Case 6:21-cv-01101-ADA Document 34-12 Filed 06/09/22 Page 1 of 23
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`Exhibit 12
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`Case 6:21-cv-01101-ADA Document 34-12 Filed 06/09/22 Page 2 of 23
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`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`Plaintiff,
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`v.
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`Defendants.
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`Plaintiff,
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`Defendant.
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`Plaintiff,
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`v.
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`v.
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`AIRE TECHNOLOGY LTD.,
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`SAMSUNG ELECTRONICS CO., LTD. and
`SAMSUNG ELECTRONICS AMERICA, INC.,
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`AIRE TECHNOLOGY LTD.,
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`APPLE INC.
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`AIRE TECHNOLOGY LTD.,
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`GOOGLE LLC,
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`Case No. 6:21-cv-955-ADA
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`JURY TRIAL DEMANDED
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`Case No. 6:21-cv-1101-ADA
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`JURY TRIAL DEMANDED
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`Case No. 6:21-cv-1104-ADA
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`JURY TRIAL DEMANDED
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`Defendant.
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`DECLARATION OF DR. HUGH SMITH IN SUPPORT OF
`AIRE’S RESPONSIVE CLAIM CONSTRUCTION BRIEF
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`Case 6:21-cv-01101-ADA Document 34-12 Filed 06/09/22 Page 3 of 23
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`INTRODUCTION
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`I, Hugh Smith, Ph.D hereby declare and state as follows:
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`I.
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`1.
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`I have been retained by Plaintiff Aire Technology Ltd. (“Aire”) to provide my
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`opinions as to the scope and meaning of certain terms and phrases appearing in U.S. Patent No.
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`8,205,249 (“the ’249 Patent”) as a person of ordinary skill in the art at the time of the inventions
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`(“POSITA”). I understand that Defendants Samsung Electronics Co., Ltd. and Samsung
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`Electronics America, Inc. (“Samsung”), Apple Inc. (“Apple”), and Google LLC (“Google”)
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`(collectively, “Defendants”) have offered constructions for certain terms and phrases for the ’249
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`Patent. I have reviewed those constructions and provide my opinions on those constructions
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`herein.
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`2.
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`In rendering my opinions, I have reviewed the ’249 Patent and the respective file
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`history, as well as the extrinsic evidence offered by Defendants. My opinions are further based
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`upon over 40 years of education, training, research, knowledge, and personal and professional
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`experience in the relevant art.
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`3.
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`I reserve the right, if permitted by the Court, to supplement and/or amend my
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`opinions in this declaration based on future positions taken by Defendants, their experts, additional
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`documents, testimony, or other information provided by the Defendants or their witnesses, any
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`orders from the Court, or as otherwise necessary.
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`4.
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`A detailed record of my professional qualifications, including a list of publications,
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`awards, professional activities, and recent testimony either at trial or at deposition, has been
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`provided to Defendants and is attached hereto as Exhibit 1. I also included a list of cases in the
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`last five years that I have testified by trial or deposition.
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`5.
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`I am a tenured full professor in the Department of Computer Engineering at the
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`Case 6:21-cv-01101-ADA Document 34-12 Filed 06/09/22 Page 4 of 23
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`California Polytechnic State University. I also served as Director of the Cal Poly Computer
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`Engineering Program, both in 2009-2013 and again in 2016-2017. I received my B.S. degree in
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`Computer Science from Xavier University in 1985. I received my M.S. degree in Computer
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`Science from Michigan State University in 1994 with a research focus on parallel and distributed
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`computing. I received my Ph.D. in Computer Science in 1999 with a research focus on networking
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`and the transmission of video over the Internet from Michigan State University.
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`6.
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`Upon receiving my PhD, I joined the faculty of the Cal Poly Department of
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`Computer Science in 2000 and moved to Cal Poly’s newly created Department of Computer
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`Engineering in 2021. I have been teaching and doing research on computer networks, network
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`security, distributed systems, embedded systems, programming and robotics for the last 22 years.
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`I have developed and taught courses including an introduction to computer networks, advanced
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`computer networks, graduate level computer networks, embedded systems and robotics, and
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`digital design and microcontrollers. Course activities included both hardware and software, the
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`theoretical aspects of computer networks, security (including both privacy and authentication),
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`wired and wireless networks, and the implementation of protocol layers from the physical to the
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`application layer. As part of my teaching, I cover topics including privacy and authentication from
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`both a theoretical perspective as well as using these technologies in the real-world.
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`7.
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`I have over 40 years of experience in computer engineering and computer science.
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`In addition to my educational and teaching/research experience, I have professional experience in
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`computer system design and implementation. From 2011 to 2013, I developed, implemented, and
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`sold an Android App called Lockmenu. I was a Group Manager, Senior Systems Analyst/Project
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`Manager, and Systems Analyst for the Procter and Gamble Company from 1985-1992. I managed
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`all aspects of a large distributed Purchasing and Inventory Control system, which included over
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`Case 6:21-cv-01101-ADA Document 34-12 Filed 06/09/22 Page 5 of 23
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`2,000 users, processed over $250 million in yearly purchases, and tracked over $60 million in
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`inventory. I led a support team, designed and developed application software, managed capacity
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`planning, and on-going maintenance. Before that, I was a Programmer Analyst at the Merrell Dow
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`Research Institute from 1983-1985.
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`8.
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` I have reviewed the ’249 Patent and its prosecution history, and the subject matter
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`of the ’249 Patent is within the scope of my education and experience.
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`9.
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`I have been asked to provide my opinion as to the construction of certain terms and
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`phrases in the tables below, from the standpoint of a POSITA at the time of the respective
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`inventions.
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`10.
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`In my opinion, a POSITA would have at the time of the invention either (1) a
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`bachelor’s degree in computer science or computer engineering including experience in system
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`security and authentication and one to two years of work experience in systems involving security
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`and authentication or (2) equivalent work experience in the design and/or implementation of
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`systems involving security and authentication. As reflected in the level of ordinary skill, a person
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`of ordinary skill can have “equivalent education and work experience.” Thus, more education
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`could substitute for experience, and more experience (e.g., when combined with training), could
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`substitute for formal college education of the person of ordinary skill in the art. When performing
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`my analysis that led to my opinions, I apply this standard.
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`11.
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`I am being compensated by Aire at a rate of $700/hour for my work in this matter.
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`My compensation is not tied to the outcome of the case and I have no financial interest in the
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`outcome of the case.
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`12.
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`In forming my opinions, I have considered a variety of facts and materials. These
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`include all of the materials cited herein in this declaration. I have also relied on my more than 25
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`Case 6:21-cv-01101-ADA Document 34-12 Filed 06/09/22 Page 6 of 23
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`years of experience as a person of ordinary skill in the art in the field. I have also reviewed the
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`’249 Patent, its file history, and other extrinsic evidence cited herein.
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`U.S. PATENT NO. 8,205,249
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`II.
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`Aire’s Proposed Construction Defendants’ Proposed
`Construction
`Indefinite
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`Plain and ordinary meaning
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`Disputed Phrase
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`“an inherently relatively
`lower quality and an
`inherently relatively
`higher quality from a
`security perspective”,
`Claims 1 and 10
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`13.
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`I understand that the parties dispute whether the phrase “an inherently relatively
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`lower quality and an inherently relatively higher quality from a security perspective” in Claims 1
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`and 10 of the ’249 Patent is indefinite. I agree with Aire that no construction is necessary and that
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`the phrase is understood under its plain and ordinary meaning. I disagree with Defendants that the
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`phrase is indefinite.
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`14.
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`A POSITA would understand the meaning of the phrase “an inherently relatively
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`lower quality and an inherently relatively higher quality from a security perspective” with
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`reasonable certainty in light of the guidance provided by the ’249 Patent claims, specification, and
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`prosecution history. The disputed phrase requires (1) at least two different authentication methods
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`and (2) that they differ in their quality from a security perspective. The claims provide a standard
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`by which the difference in security quality is to be measured: the different authentication methods
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`are compared to one another, with one method being of an “inherently relatively lower quality” in
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`comparison to the other method comprising of a “inherently relatively higher quality.”
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`Additionally, the ’249 Patent provides objective criteria for determining whether a particular
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`method is of “lower” or “higher” quality from a security perspective—namely, that the “lower”
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`quality method comprise of a knowledge-based authentication method (e.g., PIN), whereas the
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`“higher” quality method comprise of a biometric-based authentication method (e.g., fingerprint).
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`15.
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`The ’249 Patent provides sufficient support to inform a POSITA with reasonable
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`certainty of the authentication methods that are “inherently relatively” lower or higher quality from
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`a security perspective. For example, the ’249 Patent specification explains the following:
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`It preferably supports at least two authentication methods of different order with
`regard to the quality of authentication. It expediently supports at least one
`knowledge-based authentication method, e.g. a PIN check, and at least one
`biometric method, within which a biometric feature of the user 30 to be presented
`at the terminal 14 is checked. The biometric method inherently constitutes the
`higher-quality one here, since it presupposes the personal presence of the user 30;
`this is not ensured in the knowledge-based method since the knowledge can have
`been acquired by an unauthorized user.
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`’249 Patent at 3:24-33.1 According to this embodiment, the “knowledge-based” method (e.g., a
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`PIN) is the inherently lower quality method in comparison to the “biometric” method, which
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`constitutes the inherently higher quality method. See also ’249 Patent at 3:58-62 (“it will
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`hereinafter be assumed that the chip card 20 supports two authentication methods, namely a PIN
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`check as a knowledge-based, inherently low-quality method, and a fingerprint check as a
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`biometric, inherently higher-quality method.”). The ’249 Patent also teaches in this embodiment
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`that the “biometric” is “inherently” of “higher-quality” because “it presupposes the personal
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`presence of the user,” whereas the “knowledge-based method” is “inherently” of “lower-quality”
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`because “the knowledge can have been acquired by an unauthorized user.” ’249 Patent at 3:24-
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`33; see also 1:31-36 (“The intended introduction of biometric features for user authentication
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`obtains a further improvement of the trustworthiness of an electronic signature compared to the
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`hitherto usual PIN authentication, because it guarantees that the signature card can only be used in
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`1 All emphasis added unless stated otherwise.
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`Case 6:21-cv-01101-ADA Document 34-12 Filed 06/09/22 Page 8 of 23
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`the presence of a definite person entitled to do so.”).
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`16.
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`The ’249 Patent provides further examples that define the objective criteria for both
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`the “inherently relatively lower quality” and “inherently relatively higher quality” authentication
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`methods. For example, the “inherently relatively higher quality” authentication methods are
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`consistently described in the context of “biometric” authentication methods. See, e.g., ’249 Patent
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`at 3:24-33, 3:58-62, 5:31-38. The ’249 Patent explains that the “biometric” authentication method
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`may include “detecting physiological features, such as facial features, features of the eye or
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`fingerprints, or behavior-based features, such as speech or writing sequences expressed by the
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`voice or by writing operations.” ’249 Patent at 2:59-63.
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`17.
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`In connection with its discussion of the “biometric” authentication methods, the
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`’249 Patent references Chapter 8.1.2 of “Handbuch der Chipkarten” (hereinafter “Chip Card
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`Manual”), W. Rankl, W. Effing, 3rd edition, 1999. ’249 Patent at 1:12-14, 2:67 – 3:2. I have
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`reviewed Chapter 8.1.2 of the “Chip Card Manual” and agree that it teaches “different types and
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`the implementation of biometric authentication methods.” For example, Chapter 8.1.2 explains
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`that “[a] biometric identification method is a method that can unambiguously identify a person by
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`means of unique, individual biological features.” Chip Card Manual at 499. Additionally, the
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`“Chip Card Manual” explains that “[b]iometric features are usually not modifiable, which is
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`precisely what makes them attractive for the unambiguous identification of persons.” Chip Card
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`Manual at 500. Chapter 8.1.2 further provides a discussion of different authentication methods:
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`Chip Card Manual at 500. Each of these biometric authentication methods are further detailed
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`therein. Chip Card Manual at 504-510. Thus, the ’249 Patent specification provides objective
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`criteria concerning the “inherently relatively higher quality” authentication methods, which are
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`taught as “biometric” authentication methods.
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`18.
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`The ’249 Patent contrasts the “higher” quality biometric authentication methods
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`with “lower” quality authentication methods that are knowledge-based, such as a password or PIN.
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`See, e.g., ’249 Patent at 1:62 – 2:3, 3:29-33, 3:58-62. The ’249 Patent explains that knowledge-
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`based methods, for example, are inherently “lower” quality to biometric authentication methods
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`because “the knowledge can have been acquired by an unauthorized user.” Id. at 3:31-33. Further,
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`Chapter 8.1.2 of the “Chip Card Manual” also explains that “biometric features cannot be
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`transferred to another person as easily as PINs” and “[t]his means that the actual person is
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`identified, rather than a secret shared by the user and the system operator.” See Chip Card Manual
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`at 499. This discussion underscores that a knowledge-based authentication is of inherently lower
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`quality than a biometric method. As such, the ’249 Patent specification also provides clear,
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`objective criteria concerning the “inherently relatively lower quality” authentication methods,
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`which are taught as knowledge-based authentication methods.
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`Case 6:21-cv-01101-ADA Document 34-12 Filed 06/09/22 Page 10 of 23
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`19.
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`The prosecution history also sheds light on the meaning of the “lower” and “higher”
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`quality authentication methods taught in the ’249 Patent. For example, on multiple occasions the
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`patentee clarified that the “lower” quality authentication methods are premised on knowledge-
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`based authentication methods, while the “higher” quality authentication methods are premised on
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`biometric authentication methods:
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`Different authentication methods provide different levels of protection. For
`example, a PIN check as a knowledge-based method is an inherently low-
`quality method while a fingerprint check as a biometric check method is an
`inherently higher-quality method (see page 5, lines 25 30 of the originally filed
`specification and the amended specification filed on May 18, 2009). The PIN
`check is a lower quality authentication method since a user merely needs to
`gain knowledge of the PIN to be successfully authenticated. A biometric check
`method is a higher quality method since it would be more difficult for a user
`to duplicate a fingerprint in order to be authenticated and thus, the check
`“presupposes the personal presence of the user” (see specification, page 5, lines
`3-5).
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`See U.S. Patent App. No. 10/531,259, March 30, 2011 Applicant Remarks; see also U.S. Patent
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`App. No. 10/531,259, May 27, 2010 Applicant Remarks (“The portable data carrier itself is set up
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`to perform at least one but expediently a plurality of different quality user authentication methods,
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`preferably at least two different authentication methods having a different order of security. For
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`example, it may support at least one knowledge-based authentication method (a PIN check), and
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`at least one biometric method. Obviously, the biometric method inherently constitutes a higher
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`quality method of authentication as compared with the knowledge-based authentication
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`method (id., page 5, first paragraph).”). The patentee’s statements during prosecution reinforce
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`the ’249 Patent’s teachings concerning the scope of the “inherently relatively higher” and
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`“inherently relatively lower” authentication methods.
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`20.
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`I disagree with Defendants that the patentee’s addition of the word “inherently” to
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`the ’249 Patent specification and claims adds confusion as to the meaning of the disputed phrase.
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`Case 6:21-cv-01101-ADA Document 34-12 Filed 06/09/22 Page 11 of 23
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`Defendants’ Brief at 18-19. A review of the amendments and corresponding explanation reveals
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`that the patentee further clarified the scope of the claim. For example, the patentee amended Claim
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`10 as follows:
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`10. (Currently Amended) A portable data carrier for performing a security-
`establishing operation within a secure electronic transaction and arranged to
`perform different quality user authentication methods, wherein the difference in
`quality of user authentication varies between an inherently relatively lower quality
`and an inherently relatively higher quality from a security perspective, whereby the
`portable data carrier is arranged to perform a user authentication using one of said
`implemented user authentication methods and the portable data carrier is arranged
`to confirm the authentication to a terminal, and wherein the data carrier is arranged
`to create quality information about said stating how the authentication of the user
`was performed by the used user authentication method used and to attach such
`quality information to the result of the security establishing operation.
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`See U.S. Patent App. No. 10/531,259, May 18, 2009 Amendments. The patentee explained that
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`the amendments clarified the distinction between the categories of authentication methods utilized
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`by the claimed inventions:
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`Claim 1 has been amended to clarify the intended meaning of the claim without
`affecting the scope of the claim as previously presented. The difference in
`quality of the user authentication specifically is clarified by denoting that the
`quality may be inherently a relatively lower quality or inherently a relatively
`higher quality from a security perspective. Support for the amendment is found
`on page 5, last paragraph wherein the terms “low-quality” and “higher-quality” are
`used to describe two authentication methods. The word “inherently” has been
`added for clarification to indicate that the method itself inherently provides
`less security or more security depending on the nature of the method (e.g.,
`biometric versus PIN). The objective of the amendment is to better define the
`inherent nature of the user authentication method from a security perspective.
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`See U.S. Patent App. No. 10/531,259, May 18, 2009 Applicant Remarks. This explanation was
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`provided in the context of an obviousness objection based on art that taught that the user may use
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`one of different authentication methods—however, the prior art did not teach that the different
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`authentication methods utilized by the user differed in quality from a security perspective and that
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`information regarding the quality of the method used is attached to the result of the security
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`Case 6:21-cv-01101-ADA Document 34-12 Filed 06/09/22 Page 12 of 23
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`establishing operation. May 18, 2009 Applicant Remarks at 8. To that end, the patentee added
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`the language in the context of broader amendments to clarify that the two authentication methods
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`must be “inherently” distinct from a security perspective.
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`21.
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`I also disagree with Defendants’ other arguments that the disputed phrase does not
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`define the scope of the “inherently relatively lower” and “inherently relatively higher”
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`authentication methods. For example, Defendants argue that the ’249 Patent “does not enable a
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`POSITA to determine, for example, whether a token-based method is of inherently higher or lower
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`(or equivalent) quality than a knowledge-based method.” Defendants’ Brief at 16. According to
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`the Defendants, a “token-based” method is “something you have,” such as “a key fob or ID badge.”
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`Defendants’ Brief at 14. But a “token-based” method does not make sense in the context of the
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`claimed portable data carrier because the portable data carrier is in and of itself “something you
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`have.” The ’249 Patent contemplates that merely possessing the portable data carrier (the “token,”
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`as defined by Defendants) is not sufficient—there needs to be another category of authentication
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`(e.g., knowledge-based and/or biometric authentication) used in connection with the portable data
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`carrier. See ’249 Patent at 1:65 – 2:3. The patentee made this point in distinguishing the prior art
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`during prosecution of the ’249 Patent:
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`While Russo mentions the use of smart cards in the written description of the
`published application, the smart cards are used to support a specific
`authentication method during user authentication (using something you have)
`but none of the data carriers is arranged to perform different quality user
`authentication methods and to perform user authentication using one of the
`different user authentication methods.
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`See U.S. Patent App. No. 10/531,259, May 27, 2010 Applicant Remarks. As this passage explains,
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`the ’249 Patent contemplates that a “token-based” method is not sufficient and that there needs to
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`be another category of authentication tied to the token.
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`22.
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`I also disagree with Defendants’ argument that the ’249 Patent lacks “whether any
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`given authentication method is of inherently relatively higher or lower (or equivalent) quality than
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`any other method within the same category,” such as two biometric methods. Defendants’ Brief
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`at 16. This argument is unpersuasive because the use of two methods within the same category is
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`not the distinction required by the ’249 Patent. Instead, the claims require a comparison between
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`authentication methods that differ inherently from a security perspective, for example knowledge-
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`based vs. biometric-based authentication methods. To that end, the ’249 Patent treats biometric
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`methods as the “inherently relatively higher quality” methods and are contrasted with lower-
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`quality knowledge-based authentication methods.
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`23.
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`I also find Defendants’ argument that the ’249 Patent does not provide guidance on
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`how to treat as to “multi-category” authentication methods unpersuasive. Defendants’ Brief at 16.
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`For example, Defendants argue that the ’249 Patent fails to provide “guidance on how to determine
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`if a given multi-category authentication method (e.g., fingerprints entered in a specific order) is of
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`inherently relatively higher or lower (or the same) quality as another multi-category method (e.g.,
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`fingerprint entered into a key fob), or as a single category method.” Defendants’ Brief at 16. But
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`the ’249 Patent contemplates that the use of “fingerprints” (whether in a specific order or not) is
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`considered a “biometric” method of “inherently higher quality” from a security perspective. See
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`’249 Patent at 2:59-63, 3:58-62. Further, as explained above, the “token-based” methods described
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`by Defendants are unpersuasive in light of the teachings of the ’249 Patent. For these reasons,
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`Defendants’ “multi-factor” authentication examples do not add any uncertainty to the contours of
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`the ’249 Patent.
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`24.
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`I also disagree with Defendants’ argument that the ’249 Patent’s teachings that
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`“biometrics are inherently more secure than knowledge-based methods” by arguing that this is
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`“incompatible with a POSITA’s understanding.” Defendants’ Brief at 16-17. Based on my
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`understanding of the ’249 Patent claims, specification, and prosecution history, the ’249 Patent’s
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`teachings that the “biometric” authentication methods are “inherently relatively higher quality”
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`when compared to knowledge-based authentication methods is taught with reasonable certainty.
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`Whether there may be instances where one biometric method is more secure than another biometric
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`method or whether there are instances where a biometric is not used in accordance with its intended
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`use (for example, using facial recognition or fingerprint input on someone who is “sleeping” or
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`“unconscious”) does not bear on the ultimate issue of whether the ’249 Patent teaches that
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`“biometric” authentication methods constitute those with “inherently relatively higher quality”
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`from a security perspective with reasonable certainty within the context of the ’249 Patent.
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` declare under the penalty of perjury under the laws of the United States that the above is
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` I
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`true and correct.
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`Executed on this 9th day of June, 2022 in San Luis Obispo CA.
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`By: _____________________________
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`Hugh Smith, Ph.D.
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`Exhibit 1
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`Case 6:21-cv-01101-ADA Document 34-12 Filed 06/09/22 Page 16 of 23
`Hugh M. Smith, Ph.D.
`hms@husmith.com
`(805) 550-8023
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`
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`I.
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`Education
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`Ph.D. in Computer Science November 1999
`Michigan State University, College of Engineering
`Dissertation Title: Multicast Videoconferencing over Internet Style Networks
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`Masters of Science in Computer Science, December 1994
`Michigan State University, College of Engineering
`Research Focus: Parallel and Distributed Computing
`
`
`
`Bachelors of Science in Computer Science, May, 1985
`Xavier University, College of Arts and Science
`
`
`II. Academic Experience:
`
`9/16-6/17, 9/09 – 6/13, Director of the Cal Poly Computer Engineering Program
` Associate Director of the Computer Engineering Program, 2007-2009
`
`9/21-present, Department of Computer Engineering, California Polytechnic State University
`1/00 – 9/21, Department of Computer Science, California Polytechnic State University
` Tenured Full Professor in the Department of Computer Science/Computer Engineering
` Awarded the Computer Engineering Program Most User Friendly Award (“In recognition
`of your commitment and dedication to student success), 2015
` Awarded the Computer Science Department Professor of the Year, 2006
` Awarded the College of Engineering/TRW Teaching in Excellence award, 2002.
` Awarded the Computer Engineering Program Instructor of the Year, 2002.
` Awarded the Computer Engineering Program Lab Instructor of the Year, 2001.
` Laboratory Manager for the Cal Poly Advanced Networking Laboratory, 2001-2007
` Developed and taught the senior level Computer Networks I and Networks II courses.
`Course activities included the theoretical aspects of computer networks, security, wired
`and wireless networks, and the implementation of protocol layers from the physical to
`application layer. Courses include reinforcement of these concepts through socket
`programming and hands-on networking experience (routers/switches) in Cal Poly’s
`Advanced Networking Laboratory.
` Developed and taught the Graduate Level Computer Networks course. This course
`involves the study and analysis of the theory and implementation of both academic and
`industry research of computer networks.
` Taught the Introduction to Computer Science, System Programming, and Digital
`Electronics Computer Engineering Program courses.
`
`
`
`March 22, 2022
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`

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`Case 6:21-cv-01101-ADA Document 34-12 Filed 06/09/22 Page 17 of 23
`
`Dr. Hugh M. Smith
`
`
`5/98 – 7/98, Instructor, Department of Computer Science and Engineering, Michigan State
`University
` Taught the “Algorithms and Computing” course, which covered an introduction to
`computer science and programming in C++.
`
`
`9/92 – 5/96, Teaching Assistant, Department of Computer Science and Engineering, Michigan
`State University
` Courses included Object Oriented Programming and Computer Architecture
`
`
`III. Professional Experience:
`
`3/10 – 6/13, Android Mobile Phone App Development
` Developed and released the Android App Lockmenu (www.lockmenu.com)
` Managed the design, implementation, testing, marketing and patent submission for
`the Lockmenu app.
`
`12/03 – present, Intellectual Property Consulting
` Worked as a IP Expert Witness on hardware and software related cases. Work
`included both infringement and invalidity analysis.
` Wrote expert reports and testified in both depositions and trials
`
`
`7/00 – 8/00, Faculty Employment, Cisco Systems
` Responsibilities included development of a process for setting up Advanced Networking
`Labs at teaching universities.
`
`
`9/95 – 5/98, Research Assistant, Department of Computer Science and Engineering, Michigan
`State University
` Researched issues involved in the transmission and control of multicast video over
`heterogeneous networks.
` Addressed issues in controlling multicast video using various compression algorithms
`(MPEG, Motion JPEG) over ATM and Ethernet networks.
`
`
`5/93 – 8/93, Research Assistant, Department of Computer Science and Engineering, Michigan
`State University
` Researched issues in developing AI systems to provide real-time diagnostics tools.
`
`5/85 – 8/92 The Procter and Gamble Company, Cincinnati, Ohio
`9/90 - 8/92, Group Manager,
`5/89 - 9/90, Senior Systems Analyst/Project Manager
`5/85 - 5/89, Systems Analyst
` Managed all aspects of a large distributed Purchasing and Inventory Control system,
`which included over 2,000 users, processed over $250 million in yearly purchases, and
`tracked over $60 million in inventory.
` Managed five-person support team that involved recruiting, training, performance
`appraisals and development plans.
`
`
`
`
`
`(2/5)
`
`
`
`
`
`
`
`
`
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`

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`Case 6:21-cv-01101-ADA Document 34-12 Filed 06/09/22 Page 18 of 23
`
`Dr. Hugh M. Smith
`
` Led a division wide effort as a Project Manager to develop a decentralized quality
`monitoring information system.
` Coordinated hardware and software upgrades, capacity planning, and on-going
`maintenance as a computer System Manager.
`
`
`5/83 – 5/85, Programmer Analyst, Merrell Dow Research Institute, Cincinnati, Ohio
` Responsible for system development and support.
`
`
`
`
`IV. Research related activities
`
`
` 
`
` Presented the paper titled: An Embedded System Design Experience for First Year
`Computing Majors, at the 8th annual FYEE Conference, Columbus Ohio, August 2016.
`
` Presented the paper titled: Microcontroller Based Introduction to Computer Engineering, at
`the 7th annual FYEE Conference, Roanoke VA, August 2015.
`
`
` Presented the paper titled: Toward a common host interface for network processor at the
`2003 IASTED International Conference on Communications, Internet, & Information
`Technology (CIIT) Scottsdale, AZ, November 2003.
` Conference session chair for the “Information Systems and the Internet III – Systems
`Architectures” session
`
`
` General Conference Program Committee, IEEE International Conference on
`Communications (ICC), 2003
`
` Presented the paper titled: Effective Call Admission Control for Video Phone Applications at
`the International Conference on Networking (ICON’03) in Sydney Australia, September
`2003.
`
` Presented the paper titled: Feedback Scalability for Multicast Videoconferencing at the
`International Conference on Networking (ICN’01) in Colmar France in July 2001.
`
` Presented the paper titled: Fair Link Sharing with Layered Multicast Videoconferencing at
`the IEEE GLOBECOM in San Francisco in November 2000.
`
` Presented the paper titled: Pattern Smoothing for Compressed Video Transmission at the
`IEEE International Conference on Communications (ICC ’97) in Montreal Canada in June
`1997.
`
` Patent Application t