`
`
`3/14
`
`2/14
`10/11
`7/11
`
`11/10
`7/10
`
`12/09
`4/09
`
`4/08
`
`3/08
`
`2/07
`
`1/05
`
`7/03
`
`7/04
`
`5/03
`
`6/01
`
`6/00
`
`
`
`9/99
`
`1/99
`
`4/97
`
`4/97
`11/96
`11/95
`
`11/16
`5/16
`11/14
`4/16
`4/14
`
`present
`present
`10/11
`8/11
`12/10
`8/10
`12/09
`4/09
`5/08
`4/08
`2/07
`8/06
`7/04
`7/04
`5/03
`6/02
`6/02
`
`9/04
`7/99
`3/99
`4/98
`12/96
`12/95
`
`

`

`Case 5:19-cv-00036-RWS Document 161-5 Filed 12/09/19 Page 19 of 90 PageID #: 6623
`
`
`Optron Systems, Inc.
`Lyle Mays, Inc.
`
`Draper Laboratory
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`12/93
`5/87
`
`1/78
`
`
`
`
`
`
`
`
`Beginning
`
`Department and Institute Committees, Other Assigned Duties
`
`Activity
`
`12/17
`
`
`MIT ‘Engine’ C