Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 1 of 37
`
`Exhibit 11
`
`

`

`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 2 of 37
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`JAWBONE INNOVATIONS, LLC,
`
`
`Plaintiff,
`
`
`
`v.
`
`
`META PLATFORMS, INC.,
`
`
`Defendant.
`
`
`
`
`Case No. 6:23-cv-00158-ADA
`
`JURY TRIAL DEMANDED
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`
`DEFENDANT’S DISCLOSURE OF EXTRINSIC EVIDENCE
`
`Pursuant to the Scheduling Order and the Court’s Order Governing Proceedings (“OGP
`
`
`
`
`
`
`
`
`
`
`4.4”), Defendant Meta Platforms, Inc. (“Meta”) discloses the following extrinsic evidence for
`
`U.S. Patent Nos. 10,779,080, 11,122,357, 7,246,058, 8,019,091, 8,321,213, 8,326,611,
`
`8,467,543, and 8,503,691 (the “Patents-in-Suit”). Along with these disclosures, Meta is
`
`producing copies of the disclosed extrinsic evidence concurrently. Meta reserves the right to
`
`supplement and/or amend its disclosures in light of the disclosures of extrinsic evidence and/or
`
`disclosures of bases for proposed claim constructions, including any expert testimony, made by
`
`Jawbone Innovations, LLC (“Jawbone”), and/or any other developments in this case.
`
`Meta may rely on the testimony of Dr. Cliff Reader to offer his expert opinion in the form
`
`of expert declaration(s) and/or live testimony. A copy of Dr. Reader’s curriculum vitae is being
`
`produced herewith. Dr. Reader may be asked to provide background and context regarding the
`
`technology related to and needed for an understanding of the patents-in-suit including, but not
`
`limited to, the level of ordinary skill in the art at the relevant time. Dr. Reader may be asked to
`
`
`
`1
`
`

`

`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 3 of 37
`
`
`
`
`
`explain the knowledge of a person having ordinary skill in the art (“POSITA”) at the relevant
`
`time including, but not limited to, the requisite education and experience level of a POSITA.
`
`With respect to the disputed claim terms for which the parties have proposed a
`
`construction, Dr. Reader may provide testimony to explain how Meta’s proposed constructions
`
`are supported by intrinsic evidence, extrinsic evidence, and/or the knowledge of a POSITA at the
`
`time. With respect to the claim terms which Meta contends to be indefinite, Dr. Reader may
`
`opine on how those claim terms fail to adequately inform, with reasonable certainty, a POSITA
`
`about the scope of the claimed invention. Dr. Reader may be asked to respond to Plaintiff’s
`
`proposed constructions and supporting evidence. Dr. Reader may also provide testimony to
`
`rebut any opinion proffered by a witness upon which Plaintiff relies.
`
`The following disclosures are made based upon information currently available to Meta.
`
`To date, Jawbone’s infringement contentions remain insufficient and therefore Meta reserves the
`
`right to supplement or amend these disclosures in response to amended or supplemental
`
`infringement contentions served by Jawbone. Moreover, Meta’s identification of extrinsic
`
`evidence is not exhaustive and is exemplary. Meta has not been apprised of the extent to which
`
`Jawbone will rely on extrinsic evidence and reserves the right to rely on additional extrinsic
`
`evidence to the extent Jawbone introduces extrinsic evidence that is inconsistent with the plain
`
`and ordinary meaning of the terms from the perspective of a person of ordinary skill in the art at
`
`the time of filing and/or invention of the claimed subject matter. Subject to these reservations,
`
`Meta discloses the below initial extrinsic evidence for the claim terms identified as requiring
`
`construction.
`
`Terms Previously Construed1
`
`1 The terms listed or terms similar to those listed have been previously construed in Federal
`Court and/or the United States Patent Trial and Appeal Board (“PTAB”). Unless otherwise
`
`
`
`2
`
`

`

`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 4 of 37
`
`
`
`
`
`
`
`PROPOSED CLAIM
`TERM
`“an adaptive noise removal
`application . . . generating
`denoised output signals
`by forming a plurality of
`combinations . . . by filtering
`and summing the plurality of
`combinations . . . and by a
`varying linear transfer
`function between the
`plurality of combinations”
`“microphone(s)”
`
`“acoustic noise”
`
`“transfer function(s)”
`
`ASSERTED
`CLAIMS
`’080: 1, 7, 14
`
`META’S PROPOSAL
`
`Meta’s proposal is the same as proposed by
`Samsung in the Samsung 0186 Case. Meta
`adopts Samsung’s evidence relied on in the
`Samsung 0186 Case.
`
`Expert testimony.
`
`’058: 1
`’091: 1, 9-11,
`15-18
`’543: 1, 26
`
`’091: 1, 9, 11,
`15, 18
`’080: 1, 2, 7
`
`’091: 1, 2, 4, 5,
`9, 11, 15, 18
`’080: 1, 7, 14
`’357: 1, 15
`
`Meta’s proposal is the same as adopted by
`the Court and proposed by Samsung in the
`Samsung 0186 Case. Meta adopts the
`parties’ evidence relied on in the Samsung
`0186 Case.
`
`Expert testimony.
`Meta’s proposal is the same as adopted by
`the Court in the Samsung 0186 Case, and is
`the same as proposed by Jawbone in the
`Google 0985 Case. Meta adopts the
`parties’ evidence relied on in the Samsung
`0186 Case and Google 0985 Case.
`
`Expert testimony.
`Meta’s proposal is the same as greed
`between Jawbone and Samsung, in the
`Samsung 0186 Case. Meta adopts the
`parties’ evidence relied on in the Samsung
`0186 Case.
`
`Expert testimony.
`
`
`indicated, for purposes of simplifying the claim construction proceedings in this case and
`without conceding the constructions of these terms, Meta proposes the parties adopt certain
`constructions already decided in prior matters involving the asserted and related patents,
`including but not limited to Jawbone v. Samsung, 2-21-00186 (E.D.Tex. May 27, 2021)
`(“Samsung 0186 Case”); Jawbone v. Google, 2-21-00985 (W.D.Tex. Sep. 23, 2021)
`(“Google 0985 Case”); PTAB matters IPR2022-01027; IPR2023-00275; IPR2022-00623;
`and any future matters that may bear on the construction of these terms. Meta reserves the
`right to appeal these constructions, and further reserves the right to adopt defendants’ or
`petitioners’ arguments made in any of the aforementioned cases for purposes of appeal.
`
`
`
`3
`
`

`

`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 5 of 37
`
`
`
`
`
`
`
`“approximately similar” /
`“approximately, dissimilar” /
`“approximately dissimilar”
`
`’213: 2, 37, 38
`’611: 3, 4, 30
`
`“substantially similar” /
`“substantially dissimilar”
`
`’691: 1, 23, 27-
`29, 41
`’080: 1, 7, 14
`’357: 1, 15
`
`4
`
`
`
`
`
`Meta’s proposal is the same as proposed by
`Google, and adopted by the court, in the
`Google 0985 Case. Meta adopts the
`parties’ evidence relied on in the Google
`0985 Case.
`
`Meta further discloses the following
`additional extrinsic evidence:
`
`• Approximately, Collins English
`Dictionary (7th ed.) (2005)
`• Approximate, New Oxford American
`Dictionary (2nd ed.) (2005)
`• Approximate, Merriam Webster
`Dictionary (new ed.) (2005)
`• Approximate, Penguin Complete English
`Dictionary (2006)
`• Dissimilar, Collins English Dictionary
`(7th ed.) (2005)
`• Dissimilar, New Oxford American
`Dictionary (2nd ed.) (2005)
`• Dissimilar, Merriam Webster Dictionary
`(new ed.) (2005)
`• Dissimilar, Penguin Complete English
`Dictionary (2006)
`• Similar, Collins English Dictionary (7th
`ed.) (2005)
`• Similar, New Oxford American
`Dictionary (2nd ed.) (2005)
`• Similar, Merriam Webster Dictionary
`(new ed.) (2005)
`• Similar, Penguin Complete English
`Dictionary (2006)
`• Expert testimony.
`
`Meta’s proposal is the same as proposed by
`Google, and adopted by the court, in the
`Google 0985 Case. Meta adopts the
`parties’ evidence relied on in the Google
`0985 Case.
`
`Meta further discloses the following
`additional extrinsic evidence:
`
`

`

`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 6 of 37
`
`
`
`
`
`
`
`• Substantially, New Oxford American
`Dictionary (2nd ed.) (2005)
`• Substantial, Collins English Dictionary
`(7th ed.) (2005)
`• Substantial, Merriam Webster Dictionary
`(new ed.) (2005)
`• Substantial, Penguin Complete English
`Dictionary (2006)
`• Dissimilar, Collins English Dictionary
`(7th ed.) (2005)
`• Dissimilar, New Oxford American
`Dictionary (2nd ed.) (2005)
`• Dissimilar, Merriam Webster Dictionary
`(new ed.) (2005)
`• Dissimilar, Penguin Complete English
`Dictionary (2006)
`• Similar, Collins English Dictionary (7th
`ed.) (2005)
`• Similar, New Oxford American
`Dictionary (2nd ed.) (2005)
`• Similar, Merriam Webster Dictionary
`(new ed.) (2005)
`• Similar, Penguin Complete English
`Dictionary (2006)
`• Expert testimony.
`
`Meta’s proposal is the same as agreed
`between Google and Jawbone in the Google
`0985 Case and Samsung and Jawbone in the
`Samsung 0186 Case. Meta adopts the
`parties’ evidence relied on in the Google
`0985 Case and Samsung 0186 Case.
`
`Expert testimony.
`
`Meta’s proposal is the same as agreed
`between Google and Jawbone in the Google
`0985 Case and Samsung and Jawbone in the
`Samsung 0186 Case. Meta adopts the
`parties’ evidence relied on in the Google
`0985 Case and Samsung 0186 Case.
`
`
`“acoustic microphone(s)”
`
`’091: 1, 10, 11,
`17
`
`“virtual microphone”
`
`’213: 1, 2, 5-8,
`10, 14, 19-22,
`24, 36-38, 42
`’611: 1-4, 9-12,
`14, 29, 30, 33-
`36, 38, 44
`’691: 1, 4, 10,
`
`5
`
`
`
`
`
`

`

`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 7 of 37
`
`
`
`
`
`“voice activity”
`
`“null”
`
`12, 15, 17, 21-
`23, 27-29, 31,
`38, 41, 42
`’080: 1, 7, 14,
`18, 19
`’357: 1, 5, 11-15,
`17-19
`’213: 1, 14, 42
`’611: 1, 29, 44
`’080: 4, 10, 15
`
`’691: 3-5, 20, 23,
`24, 30-32, 41-43,
`46
`’080: 7, 9
`’357: 15, 17
`
`
`
`“voice detection subsystem,”
`
`“voice activity signal(s),”
`and
`
`“human voicing activity”
`
`’058: 1, 2
`’091: 1, 11, 18
`’543: 1, 3, 11,
`12, 26
`’080: 4, 10, 15
`
`“voicing sensor”
`
`’058: 1, 2
`
`“cross correlation data”
`
`’058: 1, 2
`
`
`
`New Terms
`
`Expert testimony.
`
`
`Meta’s proposal is the same as agreed
`between Google and Jawbone in the Google
`0985 Case. Meta adopts the parties’
`evidence relied on in the Google 0985 Case.
`
`Expert testimony.
`Meta’s proposal is the same as agreed
`between Google and Jawbone in the Google
`0985 Case and Samsung and Jawbone in the
`Samsung 0186 Case. Meta adopts the
`parties’ evidence relied on in the Google
`0985 Case and Samsung 0186 Case.
`
`Expert testimony.
`Meta’s proposals are the same as Jawbone’s
`construction in IPR2022-01027 and
`IPR2023-00275. Meta adopts the parties’
`evidence relied on in IPR2022-01027 and
`IPR2023-00275.
`
`Expert testimony.
`Meta’s proposal is the same as Jawbone’s
`construction in IPR2022-00623. Meta
`adopts the parties’ evidence relied on in
`IPR2022-00623.
`
`Expert testimony.
`Meta’s proposal is the same as Jawbone’s
`construction in IPR2022-00623. Meta
`adopts the parties’ evidence relied on in
`IPR2022-00623.
`
`Expert testimony.
`
`PROPOSED CLAIM
`TERM
`
`ASSERTED
`CLAIMS
`
`EXTRINSIC EVIDENCE
`
`
`
`6
`
`

`

`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 8 of 37
`
`
`
`
`“the processing
`component”
`
`’080: 10, 11
`
`Expert testimony.
`
`Date: March 20, 2024
`
`
`
`Respectfully submitted,
`
`By: /s/ Lisa K. Nguyen
`Paige Arnette Amstutz
`Texas State Bar No. 00796136
`SCOTT DOUGLASS & MCCONNICO LLP
`303 Colorado Street, Suite 2400
`Austin, TX 78701
`Telephone: (512) 495-6300
`Facsimile: (512) 495-6399 pamstutz@scottdoug.com
`
`Lisa K. Nguyen (admitted)
`Eric E. Lancaster (admitted)
`PAUL HASTINGS LLP
`1117 S California Ave.
`Palo Alto, CA 94304
`Telephone: (650) 320-1800
`lisanguyen@paulhastings.com
`ericlancaster@paulhastings.com
`
`Attorneys for Defendant Meta
`Platforms, Inc.
`
`7
`
`
`
`
`
`
`
`
`
`

`

`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 9 of 37
`
`Addendum
`
`

`

`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 10 of 37
`
`
` §
`
`
`Cliff Reader, Ph.D.
`
`
`Expertise
` Real-time Processing and Display
`§ Video coding (MPEG-HEVC)
`§ Audio coding (MPEG-AAC)
`§
`Imaging/Video Systems Architecture
`§
`Imaging/Video Chip Architecture
`
`
`Professional Summary
`Dr. Reader has over forty five years of work experience in digital imaging, digital video & audio
`and digital speech processing. In the 1970’s and early 1980’s, he was one of the leaders in the
`digital imaging field, performing extensive work in areas of compression, real-time processing,
`real-time display, image enhancement, and others. Applications included reconnaissance
`imaging, medical imaging, earth resources management and videoconferencing. This work
`anticipated much of the technology being used in contemporary consumer digital video systems.
`He has in-depth experience of the commercial history and when key parts of technology were
`first developed and published.
`
`§ Videoconferencing
`§ Speech Processing
`§ Consumer audio/video
`§ Reconnaissance Imaging
`§ Medical Imaging
`
`Dr. Reader’s career includes technical work in areas of algorithm design, system design, and
`semiconductor chip design; and business development, marketing and sales work in areas of
`market analysis, product roadmap development and direct sales.
`
`Dr. Reader has held many leadership roles in standards development: US Head of Delegation to
`MPEG (1991-1993); chief editor of the MPEG1 standard (1991-1993); instigator of the
`successful effort to make MPEG2 the market standard for digital TV over proprietary
`competitors in the US and national competitors in Europe and Japan (1992); MPEG4
`Subcommittee Chairman (1993-1996); AVS (China) Subgroup Chairman (2003-Present). He is
`an expert in all major audio-video standards. MPEG audio (Layer I, II, mp3, AAC), Dolby AC3,
`MPEG video (1, 2, 4), H.264, Windows Media 9 (VC-1), H.265 (HEVC), AVS and AV1. He is
`also an expert in DVD standards, including formatting, navigation and authoring.
`
`Dr. Reader has extensive experience in patent licensing and patent pools. He was the technical
`expert for developing the initial list of potentially essential patents for the first MPEGLA patent
`pool (MPEG2 video and systems). He is the Co-Director leading the pool formation and license
`negotiations for the AVS patent pools. Dr. Reader has experience in the valuation of patents and
`the acquisition and sale of patent portfolios.
`
`Dr. Reader has authored over twenty technical papers, two book chapters and two patents in
`digital video processing, display, and compression. He taught digital signal processing and image
`processing at Santa Clara University in the early 1980s and is an Adjunct Professor at Peking
`University, Beijing, China.
`
`Resume of Cliff Reader, Ph.D.
`Printed: 11/29/23
`
`
`
`
`
`Page 1
`
`

`

`
`
`
`Employment History
`
`
`From:
`To:
`
`
`2001
`Present
`
`
`Independent Consultant
`Escondido, CA
`Provide technical and marketing consulting services in the areas of
`digital imaging, digital video, digital audio and speech including:
`§ consumer video
`§
`real-time processing and display
`§
`image and video & audio compression (specializing in standards)
`§
`imaging/video systems architecture
`§
`imaging/video chip architecture
`§ audio/video transmission, including optical & wireless networks
`Over 80 clients including Apple, AT&T, Adobe, Broadcom, China
`Central TV, Chinese Academy of Sciences, Cisco, Comcast,
`DirecTV, Dish Network, Disney, EchoStar, ETRI, Facebook,
`Fujifilm, Gateway, GE, Google, Haier, Hisense, HP, Hulu, IBM,
`Intel, Johnson Controls, KAIST, Lenovo, LG, Matsushita, MediaTek,
`Microsoft, Motorola, Netflix, Nikon, Nokia, ON2, OPPO, Peloton,
`Philips, Quanta, Riverbed, Samsung, Sharp, Siemens, Sony, Starz,
`Sun Microsystems, Toshiba, TPV, Tyco, US Department of Justice,
`Verizon, Vimeo, Vizio, Wistron, Xiaomi, Yahoo, Zoran and ZTE.
`
`Personal database of patent analysis:
`-Evaluation of all the US patents in the MPEG2, H.264 and H.265
`patent pools.
`-Evaluation of the US patents and published applications underlying
`the H.264 and H.265 standards.
`-Personal archive of over 2000 audiovisual patents.
`
`Personal database of audio and video prior art.
`-Virtually complete collection of all contributions to the H.26x and
`MPEGx families of standards from 1985 to today.
`-Many hundreds of technical journal and conference articles
`documenting the first invention of key technologies.
`-Work-in-progress book on the history of video compression.
`-Historical collection of technical data from the earliest digital video,
`image processing and real-time image display systems in the 1970s
`and 1980s.
`
`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 11 of 37
`
`
`
`
`From:
`To:
`
`
`1999
`2001
`Title:
`
`nDSP Corporation
`Campbell, CA
`Vice President of Marketing and Acting Vice President of Sales
`
`Resume of Cliff Reader, Ph.D.
`Printed: 11/29/23
`
`
`
`
`
`Page 2
`
`

`

`
`
`
`
`
`
`
`
`
`
`From:
`To:
`
`
`
`From:
`To:
`
`
`
`
`From:
`To:
`
`
`
`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 12 of 37
`
`
`
`
`Responsible for marketing and sales in a startup company providing
`high-quality video signal processors to TV manufacturers.
`Developed product specifications and roadmap. Built and managed
`sales and marketing team of 6 direct and contractor staff in the US
`and Japan to provide technical sales, sales support, application
`engineering, Marcomm and PR. Established distribution in China,
`Japan and throughout the Far East. Secured first sales as company
`moved into production phase with design wins in China, Japan and
`Europe. Initiated and secured major design wins in emerging
`Progressive DVD business, with production volumes beginning in
`4Q00 at an annualized rate of $3.5M. Established strategic
`partnership with Pixelworks in LCD chip business. Pixelworks
`acquired nDSP in 2001.
`
`CagEnt Technologies, Inc. (wholly owned by Samsung)
`1997
`Santa Clara, CA
`1998
`Position: Vice President of Sales, Digital Video Products
`
`Responsible for a line of PC-based real-time MPEG2 and Dolby
`Digital encoders. Established distribution agreements for third-party
`DVD authoring software. Secured OEM contracts for the products.
`Built the sales channel worldwide. Built sales to break-even point in
`9 months leading to sale of the product line.
`
`Samsung Semiconductor, Inc.
`1993
`San Jose, CA
`1997
`Position: Director of Marketing, Digital Media Products;
`Acting Director of Software Engineering
`Developed business plans for digital audiovisual semiconductor
`chips. Managed team of over 50 software engineers in US and Korea
`for development of a media processor. Established strategic
`partnerships with Microsoft and IBM for media processor
`
`
`
`Cypress Semiconductor, Inc.
`1990
`San Jose, CA
`1993
`Position: Business Development Manager
`
`Founding member of new business unit chartered to develop a
`“video DSP”. Jointly developed a complete business plan, and
`personally initiated and developed relationships with Philips,
`Sun Microsystems, Apple Computers and IBM. Chief architect
`for this early media DSP design, capable of complete MPEG1
`decode in real time. (Fully validated by cycle-accurate
`simulation). Managed R&D team of 10 hardware and software
`engineers.
`
`Head of US Delegation to MPEG, 1991 to 1992. Chief Editor
`of the MPEG1 standard. Technical Expert for establishing the
`
`Resume of Cliff Reader, Ph.D.
`Printed: 11/29/23
`
`
`
`
`
`Page 3
`
`

`

`
`
`
`
`
`
`
`
`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 13 of 37
`
`
`MPEGLA Patent Licensing Pool.
`
`From:
`To:
`
`
`
`Sun Microsystems, Inc.
`1988
`Mountain View, CA
`1990
`Position: Program Manager
` Developed requirements and specifications for real-time imaging
`
`system. Managed a team of 20 engineers to develop the architecture
`and high-level design. Interfaced with two key customers – Philips
`Medical Systems and Lockheed. Developed design for single-board
`real-time medical and reconnaissance image display.
`
`From:
`To:
`
`1981
`1988
`
`From:
`To:
`
`1975
`1981
`
`International Imaging Systems, Zoran, Virtual Imaging
`Design and development of real-time image processing and display
`systems. Details available on request.
`
`Ford Aerospace & ESL (A Division of TRW)
`Details available on request.
`
`
`
`
`
`Consulting History
`
`
`Date
`To:
`
`
`2023
`Present
`Duties:
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`2023
`Present
`Duties:
`
`2023
`Present
`Duties:
`
`2023
`Present
`Duties:
`
`2023
`2023
`Duties:
`
`2023
`Present
`Duties:
`
`Intel
`
`Consulting Expert
`
`Disney
`
`Consulting Expert
`
`Samsung
`
`Consultant
`
`Peloton
`
`Consulting Expert in NEC matter
`
`Alps Alpine
`
`Consulting Expert in DivX matter
`
`Fish & Richardson
`
`Consultant
`
`Resume of Cliff Reader, Ph.D.
`Printed: 11/29/23
`
`
`
`
`
`Page 4
`
`

`

`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 14 of 37
`
`
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`
`2023
`Present
`Duties:
`
`2022
`2023
`Duties:
`
`2022
`2023
`Duties:
`
`2022
`2023
`Duties:
`
`2022
`Present
`Duties:
`
`2022
`Present
`Duties:
`
`2022
`Present
`Duties:
`
`2022
`2023
`Duties:
`
`2021
`2022
`Duties:
`
`2021
`2022
`Duties:
`
`2021
`2023
`Duties:
`
`2021
`
`
`Oppo
`
`Consulting Expert on speech processing in Nokia matter
`
`Samsung
`
`Testifying Expert on speech processing in Jawbone matter
`
`Asus, Lenovo, MSI
`
`Consulting Expert in VideoLabs matter
`
`Google
`
`Consulting Expert on speech processing in Jawbone matter
`
`Starz
`
`Consulting Expert in VideoLabs matter
`
`Meta Platforms (Facebook)
`
`Consulting Expert in VideShare matter
`
`Oppo
`
`Consulting Expert in InterDigital matter
`
`Apple
`
`Consulting Expert on speech processing in Jawbone matter
`
`Verkada
`
`Testifying Expert in Motorola Solutions matter
`
`Facebook
`
`Consulting Expert in EyesMatch matter
`
`Videoconferencing company
`
`Testifying Expert
`
`Canon
`
`Resume of Cliff Reader, Ph.D.
`Printed: 11/29/23
`
`
`
`
`
`Page 5
`
`

`

`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 15 of 37
`
`
`
`
`To:
`
`
`Date
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`2022
`Duties:
`
`2021
`Duties:
`
`2021
`2022
`Duties:
`
`2020
`2021
`Duties:
`
`2020
`2021
`Duties:
`
`2020
`2023
`Duties:
`
`2020
`2022
`Duties:
`
`2020
`Present
`Duties:
`
`2020
`Present
`Duties:
`
`2019
`2021
`Duties:
`
`2019
`2021
`Duties:
`
`2019
`2020
`
`
`Consulting Expert in WSOU Investments/Brazos Licensing matter.
`
`Axis
`Consulting Expert
`
`nVIDIA
`
`Consultant
`
`Xiaomi
`
`Consulting Expert in InterDigital matter
`
`LG
`
`Consulting Expert DivX matter
`
`Vizio
`
`Consulting Expert VDPP matter
`
`Netflix
`
`Consultant
`
`Oppo
`
`Consultant
`
`IdeaHub
`
`Preparation of declaration for Inter Partes Review proceedings. (Unified
`Patents matter)
`
`Google
`
`Preparation of declarations for Inter Partes Review proceedings (PMC
`matter)
`
`Google
`
`Consulting Expert (Multiple projects)
`
`LG
`
`
`Resume of Cliff Reader, Ph.D.
`Printed: 11/29/23
`
`
`
`
`
`Page 6
`
`

`

`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 16 of 37
`
`
`Duties:
`
`2019
`2021
`Duties:
`
`2019
`2021
`Duties:
`
`2019
`Duties:
`
`2019
`Duties:
`
`2019
`2021
`Duties:
`
`2019
`2020
`Duties:
`
`Preparation of declarations for Inter Partes Review proceedings. (Uniloc
`matter)
`
`Klarquist, Sparkman
`
`Consulting Expert (Multiple projects)
`
`Netflix, Hulu
`
`Preparation of declarations for Inter Partes Review proceedings. (DivX
`matter)
`
`MediaTek
`Consulting Expert in American Patents matter
`
`AT&T
`Consulting Expert
`
`KAIST/KBS
`
`Consulting Expert for Inter Partes Review proceedings. (Unified Patents
`matter)
`
`Vimeo
`
`Preparation of declarations for Inter Partes Review proceedings. (BT
`matter)
`
`Apple
`Preparation of declarations for Inter Partes Review proceedings.
`(Red.com matter)
`
`Adobe
`
`Preparation of declarations for Inter Partes Review proceedings and
`consulting expert. (Realtime matter)
`
`Toshiba
`
`Testifying expert concerning valuation of essential patents for ATSC
`standards
`
`Hisense
`Analysis of essential patents for AAC standards
`
`HTC
`
`
`
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`
`
`Date
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`
`
`2019
`Duties:
`
`Date
`To:
`
`
`Date
`To:
`
`
`2019
`2021
`Duties:
`
`2018
`2019
`Duties:
`
`Date
`
`
`2018
`Duties:
`
`Date
`
`2018
`
`Resume of Cliff Reader, Ph.D.
`Printed: 11/29/23
`
`
`
`
`
`Page 7
`
`

`

`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 17 of 37
`
`
`
`
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`
`
`Date
`
`
`2020
`Duties:
`
`2018
`2020
`Duties:
`
`2017
`2023
`Duties:
`
`2017
`2019
`Duties:
`
`2017
`2020
`Duties:
`
`2017
`2020
`Duties:
`
`2017
`Duties:
`
`2017
`Duties:
`
`Date
`
`
`2017
`Duties:
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`2016
`2019
`Duties:
`
`2016
`2018
`Duties:
`
`2016
`2017
`Duties:
`
`
`Analysis of essential patents for the H.265 standard
`
`Cisco
`
`Consulting expert in Realtime matter
`
`Dish Network
`
`Consulting expert in ClearPlay matter
`
`Apple
`
`Preparation of declarations for Inter Partes Review proceedings. (Uniloc
`matter)
`
`Dish Network
`
`Testifying expert in Realtime matter
`
`CustomPlay
`
`Preparation of declaration for summary judgment in Amazon case.
`
`Vizio, Funai, LG, MediaTek, MStar
`Testifying expert in Broadcom case.
`
`Apple
`Preparation of declarations for Inter Partes Review proceedings. (Nokia
`matter)
`
`Vizio
`Preparation of declarations for Inter Partes Review proceeding.
`(Lightside Technologies matter)
`
`Dell, Riverbed, EchoStar, Dish Network
`
`Testifying expert in Realtime matter
`
`Sharp, Vizio, ON
`
`Testifying expert in WiLAN matter
`
`Avid
`
`Testifying expert in Harmonic matter.
`
`Resume of Cliff Reader, Ph.D.
`Printed: 11/29/23
`
`
`
`
`
`Page 8
`
`

`

`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 18 of 37
`
`
`
`
`Date
`
`
`Date
`
`
`Date
`
`To:
`
`
`Date
`To:
`
`
`Date
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`
`
`2016
`Duties:
`
`2016
`Duties:
`
`2016
`
`2021
`Duties:
`
`2015
`2016
`Duties:
`
`2015
`Duties:
`
`2015
`2016
`Duties:
`
`2015
`2016
`Duties:
`
`2015
`2019
`Duties:
`
`2015
`Duties:
`
`Date
`
`
`2015
`Duties:
`
`Date
`
`
`2015
`Duties:
`
`Date
`To:
`
`2015
`2016
`
`
`Apple
`Testifying expert in PUMA matter.
`
`Vizio
`Testifying expert in PMC matter.
`
`US Dept. of Justice, Dept. of Homeland Security, DoD, FBI, NSA, &
`Others
`
`Consulting expert in Discovery Patents (3rd Eye Surveillance) matter.
`Declarations in support of six Inter Partes Reviews.
`
`ST Micro
`
`Consulting expert in Avago matter.
`
`AT&T
`Consulting expert in Raniere matter.
`
`Motorola
`
`Consulting expert in PUMA matter.
`
`TPV
`
`Consulting expert in Thomson licensing matter.
`
`Tyco (Exacq, Johnson Controls)
`
`Consulting expert in JDS Technologies matter.
`
`Tyco
`Declaration in support of Inter Partes Review petition in Hawk
`Technology matter.
`
`Sceptre
`Expert reports in licensing matter concerning MPEGLA MPEG2 pool
`patents.
`
`Samsung
`Consultant and fact witness in case asserting Samsung patents of which I
`am a named inventor, against NVidia.
`
`Nissim
`
`
`Resume of Cliff Reader, Ph.D.
`Printed: 11/29/23
`
`
`
`
`
`Page 9
`
`

`

`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 19 of 37
`
`
`Duties:
`
`2015
`Present
`Duties:
`
`2015
`Duties:
`
`2015
`Duties:
`
`2014
`2018
`Duties:
`
`2014
`2021
`Duties:
`
`2014
`2015
`Duties:
`
`2014
`2015
`Duties:
`
`2013
`Duties:
`
`2014
`2015
`Duties:
`
`2014
`2015
`Duties:
`
`2014
`2016
`Duties:
`
`Consultant expert for patent holder in 20th Century Fox, MGM, and
`Paramount cases concerning patents related to DVD navigation.
`Testified at Markman hearings.
`
`Nikon
`
`Consultant.
`
`Humax
`Search and analysis of prior art.
`
`Apple
`Analysis of patent portfolio potentially essential for the H.264 standard.
`
`Haier
`
`Analysis of patent portfolios for smart consumer devices.
`
`Cisco
`
`Consultant.
`
`ZTE, Sony, LG, Samsung, Nokia, GoPro
`
`Consulting expert.
`
`Tyco
`
`Expert reports; declaration in support of Inter Partes Review in Trover
`matter.
`
`Humax
`Consultant.
`
`GE Licensing
`
`Consultant.
`
`HikVision & Axis
`
`Declaration in support of Inter Partes Review. Expert reports in Trover
`matter.
`
`Sharp
`
`Declaration in support of Inter Partes Review in Wi-Lan matter.
`
`
`
`
`
`Date
`To:
`
`
`Date
`
`
`Date
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Resume of Cliff Reader, Ph.D.
`Printed: 11/29/23
`
`
`
`
`
`Page 10
`
`

`

`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 20 of 37
`
`
`Date
`To:
`
`
`Date
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`
`
`Date
`To:
`
`
`Date
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`
`
`2013
`2015
`Duties:
`
`2013
`Duties:
`
`2013
`2014
`Duties:
`
`2013
`2014
`Duties:
`
`2013
`Duties:
`
`2013
`Present
`Duties:
`
`2012
`Duties:
`
`2012
`2014
`Duties:
`
`2012
`2014
`Duties:
`
`2012
`2013
`Duties:
`
`2012
`2013
`Duties:
`
`2012
`Duties:
`
`
`InterDigital
`
`Consulting expert in support of licensing a patent portfolio.
`
`Apple
`Consulting expert in National Cheng Kung University matter.
`
`Acer, ASUS, TPV
`
`Testifying expert in Florida Atlantic University matter.
`
`Toshiba
`
`Testifying expert in WiLAN matter.
`
`Grass Valley Group
`Consulting expert for defense in FastVDO matter.
`
`TI
`
`Consulting expert.
`
`Vizio
`Consulting expert in Innovus Prime matter.
`
`Haier & Shandong Provincial Government
`
`Foreign expert advisor for developing and acquiring patent portfolios for
`innovative consumer products. Development of a patent pool for patents
`essential to standards for wireless power.
`
`Vizio
`
`Consulting expert in MIT matter.
`
`Nokia
`
`Consulting expert.
`
`TPV & Vizio
`
`Testifying expert for defense in Hitachi matter.
`
`Samsung
`Consulting expert in Myport matter.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Resume of Cliff Reader, Ph.D.
`Printed: 11/29/23
`
`
`
`
`
`Page 11
`
`

`

`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 21 of 37
`
`
`Date
`To:
`
`
`Date
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`
`
`Date
`
`
`Date
`
`
`Date
`To:
`
`
`Date
`
`
`Date
`
`
`Date
`
`
`Date
`To:
`
`
`Date
`
`
`Date
`
`2012
`2013
`Duties:
`
`2011
`Duties:
`
`2012
`2014
`Duties:
`
`2012
`2014
`Duties:
`
`2011
`Duties:
`
`2011
`Duties:
`
`2011
`Duties:
`
`2011
`2014
`Duties:
`
`2011
`Duties:
`
`2011
`Duties:
`
`2011
`Duties:
`
`2011
`2014
`Duties:
`
`2011
`Duties:
`
`2011
`
`Verizon Wireless (Cellco) & T-Mobile
`
`Testifying expert for defense in Realtime Data matter.
`
`Apple
`Consulting expert in Technicolor matter.
`
`Microsoft
`
`Consulting expert for plaintiff in Motorola matter.
`
`Apple & LG
`
`Testifying expert for defense in MPT matter.
`
`Sanyo & Olympus
`Consulting expert for defense in FastVDO matter.
`
`Apple
`Consulting expert for defense in FastVDO matter.
`
`Sony
`Consulting expert for defense in FastVDO matter.
`
`Philips
`
`Consulting expert for licensing essential patents.
`
`Apple
`Consulting expert for defense in MobileMediaIdeas matter.
`
`Video264Innovations
`Consulting expert.
`
`Nikon, Fujifilm & Panasonic
`Consulting expert for defense in FastVDO matter.
`
`Haier
`
`Consultant for standards, patent pools and patent licensing.
`
`Susman Godfrey
`Consultant for patent analysis.
`
`Vizio
`
`Resume of Cliff Reader, Ph.D.
`Printed: 11/29/23
`
`
`
`
`
`Page 12
`
`

`

`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Case 6:23-cv-00158-ADA Document 63-11 Filed 04/03/24 Page 22 of 37
`
`
`
`
`Date
`
`
`Date
`To:
`
`
`Date
`
`
`Date
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`To:
`
`
`Date
`
`
`Duties:
`
`Testifying expert for defense in MPT matter.
`
`2011
`Duties:
`
`2011
`2013
`Duties:
`
`2011
`Duties:
`
`2010
`Duties:
`
`2010
`2012
`Duties:
`
`2010
`2011
`Duties:
`
`2010
`Duties:
`
`2010
`2011
`Duties:
`
`2010
`2011
`Duties:
`
`2010
`2011
`Duties:
`
`2010
`2015
`Duties:
`
`2009
`Duties:
`
`Tivo
`Consulting expert.
`
`Nikon
`
`Consulting expert for defense in MPT matter.
`
`Broadcom
`Consulting expert.
`
`Lionsgate Entertainment
`Consulting expert in MPEG licensing matter.
`
`Verizon
`
`Testifying expert for defense in ActiveVideo Networks matter.
`
`Lenovo
`
`Consulting expert for defense in licensor matter.
`
`Sonic, Cyberlink & Joint Defense Team
`Consulting expert for defense in Mediostream licensor matter.
`
`Wistron
`
`Consulting expert for defense in Toshiba licensor matter.
`
`Panasonic, Pioneer
`
`Consulting expert for defense in VES licensor matter.
`
`Zoran
`
`Technical analysis of patents potentially related to video coding
`standards.
`
`Intravisual
`
`Consulting exp