Filed on behalf of Petitioner
`By: Richard F. Giunta
`Daniel T. Wehner
`Randy J. Pritzker
`WOLF, GREENFIELD & SACKS, P.C.
`600 Atlantic Avenue
`Boston, MA 02210
`Tel: (617) 646-8000
`Fax: (617) 646-8646
`RGiunta-PTAB@wolfgreenfield.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`RPX Corporation
`Petitioner
`
`v.
`
`MD Security Solutions, LLC
`Patent Owner
`_____________
`
`Case No. TBD
`Patent No. 7,864,983
`_____________
`
`DECLARATION OF TAL LAVIAN, PH.D.
`
`RPX Exhibit 1010
`RPX v. MD SECURITY
`
`

`
`TABLE OF CONTENTS
`
`TABLE OF CONTENTS
`
`I.
`
`PERSONAL AND PROFESSIONAL BACKGROUND ............................... ..1
`
`II. MATERIALS REVIEWED AND CONSIDERED ........................................ ..4
`
`III. LEVEL OF ORDINARY SKILL IN THE ART ............................................. ..4
`
`IV. OVERVIEW OF THE ‘983 PATENT ............................................................ ..6
`
`V.
`
`SUMMARY OF THE ‘983 PATENT CLAIMS ............................................. ..7
`
`VI. CLAIMS 1-20 ARE UNPATENTABLE IN LIGHT OF THE PRIOR
`
`ART IDENTIFIED IN RPX’S PETITION ................................................... .. 13
`
`PERSONAL AND PROFESSIONAL BACKGROUND .................................1
`I.
`II. MATERIALS REVIEWED AND CONSIDERED ..........................................4
`III. LEVEL OF ORDINARY SKILL IN THE ART...............................................4
`IV. OVERVIEW OF THE ‘983 PATENT ..............................................................6
`V. SUMMARY OF THE ‘983 PATENT CLAIMS...............................................7
`VI. CLAIMS 1-20 ARE UNPATENTABLE IN LIGHT OF THE PRIOR
`ART IDENTIFIED IN RPX’S PETITION .....................................................13
`A. Ground 1: Claims 1-8, 11, and 18-20 of the ‘983 Patent Each
`A. Ground 1: Claims 1-8, 11, and 18-20 of the ‘983 Patent Each
`Would have Been Obvious in View of Lee...............................................14
`Would have Been Obvious in View of Lee ............................................. .. 14
`B. Ground 2: Claims 9, 10, and 12-17 of the ‘983 Patent Each Would
`B. Ground 2: Claims 9, 10, and 12-17 of the ‘983 Patent Each Would
`Have Been Obvious In View of Lee and Ozer..........................................59
`C. Ground 3: Claims 1-8, 11, and 18-20 of the ‘983 Patent are
`C. Ground 3: Claims 1-8, 11, and 18-20 of the ‘983 Patent are
`Obvious in view of Milinusic and Osann..................................................76
`Obvious in view of Milinusic and Osann ................................................ ..76
`D. Ground 4: Claims 9, 10, and 12-17 of the ‘983 Patent are Obvious
`D. Ground 4: Claims 9, 10, and 12-17 of the ‘983 Patent are Obvious
`in view of Milinusic, Osann, and Ozer....................................................114
`in view of Milinusic, Osann, and Ozer.................................................. ..114
`VII. SIGNATURE.................................................................................................130
`
`Have Been Obvious In View of Lee and Ozer ........................................ ..59
`
`VII. SIGNATURE ............................................................................................... ..130
`
`APPENDICES A-D…………………………………………………………….
`
`APPENDICES A-D .................................................................... ..
`
`i
`
`

`
`I, Tal Lavian, Ph.D., declare:
`
`1.
`
`I have been retained by Petitioner RPX Corporation (“RPX”), to
`
`assess U.S. Patent No. 7,864,983 (“the ’983 patent). I am being compensated
`
`for my time at a rate of $400 per hour, plus actual expenses. My compensation
`
`is not dependent in any way upon the outcome of RPX’s petition.
`
`I.
`
`PERSONAL AND PROFESSIONAL BACKGROUND
`
`2.
`
`I have more than 27 years of professional experience. In 1987, I
`
`obtained a Bachelor of Science (“B.Sc.”) in Mathematics and Computer Science
`
`from Tel Aviv University, Israel. In 1996, I obtained a Master’s of Science
`
`(“M.Sc.”) degree in Electrical Engineering also from Tel Aviv University. In
`
`2006, I received a Ph.D. in Computer Science from the University of California
`
`at Berkeley.
`
`3.
`
`I am employed by the University of California at Berkeley, and was
`
`appointed as a lecturer and Industry Fellow in the Center of Entrepreneurship
`
`and Technology (“CET”) as part of UC Berkeley College of Engineering. I have
`
`been with the University of California at Berkeley since 2000 where I served as
`
`a Berkeley Industry Fellow, Lecturer, Visiting Scientist, Ph.D. Candidate, and
`
`Nortel’s Scientist Liaison.
`
`4.
`
`As an undergraduate and a Masters student in Tel Aviv University,
`
`I worked part time as a security officer and first respondent in a national oil and
`
`1
`
`

`
`gas repository. My duties included operating a control room with multiple
`
`security alarm systems, including many security cameras, different types of
`
`sensor technologies including motion sensors.
`
`5.
`
`My Master’s thesis was in the area of image processing. From
`
`1987 until 1990, I worked for an Israeli startup (Shalev, Inc.). At that position, I
`
`developed image processing software for analysis of camera images from
`
`multiple angles. This included finding the exact shapes, borders and contours of
`
`objects.
`
`6.
`
`From 1990 to 1993, I worked as a software engineer and team
`
`leader at Scitex Ltd., where I developed system and network communications
`
`tools. From 1994 to 1995, I worked as a software engineer and team leader for
`
`Aptel Communications, designing and developing mobile wireless devices and
`
`network software products.
`
`7.
`
`From 1996 to 2007, I worked for Bay Networks and Nortel
`
`Networks. Bay Networks was in the business of making and selling computer
`
`network hardware and software. Nortel Networks acquired Bay Networks in
`
`1998, and I continued to work at Nortel after the acquisition. Throughout my
`
`tenure at Bay and Nortel, I held positions including Principal Scientist, Principal
`
`Architect, Principal Engineer, Senior Software Engineer, and led the
`
`2
`
`

`
`development and research involving a number of networking technologies. I led
`
`the efforts of Java technologies at Bay network and Nortel Networks.
`
`8.
`
`I am named as a co-inventor on more than 80 issued patents and I
`
`have co-authored more than 25 scientific publications, journal articles, and peer-
`
`reviewed papers. Furthermore, I am a Senior Member of the Institute of
`
`Electrical and Electronics Engineers (“IEEE”).
`
`9.
`
`I currently serve as a Co- Founder and Chief Technology Officer
`
`(CTO) of VisuMenu, Inc., where I design and develop architectures of visual
`
`IVR technologies for smartphones and wireless mobile devices in the area of
`
`network communications.
`
`10. A detailed record of my professional qualifications, including a list
`
`of patents and academic and professional publications, is set forth in my
`
`curriculum vitae attached to this declaration as Exhibit 1011.
`
`11.
`
`Prior to reviewing the ‘983 patent, I was well familiar with the
`
`subject matter described and claimed in the ‘983 patent. The ‘983 patent
`
`concerns a security system that includes one or more motion-activated cameras
`
`that records images in response to detecting motion and can be controlled by a
`
`handheld device, such as a cellular phone. (Ex. 1001 at 2:30-52;11:1-16 ) I am
`
`an expert in the field of home security systems and networking for connecting
`
`and controlling such systems.
`
`3
`
`

`
`II. MATERIALS REVIEWED AND CONSIDERED
`
`12.
`
`In connection with my work on this matter, I have reviewed the
`
`‘983 patent (Ex. 1001) as well as the other following documents:
`
`EXHIBIT
`
`DESCRIPTION
`
`1001
`
`1002
`
`1003
`
`1004
`
`1005
`
`1006
`
`1007
`
`1008
`
`U.S. Patent No. 7,864,983 (“the ‘983 patent”)
`
`U.S. Patent Publication No. 2005/0267605 (“Lee”)
`
`U.S. Patent No. 7,106,333 (“Milinusic”)
`
`U.S. Patent No. 7,253,732 (“Osann”)
`
`U.S. Patent Publication No. 2004/0120581 (“Ozer”)
`
`U.S. Patent Publication No. 2007/0070185 (“Dy”)
`
`U.S. Patent No. 7,463,145 (“Jentoft”)
`
`Website: http://www.apple.com/pr/library/2001/10/16Apple-Powers-
`
`Up-Titanium-PowerBook-G4-with-New-G4-Processors.html
`
`1009
`
`Website: http://searchnetworking.techtarget.com/definition/terminal
`
`III. LEVEL OF ORDINARY SKILL IN THE ART
`
`13.
`
`For purposes of assessing whether prior art references disclose
`
`every element of a patent claim (thus “anticipating” the claim) and/or would
`
`have rendered the claimed invention obvious, I understand that the ‘983 patent
`
`and the prior art references must be assessed from the perspective of a person
`
`4
`
`

`
`having ordinary skill in the art (“POSA”) to which the patent is related, based on
`
`the understanding of that person at the time of the invention date. I understand
`
`that a POSA is presumed to be aware of all pertinent prior art and the
`
`conventional wisdom in the art, and is a person having ordinary creativity. I
`
`have applied this standard throughout my declaration.
`
`14.
`
`I have been asked to provide my opinion as to the state of the art in
`
`the field of security systems in the 2006 timeframe. I use the 2006 timeframe
`
`because the ‘983 patent claims priority on its face to applications filed in March
`
`and June of 2006. Whenever I offer an opinion below about the knowledge of a
`
`POSA, the manner in which a POSA would have understood the claims of the
`
`‘983 patent, the manner in which a POSA would have understood the prior art,
`
`or what a POSA would have been led to do based on the prior art, I am
`
`referencing this timeframe (i.e., 2006). When I offer an opinion or explanation
`
`below about the teachings of the prior art and/or the claims of the ‘983 patent, I
`
`am explaining how the issue would have been viewed by a POSA in the 2006
`
`timeframe, even if I do not say so specifically in each case. In my opinion, a
`
`POSA related to the ‘983 patent in the 2006 timeframe would have had at least a
`
`B.S. in Electrical Engineering, Computer Engineering or Computer Science or
`
`the equivalent, along with 2 years of working experience in image processing
`
`and/or developing telecommunications systems such as networked computer
`
`5
`
`

`
`systems. This person would have been capable of understanding and applying
`
`the prior art references discussed herein.
`
`15. By 2006, I had received a Ph.D. in Computer Science with a focus
`
`on telecommunications, had received a Master’s degree with a thesis focused on
`
`image processing, and had over 18 years of relevant professional experience.
`
`Therefore, I was a person of more than ordinary skill in the art during the
`
`relevant time period. However, I worked with many people who fit the
`
`characteristics of the POSA, and I am familiar with their level of skill. When
`
`developing the opinions set forth below, I assumed the perspective of a person
`
`having ordinary skill in the art, as set forth above.
`
`IV. OVERVIEW OF THE ‘983 PATENT
`
`16.
`
`The claims of the ‘983 patent relate to a security alarm system
`
`having one or more cameras and one or more motion detectors associated with
`
`and coupled to the camera(s) to activate the camera(s) when the motion
`
`detector(s) detect motion in a monitored area. The security system also includes
`
`a processor that receives commands from a handheld telecommunications unit,
`
`such as a cell phone, so that the system can be remotely controlled from the
`
`handheld telecommunications unit. The commands sent from the handheld
`
`telecommunications unit to the computer include a command for the processor to
`
`provide images captured by the camera(s) to the handheld telecommunications
`
`6
`
`

`
`unit. Some of the dependent claims describe other commands that the handheld
`
`telecommunications unit can send to the computer. Other dependent claims
`
`describe an image analysis process where images captured by the camera(s) are
`
`analyzed to identify objects in the images and perform actions based on the
`
`identified objects. As discussed further below, security systems with all of these
`
`features were well known before the ‘983 patent’s filing date.
`
`17. As discussed below, the claims of the ‘983 patent cover a security
`
`system and a method of operating a security alarm system having motion-
`
`activated cameras that can be controlled by a handheld telecommunications unit
`
`and include a number of other requirements. Systems and methods meeting all
`
`of the requirements of the claims were known to those of skill in the art before
`
`the ‘983 patent was filed. Both of the primary prior art references discussed
`
`below (i.e., Lee and Milinusic) provide an example of a security system that
`
`included motion-activated cameras controllable by a handheld
`
`telecommunications unit before the priority date of the ‘983 patent and meet or
`
`render obvious, alone or in combination with other references, all of the
`
`challenged claims.
`
`V.
`
`SUMMARY OF THE ‘983 PATENT CLAIMS
`The ‘983 patent (Ex. 1001)1 describes and claims an alarm system
`
`18.
`
`1 Unless otherwise indicated, all citations in Section V are to Ex. 1001.
`
`7
`
`

`
`as described in Section IV above. I understand that each claim must be
`
`evaluated individually on its merits, and I have done so below. The ‘983 patent
`
`includes independent claims 1 and 11. The bracketed letters are added for
`
`purposes of cross reference.
`
`1. An alarm system for protecting a structure, comprising:
`[A] at least one motion detector arranged to have a field of view
`external of the structure and including an area proximate the
`structure;
`[B1] at least one camera associated with and coupled to each of
`said at least one motion detector,
`[B2] each of said at least one camera being arranged relative to
`the associated one of said at least one motion detector such that
`said camera has a field of view encompassing at least part of the
`field of view of the associated one of said at least one motion
`detector,
`[B3] each of said at least one camera having a dormant state in
`which images are not obtained and an active state in which
`images are obtained and being activated into the active state
`when the associated one of said at least one motion detector
`detects motion;
`[C] a processor coupled to said at least one camera and arranged
`to control said at least one camera and receive the image obtained
`by said at least one camera;
`
`8
`
`

`
`[D]
`a telecommunications module coupled to said processor,
`telecommunications module
`being
`capable
`of
`said
`communications over a telecommunications network; and
`[E] a handheld telecommunications unit for transmitting
`commands for said processor via said telecommunications
`module to cause said processor to provide images to said
`telecommunications module
`to be
`transmitted
`to
`the
`telecommunications unit.
`
`19.
`
`Independent claim 11 is a method claim that includes limitations
`
`similar to those in claim 1, with some differences noted below.
`
`11. A method for protecting a structure, comprising:
`[A] arranging a plurality of motion detectors on or around the
`structure, each in a position in which its field of view includes an
`area proximate the structure;
`[B1] arranging a plurality of cameras on or around the structure,
`each camera being associated with one or more of the motion
`detectors
`[B2] such that the camera has a field of view encompassing at
`least part of the field of view of any associated motion detector,
`[C] providing a processor which controls the at least one camera
`and receives images obtained by the at least one camera;
`[D]
`coupling a telecommunications module coupled to the
`processor, the telecommunications module being capable of
`communications over a telecommunications network; and
`[E]
`
`
`transmitting
`commands
`from
`a
`handheld
`telecommunications
`unit
`to
`the
`processor
`via
`the
`
`9
`
`

`
`telecommunications module to cause the processor to provide
`images to the telecommunications module to be transmitted to the
`telecommunications unit.
`
`20.
`
`Elements A, B1, and B2 recite typical components of a security
`
`system that includes one or more motion detectors and one or more cameras
`
`having a field of view that overlaps at least partially with the field of view of the
`
`motion detector(s). The specification of the ‘983 patent indicates that the motion
`
`detectors and the cameras both can be “standard, off-the-shelf components.” (Ex.
`
`1001: 7:19-21; 8:23-26). Element B3 recites functionality of the camera as
`
`being activated into an active state in which images are acquired when the
`
`motion detector detects motion. Motion-activated cameras for use in security
`
`systems were well-known prior to the relevant timeframe, as discussed in more
`
`detail below. Element B3 is absent from independent claim 11.
`
`21.
`
`Elements C, D, and E recite typical components of a security
`
`system that can be controlled by a device over a telecommunications network.
`
`Element C (a processor) interfaces with the security system components such as
`
`the camera and the motion detector. Element D (a “telecommunications
`
`module”) provides a communications interface between a handheld device and
`
`the processor. Element E (a “handheld telecommunications unit”) sends and
`
`receives information to/from the processor via the telecommunications module.
`
`10
`
`

`
`22.
`
`I have been informed by counsel that a claim in a patent subject to
`
`inter partes review must be given its “broadest reasonable interpretation”
`
`(BRI),” consistent with the specification. I understand that a claim term
`
`explicitly defined in the specification of the patent should be interpreted in
`
`accordance with that definition. I further understand that a claim term that is not
`
`defined in the specification should be interpreted in accordance with its plain
`
`and ordinary meaning to a POSA at the time that the patent was filed if that plain
`
`and ordinary meaning is consistent with the specification. For example, I
`
`understand that the BRI of a claim term should be sufficiently broad to
`
`encompass any examples or embodiments of the term described in the
`
`specification. I apply the BRI standard in my analysis below.
`
`23.
`
`“Structure” is not defined in the specification of the ‘983 patent.
`
`The specification provides several non-limiting examples of “premises or
`
`structure” such as a house, a warehouse, a boatyard, a business, a boat, or a land
`
`vehicle. (Ex. 1001 at 6:54-65). Thus, the BRI of the term “structure” includes at
`
`least the types of structures identified in the specification.
`
`24.
`
`“Telecommunications network” is not defined in the specification
`
`of the ‘983 patent. The specification describes communications between the
`
`handheld telecommunications unit and the processor using a telephone network
`
`(Ex. 1001 at 11:23-30) or a computer network, such as the Internet (Ex. 1001 at
`
`11
`
`

`
`13:21-24). The plain and ordinary meaning of “telecommunications network”
`
`encompasses at least such networks. The BRI of “telecommunications network”
`
`to a POSA refers to a collection of nodes and links that enables the transmission
`
`of information between two computing entities, and encompasses at least
`
`telephone networks and computer networks, such as the Internet.
`
`25.
`
`“Handheld telecommunications unit” is not defined in the
`
`specification of the ‘983 patent. The specification provides several examples of
`
`handheld telecommunication units including a cellular telephone, an iPod, a
`
`PDA, and a laptop computer. (Ex. 1001 at 6:2-6). Thus, the BRI of “handheld
`
`telecommunications unit” consistent with the specification includes at least those
`
`devices described as examples in the ‘983 patent specification.
`
`26.
`
`“Silhouette” is not defined in the specification of the ‘983 patent. A
`
`silhouette generally refers to the shape or outline of an object. The specification
`
`describes derivation of a silhouette of an object as being based on a number of
`
`descriptors that are typical for the object (e.g., human body), or on other factors
`
`which can be used to distinguish, discriminate and/or differentiate the object
`
`from other types of objects (e.g., distinguishing animals from humans). (Ex.
`
`1001 at 9:35-39). Thus, the BRI of “silhouette” consistent with the specification
`
`includes a representation of an object derived using at least the techniques
`
`described in the ‘983 patent specification.
`
`12
`
`

`
`VI. CLAIMS 1-20 ARE UNPATENTABLE IN LIGHT OF THE PRIOR
`ART IDENTIFIED IN RPX’S PETITION
`
`27.
`
`I have been asked to provide my opinion concerning whether
`
`claims 1-20 of the ‘983 patent are unpatentable based on the prior art references
`
`identified in RPX’s petition. The prior art references I reviewed include:
`
`EXHIBIT
`
`PRIOR ART REFERENCE
`
`1002
`
`1003
`
`1004
`
`1005
`
`U.S. Patent Publication No. 2005/0267605 (“Lee”)
`
`U.S. Patent No. 7,106,333 (“Milinusic”)
`
`U.S. Patent No. 7,253,732 (“Osann”)
`
`U.S. Patent Publication No. 2004/0120581 (“Ozer”)
`
`28.
`
`I understand that in an inter partes review proceeding, claim terms
`
`should be given their broadest reasonable interpretation (BRI) consistent with
`
`the specification. In my analysis below and as discussed above, I apply that
`
`standard to the words and phrases of the challenged claims.
`
`29. My opinions on the disclosure of each prior art reference, as
`
`relevant to the limitations of claims 1-20 of the ‘983 patent, are provided below.
`
`Claim charts with mappings from references to the claims of the ‘983 patent are
`
`attached for each of Grounds 1-4 as Appendices A-D, respectively, to this
`
`Declaration.
`
`13
`
`

`
`A.
`
`Ground 1: Claims 1-8, 11, and 18-20 of the ‘983 Patent
`Each Would have Been Obvious in View of Lee
`
`30. According to the face of the document, Lee (Ex. 1002) is a U.S.
`
`patent application that published on December 1, 2005, from an application that
`
`was filed on January 6, 2005. I have been informed by counsel that it meets the
`
`requirements to be prior art to the ‘983 patent.
`
`31.
`
`Lee describes a home entertainment security, surveillance, and
`
`automation control system that includes a main control unit, a plurality of
`
`remote devices, including a surveillance and security device (“S&S device”),
`
`and various user input devices capable of receiving a home user’s commands
`
`(abstract, FIG. 1) 2. Lee teaches that, in the 2005 timeframe, integrating audio
`
`and video devices into an existing home or building was complicated and costly
`
`due to the requirement to install new control wires. [0012]. The system of Lee
`
`uses RF/wireless communication and power line communication that is capable
`
`of transmitting various data via the power line without additional hardwire
`
`connections. [0066]-[0067].
`
`32.
`
`The main control unit 100 of Lee is connected to remote devices
`
`(including S&S device 212) via a power line communication link 200 (FIG. 1).
`
`The main control unit 100 is configured to control the system and perform
`
`communication with one or more remote devices and user input devices via the
`
`2 Unless otherwise indicated, all citations in §A(¶¶30-86) are to Ex. 1002 (Lee).
`
`14
`
`

`
`power line communication link 200 or a wireless connection link. [0068]. Lee
`
`describes several types of user devices that can send control signals or control
`
`data to the main control unit 100. These user devices include a remote control
`
`281, a cell phone 283, a wireless PDA 282, and a remote computer 291 that can
`
`communicate with main control unit 100 over the Internet. [0060];[0062]. The
`
`main control unit 100 controls the operation of remote devices, including S&S
`
`device 212, in response to commands received from one or more of the user
`
`devices. [0057]; [0107]; [0109].
`
`33.
`
`The S&S device 212 is shown in more detail in FIG. 9 and includes
`
`one or more camera modules and one or more sensor modules. [0103]-[0104].
`
`Each of the camera modules includes a camera 922, a sensor 923, and a camera
`
`interface 921. [0104]. Each of the sensor modules includes a sensor 931 and a
`
`sensor interface 932. [0104]. A house or building can be provided with a
`
`plurality of S&S devices 212 inside and outside the house/building to record
`
`information. [0105]; [0112]. Lee describes several modes in which the S&S
`
`device 212 may be set to operate, including an “ON mode,” an “OFF mode,” and
`
`an “INTERRUPT mode.” [0107]. When the S&S device 212 is in “ON mode,”
`
`the camera 922 is in a non-stop working state and in the “OFF mode” the camera
`
`is not working. [0107]. Lee describes that in “INTERRUPT mode,” the camera
`
`will be on if a triggered signal is received from sensor 923. [0107]-[0108]. The
`
`15
`
`

`
`sensor 923 may trigger activation of the camera when, for example, presence of
`
`an intruder is detected by the sensor. [0108]; [0111]. Lee does not explicitly
`
`state that in “INTERRUPT mode” the camera is off (or “dormant”) and not
`
`recording images prior to receiving a trigger signal, but a POSA would have
`
`understood that to be the case because otherwise, there would be no difference
`
`between Lee’s “INTERRUPT mode” and Lee’s “ON mode” in which images are
`
`recorded continuously.
`
`34.
`
`The S&S device 212 can include any number of camera and sensor
`
`modules ([0105]), and numerous types of sensors including motion sensors.
`
`[0110].
`
`35.
`
`Images acquired by the camera 922 are transmitted to the main
`
`control unit 100 via power line communication network 200. [0111]. The
`
`images may be watched live on an LCD display 50 (FIG. 1; [0084]; [0112]),
`
`stored on a mass storage module of the main control unit 100 ([0076]), and/or
`
`provided to remote computer 291 [0062]. When the S&S device 212 is
`
`triggered, information is sent to the main control unit 100 to alert the user of the
`
`event sensed by the S&S device 212 and the main control unit may
`
`automatically call the user’s mobile telephone 283 if the user is not home.
`
`[0111]. The user may also monitor the system over the Internet. [0111].
`
`16
`
`

`
`36. After reviewing Lee and claims 1-8, 11, and 18-20 of the ‘983
`
`patent, it is my opinion that every one of these claims would have been obvious
`
`to a POSA in view of Lee. The basis for my opinion and the details of my
`
`analysis are below.
`
`i.
`
`Claim 1: “An alarm system for protecting a structure,
`comprising:”
`
`37.
`
`Lee’s system incorporates a surveillance and security (“S&S”)
`
`device 212 that includes one or more camera modules 920 and one or more
`
`sensor modules 930. [0103]-[0104]. When the S&S device 212 has been
`
`triggered, the user can be alerted about the nature of the unusual event
`
`information sensed by the sensor(s) in the system in a number of ways, including
`
`via a text message, a live image sent to a display device 50, a telephone call to
`
`the user’s mobile telephone if the user is not home, and/or via remote monitoring
`
`by the user over the Internet. [0111]. Accordingly, a POSA would have
`
`understood Lee’s system to be an alarm system.
`
`38.
`
`The camera modules 920 and sensor modules 930 are installed
`
`inside and outside of a house, which is a structure (see ¶23). Accordingly, Lee’s
`
`system is an alarm system for protecting a structure.
`
`17
`
`

`
`a.
`
`“[A] at least one motion detector arranged to have a
`field of view external of the structure and including
`an area proximate the structure;”
`
`39.
`
`Each of the camera modules 920 and sensor modules 930 in S&S
`
`device 212 includes a sensor. [0104]. The sensors include motion sensors.
`
`[0110]. The camera module(s) 920 and the sensor module(s) 930 may be
`
`installed outside a house as well as inside. [0105]. Lee describes that the
`
`purpose of the S&S device 212 is to monitor the house and detect intruders
`
`(“there is provided a security and surveillance device, including a plurality of
`
`sensors and cameras installed in correspondence to a place to be monitored for
`
`detecting information about [an] intruder.” [0028]; “the sensor can send [a]
`
`trigger signal to the camera 922 when the presence of an intruder has been
`
`detected by the sensor and the sensor is triggered.” [0108]). Lee is not explicit
`
`about where the camera modules 920 and sensor modules 930 of the S&S device
`
`212 are placed outside the house and what field of view the motion detectors and
`
`cameras incorporated into the modules would have, but teaches that the modules
`
`should be “installed in the necessary sites inside and outside the house.” [0105].
`
`To achieve Lee’s stated purpose of detecting the presence of an intruder and
`
`detecting information about an intruder ([0028]; [0108]), a POSA would have
`
`understood that “the necessary sites” to monitor include the areas proximate the
`
`access points to the house (e.g., doors and windows). Thus, it would have been
`
`18
`
`

`
`obvious to a POSA to implement a home installation of the Lee system by
`
`arranging motion sensors to have a field of view external of a structure (i.e., the
`
`house), and that the field of view would include areas proximate the structure
`
`(e.g., proximate doors and windows) to detect motion of any intruders seeking to
`
`enter the house.
`
`b.
`
`“[B1] at least one camera associated with and coupled
`to each of said at least one motion detector,”
`
`40.
`
`The S&S device 212 in Lee’s system includes a plurality of camera
`
`modules 920 that each includes a surveillance camera 922 coupled to a sensor
`
`923 (which may be a motion detector), and where the camera can be activated to
`
`record images when the motion detector is triggered. [0108]; [0110]-[0111];
`
`FIG. 9. For example, Lee states, “the sensor can send [a] trigger signal to the
`
`camera 922 when the presence of an intruder has been detected by the sensor
`
`and the sensor is triggered.” [0108]. Accordingly, a POSA would have
`
`understood that Lee discloses at least one camera associated with and coupled to
`
`at least the motion detector.
`
`19
`
`

`
`c.
`
`“[B2] each of said at least one camera being arranged
`relative to the associated one of said at least one
`motion detector such that said camera has a field of
`view encompassing at least part of the field of view of
`the associated one of said at least one motion
`detector,”
`
`41.
`
`Lee does not explicitly state that the field of view of a camera 922
`
`within a camera module 920 encompasses at least part of the field of view of at
`
`least one motion detector 923 that is within the same camera module 920 and
`
`associated with the camera 922. However, a POSA would have understood this
`
`to have been implicitly disclosed by Lee’s description of a sensor (motion
`
`detector) 923 being disposed in the same module as the associated camera 922.
`
`([0104]; FIG. 9), and by Lee’s disclosure that cameras and motion detectors are
`
`“installed in correspondence to a place to be monitored for detecting information
`
`about [an] intruder.” [0028]. A POSA would have understood that the camera
`
`and sensor in the same module “installed in correspondence to a place to be
`
`monitored” (emphasis added) would be arranged to monitor the same “place”
`
`by having fields of view that both encompass that “place.”
`
`42. Alternatively, even if a POSA would not have considered Lee to
`
`implicitly disclose that the camera 922 had a field of view that encompasses at
`
`least part of the field of view of its associated sensor 923 within a camera
`
`module 920, this would have been the obvious way a POSA would have
`
`implemented Lee’s system. Lee indicates that cameras and motion detectors are
`
`20
`
`

`
`“installed in correspondence to a place to be monitored for detecting information
`
`about [an] intruder” ([0028]) and that “[g]enerally, the camera module 920,
`
`sensor module 930, and wireless module 940 are installed at necessary sites
`
`inside and outside the house.” [0105]. To achieve Lee’s stated purpose of
`
`detecting the presence of an intruder in a place and detecting information about
`
`an intruder in that place ([0028]; [0108]), and to implement the “INTERRUPT
`
`mode” where the camera is activated by a trigger signal from the motion detector
`
`([0107]-[0111]), a POSA would have understood that the area monitored by the
`
`camera should include at least part of the area monitored by the sensor.
`
`Otherwise, the camera would not be able to capture images of the intruder
`
`detected by the motion detector. In addition, there would be no reason to
`
`activate the camera based upon an event (e.g., detected motion) if the camera
`
`cannot capture any information about the triggering event. Thus, it would have
`
`been obvious to a POSA to implement a home installation of the Lee system by
`
`arranging the camera 922 within a camera module 920 to have a field of view
`
`that encompasses at least part of the field of view of at least one motion detector
`
`923 within the same camera module.
`
`43.
`
`To further support my opinion that it would have been obvious to a
`
`POSA to implement Lee’s system so that the