`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________
`
`JUNIPER NETWORKS INC.,
`RUCKUS WIRELESS, INC.,
`BROCADE COMMUNICATION SYSTEMS, INC.,
`and NETGEAR, INC.,
`
`Petitioners,
`
`v.
`
`CHRIMAR SYSTEMS, INC.,
`
`Patent Owner.
`
`
`
`
`
`Case Nos. IPR2016-01391, 2016-01399, and 2016-013971
`
`U.S. Patent Nos. 8,942,107 B2, 8,902,760 B2, and 9,019,838 B2
`
`
`
`
`SUPPLEMENTAL DECLARATION OF DR. VIJAY K. MADISETTI
`IN SUPPORT OF PATENT OWNER’S RESPONSE UNDER
`37 C.F.R. § 42.64(b)(2)
`
`
`
`
`1 Ruckus Wireless, Inc., Brocade Communication Systems, Inc. and Netgear, Inc.
`filed a petition in (now terminated) IPR2017-00718, IPR2017-0719, and IPR2017-
`0720 who have been joined to the instant proceeding.
`
`Page 1 of 8
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`CHRIMAR 2053
`
`
`
`Identifier
`
`
`
`
`
`List of Exhibits
`
`
`Exhibit
`Description
`No.
`2017 Memorandum Opinion and Order,
`Dkt. No. 96, filed in Chrimar
`Systems, Inc., et al. v. AMX,
`LLC, Civil Action No. 6:13-cv-
`881-JDL, Eastern District of
`Texas
`2018 Memorandum Opinion and Order,
`Dkt. No. 105, filed in Chrimar
`Systems, Inc., et al. v. AMX,
`LLC, Civil Action No. 6:13-cv-
`881-JDL, Eastern District of
`Texas
`2019 Memorandum Opinion and Order,
`Dkt. No. 108, filed in Chrimar
`Systems, Inc., et al. v. AMX,
`LLC, Civil Action No. 6:13-cv-
`881-JDL, Eastern District of
`Texas
`2020 Memorandum Opinion and Order,
`Dkt. No. 122, filed in Chrimar
`Systems, Inc., et al. v. Alcatel-
`Lucent, et al., Civil Action No.
`6:15-cv-163-JDL, Eastern District
`of Texas
`2021 Memorandum Opinion and Order,
`Dkt. No. 123, filed in Chrimar
`Systems, Inc., et al. v. Alcatel-
`Lucent, et al., Civil Action No.
`6:15-cv-163-JDL, Eastern District
`of Texas
`
`Date
`October 12,
`2016
`
`October 12,
`2016
`
`October 12,
`2016
`
`October 12,
`2016
`
`October 12,
`2016
`
`
`
`
`
`
`
`
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`
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`Page 2 of 8
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`CHRIMAR 2053
`
`
`
`
`
`Date
`October 12,
`2016
`
`October 12,
`2016
`
`October 12,
`2016
`
`
`
`
`11/5/1999
`
`Identifier
`
`
`
`
`
`
`
`Madisetti Decl.
`¶Dep.
`
`Anderson 1999
`slides
`
`3/7-8/2000
`
`5/24-25/2000
`
`
`
`
`
`5/24/2000
`
`Dove slides
`
`2040
`
`2041
`
`2042
`
`
`Exhibit
`Description
`No.
`2035 Memorandum Opinion and Order,
`Dkt. No. 318, filed in Chrimar
`Systems, Inc., et al. v. AMX,
`LLC, Civil Action No. 6:13-cv-
`881-JDL, Eastern District of
`Texas
`2036 Response to Office Action
`(Reexam Control No. 90/009,513)
`(June 15, 2010)
`2037 Notice of Intent to Issue Ex Parte
`Reexamination Certificate
`(Reexam Control No. 90/009,513)
`(Nov. 22, 2010)
`2038 Declaration of Dr. Vijay Madisetti
`2039 Deposition transcript of Ian
`Crayford
`Slides titled “DTE Power via
`MDI: System Requirements,”
`presented on November 5, 1999
`by Arlan Anderson of Nortel
`Networks
`IEEE Power via MDI Task Force
`Meeting Minutes from March 7-8,
`2000
`IEEE Power via MDI Task Force
`Meeting Minutes from May 24-25,
`2000
`Slides titled “DTE Power over
`MDI: Building Consensus,”
`presented on May 24, 2000 by
`Ralph Andersson of TDK
`Semiconductor, Daniel Dove of
`Hewlett Packard, and Robert Muir
`of Level One Communications
`
`2043
`
`Page 3 of 8
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`CHRIMAR 2053
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`
`
`
`Exhibit
`No.
`2044
`
`2045
`
`2046
`
`
`
`Date
`5/24/2000
`
`Identifier
`Anderson 2000
`slides
`
`7/11-12/2000
`
`
`
`
`
`Karam slides
`
`May 1993
`
`Krol RFC
`
`
`
`
`
`
`
`
`
`
`Camp Decl.
`
`
`
`the ‘142 patent
`
`
`
`
`Description
`Slides titled “Powering and
`Discovery Alternatives,”
`presented on May 24, 2000 by
`Arlan Anderson of Nortel
`Networks
`IEEE Power via MDI Task Force
`Meeting Minutes from July 11-12,
`2000
`Slides titled “Technical Feasibility
`of Sending Common Mode Power
`on the Signal Pairs,” presented on
`May 24, 2000 by Roger Karam
`and Karl Nakamura of Cisco
`Systems
`E. Krol & E. Hoffman, Internet
`Engineering Task Force Network
`Working Group, Request for
`Comments: 1462, “FYI on ‘What
`is the Internet?’”
`2048 Declaration of Clyde Camp
`2049 U.S. Patent No. 5,995,392
`2050 Dr. Vijay Madisetti CV
`2051 Not used
`2052 U.S. Pat. No. 7,061,142 B1
`2053
`Supplemental Declaration of Dr.
`Vijay Madisetti
`2054 Declaration of Steven Johnson
`
`2047
`
`
`
`I, Dr. Vijay Madisetti, declare as follows:
`
`
`
`I am making this declaration at the request of Chrimar Systems, Inc.
`
`(“Chrimar” or “Patent Owner”) in the matter of Inter Partes Review (“IPR”) of U.S.
`
`Patent Nos. 8,942,107 (“the ‘107 Patent”), 8,155,012 (“the ‘012 Patent”), 8,902,760
`
`(“the ‘760 Patent”), and 9,019,838 (“the ‘838 Patent”).
`
`Page 4 of 8
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`CHRIMAR 2053
`
`
`
`
`
`
`
`
`
`I have previously submitted a declaration in the IPR.
`
`I am being compensated for my work in this matter at a rate of
`
`
`
`$450/hour. I am also reimbursed for my reasonable expenses incurred in connection
`
`with my work on this proceeding. My compensation in no way depends on the
`
`outcome of this proceeding.
`
`
`
`I understand that the Petitioners have filed objections to my declaration
`
`pursuant to 37 C.F.R. § 42.64. Specifically, Petitioners have objected to paragraphs
`
`45, 56, 93, 157, and 191 of my declaration.
`
`
`
`Paragraph 45 states:
`
`Both Grounds fail to take into consideration the pre-existing Ethernet
`environment, which is the environment for the claimed invention. (Pet., p. 3;
`Ex.1002, ¶45.) Petitioners’ unstated assumption is that telephony devices
`could simply have been added into the Ethernet systems, but that is untrue.
`Using Petitioners’ proposed telephone-based phantom-power combinations –
`unaltered, as proposed – in an existing Ethernet network would have burned
`out the existing Bob Smith terminations. The result would be impaired signal
`integrity and degraded propagation of Ethernet data. (See, e.g., Ex.2039 at
`45:10-21.) That would be contrary to the stated motivation of not “using any
`bandwidth from [the Ethernet] channel.” (Pet. at 53.) Damaging Bob Smith
`terminations would most certainly have reduced the available bandwidth.
`
`
`
`
`Paragraph 56 states:
`
`At the time of the invention of the patents, and for several years afterward,
`experts in the field were skeptical that operating power could be delivered to
`terminal equipment using the Ethernet data pairs (contacts 1, 2, 3, and 6)
`without disrupting the data propagation.
`
`
`
`
`Paragraph 93 states:
`
`Page 5 of 8
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`CHRIMAR 2053
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`For many years, Ethernet terminal devices could not receive operating power
`over the Ethernet data path. If an Ethernet network hub were to apply PoE
`power and create a DC current path using the Ethernet data wires to Ethernet
`equipment, the operating power would have destroyed the “Bob Smith”
`terminations in the equipment and saturated the common mode chokes. As
`such, a PoE network could not provide PoE power to an Ethernet terminal
`device unless it already knew that the device was a PoE terminal device and
`not a standard Ethernet terminal device.
`
`
`
`
`Paragraphs 157 and 191 mentioned by Petitioners are similar to
`
`paragraph 93.
`
`
`
`I have provided my support for each of these paragraphs in my
`
`declaration, which includes my knowledge and experience in the field as well as the
`
`knowledge of IEEE standards committee documents and activities.
`
` While I believe it unnecessary, I provide this supplemental declaration
`
`in response to Petitioners’ objections. I am familiar with the following references
`
`that support my earlier testimony.
`
` Cisco Systems is the leading provider of networking and Ethernet
`
`products both in the US and internationally, and has provided a form of power over
`
`Ethernet called “Inline Power” for many years. US Patent 7,061,142 (the ‘142
`
`patent) titled “Inline Power Device Detection” was filed on May 28, 2003. (Exhibit
`
`2052.) It issued on June 13, 2006 and is assigned to Cisco Technology Inc. The ‘142
`
`patent explicitly discloses in the section Background of the Invention:
`
`A communication device that is not configured to receive inline power
`relies on a separate AC or DC power source for power. Such a
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`Page 6 of 8
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`CHRIMAR 2053
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`communications device may be damaged when the device is plugged
`into a jack that provides inline power. For example, Ethernet inline
`power may destroy the bob smith termination resistors that are coupled
`to the center tap of isolation transforms in a communications device.
`(Emphasis added)
`
`(Ex. 2052 at 1:22-30; see also, id. at 3:34-42, “If non-inline power device 20 is
`
`plugged into jack unit 30 that provides inline power, components of the non-inline
`
`power device 20 may be damaged. For example, the bob smith termination resistors
`
`coupled to the center tap of the isolation transformers that are within non-inline
`
`power device 20 may be damaged, because the resistors are designed to reduce
`
`electromagnetic interference, not dissipate inline power.”)
`
` As an example, if operating power at 48 Volts were applied as a DC
`
`power source in an unmanaged scenario, then for typical Bob Smith termination
`
`having resistors totaling to about 150 Ohms, a current of 48/150 = 1/3 Amperes
`
`flows through the resistors. The power dissipation is the square of the current times
`
`the resistance resulting in a dissipation of about 15W! Typical termination
`
`resistances in the Ethernet context have power ratings much less than 1W, and
`
`indeed, practical designs use resistances of power ratings of around 0.1W. Therefore,
`
`in our example, application of operating power at 48V would destroy any
`
`termination resistance in the Ethernet terminal device and seriously impair its
`
`performance since the lines would be unbalanced and noise would be amplified.
`
` This Cisco patent reinforces the need for the invention described in the
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`Page 7 of 8
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`CHRIMAR 2053
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`Chrimar patents, which enable, e.g., detection of legacy Ethernet terminal devices
`
`
`
`before operating power is applied to the Bob Smith terminations that are present in
`
`Ethernet terminal equipment. In contrast, Petitioners’ proposed prior art
`
`combinations do not disclose the Chrimar invention and, if combined as Petitioners
`
`assert, an ordinary artisan would know that they would impair, if not destroy, legacy
`
`Ethernet terminal devices on existing 10Base-T and 100Base-T networks.
`
`
`
`I reserve the right to supplement my opinions to address any
`
`information obtained, or positions taken, based on any new information that comes
`
`to light throughout this proceeding.
`
`I declare under penalty of perjury that the foregoing is true and accurate to the
`
`best of my ability.
`
`
`Executed on: April 25, 2017
`
`
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`
`
`
`
`_______________________
`Dr. Vijay Madisetti
`
`
`
`
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`
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`Page 8 of 8
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`CHRIMAR 2053
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`
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