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 IPR2016-013971
`
`U.S. Patent No. 9,019,838 B2
`
`
`
`
`
`
`
`
`
`
`
`PATENT OWNER’S MOTION FOR OBSERVATIONS ON
`CROSS-EXAMINATION OF IAN CRAYFORD
`
`
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`1 Ruckus Wireless, Inc., Brocade Communication Systems, Inc. and Netgear, Inc.
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`(“Ruckus et al.”) filed a petition in (now terminated) IPR2017-00720, and Ruckus
`
`et al. has been joined to the instant proceeding.
`
`
`
`______________
`
`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 IPR2016-013971
`
`U.S. Patent No. 9,019,838 B2
`
`
`
`
`
`
`
`
`
`
`
`PATENT OWNER’S MOTION FOR OBSERVATIONS ON
`CROSS-EXAMINATION OF IAN CRAYFORD
`
`
`
`1 Ruckus Wireless, Inc., Brocade Communication Systems, Inc. and Netgear, Inc.
`
`(“Ruckus et al.”) filed a petition in (now terminated) IPR2017-00720, and Ruckus
`
`et al. has been joined to the instant proceeding.
`
`
`
`Case No.: IPR2016-01397
`Patent No.: 9,019,838
`
`
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`Atty. Dkt. No.: CHRMC0111IPR1
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`Patent Owner Chrimar Systems, Inc. (“Chrimar”) moves the Board to observe
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`the following passages in the cross-examination of Ian Crayford from July 21, 2017.
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`Chrimar submits the complete transcript of the cross-examination as Exhibit 2055.
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`1.
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`In Exhibit 2055, at 25:10-11, the witness testified “ISDN alone can
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`handle voice, video, and data services to a desktop computer.” That testimony is
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`relevant to the Reply’s argument (pp. 15-17, 21-22) and Crayford 2nd Decl. (Ex.
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`1046) (¶¶73-74) regarding Hunter supplying voice and data to PC 125 and telephone
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`instrument 127.
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`2.
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`In Exhibit 2055, at 27:9-21, the witness testified that he did “not recall
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`anywhere in the [Hunter] specification where [Hunter] indicates that he's attempting
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`to power anything like a PC.” That testimony is relevant to the Petition’s argument
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`(pp. 10, 25-26) that “Hunter seeks to supply phantom-power to equipment
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`generally.” (Emphasis in original.)
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`3.
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`In Exhibit 2055, at 30:24-31:21, the witness testified, “[i]soEthernet is,
`
`I believe, a trademark term, and I don't believe we'll see it used in here in this [Ex.
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`1032] 802.9 specification. It was a term that was – I believe trademarked by National
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`Semiconductor . . . . Certainly one of the first implementations of isoEthernet and
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`National, I believe, proposed isoEthernet as an IEEE standard and what we see here,
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`I believe, is the work of a committee to make this more like a standard than a
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`proprietary developed system of isoEthernet.” The testimony is relevant as context
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`for Hunter’s (Ex. 1003) use of the term “isoEthernet®” throughout the document.
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`Atty. Dkt. No.: CHRMC0111IPR1
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`4.
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`In Exhibit 2055, at 36:21-39:18, the witness testified that the draft IEEE
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`802.9f specification states on page 7, “In the 10Base-T mode of operation remote
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`powering shall not be supported. . . . This insures that 10Base-T services are
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`unaffected by this optional feature.” The witness also testified that the IEEE 802.9f
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`draft specification has “a date of 17 June, 1999.” That testimony is relevant to the
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`Reply’s argument (at 1718, 23), Mr. Crayford’s 2nd Decl. (Ex. 1046) (¶¶73-75, 79),
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`and Mr. Crayford’s testimony (Ex. 2055, 41:7-9) regarding Hunter’s purported
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`disclosure of phantom power combined with Ethernet data. The testimony is
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`relevant because the IEEE 802.9f committee worked on phantom power for
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`isoEthernet standard.
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`5.
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`In Exhibit 2055, at 46:2-18, the witness testified that he did not believe
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`he could find a definition of “Ethernet AU interface” in “any of the documents that
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`are part of this record” to support his belief that “no person of ordinary skill would
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`understand the word Ethernet before AU interface is referring to the 802.3 standard
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`as opposed to the 802.9 standard.” That testimony is relevant to the Reply’s
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`argument (at page 23) and Mr. Crayford’s 2nd Decl. (Ex. 1046) (¶80) that the phrase
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`“Ethernet® AU interface” (at 34:19-20 of Hunter (Ex. 1003)) means “Ethernet®
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`access unit interface,” as opposed to “Ethernet® Attachment Unit Interface.”
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`6.
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`In Exhibit 2055, at 62:8-17, the witness testified that, “[w]hen [he] filed
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`[his] first declaration,” he was “aware that there was an 802.9 specification the IEEE
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`Atty. Dkt. No.: CHRMC0111IPR1
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`had done,” but nevertheless, “Exhibit 1032 was not an exhibit that [he] submitted to
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`the Board with [his first] declaration.” The testimony is relevant to the timeliness
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`of Petitioners’ submission of Ex. 1032.
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`7.
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`In Exhibit 2055, at 65:13-22, the witness testified that, “in the context
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`of the '012 patent and the shared specification . . . we're talking about Ethernet
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`communications over pre-existing wiring or cables” and “predominantly 10Base-T
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`Ethernet over unshielded twisted pair.” That testimony is relevant to the Reply’s
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`argument (pp. 2-4) and Mr. Crayford’s 2nd Decl. (Ex. 1046) (¶¶13-21) that “BSTs
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`and CMCs are not relevant.” The testimony is relevant to the environment for
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`Chrimar’s claimed inventions and the knowledge of a person of ordinary skill in the
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`art at the time of the invention.
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`8.
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`In Exhibit 2055, at 66:5-67:3, the witness testified that, “by terminating
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`the line correctly,” in 10Base-T transmission line systems “you'll enhance the
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`performance.” That testimony is relevant to the Reply’s argument (pp. 2-4) and Mr.
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`Crayford’s 2nd Decl. (Ex. 1046) (¶¶13-21) that “BSTs and CMCs are not relevant.”
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`The testimony is relevant to the issue of whether a person of ordinary skill in the art
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`at the time of the invention would consider Ethernet terminations when attempting
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`to apply power to conductors that transmit Ethernet data.
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`9.
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`In Exhibit 2055, at 76:15-23, the witness testified that there is no way
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`for an average user to determine, “just by looking at the equipment or looking at the
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`markings on the equipment whether it has a Bob Smith termination, a [L]evel 1
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`termination, or some other termination.” He further testified, at 77:24-79:2, that the
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`same is true with respect to a “common mode choke.” That testimony is relevant to
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`the Reply’s argument (pp. 2-4) and Mr. Crayford’s 2nd Decl. (Ex. 1046) (¶¶13-21)
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`that “BSTs and CMCs are not relevant.” The testimony is relevant to what a person
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`of ordinary skill in the art at the time of the invention would consider regarding Bob
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`Smith terminations and common mode chokes when attempting to apply power to
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`conductors that transmit Ethernet data.
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`10.
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`In Exhibit 2055, at 80:10-18, the witness testified that he had not “done
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`any analysis of either of the Fisher patents [Exs. 1025, 1026] to determine whether
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`either of these patents invalidate any of the claims of the Chrimar patents that are at
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`issue.” The testimony is relevant to whether the Fisher patents are relevant to the
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`claims of the Chrimar patents at issue in the IPRs as argued in the Reply (pp. 7 and
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`14) and Mr. Crayford’s 2nd Decl. (Ex. 1046) (¶¶25, 31, 57).
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`11.
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`In Exhibit 2055, at 96:12-23, the witness testified that he was aware
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`“there is a specification for things like attenuation on Cat-3 and Cat-5, and other
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`electrical parameters of the – of the performance of the transmission line.” The
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`testimony is relevant because Petitioners have asserted that CAT-3 and CAT-5
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`cables comprise 2 unshielded twisted pairs of conductors as argued in the Reply (pp.
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`14-15) and Mr. Crayford’s 2nd Decl. (Ex. 1046) (¶60).
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`Atty. Dkt. No.: CHRMC0111IPR1
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`12.
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`In Exhibit 2055, at 99:11-14, the witness testified, “To the best of my
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`knowledge Hunter consistently uses the registered trademark symbol after instances
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`of Ethernet, isoEthernet, and Token Ring.” That testimony is relevant to the
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`Petition’s statement (p. 27, n. 8) that “Hunter evidently cites to ‘Ethernet®’ to
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`distinguish the original trademarked form of Ethernet (owned by Xerox Corp.) from
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`subsequent nontrademarked forms of 802.3/Ethernet such as 10Base-T and
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`100Base-T” and to Mr. Crayford’s testimony (Ex. 2055, 30:24-31:21) that the
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`trademarked form “isoEthernet®” refers to a proprietary National Semiconductor
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`version of isoEthernet. The testimony is relevant because the germane specifications
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`are not part of the record for Xerox’s Ethernet® and National Semiconductor’s
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`isoEthernet®, to which Hunter refers.
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`13.
`
`In Exhibit 2055, at 99:16-101:13, the witness testified that the term
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`“bus” used in claim 1 and in claim 3 Hunter [Ex. 1003] is “talking about two twisted
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`pair conductors typically between – typically, but not exclusively, between, you
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`know, a hub device and an end station device.” The witness further testified, at
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`102:7-103:1, the witness testified, “when Hunter's talking about the bus, the 10Base-
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`T bus” Hunter [Ex. 1003] is talking about “UTP or unshielded twisted pair media.”
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`The testimony is relevant to the Petition’s contention (pp. 26-27) and Mr. Crayford’s
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`testimony (Ex. 2055, 41:24-43:4) that Hunter’s reference to a “bus” (e.g., in Hunter’s
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`claims 3 and 13) refers to 10Base-T or Ethernet data signals as opposed to the media
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`Atty. Dkt. No.: CHRMC0111IPR1
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`(conductors).
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`14.
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`In Exhibit 2055, at 57:20-25, 60:17-62:7, the witness testified, “[T]he
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`connection which is the Figure 2 connection which is an exemplary example of one
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`of those connections between the 120 hub which is the AU hub and the other hubs
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`underneath it. . . . It's calling out an example such as, like I said, between 120 and
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`125 or 120 and any of the other devices.” That testimony is relevant to the credibility
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`of Mr. Crayford’s testimony (Ex. 2055, 57:20-25, 60:17-62:7, 104:22-105:7,
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`110:12-18, 110:25-112:19, 118:8-119:7, 119:19-25, 122:11-123:1, 127:9-25, 128:2-
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`10, 129:11-130:18, 130:21-131:10, 132:18-133:17, 134:3-14, 134:25-135:9, 136:1-
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`136:10, 136:11-137:10, 137:15-138:2, 150:4-10) (hereafter, “the Crayford
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`Testimony”) and to what Hunter (Ex. 1003) discloses regarding phantom power.
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`15.
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`In Exhibit 2055, at 104:22-105:7, the witness testified, “I'd characterize
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`it more as there's an ISTE function or part thereof resident in [hubs 140-180] rather
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`than a pure ISTE card. And I don't know the physical form.” That testimony is
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`relevant to the credibility of the Crayford Testimony and to what Hunter (Ex. 1003)
`
`discloses regarding phantom power.
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`16.
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`In Exhibit 2055, at 110:12-18, the witness testified, “Multimedia
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`chassis 110 contains the plurality of cards, each representing one of the hubs located
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`on the right-hand side of the figure. A POSITA would understand that the
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`connections between the cards in multimedia chassis 110 likely would be in the
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`backplane that the cards plug into, rather than through panels on walls in different
`
`parts of buildings.” That testimony is relevant to the credibility of the Crayford
`
`Testimony and to what Hunter (Ex. 1003) discloses regarding phantom power.
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`17.
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`In Exhibit 2055, at 110:25-112:19, the witness testified, “A POSITA
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`would understand a power source in hub 120 would not be able to provide sufficient
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`power to all of the connected hubs and the dozens of devices connected to them. . . .
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`I think, if you look, you'll find, for instance, hub 150 and hub 180 also talk about the
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`region of 12 to 24 ports of devices . . . we're not going to be out of [sic – able to]
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`power all of those over the one line that goes back to multimedia hub 120.” That
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`testimony is relevant to the credibility of the Crayford Testimony and to what Hunter
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`(Ex. 1003) discloses regarding phantom power.
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`18.
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`In Exhibit 2055, at 118:8-119:7, when asked, “So when Hunter talks
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`about [a] TE, that must support at least voice in the case of power or device failure
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`of the client, what is he referring to in Figure 1,” the witness testified, “‘Hunter
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`plainly states multiple ISTEs can be powered and each of the hubs (in Fig. 1) would
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`contain one of the cards otherwise located in the multimedia chassis [110].’ . . .
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`‘Therefore, a POSITA would understand that a power source which Chrimar agrees
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`can be located in hub 120 is capable of’ powering – ‘providing power to ISTEs
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`located in the PC and hubs connected [to] hub 120.’” That testimony is relevant to
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`the credibility of the Crayford Testimony and to what Hunter (Ex. 1003) discloses
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`Atty. Dkt. No.: CHRMC0111IPR1
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`regarding phantom power.
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`19.
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`In Exhibit 2055, at 119:19-25, the witness testified as follows regarding
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`the PC 125 and its attached phone 127 and video camera 126 in Hunter (Ex. 1003)
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`Fig. 1, “the whole thing is terminal equipment. The PC, the phone, in this case it's
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`got a video camera. So all of the entire thing is terminal equipment.” That testimony
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`is relevant to the credibility of the Crayford Testimony and to what Hunter (Ex.
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`1003) discloses regarding phantom power.
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`20.
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`In Exhibit 2055, at 122:11-123:1, the witness testified, “so let's talk hub
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`150 [in Hunter (Ex. 1003) Fig. 1]. It wouldn't necessarily be an ISTE card in there,
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`as I said, form-factor wise, but an ISTE function in there.” That testimony is relevant
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`to the credibility of the Crayford Testimony and to what Hunter (Ex. 1003) discloses
`
`regarding phantom power.
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`21.
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`In Exhibit 2055, at 127:9-25, the witness testified, “that everything to
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`the right of the connector on the wall [in Hunter (Ex. 1003) Fig. 2] would be part of
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`the TE. . . . The right most 297 connector and everything to the right of it would be
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`the TE equipment,” and Hunter Fig. 2 can “be applied to hub 150.” That testimony
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`is relevant to the credibility of the Crayford Testimony and to what Hunter (Ex.
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`1003) discloses regarding phantom power.
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`22.
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`In Exhibit 2055, at 128:2-10, the witness testified, “My testimony is
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`consistent with Hunter's disclosure that each of the hubs would contain one of the
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`cards, for example, ISTE card 260, otherwise located in multimedia chassis 110.”
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`That testimony is relevant to the credibility of the Crayford Testimony and to what
`
`Hunter (Ex. 1003) discloses regarding phantom power.
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`23.
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`In Exhibit 2055, at 129:11-130:18, the witness testified, “the ISTE
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`function in the hub, hub 170, which would extract the Ethernet data and then pass it
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`to the 10Base-T hub function which would do the distribution to the Ethernet, in
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`which case the Ethernet ports on that hub are Ethernet end stations. . . . Figure 2, for
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`instance, is an embodiment which covers – since the wiring is essentially the same,
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`this covers an AU to ISTE card, such as the connection between hub 120 and PC
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`125. . . . [W]e assume that you're trying to connect PCs to an Ethernet hub. And
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`that's the same. Figure 2 applies to hub 170 and its connection to effectively an
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`Ethernet card.” That testimony is relevant to the credibility of the Crayford
`
`Testimony and to what Hunter (Ex. 1003) discloses regarding phantom power.
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`24.
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`In Exhibit 2055, at 130:21-131:10, the witness testified that, if Hunter
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`(Ex. 1003) Fig. 2 were in hub 170 of Fig. 1, “That part [labeled ‘voice instrument
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`299’ in Figure 2] wouldn't be there at all. . . . There would be no ISDN
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`functionality.” That testimony is relevant to the credibility of the Crayford
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`Testimony and to what Hunter (Ex. 1003) discloses regarding phantom power.
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`25.
`
`In Exhibit 2055, at 132:18-133:17, the witness testified, “So in this case
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`[involving hub 170] the ISTE is acting as an intermediary and the same diagram in
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`Figure 2 applies, except the left most piece of equipment is now a 10Base-T hub,
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`and the right most piece of equipment is now a 10Base-T end station. But other than
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`that, the same diagram applies. So the 10Base-T hub 170 is responsible for the
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`phantom powering of those 10Base-T devices as they – to the extent they need
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`phantom powering.” That testimony is relevant to the credibility of the Crayford
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`Testimony and to what Hunter (Ex. 1003) discloses regarding phantom power.
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`26.
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`In Exhibit 2055, at 134:3-14, the witness testified, “What I believe is
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`one of ordinary skill would look at Figure 2 and understand that 10Base-T can be –
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`can be overlaid directly on this figure. The difference is that the thing called ISTE
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`card will be an Ethernet LAN card. There won't be any ISDN services. . . . [C]ard
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`260 would no longer be ISTE card 260, it would be Ethernet LAN card 260.” That
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`testimony is relevant to the credibility of the Crayford Testimony and to what Hunter
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`(Ex. 1003) discloses regarding phantom power.
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`27.
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`In Exhibit 2055, at 134:25-135:9, the witness testified, “the ISTE
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`function in hub 170 [Hunter (Ex. 1003) Fig. 1] gets the Ethernet data from the AU,
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`and then there's another distribution function which is an Ethernet repeater or hub,
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`and that distributes the Ethernet data to the ports connected to hub 170.” That
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`testimony is relevant to the credibility of the Crayford Testimony and to what Hunter
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`(Ex. 1003) discloses regarding phantom power.
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`28.
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`In Exhibit 2055, at 136:1-136:10, the witness testified, “So connecting
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`to 170 [in Hunter (Ex. 1003) Fig. 1] then, there's a port in hub 120 [in Fig. 1] that
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`connects to a port in 170 . . . And if we look at Figure 2, that would be connector on
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`AU, patch panel, connector patch panel, all the way through there until you get to
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`connector on an ISTE. . . . So then that LAN data that comes out of ISTE card [in
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`Fig. 2] on the bottom, so we're still talking about – still talking about the AU port
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`connected 120, but this is the LAN data that hub 170 is extracting from that port.”
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`That testimony is relevant to the credibility of the Crayford Testimony and to what
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`Hunter (Ex. 1003) discloses regarding phantom power.
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`29.
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`In Exhibit 2055, at 136:11-137:10, the witness testified, “So Figure 2 is
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`a depiction of hub 120's connection to PC 125. . . . It’s also a depiction of connection,
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`in my opinion, 120 to 170. . . . In this case, the stuff that says connector on ISTE, it
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`is an ISTE function, but it's actually located in hub 170.” That testimony is relevant
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`to the credibility of the Crayford Testimony and to what Hunter (Ex. 1003) discloses
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`regarding phantom power.
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`30.
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`In Exhibit 2055, at 137:15-138:2, the witness testified, “That connector
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`[the rightmost connector 297 in Hunter Fig. 2] is, yes, on 170, [in Fig. 1] and then
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`everything to the right up to the thing that says ISTE card [ in Fig. 2] is in that hub
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`[170 in Fig. 1], there's no voice instrument, there's no voice anything in this thing.
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`And then LAN data which comes out at the bottom is the thing that the 10Base-T
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`hub function distributes.” That testimony is relevant to the credibility of the Crayford
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`Testimony and to what Hunter (Ex. 1003) discloses regarding phantom power.
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`31.
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`In Exhibit 2055, at 144:14-20, the witness testified, “in the Hunter-
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`Bulan combination, if the protective device for a particular TE detects an operational
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`fault, it will cease providing power to that TE. . . . And the remaining TEs are
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`unaffected.” That testimony is relevant to the credibility of Mr. Crayford’s
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`testimony (Ex. 2055, 165:13-23) that “[t]he Bulan circuit as well as the original
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`Hunter circuit is intended to protect the – there's only one protection circuit per line,
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`so if you – if there's a short on the line, it will protect the line.”
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`32.
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`In Exhibit 2055, at 145:5-146:1, the witness testified “if the circuitry of
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`Bulan is [in] multimedia hub 120 [Hunter Fig. 1], and it's protecting the devices that
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`are connected to [hub] 150, the three phones that we've talked about, that's [not] a
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`scenario that's within the scope of the combination” because hub 120 cannot supply
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`sufficient power. That testimony is relevant to the credibility of the Crayford
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`Testimony and the effect of Bulan’s operation on purported “TEs” within the circuit
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`proposed by Petitioners in Ground 1.
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`33.
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`In Exhibit 2055, at 150:4-10, the witness testified, “I would expect all
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`of the hubs, 120, 40, 50, 60, 70, and 80 – all of those were with a 1 in front of them
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`– 120 through 180, I'm sorry. I would expect all those hubs to be either located in
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`one wiring closet on a floor or maybe on different floors in a wiring closet on each
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`floor, but I wouldn't expect them to be near the user.” That testimony is relevant to
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`the credibility of the Crayford Testimony and to what Hunter (Ex. 1003) discloses
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`regarding phantom power.
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`34.
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`In Exhibit 2055, at 152:2-7, the witness testified that, in the proposed
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`Hunter-Bulan combination, “the Bulan circuitry would be in hub 120.” That
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`testimony is relevant to the credibility of the Crayford Testimony and the effect of
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`Bulan’s operation on purported “TEs” within the circuit proposed by Petitioners in
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`Ground 1.
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`35.
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`In Exhibit 2055, at 153:24-154:12, the witness testified, “in the
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`[proposed] Hunter-Bulan combination . . . Bulan is not trying to protect from a power
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`surge from the PC itself. . . . We've kind of agreed it's not the 200 Watt powered PC,
`
`because that doesn't make any sense.” That testimony is relevant to understanding
`
`Bulan’s operation within the circuit (Petition Figure 3) proposed by Petitioners in
`
`Ground 1.
`
`36.
`
`In Exhibit 2055, at 155:10-13, the witness testified he “would [not]
`
`expect the video camera 126 [in Hunter Fig. 1] to be phantom powered” when the
`
`Hunter reference was written. That testimony is relevant to understanding Bulan’s
`
`operation within the circuit (Petition Figure 3) proposed by Petitioners in Ground 1.
`
`37.
`
`In Exhibit 2055, at 155:20-157:10, the witness testified, with respect to
`
`the Bulan circuit’s proposed connection between hub 120 and computer 125 and
`
`13
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`Case No.: IPR2016-01397
`Patent No.: 9,019,838
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`phone 127, “the DC-DC converter is most likely to be actually on the ISTE card
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`Atty. Dkt. No.: CHRMC0111IPR1
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`[shown in Hunter Fig. 2] where it does the DC-DC conversion, and then since it says
`
`– and we established both power and data go across 298.” That testimony is relevant
`
`to understanding Bulan’s operation within the circuit (Petition Figure 3) proposed
`
`by Petitioners in Ground 1.
`
`38.
`
`In Exhibit 2055, at 165:13-23, when asked, “If we take the hypothetical
`
`that there are two phones plugged into the ISTE card that's in computer 125 [in
`
`Hunter Fig. 1] and one of the phones shorts, won't Bulan terminate the power to both
`
`phones? The phantom power?”, the witness testified, “The Bulan circuit as well as
`
`the original Hunter circuit is intended to protect the – there's only one protection
`
`circuit per line, so if you – if there's a short on the line, it will protect the line.” That
`
`testimony is relevant to the credibility of Mr. Crayford’s testimony (Ex. 2055,
`
`144:14-20) and the effect of Bulan’s operation on purported “TEs” within the circuit
`
`proposed by Petitioners in Ground 1.
`
`39.
`
`In Exhibit 2055, at 172:9-173:16, the witness testified that the
`
`“Technical Systems Bulletin Additional Cable Specifications for Unshielded
`
`Twisted Pair Cables,” dated November 1991, states under heading 1: “As LAN
`
`speeds increase and users migrate to higher performance UTP cables, it is important
`
`for the industry to provide guidance on the categories of UTP cables available for
`
`data applications.” He further testified that “UTP” stands for “unshielded twisted
`
`14
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`Case No.: IPR2016-01397
`Patent No.: 9,019,838
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`pair.” The testimony is relevant because Petitioners have asserted that CAT-3 and
`
`Atty. Dkt. No.: CHRMC0111IPR1
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`CAT-5 cables comprise 2 unshielded twisted pairs of conductors as argued in the
`
`Reply (pp. 14-15) and Mr. Crayford’s 2nd Decl. (Ex. 1046) (¶60).
`
`40.
`
`In Exhibit 2055, at 173:20-174:6, the witness testified that the
`
`“Technical Systems Bulletin Additional Cable Specifications for Unshielded
`
`Twisted Pair Cables,” dated November 1991, refers to Category 3 and Category 5
`
`cables. The testimony is relevant because Petitioners have asserted that CAT-3 and
`
`CAT-5 cables comprise 2 unshielded twisted pairs of conductors as argued in the
`
`Reply (pp. 14-15) and Mr. Crayford’s 2nd Decl. (Ex. 1046) (¶60).
`
`41.
`
`In Exhibit 2055, at 175:12-176:13, the witness testified that the
`
`“Technical Systems Bulletin Additional Cable Specifications for Unshielded
`
`Twisted Pair Cables,” dated November 1991, states under heading 3: “The
`
`transmission characteristics presented herein apply to cables consisting of four
`
`unshielded twisted pairs of 24 AWG thermoplastic insulated conductors and
`
`enclosed by a thermoplastic jacket. . . . Four-pair, 22 AWG cables which meet or
`
`exceed these requirements may also be used.” The testimony is relevant because
`
`Petitioners have asserted that CAT-3 and CAT-5 cables comprise 2 unshielded
`
`twisted pairs of conductors as argued in the Reply (pp. 14-15) and Mr. Crayford’s
`
`2nd Decl. (Ex. 1046) (¶60).
`
`Dated: August 2, 2017
`
`
`
`
`
` /Thomas A. Lewry/
`
`
`
`
`
`15
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`
`
`Case No.: IPR2016-01397
`Patent No.: 9,019,838
`
`
`
`Atty. Dkt. No.: CHRMC0111IPR1
`
`Frank A. Angileri (Reg. No. 36,733)
`Thomas A. Lewry (Reg. No. 30,770)
`Marc Lorelli (Reg. No. 43,759)
`Christopher C. Smith (Reg. No. 59,669)
`Brooks Kushman P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`(248) 358-4400
`
`Richard W. Hoffmann (Reg. No. 33,711)
`Reising Ethington PC
`755 West Big Beaver Rd., Suite 1850
`Troy, Michigan 48084
`248.786.0163
`
`Attorneys for Patent Owner
`
`
`
`
`
`
`16
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`
`
`Case No.: IPR2016-01397
`Patent No.: 9,019,838
`
`
`
`Atty. Dkt. No.: CHRMC0111IPR1
`
`Certificate of Service
`
`
`On August 2, 2017, a copy of this PATENT OWNER’S MOTION FOR
`OBSERVATIONS ON CROSS-EXAMINATION OF IAN CRAYFORD has
`been served on Petitioner’s counsel via electronic mail at the email addresses
`shown below:
`
`
`Lead Counsel & Back-up Counsel for Juniper
`Talin Gordnia, Reg. No. 76,214
`Michael Fleming, Reg. No. 67,933
`Jonathan Kagan, pro hac vice
`IRELL & MANELLA, LLP
`1800 Avenue of the Stars, Suite 900
`IRELL & MANELLA, LLP
`Los Angeles, CA 90067
`1800 Avenue of the Stars, Suite 900
`Juniper-ChrimarIPR@irell.com
`Los Angeles, CA 90067
`Juniper-ChrimarIPR@irell.com
`
`Nima Hefazi Reg. No. 63,658
`IRELL & MANELLA, LLP
`840 Newport Center Drive, Suite 400
`Newport Beach, CA 92660
`Juniper-ChrimarIPR@irell.com
`
`Lead Counsel & Back up Counsel for Ruckus Wireless, Inc., Brocade
`Communication Systems, Inc., & Netgear, Inc.
`Joseph Powers (Reg. No. 47,006)
`Christopher Tyson (Reg. No. 63,850)
`Duane Morris LLP
`Duane Morris LLP
`30 South 17th Street
`505 9th St. NW, Ste 1000
`Philadelphia PA 19103-4196
`Washington DC 20004
`JAPowers@duanemorris.com
`CJTyson@duanemorris.com
`
`
`Matthew S. Yungwirth
`DUANE MORRIS LLP
`1075 Peachtree Street, NE, Suite 2000
`Atlanta, Georgia 30309
`msyungwirth@duanemorris.com
`
`
`
`
`
`
`Respectfully submitted,
`
` /Thomas A. Lewry/
`
`
`
`
`
`17
`
`
`
`Case No.: IPR2016-01397
`Patent No.: 9,019,838
`
`
`
`Atty. Dkt. No.: CHRMC0111IPR1
`
`Frank A. Angileri (Reg. No. 36,733)
`Thomas A. Lewry (Reg. No. 30,770)
`Marc Lorelli (Reg. No. 43,759)
`Christopher C. Smith (Reg. No. 59,669)
`Brooks Kushman P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`(248) 358-4400
`
`Richard W. Hoffmann (Reg. No. 33,711)
`Reising Ethington PC
`755 West Big Beaver Rd., Suite 1850
`Troy, Michigan 48084
`248.786.0163
`
`Attorneys for Patent Owner
`
`
`
`
`
`
`18
`
`
`
`Case No.: IPR2016-01397
`Patent No.: 9,019,838
`
`
`
`Atty. Dkt. No.: CHRMC0111IPR1
`
`Certificate of Compliance Pursuant to 37 C.F.R. § 42.24
`
`
`
`
`This paper complies with the type-volume limitation of 37 C.F.R. § 42.24.
`
`The paper contains no more than 15 pages, excluding the parts of the paper exempted
`
`by §42.24(a).
`
`This paper also complies with the typeface requirements of 37 C.F.R.
`
`§ 42.6(a)(ii) and the type style requirements of § 42.6(a)(iii)&(iv).
`
`Dated: August 2, 2017
`
`
`
`
`Respectfully submitted,
`
`
`
` /Thomas A. Lewry/
`Frank A. Angileri (Reg. No. 36,733)
`Thomas A. Lewry (Reg. No. 30,770)
`Marc Lorelli (Reg. No. 43,759)
`Christopher C. Smith (Reg. No. 59,669)
`Brooks Kushman P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`(248) 358-4400
`
`Richard W. Hoffmann (Reg. No. 33,711)
`Reising Ethington PC
`755 West Big Beaver Rd., Suite 1850
`Troy, Michigan 48084
`248.786.0163
`
`Attorneys for Patent Owner
`
`
`19
`
`
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