Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
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`EXPERT DECLARATION OF DR. FARAMARZ FARAHI
`IN SUPPORT OF
`INTER PARTES REVIEW OF U.S. PATENT NO. 7,030,971
`
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`HALLIBURTON, Exh. 1003, p. 0001
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`
`
`EXPERT DECLARATION OF DR. FARAMARZ FARAHI
`IN SUPPORT OF
`INTER PARTES REVIEW OF U.S. PATENT NO. 7,030,971
`
`
`HALLIBURTON, Exh. 1003, p. 0001
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`
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`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
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`TABLE OF CONTENTS
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`INTRODUCTION......................................................................................... 3
`I.
`QUALIFICATIONS ..................................................................................... 5
`II.
`PERSON OF ORDINARY SKILL IN THE ART ........................................ 6
`III.
`LEGAL UNDERSTANDING ...................................................................... 7
`IV.
`THE ’971 PATENT ....................................................................................13
`V.
`CLAIM CONSTRUCTION ........................................................................24
`VI.
`STATE OF THE ART ................................................................................26
`VII.
`VIII. UNPATENTABILITY ANALYSIS OF THE ’971 PATENT ...................31
`IX.
`CONCLUSION ...........................................................................................92
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`HALLIBURTON, Exh. 1003, p. 0002
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`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
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`I.
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`INTRODUCTION
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`1.
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`I, Dr. Faramarz Farahi, submit this declaration in support of a Petition
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`for Inter Partes Review of United States Patent No. 7,030,971 owned by The
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`United States of America represented by the Secretary of the Navy. ( “Patent
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`Owner”). I have been retained in this matter by Baker Botts L.L.P. (“Counsel”) on
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`behalf of Halliburton Energy Services, Inc. (“Petitioner”).
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`2.
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`I make this declaration based upon my personal knowledge. I am over
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`the age of 21 and am competent to make this declaration.
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`3.
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`The statements herein include my opinions and the bases for those
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`opinions, which relate to at least the following documents of the pending inter
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`partes review petition:
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`(cid:1) U.S. Patent No. 7,030,971 by Robert Michael Payton entitled “Natural
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`fiber span reflectometer providing a virtual signal sensing array
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`capability” (“the ’971 Patent”) (Ex. 1001).
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`(cid:1) File History for U.S. Patent No. 7,030,971 (Ex. 1002).
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`(cid:1) UK Patent Application No. GB 2 190 186 A by Jeremy Kenneth Arthur
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`Everard entitled “Greatly Enhanced Spatial Detection Of Optical
`
`Backscatter For Sensor Applications,” published November 11, 1987
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`(Ex. 1004).
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`(cid:1) U.S. Patent No. 6,285,806 by Alan D. Kersey, et al. entitled “Coherent
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`- 3 -
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`HALLIBURTON, Exh. 1003, p. 0003
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`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
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`Reflectometric Fiber Bragg Grating Sensor Array,” filed May 31, 1998,
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`issued September 4, 2001 (Ex. 1005).
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`(cid:1) U.S. Patent No. 4,794,249 by Friedrich-Karl Beckmann, et al. entitled
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`“Optical Time Domain Reflectometer With Heterodyne Reception,” filed
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`March 17, 1987, issued December 27, 1988 (Ex. 1006).
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`(cid:1) Toshihiko Yoshino et al., “Common Path Heterodyne Optical Fiber
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`Sensors,” Journal of Lightwave Technology, Vol. 10, No. 4, April 1992,
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`pp. 503-513 (Ex. 1007).
`
`(cid:1) U.S. Patent No. 6,606,148 by Leif Fredin, et al. entitled “Method And
`
`System For Measuring Optical Scattering Characteristics,” filed April 23,
`
`2001, issued August 12, 2003 (Ex. 1008).
`
`(cid:1) UK Patent Application No. GB 2 197 953 A by Michael Laurence
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`Henning et al. entitled “Acoustic Sensor,” published June 2, 1988 (Ex.
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`1009).
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`(cid:1) U.S. Patent No. 4,596,052 by Stephen Wright et al. entitled “Coherent
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`Optical Receiver,” filed May 20, 1983, issued June 17, 1986 (Ex. 1010).
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`(cid:1) U.S. Patent No. 6,043,921 by Robert M. Payton entitled “Fading-Free
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`Optical Phase Rate Receiver,” filed August 12, 1997, issued March 28,
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`2000 (Ex. 1011).
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`(cid:1) Portions of McGraw-Hill Dictionary of Scientific and Technical Terms,
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`HALLIBURTON, Exh. 1003, p. 0004
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`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
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`Second Edition, 1978 (Ex. 1015).
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`(cid:1) Portions of McGraw-Hill Dictionary of Scientific and Technical Terms,
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`Fourth Edition, 1989 (Ex. 1016).
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`(cid:1) Portions of IEEE Standard Dictionary of Electrical and Electronics
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`Terms (4th Ed.) (Ex. 1017).
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`4.
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`I am being compensated for my time in preparing this declaration. The
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`opinions herein are my own, and I have no stake in the outcome of the review
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`proceeding. My compensation does not depend in any way on the outcome of the
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`Petitioner’s petition.
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`II. QUALIFICATIONS
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`5.
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`I am qualified by education and experience to testify as an expert in
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`the field of fiber optic measurement systems. Attached, as Attachment A, is a copy
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`of my resume detailing my experience and education. Additionally, I provide the
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`following overview of my background as it pertains to my qualifications for
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`providing expert testimony in this matter.
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`6.
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`I am qualified both by education and experience to testify in the field
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`of fiber optic measurement systems, and in particular, as it pertains to the ’971
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`Patent.
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`7.
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`I have been a Professor of Physics and Optics at the University of
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`North Carolina - Charlotte since 2002, including being chairman of Physics and
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`HALLIBURTON, Exh. 1003, p. 0005
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`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
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`Optics from 2002-2009. I was a Professor of Physics at the same institution from
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`1994-2002, and an Associate Professor of Physics from 1990-1994. I mentor,
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`teach, and supervise undergraduate and graduate physics and engineering students
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`in the areas of fiber optic sensors and applied optics, and am a co-author of the
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`“Handbook of Optical Sensors.” I have ten patents issued over the period from
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`1995-2016. I am a sole- or co-author of more than two hundred publications in my
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`field.
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`8.
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`In 1988, I received my Ph.D. in Physics, Fiber Optic Sensors from
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`University of Kent in Canterbury, England. My Ph.D. research focused on
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`interferometric fiber optic sensors.
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`9.
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`In 1976, I received a B.S. degree in Physics from Aryamehr (Sharif)
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`University of Technology in Tehran, Iran. In 1978, I received a M.S. degree in
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`Applied Mathematics & Theoretical Physics from University of Southampton in
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`England.
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`III. PERSON OF ORDINARY SKILL IN THE ART
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`10.
`
`I understand that the content of a patent (including its claims) and
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`prior art should be interpreted the way a person of ordinary skill in the art would
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`have interpreted the material at the time of invention.
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`11.
`
`I understand that at this time the Petitioners make no assertion as to
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`the proper “time of invention” as all of the cited prior art references would be
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`HALLIBURTON, Exh. 1003, p. 0006
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`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
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`considered prior art even as to the earliest priority application (U.S. Application
`
`No. 60/599,437) in the United States Patent and Trademark Office, namely, August
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`6, 2004.
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`12.
`
`It is my opinion that one of ordinary skill in the art at the time of the
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`filing date of the patent would have had at least (1) a Bachelor of Science in
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`Physics or a relevant Engineering field and 4 years of fiber optics industry
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`experience or (2) a Masters or Doctorate in Physics or a relevant Engineering field
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`and 2 years of fiber optics industry experience.
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`13.
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`In addition to my testimony as an expert, I am prepared to testify as
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`someone who actually designed fiber optic sensor systems from 1988 to present,
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`who actually possessed at least the knowledge of a person of ordinary skill in the
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`art in that time period, and who actually worked with others possessing at least the
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`knowledge of a person of ordinary skill in the art in that time period.
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`14.
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`I understand that the person of ordinary skill is a hypothetical person
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`who is assumed to be aware of all the pertinent information that qualifies as prior
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`art. In addition, the person of ordinary skill in the art makes inferences and takes
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`creative steps.
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`IV. LEGAL UNDERSTANDING
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`15.
`
`I have a general understanding of validity based on my experience
`
`with patents and my discussions with counsel.
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`HALLIBURTON, Exh. 1003, p. 0007
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`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
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`16.
`
`I have a general understanding of prior art and priority date based on
`
`my experience with patents and my discussions with counsel.
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`17.
`
`I understand that the ’971 Patent should be evaluated under the Pre-
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`AIA laws as the ’971 Patent was filed on February 7, 2005. I understand that the
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`inventors are entitled to a priority date up to one year earlier than the date of filing
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`to the extent that they can show complete possession of particular claimed
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`inventions at such an earlier priority date and reasonable diligence to reduce the
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`claims to practice between such an earlier priority date and the date of filing of the
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`patent. I understand that if the patent holder contends that particular claims are
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`entitled to an earlier priority date than the date of filing of the patent, then the
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`patent holder has the burden to prove this contention with specificity.
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`18.
`
`I understand that an invention by another must be made before the
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`priority date of a particular patent claim in order to qualify as “prior art” under 35
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`U.S.C. § 102 or § 103, that a printed publication or patent must be publicly
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`available more than one year prior to the date of the application for patent in the
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`United States in order to qualify as “prior art” under 35 U.S.C. § 102(b), or that the
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`invention by another must be described in an application for patent filed in the
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`United States before the priority date of a particular patent claim in order to qualify
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`as “prior art” under 35 U.S.C. § 102(e). I understand that the Defendants have the
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`burden of proving that any particular publication or patent is prior art.
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`HALLIBURTON, Exh. 1003, p. 0008
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`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
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`19.
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`I have a general understanding of anticipation based on my experience
`
`with patents and my discussions with counsel.
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`20.
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`I understand that anticipation analysis is a two-step process. The first
`
`step is to determine the meaning and scope of the asserted claims. Each claim
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`must be viewed as a whole, and it is improper to ignore any element of the claim.
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`For a claim to be anticipated under U.S. patent law: (1) each and every claim
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`element must be identically disclosed, either explicitly or inherently, in a single
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`prior art reference; (2) the claim elements disclosed in the single prior art reference
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`must be arranged in the same way as in the claim; and (3) the identical invention
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`must be disclosed in the single prior art reference, in as complete detail as set forth
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`in the claim. Where even one element is not disclosed in a reference, the
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`anticipation contention fails. Moreover, to serve as an anticipatory reference, the
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`reference itself must be enabled, i.e., it must provide enough information so that a
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`person of ordinary skill in the art can practice the subject matter of the reference
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`without undue experimentation.
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`21.
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`I further understand that where a prior art reference fails to explicitly
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`disclose a claim element, the prior art reference inherently discloses the claim
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`element only if the prior art reference must necessarily include the undisclosed
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`claim element. Inherency may not be established by probabilities or possibilities.
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`The fact that an element may result from a given set of circumstances is not
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`HALLIBURTON, Exh. 1003, p. 0009
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`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
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`sufficient to prove inherency. I have applied these principles in forming my
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`opinions in this matter.
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`22.
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`I have a general understanding of obviousness based on my
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`experience with patents and my discussions with counsel.
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`23.
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`I understand that a patent claim is invalid under 35 U.S.C. § 103 as
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`being obvious only if the differences between the claimed invention and the prior
`
`art are such that the subject matter as a whole would have been obvious at the time
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`the invention was made to a person of ordinary skill in that art. An obviousness
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`analysis requires consideration of four factors: (1) scope and content of the prior
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`art relied upon to challenge patentability; (2) differences between the prior art and
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`the claimed invention; (3) the level of ordinary skill in the art at the time of the
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`invention; and (4) the objective evidence of non-obviousness, such as commercial
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`success, unexpected results, the failure of others to achieve the results of the
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`invention, a long-felt need which the invention fills, copying of the invention by
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`competitors, praise for the invention, skepticism for the invention, or independent
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`development.
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`24.
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`I understand that a prior art reference is proper to use in an
`
`obviousness determination if the prior art reference is analogous art to the claimed
`
`invention. I understand that a prior art reference is analogous art if at least one of
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`the following two considerations is met. First a prior art reference is analogous art
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`HALLIBURTON, Exh. 1003, p. 0010
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`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
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`if it is from the same field of endeavor as the claimed invention, even if the prior
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`art reference addresses a different problem and/or arrives at a different solution.
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`Second, a prior art reference is analogous art if the prior art reference is reasonably
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`pertinent to the problem faced by the inventor, even if it is not in the same field of
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`endeavor as the claimed invention.
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`25.
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`I understand that it must be shown that one having ordinary skill in
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`the art at the time of the invention would have had a reasonable expectation that a
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`modification or combination of one or more prior art references would have
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`succeeded. Furthermore, I understand that a claim may be obvious in view of a
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`single prior art reference, without the need to combine references, if the elements
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`of the claim that are not found in the reference can be supplied by the knowledge
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`or common sense of one of ordinary skill in the relevant art. However, I
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`understand that it is inappropriate to resolve obviousness issues by a retrospective
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`analysis or hindsight reconstruction of the prior art and that the use of “hindsight
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`reconstruction” is improper in analyzing the obviousness of a patent claim.
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`26.
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`I further understand that the law recognizes several specific guidelines
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`that inform the obviousness analysis. First, I understand that a reconstructive
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`hindsight approach to this analysis, i.e., the improper use of post-invention
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`information to help perform the selection and combination, or the improper use of
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`the listing of elements in a claim as a blueprint to identify selected portions of
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`- 11 -
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`HALLIBURTON, Exh. 1003, p. 0011
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`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
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`different prior art references in an attempt to show that the claim is obvious, is not
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`permitted. Second, I understand that any prior art that specifically teaches away
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`from the claimed subject matter, i.e., prior art that would lead a person of ordinary
`
`skill in the art to a specifically different solution than the claimed invention, points
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`to non-obviousness, and conversely, that any prior art that contains any teaching,
`
`suggestion, or motivation to modify or combine such prior art reference(s) points
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`to the obviousness of such a modification or combination. Third, while many
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`combinations of the prior art might be “obvious to try,” I understand that any
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`obvious to try analysis will not show a claim to be unpatentable unless it is shown
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`that the possible combinations are: (1) sufficiently small in number so as to be
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`reasonable to conclude that the combination would have been selected; and
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`(2) such that the combination would have been believed to be one that would
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`produce predictable and well understood results. Fourth, I understand that if a
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`claimed invention that arises from the modification or combination of one or more
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`prior art references uses known methods or techniques that yield predictable
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`results, then that factor also points to obviousness. Fifth, I understand that if a
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`claimed invention that arises from the modification or combination of one or more
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`prior art references is the result of known work in one field prompting variations of
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`the known work for use in the same field or a different one based on design
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`incentives or other market forces that yields predicable variations, then that factor
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`HALLIBURTON, Exh. 1003, p. 0012
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`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
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`also points to obviousness. Sixth, I understand that if a claimed invention arises
`
`from the modification or combination of one or more prior art references is the
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`result of routine optimization, then that factor also points to obviousness. Seventh,
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`I understand that if a claimed invention that arises from the modification or
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`combination of one or more prior art references is the result of a substitution of one
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`known prior art element for another known prior art element to yield predictable
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`results, then that factor also points to obviousness.
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`27.
`
`I understand that a dependent claim incorporates each and every
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`limitation of the claim from which it depends. Thus, my understanding is that if a
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`prior art reference fails to anticipate an independent claim, then that prior art
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`reference also necessarily fails to anticipate all dependent claims that depend from
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`the independent claim. Similarly, my understanding is that if a prior art reference
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`or combination of prior art references fails to render obvious an independent claim,
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`then that prior art reference or combination of prior art references also necessarily
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`fails to render obvious all dependent claims that depend from the independent
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`claim.
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`V. THE ’971 PATENT
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`28. The ’971 Patent (Ex. 1001), entitled “Natural fiber span reflectometer
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`providing a virtual signal sensing array capability” asserts that it enables virtual
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`sensors along the span of fiber. Ex. 1001 at 1:45-46.
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`HALLIBURTON, Exh. 1003, p. 0013
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`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
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`29.
`
`I note that the ’971 Patent claims priority to a prior provisional
`
`application, U.S. Application No. 60/599,437 filed on August 6, 2004. I am not
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`aware at this time of any basis for an assertion of a priority date earlier than August
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`6, 2004.
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`30. The ’971 Patent includes three independent system claims. Ex. 1001
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`at claims 1, 21, and 22.
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`31.
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`Independent reflectometer claim 1 from the ’971 Patent is presented
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`below:
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`1. A time-domain reflectometer for sensing at a desired set of n
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`spaced sensing positions along an optical fiber span, said sensing
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`positions being for sensing a type of external physical signal having
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`the property of inducing light path changes within the optical fiber
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`span at regions there along where the signal is coupled to the span,
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`comprising: an optical fiber span having a first end which
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`concurrently serves as both the interrogation signal input end and the
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`back propagating signal output end for purposes of reflectometry, and
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`having a second remote end; a first light source for producing a
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`coherent carrier lightwave signal of a first predetermined wavelength;
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`a binary pseudonoise code sequence modulator modulating said
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`carrier signal for producing a pseudonoise code sequence modulated
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`interrogation lightwave signal which continuously reiterates the
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`binary pseudonoise code sequence, the reiterated sequences being
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`executed in a fixed relationship to a predetermined timing base; a
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`lightwave heterodyner having first and second inputs for receiving a
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`HALLIBURTON, Exh. 1003, p. 0014
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`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
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`primary signal and a local oscillator signal, respectively, and operative
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`to produce the beat frequencies of their respective frequencies; a
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`lightwave directional coupler having a first port which receives said
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`binary pseudonoise code sequence modulated interrogation lightwave,
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`a second port coupled to said first end of said optical fiber span, and a
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`third port coupled to said primary signal input of the heterodyner; said
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`directional coupler coupling said binary pseudonoise code sequence
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`modulated interrogation lightwave to said second port where it is
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`launched in a forwardly propagating direction along said optical fiber
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`span causing the return to said second port of a composite back-
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`propagating lightwave which is a summation of lightwave back-
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`propagations from a continuum of locations along the length of the
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`span, said composite back-propagating lightwave signal comprising a
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`summation of multiple components including a first signal component
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`comprising the summation of portions of the said pseudonoise code
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`sequence modulated interrogation lightwave signal which the innate
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`properties of the optical fiber cause to backpropagate at a continuum
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`of locations along the span, and a second signal component
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`comprising the modulation of said first signal component caused by
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`longitudinal components of optical path changes induced into said
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`span at a continuum of locations along said span by external physical
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`signals, said second signal component further including a
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`corresponding set of subcomponents comprising the modulation of
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`said first signal component by optical path changes caused by said
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`external signals at the respective sensing positions; said directional
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`coupler coupling said composite back-propagating lightwave to said
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`third port where it is applied to said first input of the heterodyner; a
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`HALLIBURTON, Exh. 1003, p. 0015
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`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
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`second light source coupled to said second input of the lightwave
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`heterodyner, said second light source producing a coherent local
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`oscillator lightwave signal in phase locked relation to said carrier
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`lightwave signal, said local oscillator signal being of a second
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`predetermined wavelength which differs from the first predetermined
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`wavelength by an amount of difference small enough to produce at the
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`output of the heterodyner a radio frequency (r.f.) composite difference
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`beat signal, but by an amount large enough to cause said r.f.
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`composite difference beat signal to have sufficient bandwidth to cause
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`it to include r.f. counterparts of signal components and
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`subcomponents of said composite back propagating lightwave signal;
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`said r.f. composite difference beat frequency signal being coupled to
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`an n-way splitter providing a corresponding set of n output channels,
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`each transmitting said r.f. composite difference beat signal; a
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`corresponding set of n correlation-type binary pseudonoise code
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`sequence demodulators having their respective inputs connected to the
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`corresponding output channels of said n-way splitter through a
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`corresponding set of time delay circuits which respectively provide a
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`corresponding set of predetermined time delays in relation to said
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`predetermined timing base of the binary pseudonoise code sequence
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`modulator, to establish said n desired sensing positions along said
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`optical fiber span; and said set of correlation-type binary pseudonoise
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`code sequence demodulators serving to conjunctively temporally and
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`spatially de-multiplex said r.f. composite difference beat signal to
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`provide at their respective outputs r.f. counterparts of the
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`subcomponents of said second signal component of said composite
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`back-propagating lightwave signal caused by changes in the optical
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`HALLIBURTON, Exh. 1003, p. 0016
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`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
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`path within said optical fiber span induced by external physical
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`signals respectively coupled to the corresponding sensing positions.
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`32.
`
`Independent system claim 21 from the ’971 Patent is presented below:
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`21. A system wherein, at respective sensing stations of a
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`plurality of sensing stations along a span of optical fiber, the system
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`senses input signals of a type having a property of inducing light path
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`changes at regions of the span influenced by such input signals,
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`comprising: means for illuminating an optical fiber span with a CW
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`optical signal; means for retrieving back-propagating portions of the
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`illumination back propagating from a continuum of locations along
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`the span; means for modulating said CW optical signal with a
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`reiterative autocorrelatable form of modulation; means for picking off
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`a radio frequency (r.f.) counterpart of the retrieved signal, wherein the
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`r.f. counterpart is in phase locked synchronism with the CW optical
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`signal; means for performing a corresponding plurality of
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`autocorrelation detections upon said (r.f.) counterpart of the retrieved
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`optical signal wherein said performing of the respective
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`autocorrelation detections of the plurality of autocorrelation detection
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`by said means for performing autocorrelation-detections are done in a
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`corresponding plurality of different timed relationships with respect to
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`the reiterative autocorrelatable form of modulation of the CW optical
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`signal.
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`33.
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`Independent apparatus claim 22 from the ’971 Patent is presented
`
`below:
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`- 17 -
`
`HALLIBURTON, Exh. 1003, p. 0017
`
`
`
`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
`
`22. Signal sensing apparatus for sensing input signals at an
`
`array of a plurality of sensing stations along an optical fiber span,
`
`wherein at respective sensing station of the array the apparatus senses
`
`input signals of a type having the property of inducing light path
`
`changes within regions influenced by such input signals, said
`
`apparatus comprising: an optical wave network comprising a
`
`transmitter laser and a lightwave directional coupler, said network
`
`being operative to illuminate an optical fiber span with a CW optical
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`signal and to retrieve portions of the illumination back-propagating
`
`from a continuum of locations along the fiber span; a modulator
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`operative to modulate the CW optical signal in accordance with a
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`reiterative autocorrelatable form of modulation code; a heterodyner
`
`which, in phase locked synchronism with said transmitter laser,
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`receives said retrieved back-propagated portions of illumination and
`
`derives therefrom a radio frequency (r.f.) counterpart; and a
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`corresponding plurality of autocorrelation detectors operative upon
`
`said r.f. counterpart of the retrieved optical signal in respective timed
`
`relationships of a corresponding plurality of different timed
`
`relationsips with respect to said reiterative autocorrelatable form of
`
`modulation code.
`
`34. The ’971 Patent specification includes 13 figures. The ’971 Patent
`
`describes Figure 1 and Figure 2 as helpful in depicting concepts and underlying
`
`mechanisms of optical systems. Ex. 1001 at 4:25-31.
`
`35. The ’971 Patent describes Figure 3 as “a block diagram of a natural
`
`fiber span time-domain reflectometer system in accordance with the present
`
`- 18 -
`
`HALLIBURTON, Exh. 1003, p. 0018
`
`
`
`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
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`invention.” Ex. 1001 at 4:32-34. It also describes Figure 12 as “a block diagram
`
`of a programmable routing and phase signal switching network which provides
`
`selective pairing of the outputs of the set of phase demodulators of FIG. 7 to
`
`provide differential phase signals across pairs of virtual sensors along the fiber
`
`span in accordance with the present invention” and Figure 13 as “a diagrammatic
`
`depiction of embodiment of invention [sic] of FIG. 3 in which portions of the
`
`optical fiber span are wound around a hollow mandrel.” Id. at 4:65-67. Those are
`
`the only three figures that are described with respect to the invention, though other
`
`figures reference particular portions of Figure 3. Figure 3 is reproduced below.
`
`
`
`- 19 -
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`HALLIBURTON, Exh. 1003, p. 0019
`
`
`
`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
`
`36. The ’971 Patent provides a “Description of the Preferred
`
`Embodiment” that includes the components of Figure 3. The transmitter laser (3),
`
`in the upper left, projects light through optical coupler or beamsplitter (4) and into
`
`optical modulator (5). The modulated light moves through optical coupler,
`
`beamsplitter, or circulator (7) and into optical fiber (9). Id. at 15:53-55; 15:58-61;
`
`and 16:1-5. The type of modulation applied is determined by master correlation
`
`code generator (53), which is connected to the modulator (5) by an amplifier 49.
`
`Id. at 15:62-63.
`
`37. The ’971 Patent explains that sending modulated light down an optical
`
`fiber span “causes a back-propagating composite optical signal, which is a linear
`
`summation, or integration spatially, of all the individual, continuous, or continuum
`
`of back-reflections along the span of fiber.” Id. at 16:21-24. That “composite
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`signal” has several components according to the ’971 Patent, including at least the
`
`“naturally occurring continuum of optical back reflections” and “the continuum of
`
`modulations at locations along the span of the reflected signals due to longitudinal
`
`components of optical path length change.” Id. at 16:26, 36-38. The second
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`component can be caused by many conditions along the fiber including acoustic
`
`pressure waves, mechanical strain or pressure, and thermal strain or pressure. Id.
`
`16:40-45. Put another way, there is always some backscattering, but the exact type
`
`of backscattering received can vary based on fiber conditions such as temperature
`
`- 20 -
`
`HALLIBURTON, Exh. 1003, p. 0020
`
`
`
`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
`
`and pressure. The ’971 Patent considers those variations separately though it is
`
`always the composite signal, including the natural continuum, that is received in
`
`any system.
`
`38. The system depicted in Figure 3 connects an optical pathway (11) to
`
`optical coupler, beamsplitter, or circulator (7) to receive the backscattered light
`
`from fiber (9) and relay it to optical receiver (15). Ex. 1001 at 17:10-14. Figures 4
`
`and 5 are schematics showing alternative arrangements of the internal components
`
`of the optical receiver (15). Id. at 4:36-39. Figure 4 shows the use of two photo-
`
`detectors (111) and (113), while in Figure 5 the optical receiver shows only one
`
`photodetector (111). Id. at Figs. 4 & 5. The optical receiver (15) also receives an
`
`input from local oscillator laser (45). Id. at 18:64-19:8. The transmitter laser (3)
`
`and local oscillator laser (45) are also connected to optical receiver (35) through
`
`optical couplers or beamsplitters (4) and (43) and optical pathways (49) and (41),
`
`respectively. Id. at 15:55-58, 18:67-19:4. Optical receiver (35) is then connected
`
`back to local oscillator laser (45) through phase locking circuitry (31), which
`
`employs “a conventional phase locked loop mechanism.” Id. at 19:14-22.
`
`39. Figure 3 of the ’971 patent also shows that the optical receiver (15) is
`
`connected through an amplifier (19) to a programmable correlator (23), which also
`
`receives an input from the master correlation code generator (53). Figure 6 shows
`
`- 21 -
`
`HALLIBURTON, Exh. 1003, p. 0021
`
`
`
`Expert Declaration of Dr. Faramarz Farahi for Inter Parties Review of US Patent No. 7,030,971
`
`a block diagram of the components inside programmable correlator (23). Ex. 1001
`
`at 4:40-42. Figure 6 is reproduced below:
`
`
`
`40. The input from the master correlation code generator (53) is provided
`
`to multiple programmable del
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