Case 6:21-cv-01101-ADA Document 34-13 Filed 06/09/22 Page 1 of 44
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`Exhibit 13
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`Case 6:21-cv-01101-ADA Document 34-13 Filed 06/09/22 Page 2 of 44
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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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`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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`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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`Expert Declaration of Michael C. Brogioli, Ph.D.
`in Support of Aire’s Claim Construction Brief
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`Case 6:21-cv-01101-ADA Document 34-13 Filed 06/09/22 Page 3 of 44
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`I. INTRODUCTION
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`1.
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`I have been retained as an expert in the above captioned case by Plaintiff Aire
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`Technology Ltd. (“Aire”). I understand that the parties dispute the meaning of certain claim
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`terms. In particular, I have reviewed Defendants’ Consolidated Opening Claim Construction
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`Brief and provide this declaration in response. I have studied the intrinsic and relevant extrinsic
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`evidence pertaining to those terms. In this declaration, I provide my opinions regarding how
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`one of ordinary skill in the relevant art would understand two disputed terms for U.S. Patent No.
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`8,174,360 (the “’360 Patent”).
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`II. QUALIFICATIONS
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`2.
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`My qualifications for forming the opinions given in this declaration are
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`summarized here and are addressed more fully in my curriculum vitae, which is attached as
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`Exhibit 1. That exhibit also includes a list of my publications.
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`3.
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`I am currently an Adjunct Professor of Electrical and Computer Engineering at
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`Rice University in Houston, TX, teaching Ph.D. candidate level courses in wireless
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`telecommunications, embedded computing software, embedded computing hardware, and
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`software/hardware optimization in modern computing systems utilizing modern high-level
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`programming languages, and I have held this position since July 2009. I am also currently the
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`Managing Director of Polymathic Consulting in Austin, TX, a company that advises a variety
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`of clients on engineering, research and development, intellectual property, and other technical
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`leadership matters, and I have held this position since October 2011.
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`4.
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`I am a named inventor on multiple U.S. Patents as well as various pending
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`applications. The subject matter of these patents includes, but is not limited to, embedded
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`processing, edge computing, heterogeneous wireless systems development and deployment, as
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`1
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`Case 6:21-cv-01101-ADA Document 34-13 Filed 06/09/22 Page 4 of 44
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`well as various aspects of distributed systems including computation, interconnectivity design
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`and implementation.
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`5.
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`From November 2009 to October 2011, I was Chief Architect, Senior Member
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`Technical Staff at Freescale Semiconductor in Austin, TX (formerly Motorola), responsible for
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`management of technology, engineering roadmaps, design lead on compiler infrastructure and
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`optimizations for wireless and embedded computing solutions. From 2008 to 2009, I was Senior
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`Engineer working with high performance compiler design and next generation wireless
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`architectures at Freescale Semiconductor in Austin, Texas. Prior to this, I held roles at Texas
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`Instruments in their Advanced Architecture and Chip Technologies group in the area of
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`architectures for wireless communications, as well as roles at Intel’s Microprocessor Research
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`Labs.
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`6.
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`From June 2006 to August 2007, I worked as the Technical Co-Founder of
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`Method Seven LLC, in Boston, MA, working with high performance software and hardware
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`systems architecture. I am currently the co-founder, co-inventor, and Chief Technology Officer
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`of Network Native, an Internet of Things hardware and software company. I am also a co-
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`founder, and co-inventor at AgCompute, an intelligent Agriculture Technology company
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`developing solutions using wired/wireless networks and drone technologies.
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`7.
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`While at Rice University, I developed various computer architecture designs
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`relating to networking and wireless technologies. For example, from 2002 to 2004, I developed
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`Spinach, a simulator design toolset for modeling programmable network interface architectures,
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`which models system components common to all programmable computing environments as
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`well as components specific to embedded. From 2004 to 2009, I developed Spinach DSP-
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`FPGA, a modular and composable simulator design infrastructure for programmable and
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`Case 6:21-cv-01101-ADA Document 34-13 Filed 06/09/22 Page 5 of 44
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`reconfigurable embedded SOC architectures specifically targeting mobile and wireless
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`computing devices. From 2005 to 2009, I developed and published a retargetable compiler
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`infrastructure for software and systems related to mobile, wireless and embedded computing
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`technologies. Many of these tools have been used at U.S. universities in the area of electrical
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`and computer engineering research.
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`8.
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`I am recognized as an expert in the field of computer hardware, computer
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`software, and wireless technologies as they relate to the subject matter at hand. I am a member
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`of the Institute of Electrical and Electronics Engineers (IEEE). I am formerly the Program Chair
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`of Design Automation Conference in the areas of Embedded and Wireless Solutions, as well as
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`a current technical committee member. I have previously been a Program Committee member
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`for the IEEE and ACM Design Automation Conference from 2011 to the present, in addition to
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`a number of other IEEE and ACM conferences related to wireless technologies and various
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`aspects of computer hardware, software, and wireless technologies. I have published, co-
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`published and contributed to numerous works on wireless and mobile computing, sensor
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`technologies, software optimizations, signal processing systems, digital signal processing and
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`related architectures, and low power computing, among other topics.
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`9.
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`I have previously served as an engineering consultant and testifying witness on
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`matters related to, and including, various types of wireless technologies including those
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`described in the patents at issue. These include mobile devices, wireless cellular devices, and
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`technologies such as near field communication, as well as hardware and software design for these
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`types of systems. I have also worked on a number of technologies related to various types of
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`wireless communications, including short range wireless in my 20+ years of experience.
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`10. My current curriculum vitae, provided in Exhibit 1, contains more information on
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`Case 6:21-cv-01101-ADA Document 34-13 Filed 06/09/22 Page 6 of 44
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`my background and experience, as well as the cases in which I have served as an expert witness
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`the past four years.
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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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`No part of my compensation is contingent upon the outcome of this litigation. I have no other
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`interests in this litigation or with any of the parties.
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`III. MATERIALS CONSIDERED FOR THIS DECLARATION
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`12.
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`In forming my opinions, I have reviewed and considered the patent specification
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`and claims, their prosecution histories, Defendants’ Consolidated Opening Claim Construction
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`Brief and corresponding exhibits, and the materials cited in this declaration. I have also relied
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`on my professional experience. I reserve the right to consider additional documents as I become
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`aware of them and to revise my opinions accordingly.
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`IV. UNDERSTANDING OF CLAIM CONSTRUCTION PRINCIPLES
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`13.
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`I understand that a claim construction inquiry begins and ends in all cases with
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`the actual words of the claim. Thus, aside from the written description and prosecution history,
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`the claims themselves provide substantial guidance as to the meaning of particular terms. I
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`further understand that to begin with, the context in which a term is used in the asserted claim
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`can be highly instructive. The patent specification can also provide guidance as to the meaning
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`of claim terms.
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`14.
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`I understand that when conducting a claim construction inquiry, district courts
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`are not required to construe every limitation present in a patent’s asserted claims. Simply put,
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`claim construction is not an obligatory exercise in redundancy. I further understand that where
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`a term is used in accordance with its plain meaning, the court should not re-characterize it using
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`different language.
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`Case 6:21-cv-01101-ADA Document 34-13 Filed 06/09/22 Page 7 of 44
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`15.
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`I understand that there is a “heavy presumption” that claim terms carry their full
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`ordinary and customary meaning, unless the accused infringer can show the patentee expressly
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`relinquished claim scope. The ordinary and customary meaning of a claim term is the meaning
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`that the term would have to a person of ordinary skill in the art in question at the time of the
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`invention. Thus, the task of comprehending the claims often involves little more than the
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`application of the widely accepted meaning of commonly understood words.
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`16.
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`I understand that without clear and unambiguous disclaimer, courts do not import
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`limitations into claims from examples or embodiments appearing only in a patent’s written
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`description, even when a specification describes very specific embodiments of the invention or
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`even only a single embodiment. Similarly, statements during patent prosecution do not limit
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`the claims unless the statement is a clear and unambiguous disavowal of claim scope.
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`17.
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`I understand that Defendants bear the burden of proving that a claim is indefinite
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`by clear and convincing evidence. I understand that a patent is invalid for indefiniteness if its
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`claims, read in light of the specification delineating the patent, and the prosecution history, fail
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`to inform, with reasonable certainty, those skilled in the art about the scope of the invention.
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`V.
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`LEVEL OF ORDINARY SKILL IN THE ART
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`18.
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`I understand that Apple’s expert, Dr. Michael Caloyannides, sets forth opinions
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`as to the relevant skill level of a person of ordinary skill in the art. See Dkt. 31-4 at ¶ 18. I agree
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`with Dr. Caloyannides that a person of ordinary skill in the art (“POSITA”) would have had a
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`Bachelor’s degree in computer science, computer engineering, electrical engineering, or a
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`similar field, with 2-5 years of experience in wireless communications, short range
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`communications or RFID technologies. I further agree that additional education might substitute
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`for some of the experience, and substantial experience might substitute for some of the
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`Case 6:21-cv-01101-ADA Document 34-13 Filed 06/09/22 Page 8 of 44
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`educational background.
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`19.
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`As shown by the summary of my qualifications above and my CV submitted as
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`Exhibit 1, I have significantly more than the level of ordinary skill in the art under this definition
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`of the level of skill in the art.
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`VI. DISPUTED TERMS
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`A. “a measuring device…”, Claim 1
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`Aire’s Proposed Construction
`No construction necessary.
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`This claim term does not invoke §112(6).
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`Apple and Google’s Proposed Construction
`Governed by 35 U.S.C. § 112 ¶ 6.
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`Function: monitoring a property of
`the
`transmission oscillator, and outputting a
`control signal when ascertaining a change of
`the monitored property, wherein the monitored
`property of the transmission oscillator includes
`the
`frequency or
`impedance of
`the
`transmission oscillator in resonance.
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`Structure: Indefinite
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`1.
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`Applicability of § 112 ¶ 6
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`20.
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`I understand that Apple and Google contend that “a measuring device…,” as
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`recited in Claim 1 of the ’360 Patent, is subject to means-plus-function treatment of pre-AIA 35
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`U.S.C. § 112, ¶ 6.
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`21.
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`I understand that § 112 ¶ 6 states as follows: “An element in a claim for a
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`combination may be expressed as a means or step for performing a specified function without
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`the recital of structure, material, or acts in support thereof, and such claim shall be construed to
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`cover the corresponding structure, material, or acts described in the specification and
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`equivalents thereof.” I further understand that the failure to use the word “means” creates a
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`rebuttable presumption that § 112 ¶ 6 does not apply, and that Apple and Google bear the burden
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`of demonstrating that this presumption is overcome. I also understand that a term that might
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`not convey structure if viewed in isolation can nevertheless derive structure from the context of
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`the surrounding claim language.
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`22.
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`I have reviewed the Declaration of Dr. Michael Caloyannides. I disagree with
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`his statements that a POSITA would have understood that the term “measuring device” does not
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`disclose or describe any specific structure or class of structures. In my opinion, a POSITA
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`would understand that the known term “measuring device” describes a class of structures. For
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`example, dictionary definitions confirm that the term has a structural meaning to a POSITA:
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`• “measuring device – instrument that shows the extent or amount or quantity or
`degree of something” (https://www.thefreedictionary.com/measuring+device)
`• “measuring device” – “(noun) instrument that shows the extent or amount or
`quantity or degree of something”
`(https://mnemonicdictionary.com/word/measuring%20device);
`(https://www.vocabulary.com/dictionary/measuring%20device)
`• “measuring device” – “instrument that shows the extent or amount or quantity or
`degree of something”
`(https://www.finedictionary.com/measuring%20device.html)
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`In addition, a POSITA would understand that the term “measuring device” has a
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`23.
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`structural meaning in light of the claims, specification, and prosecution history.
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`24.
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`Claim 1 recites:
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`1. A communication apparatus for setting up a data connection between
`intelligent devices, comprising:
`a transmission oscillator for carrying out a contactless data exchange, said
`oscillator including a coil;
`a communication element which is connected to the coil and to a data
`processing component of an intelligent device and which emits search signals via
`the coil to receive a response from another intelligent device,
`a measuring device for monitoring a property of the transmission oscillator
`which outputs a control signal when ascertaining a change of the monitored
`property, the monitored property of the transmission oscillator includes the
`frequency or impedance of the transmission oscillator in resonance,
`and a switching apparatus which is connected to the measuring device and
`the communication element and which switches on the communication element
`when it has received the control signal from the measuring device by connecting
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`the communication element to an energy source.
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`25.
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`Claim 1 recites that the measuring device is configured to monitor a property of
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`the transmission oscillator and output a control signal to the switching apparatus when the
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`measuring device ascertains a change of either the frequency or impedance of the transmission
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`oscillator. The switching apparatus is configured to switch on the communication element when
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`it receives the control signal from the measuring device. A POSITA would understand that the
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`claim thereby provides a detailed recitation of the objectives and operations for the measuring
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`device.
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`26.
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`In addition, Claim 1 recites that the “switching apparatus [] is connected to the
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`measuring device.” Claim 1 further recites how the measuring device interacts with the
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`switching apparatus, stating that the switching apparatus “switches on the communication
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`element when it has received the control signal from the measuring device.” The claim also
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`recites the relationship between the “measuring device” and the “transmission oscillator.” A
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`POSITA would understand that the claim thereby provides a detailed recitation of the
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`components the “measuring device” is connected to and how it interacts with those components.
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`27.
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`In addition, a POSITA would understand that the claimed “transmission
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`oscillator,” “communication element,” “measuring device,” and “switching apparatus” are each
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`structural components.
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`28.
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`Each of these four structural components are illustrated in Figures 1 and 2 of the
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`’360 Patent. Figure 1 “shows the structure and arrangement of intelligent devices” with three
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`different embodiments labeled 10, 20, 30. ’360 Patent at 3:1-2, 3:22-23. The patent explains
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`that “the device 10, 20, 30 can have e.g. the form of a portable computer 11 or a mobile telephone
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`21 or be realized in an RFID transponder with a chip 31, formed e.g. in a contactless chip card
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`30.” Id. at 3:34-37. The specification further explains that “the communication apparatus 1, 2,
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`3 is formed as a rule as one structural unit with the data processing component 11, 21 and is thus
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`located e.g. in the housing of a portable computer 11, a mobile telephone 21 or is integrated in
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`the chip 31 of a chip card 30.” Id. at 3:50-54. In light of this explanation, a POSITA would
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`understand that the four claimed components illustrated in Figure 1 are structure.
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`29.
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`Figure 1 illustrates each of the four claimed structural components. For example,
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`Figure 1 illustrates the coil 13, 23 that is part of the transmission oscillator. Id. at 4:8-9 (“the
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`coil 13, 23, 33 is part of a transmission oscillator 50”). Figure 1 further illustrates the
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`communication element 12, 22; the measuring device 14, 24; and the switching apparatus 15,
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`25. Id. at 3:44-50. Each of these four structural components is further illustrated in Figure 2
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`that “shows a simplified equivalent circuit diagram of a device 10, 20, 30.” Id. at 3:3-4.
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`30.
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`Figure 2 illustrates the transmission oscillator 50; communication element 12,
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`22; the measuring device 14, 24; and the switching apparatus 15, 25. Id. at 4:39-5:11. A
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`POSITA would understand that the specification describes the structure shown for each of these
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`four components.
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`31.
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`First, for the transmission oscillator 50, the specification explains that
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`“[d]isposed in parallel with the coil 13, 23 is a capacitor 48 which forms together with the coil
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`13, 23 a transmission oscillator 50.” Id. at 5:9-11.
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`32.
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`Second, for the communication element 12, 22, the specification explains that
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`“the communication element 12, 22 is designed to execute an NFC protocol as described in the
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`stated publication ECMA/TC32-TG19/2003/12, or a contactless transmission protocol as
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`described e.g. in the standards ISO/IEC 14443, ISO/IEC 15699 and ISO/IEC 18000-3.” Id. at
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`3:65-4:2.
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`33.
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`Third, for the switching apparatus 15, 25, the specification explains that the
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`10
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`“switching apparatus 15, 25 comprises two switches 42, 44 which are drivable by means of an
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`actuator 43, as well as optionally a time controller 45.” Id. at 4:39-41.
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`34.
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`Fourth, for the measuring device 14, 24, the specification describes each of the
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`illustrated components:
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`Disposed in parallel with the coil 13, 23 is a capacitor 48 which forms together
`with the coil 13, 23 a transmission oscillator 50. The transmission oscillator 50
`is connectable via the switch 47 to the communication element 12 or the
`measuring unit 46. In parallel with the transmission oscillator 50 but behind the
`switch 47 with respect to the transmission oscillator 50, a further capacitor 51 as
`well as a resistor 52 can be disposed. Both elements 51, 52 can be switched to
`the transmission oscillator 50 via the switch 47. The capacitor 51 causes a
`change in the resonant frequency of the transmission oscillator 50, the resistor
`52 an increase in the bandwidth while simultaneously reducing the oscillating
`circuit quality factor. The mentioned passive components 47, 49, 51, 52 can be
`executed as discrete components but also in the form of assemblies with a
`corresponding external effect.
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`Id. at 5:9-23.
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`35.
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`The specification goes on to provide detailed “circuit implementation” figures
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`and descriptions of the “measuring unit 46,” which is a component of the measuring device 14,
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`24. Id. at Figs. 5, 7; 8:11-9:62; 10:44-11:42. Figures 5 and 7 are shown below:
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`11
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`Case 6:21-cv-01101-ADA Document 34-13 Filed 06/09/22 Page 14 of 44
`Case 6:21-cv-01101-ADA Document 34-13 Filed 06/09/22 Page 14 of 44
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`Case 6:21-cv-01101-ADA Document 34-13 Filed 06/09/22 Page 15 of 44
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`36.
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`The specification further states that “the components of the measuring device 14,
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`24 can be realized discretely, as circuits or in the form of software programs.” Id. at 4:66-5:1.
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`I am informed that software programs may connote structure to persons of ordinary skill in the
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`art. A POSITA would understand that the circuits and software programs mentioned here
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`connote structure in light of the disclosure in the specification discussed above.
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`37.
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`I have also reviewed the prosecution history for the ’360 Patent. A POSITA
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`would understand that the prosecution history confirms that a “measuring device” has a
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`structural definition that is generally known in the art. For example, the Examiner issued a
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`Case 6:21-cv-01101-ADA Document 34-13 Filed 06/09/22 Page 16 of 44
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`rejection stating that the “measuring device” recited in the pending claims was a structure
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`“known in the art of communications.” Dkt. 31-5 at AIRE-SAMS-275-276. The Examiner
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`identified a “measuring device” structure in the asserted Charrat reference. Id. Neither the
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`Examiner nor Applicant ever contended that the term was governed by 112(6).
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`2.
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`Corresponding structure (if § 112 ¶ 6 applies)
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`38.
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`I understand that when no structural support for a claimed function is recited, the
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`“claim shall be construed to cover the corresponding structure, material, or acts described in the
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`specification and equivalents thereof.” Pre-AIA 35 U.S.C. § 112 ¶ 6. Thus, I understand that if
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`§ 112 ¶ 6 is found to apply, the next step is to identify the corresponding structure described in
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`the specification.
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`39.
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`In my opinion, a POSITA would readily arrive at the conclusion that the
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`specification’s extensive descriptions of the corresponding structure for the “measuring device”
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`discussed above corresponds to the identified function. A POSITA would understand that the
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`disclosed structure is sufficient for monitoring frequency or impedance, ascertaining a change
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`in them, and outputting a control signal.
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`B. “a control signal”, Claim 1, 11, and 15
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`Aire’s Proposed Construction
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`No construction necessary.
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`Plain and ordinary meaning.
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`Samsung, Apple, and Google’s Proposed
`Construction
`“a signal that is or contains a command.”
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`40.
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`It is my understanding that not all terms of a claim require construction. I
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`understand that the purposes of claim construction include resolving disputes regarding claim
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`scope, and if necessary to clarify and explain what the patentee covered by the claims.
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`41.
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`In my opinion, “a control signal” needs no construction because the term would
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`Case 6:21-cv-01101-ADA Document 34-13 Filed 06/09/22 Page 17 of 44
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`have been (and is) well-understood by a POSITA in the context of the claims here. For example,
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`claim 1 specifies that the measuring device “outputs a control signal” and that the switching
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`apparatus “switches on the communication element when it has received the control signal from
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`the measuring device.” A such, the claim uses the term consistent with its plain and ordinary
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`meaning to a POSITA.
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`42.
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`Defendants’ construction cannot be correct because it is overly restrictive and
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`does not accurately reflect the teachings of the ’360 Patent. As used in the claims, the ordinary
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`meaning of the term to a POSITA does not include Defendants’ unduly narrow requirement that
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`it “is or contains a command.”
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`43.
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`I have also reviewed the portions of the prosecution history cited by Defendants.
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`Defendants cite the Applicant’s statement that “none of these ports . . . are shown or described
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`as being used to issue a circuit power down command or to power down a circuit.” Dkt. 31 at
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`8. A POSITA would understand that the prosecution history does not include any disclaimer
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`with respect to the term “control signal.” The quoted statements about the Charrat reference
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`were not in relation to the claimed “control signal.” A POSITA would understand that the
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`Applicant was arguing that “Charrat does not disclose switching on a communication by
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`connecting the element to an energy source as required by amended claim 1.” Dkt. 31-5 at
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`AIRE-SAMS-410. The Applicant argued that “Charrat reduces power consumption by having
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`the magnetic field operate for shorter periods of time” and that “Charrat is silent as to the specific
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`connection of circuit in the reader and the energy source.” Id. A POSITA would understand
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`that the quoted statements were in relation to the claimed “switching apparatus” and were
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`unrelated to the “control signal.”
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`15
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`Case 6:21-cv-01101-ADA Document 34-13 Filed 06/09/22 Page 18 of 44
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`VII. ADDITIONAL OR SUPPLEMENTAL OPINIONS
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`44. My analysis and conclusions herein are based on materials I have reviewed to
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`date. I reserve the right to supplement or amend these opinions based on additional evidence or
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`in light of opinions expressed by other experts, or as otherwise necessary.
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`
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed June 9, 2022.
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`By:
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`
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`Michael C. Brogioli, Ph.D.
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`16
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`Case 6:21-cv-01101-ADA Document 34-13 Filed 06/09/22 Page 19 of 44
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`Exhibit 1
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`Case 6:21-cv-01101-ADA Document 34-13 Filed 06/09/22 Page 20 of 44
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`Michael C. Brogioli, Ph.D.
`
`Contact
`Information
`
`Expertise
`
`Michael C. Brogioli, Ph.D.
`Polymathic Consulting
`100 Congress Avenue, Suite 2000
`Austin, TX 78701 USA
`
`Office: (512) 370-4936
`Cell (preferred): (713) 732-0217
`Fax: (512) 469-6306
`E-mail: michael@polymathicconsulting.com
`
`Software Analysis, Software Architecture, Embedded Computing, Microprocessor Designs, Software
`Based Simulation, Computer Hardware Design, Computer Networks, Computer and Network Based
`Gaming Platforms, High Performance Computing, Digital Signal Processing.
`
`Education
`
`Rice University, Houston, Texas USA
`
`Ph.D., Electrical and Computer Engineering, 2007
`
`• Dissertation Topic: “Reconfigurable Heterogeneous DSP/FPGA Based Embedded Architec-
`tures for Numerically Intensive Embedded Computing Workloads.”
`• Advising Committee: Dr. Joseph R. Cavallaro, Dr. Keith D. Cooper, Dr. Scott Rixner
`
`Rice University, Houston, Texas USA
`
`M.S., Electrical and Computer Engineering, 2003
`
`• Dissertation Topic: “Dynamically Reconfigurable Data Caches in Low Power Computing.”
`• Advising Committee: Dr. Keith D. Cooper, Dr. Scott Rixner, Dr. Robert Jump
`
`Rensselaer Polytechnic Institute, Troy, New York USA
`
`B.S., Electrical Engineering, Cum Laude, 1999
`
`• Advisor: Dr. William Pearlman
`
`Certificates
`
`Harvard Business School, Boston, Massachusetts, USA
`
`Certificate in Investment Portfolios with Alternate Investments, 2022
`
`• Venture Capital, Growth Equity, Distress Investing, Private Debt, Hedge Funds, Portfolio
`Construction.
`
`Professional
`Experience
`
`Polymathic Consulting, TX USA
`2011 - Present
`Managing Director
`Founder and managing director of Polymathic Consulting, servicing clients ranging from early stage
`technology start-up endeavors to Fortune 100 and beyond. Clients turn to Polymathic for expansive,
`proven engineering, research and development, intellectual property and technical leadership to
`effectively advance their real world business needs.
`
`IEEE and ACM Design Automation Conference, USA
`Steering Committee
`2016 - Present
`Conference Chair, Embedded Systems and Software Track
`Design Automation Conference is the premiere technical conference and trade show specializing
`in Hardware, Software, Internet of Things, Embedded Systems and related Design Methodologies.
`Conference chair, responsible for the review, critique, and acceptance of academia and industry
`based publications in the areas of embedded systems, embedded software, and embedded system
`design.
`
`Rice University, TX USA
`Adjunct Professor, Electrical and Computer Engineering
`
`2009 - Present
`
`Page 1
`Generated: May 17, 2022, 5:48pm CST
`
`

`

`Case 6:21-cv-01101-ADA Document 34-13 Filed 06/09/22 Page 21 of 44
`
`Professor of Ph.D. candidate level courses in wireless telecommunications, embedded computing soft-
`ware, embedded computing hardware, and software/hardware optimization in modern computing
`systems utilizing modern high level programming languages. Advisor of senior and graduate stu-
`dent based projects revolving around multi-core heterogeneous systems as they pertain to wireless
`telecommunications, medical and video.
`
`RISC-V Foundation, Berkeley, CA USA
`2018 - Present
`Technical Committee
`RISC-V is an open CPU instruction set architecture (ISA) based on established reduced instruction
`set computing (RISC) principles. The RISC-V Foundation is a non-profit consortium chartered to
`standardize, protect, and promote the free and open RISC-V instruction set architecture together
`with its hardware and software ecosystem for use in all computing devices.
`
`Freescale Semiconductor, TX USA
`2009 - 2011
`Chief Architect, Senior Member Technical Staff
`Technical architect of Freescale’s DSP compilers and related technology. Responsible for manage-
`ment of technology, engineering roadmaps, design lead on compiler infrastructure and optimizations
`(high level and low level), next generation ABI definitions and next generation architecture solutions.
`Technical lead on multi-year engagement with processor architects in design of next generation DSP
`cores. Developed software infrastructure for migrating OEM competitor software stacks to Freescale
`solutions, tools generation, software packages, migration strategies and white papers. Technical
`lead on Tier-1 OEM customer relationships, evaluations of 3rd party technologies for potential
`partnerships and acquisitions, led various university research collaborations on behalf of Freescale.
`Development and deployment of internal software engineering policies and practices.
`
`Freescale Semiconductor, TX USA
`Senior Compiler Engineer V
`2008 - 2009
`High Performance Compiler Design, Processor Architecture
`Team leader on compiler engineering effort to provide intuitive, interactive end user experience for
`DSP compiler tool suite. Designed a framework to guide users in achieving highly optimized compiled
`VLIW code. Assembly listing reports for optimization failure advice, porting advice when migrating
`from competitor architectures, advice on code modifications for optimization enablement. Lead
`designer, engineering effort director, project planning and scoping, release schedule, and drafting
`of specification. Development of various compiler optimizations for VLIW processing as well as
`software emulation layers for running competitor software solutions on Freescale silicon.
`
`Advising of next-gen DSP core architecture team in creating a highly orthogonal, compiler targetable
`multi-clustered VLIW based digital signal processor architecture. Work with future basestation
`architecture teams on designing next-gen basestation architecture for 4G LTE incorporating control
`and data plane processing with appropriate programming models.
`
`Method Seven, MA USA
`Technical Co-Founder
`2006 - 2007
`High Performance Software and Hardware Systems Architecture
`Founded Method Seven, a financial engineering company ap