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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`FITBIT, INC.,
`Petitioner
`
`v.
`
`PHILIPS NORTH AMERICA LLC
`Patent Owner
`
`_____________________
`
`Patent No. 7,088,233
`_____________________
`
`
`DECLARATION OF DR. JOSEPH PARADISO
`
`
`
`Fitbit, Inc. v. Philips North America LLC
`IPR2020-00783
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`

`

`Declaration of Dr. Joseph Paradiso
`U.S. Patent No. 7,088,233
`
`
`B.
`
`VI.
`
`I.
`II.
`III.
`IV.
`V.
`
`TABLE OF CONTENTS
`INTRODUCTION ......................................................................................... 1
`QUALIFICATIONS ...................................................................................... 1
`SUMMARY OF OPINIONS AND MATERIALS CONSIDERED ............ 6
`LEVEL OF ORDINARY SKILL IN THE ART ......................................... 11
`TECHNOLOGICAL BACKGROUND ...................................................... 11
`A.
`Electronic sensing and computer networks in the 1970s and
`1980s.................................................................................................... 12
`Communicatively-coupled portable and wearable computing in
`the 1990s .............................................................................................. 14
`C. Wireless personal area networks ......................................................... 20
`D. Applicant’s admitted prior art ............................................................. 24
`THE ’233 PATENT ..................................................................................... 27
`A. Overview ............................................................................................. 27
`B.
`Priority claims for the ’233 patent....................................................... 29
`VII. CLAIM CONSTRUCTION ........................................................................ 32
`A.
`“means for signaling the bi-directional communications module
`to transition from the powered-down state to the powered-up
`state” .................................................................................................... 33
`VIII. OVERVIEW OF THE PRIOR ART ........................................................... 35
`A.
`Jacobsen .............................................................................................. 35
`B.
`Say ....................................................................................................... 43
`C. Quy ...................................................................................................... 52
`D. Geva ..................................................................................................... 56
`E.
`Reber.................................................................................................... 58
`F.
`Gabai ................................................................................................... 61
`THE PRIOR ART DISCLOSES AND/OR SUGGESTS ALL THE
`FEATURES OF CLAIMS 1, 7-10, 13-16, 22 AND 24-26 OF THE
`’233 PATENT .............................................................................................. 62
`
`IX.
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`i
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`Declaration of Dr. Joseph Paradiso
`U.S. Patent No. 7,088,233
`
`
`A. Ground 1: Jacobsen discloses the features of claims 1, 7-10,
`and 14 of the ’233 patent ..................................................................... 62
`1.
`Claim 1 .................................................................................. 63
`[1p] A bi-directional wireless communication system
`comprising: .................................................................... 63
`[1a] (a) a first personal device, the first personal device
`further comprising: ........................................................ 65
`[1b] (i) a processor; .................................................................. 68
`[1c] (ii) a memory; ................................................................... 75
`[1d] (iii) a power supply; ......................................................... 76
`[1e] (iv) at least one detector input; and .................................. 78
`[1f] (v) a short-range bi-directional wireless
`communications module; ............................................... 82
`[1g] (b) a second device communicating with the first
`device, the second device having a short-range bi-
`directional wireless communications module
`compatible with the short-range bi-directional
`wireless communications module of the first
`device; and ..................................................................... 86
`[1h] (c) a security mechanism governing information
`transmitted between the first personal device and
`the second device. .......................................................... 93
`Claim 7 .................................................................................. 95
`2.
`Claim 8 .................................................................................. 98
`3.
`Claim 9 ................................................................................ 100
`4.
`Claim 10 .............................................................................. 101
`5.
`Claim 14 .............................................................................. 104
`6.
`B. Ground 2: Say discloses and/or suggests the features of
`claims 1, 7-10, and 14 of the ’233 patent .......................................... 106
`1.
`Claim 1 ................................................................................ 106
`[1p] A bi-directional wireless communication system
`comprising: .................................................................. 106
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`Declaration of Dr. Joseph Paradiso
`U.S. Patent No. 7,088,233
`
`
`[1a] (a) a first personal device, the first personal device
`further comprising: ...................................................... 108
`[1b] (i) a processor; ................................................................ 112
`[1c] (ii) a memory; ................................................................. 115
`[1d] (iii) a power supply; ....................................................... 118
`[1e] (iv) at least one detector input; and ................................ 120
`[1f] (v) a short-range bi-directional wireless
`communications module; ............................................. 127
`[1g] (b) a second device communicating with the first
`device, the second device having a short-range bi-
`directional wireless communications module
`compatible with the short-range bi-directional
`wireless communications module of the first
`device; and ................................................................... 133
`[1h] (c) a security mechanism governing information
`transmitted between the first personal device and
`the second device. ........................................................ 137
`Claim 7 ................................................................................ 140
`2.
`Claim 8 ................................................................................ 142
`3.
`Claim 9 ................................................................................ 149
`4.
`Claim 10 .............................................................................. 150
`5.
`Claim 14 .............................................................................. 151
`6.
`C. Ground 3: Jacobsen in view of Say discloses and/or suggests
`the features of claims 1, 7-10, and 14 of the ’233 patent .................. 153
`1.
`Claim 1 ................................................................................ 153
`2.
`Claims 7-10 and 14 ............................................................. 158
`D. Ground 4: Jacobsen in view of Say and Quy discloses and/or
`suggests the features of claim 13 of ’233 patent .............................. 158
`1.
`Claim 13 .............................................................................. 159
`Ground 5: Jacobsen in view of Say and Geva discloses and/or
`suggests the features of claims 24-25 of the ’233 patent .................. 166
`
`E.
`
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`F.
`
`Declaration of Dr. Joseph Paradiso
`U.S. Patent No. 7,088,233
`
`Claim 24 .............................................................................. 166
`1.
`Claim 25 .............................................................................. 175
`2.
`Ground 6: Jacobsen in view of Say and Reber discloses and/or
`suggests the features of claim 26 of the ’233 patent ......................... 176
`1.
`Claim 26 .............................................................................. 176
`G. Ground 7: Say in view of Gabai discloses and/or suggests the
`features of claims 15-16 and 22 of the ’233 patent ........................... 186
`1.
`Claim 15 .............................................................................. 186
`2.
`Claim 16 .............................................................................. 194
`3.
`Claim 22 .............................................................................. 196
`CONCLUSION ......................................................................................... 197
`
`X.
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`Declaration of Dr. Joseph Paradiso
`U.S. Patent No. 7,088,233
`
`
`I, Dr. Joseph Paradiso, declare as follows:
`
`I.
`
`INTRODUCTION
`I have been retained as an independent expert consultant in this
`1.
`
`proceeding before
`
`the United States Patent
`
`and Trademark Office
`
`(“PTO”) regarding U.S. Patent No. 7,088,233 (“the ’233 patent”) (Ex. 1001).1 I
`
`have been asked to consider, among other things, whether certain references
`
`disclose or suggest the features recited in claims 1, 7-10, 13-16, 22, 24-26 (“the
`
`challenged claims”) of the ’233 patent. My opinions are set forth below.
`
`2.
`
`I am being compensated at my normal rate of $600/hour for the time I
`
`spend working on this proceeding. My compensation is not dependent on the
`
`nature of my findings, or the outcome of this proceeding or any other proceeding.
`
`I have no other interest in this proceeding.
`
`II. QUALIFICATIONS
`3. My qualifications for forming the opinions in this report are
`
`summarized here and explained in more detail in my curriculum vitae, which I
`
`understand is provided as Exhibit 1003.
`
`
`1 In this declaration, I refer to exhibit numbers that I understand are assigned to
`
`documents that will be attached with the petition for Inter Partes Review of the
`
`’233 patent.
`
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`Declaration of Dr. Joseph Paradiso
`U.S. Patent No. 7,088,233
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`I received a B.S. in electrical engineering and physics from Tufts
`
`4.
`
`University in 1977 and a Ph.D. in physics from the Massachusetts Institute of
`
`Technology (MIT) in 1981. Currently, I am the Alexander W. Dreyfoos (1954)
`
`Professor and Associate Academic Head in the Program in Media Arts and
`
`Sciences at the MIT Media Laboratory.
`
`5.
`
`For over three decades, I have been involved with the research and
`
`development of sensor technology in a variety of applications. For example, after
`
`receiving my Ph.D., I was a post-doctoral researcher at the Swiss Federal Institute
`
`of Technology (ETH) in Zurich from 1981 to 1983, where I worked on sensor
`
`technology for high-energy particle physics. Following my post-doctoral position
`
`at ETH, I was a physicist at the Draper Laboratory until 1994, where I was a
`
`member of the Control and Decision Systems Directorate and Sensor and Signal
`
`Processing Directorate. There, my research encompassed spacecraft control
`
`systems, image processing algorithms, underwater sonar, and precision alignment
`
`sensors for large high-energy physics detectors.
`
`6.
`
`In 1994, I joined the MIT Media Lab, a research laboratory, founded
`
`in 1985, that promotes a unique, cross-disciplinary culture and focuses on highly-
`
`collaborative research that joins seemingly disparate technological and academic
`
`fields. Researchers at the MIT Media Lab have pioneered areas such as wearable
`
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`Declaration of Dr. Joseph Paradiso
`U.S. Patent No. 7,088,233
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`computing, tangible interfaces, and affective computing, which has led to
`
`numerous products and platforms that have become a ubiquitous part of consumer
`
`life today. Examples of technologies that have spun off from the Media Lab’s
`
`research include e-readers, such as the Amazon Kindle and Barnes & Noble Nook,
`
`the popular video game Guitar Hero, the MPEG-4 structured audio format, the first
`
`bionic lower-leg system for amputees, wireless mesh networks developed by
`
`Nortel, and the Mercury RFID Reader, commercialized by spin-off ThingMagic.
`
`Today, the Lab is supported by more than 80 members, including some of the
`
`world’s leading corporations that represent the fields of electronics, entertainment,
`
`fashion, health care, toys, and telecommunications, among others. Currently,
`
`faculty members, research staff, and students work in over 25 research groups and
`
`initiatives on more than 450 projects that range from digital approaches for treating
`
`neurological disorders, to advancing imaging technologies that can “see around a
`
`corner,” to the word’s first “smart” powered ankle-foot prosthesis.
`
`7. When I joined the Media Lab, I focused on developing new sensing
`
`modalities for human-computer interaction, which, by 1997, evolved into wearable
`
`and non-wearable wireless sensing and distributed sensor networks to measure
`
`movement activity. This work anticipated and influenced transformative products
`
`and industries that have blossomed in recent years.
`
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`Declaration of Dr. Joseph Paradiso
`U.S. Patent No. 7,088,233
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`For example, in 1997, I developed a shoe with wireless sensors for
`
`8.
`
`measuring dynamic movement of the human foot during, for example, interactive
`
`dance and other physical activities. The shoe was intended to capture motion data,
`
`which were mapped into different information representations to facilitate
`
`interactivity. The design of this sensor-laden wireless shoe is now recognized as a
`
`watershed in the field of wireless sensing for activity tracking and was an
`
`inspiration for the Nike+, one of the very first activity trackers and the first
`
`commercial product to integrate dynamic music with monitored exercise. My team
`
`went on to pioneer on-shoe sensor architecture for clinical gait analysis in
`
`collaboration with the Massachusetts General Hospital (MGH) in 2002. We then
`
`worked in sports medicine with another MGH collaboration that developed an
`
`attachable, ultra-wide-range, wireless inertial measurement unit system for
`
`evaluating professional baseball pitchers and batters in 2007.
`
`9.
`
`Leading to over 300 publications, at least 17 issued patents, and a
`
`string of awards in the Pervasive Computing, Human-Computer Interaction, and
`
`sensor network communities, my research has become the basis for widely
`
`established curricula. Many of these publications are directed to fixed, wearable,
`
`or portable sensor devices. I have also advised over 55 graduate (M.S. and Ph.D.)
`
`theses for students who have done their work in my research group, and served as a
`
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`Declaration of Dr. Joseph Paradiso
`U.S. Patent No. 7,088,233
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`reader for roughly 100 M.S. and Ph.D. students in other groups and at other
`
`universities.
`
`10.
`
`I have given over 300 invited talks, panel appearances, and seminars
`
`worldwide, recently keynoting on topics relating to ubiquitous sensing and the
`
`Internet of Things (IoT) for prestigious venues ranging from the Sensors Expo (the
`
`main industrial sensors conference) to the World Economic Forum. I am
`
`frequently asked to address industrial groups on sensing systems and IoT. For
`
`example, I recently gave the opening keynote at IoT Solutions World Congress in
`
`Barcelona, the leading Industrial IoT event, and I have been on the Editorial Board
`
`(and have served as Associate Editor in Chief) of IEEE Pervasive Computing
`
`Magazine (the original flagship publication in this area) since 2006. I often engage
`
`with the Media Lab’s extensive list of industrial partners in strategizing these
`
`areas.
`
`11.
`
`I also belong
`
`to and participate
`
`in numerous professional
`
`organizations. I am a senior member of the Institute of Electrical and Electronics
`
`Engineers (IEEE), and also belong to the Association for Computer Machinery
`
`(ACM). I also belong to the American Physical Society (the major professional
`
`society in physics), and am a senior member in the American Institute of
`
`Aeronautics and Astronautics (AIAA). Within the IEEE, I belong to the Signal
`
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`Declaration of Dr. Joseph Paradiso
`U.S. Patent No. 7,088,233
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`Processing Society, the Controls Society, and the Computer Society. I have served
`
`on many Technical Program Committees (which solicit, review, and select papers
`
`for academic conferences) and journal editorial boards. I have also organized
`
`academic conferences in areas such as wireless sensor networks, wearable
`
`computing and wearable sensing, human-computer
`
`interfaces, ubiquitous
`
`computing, and the like.
`
`III. SUMMARY OF OPINIONS AND MATERIALS CONSIDERED2
`12. All of the opinions contained in this declaration are based on the
`
`documents I reviewed and my professional judgment, as well as my education,
`
`experience, and knowledge regarding computer networking. I am not an attorney
`
`and I am not offering any legal opinions in this declaration.
`
`13.
`
`In forming my opinions expressed in this declaration, I reviewed:
`
`• the ’233 patent (Ex. 1001);
`
`• the prosecution file history for the ’233 patent (Ex. 1004);
`
`• U.S. Patent No. 6,198,394 (“Jacobsen”) (Ex. 1005);
`
`• U.S. Patent No. 6,175,752 (“Say”) (Ex. 1006);
`
`2 My citations to non-patent publications are to the original page numbers of the
`
`publication, and my citations to U.S. Patents or Patent Applications are to the
`
`column:line number or paragraph number, as applicable.
`
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`Declaration of Dr. Joseph Paradiso
`U.S. Patent No. 7,088,233
`
`
`• U.S. Patent No. 6,602,191 (“Quy”) (Ex. 1007);
`
`• U.S. Patent No. 6,366,871 (“Geva”) (Ex. 1008);
`
`• Kaveh Pahlavan, Ali Zahedi, and Prashant Krishnamurthy,
`
`“Wireband Local Access: Wireless LAN and Wireless ATM,” IEEE
`
`Communications Magazine, Vol. 35 Issue 11, November 1997,
`
`pgs. 34-40 (Ex. 1009);
`
`• Paradiso, J.A., Hsiao, K., Benbasat, A. and Teegarden, Z., “Design
`
`and Implementation of Expressive Footwear,” IBM Systems
`
`Journal, Vol. 39, No. 3&4, October 2000, pp. 511-529 (Ex. 1010);
`
`• Paradiso, J.A. “The Brain Opera Technology: New Instruments
`
`and Gestural Sensors for Musical Interaction and
`
`Performance,” Journal of New Music Research, 28(2), 1999, pp.
`
`130-149 (Ex. 1011);
`
`• Specification of the Bluetooth System, Vol. 1, Bluetooth v1.0B
`
`(Dec. 1, 1999) (Ex. 1012);
`
`• Provisional application No. 60/105,493 (Ex. 1013);
`
`• Provisional application No. 60/135,862 (Ex. 1014);
`
`• Provisional application No. 60/279,401 (Ex. 1015);
`
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`U.S. Patent No. 7,088,233
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`
`• Digital Networks’ “RoamAbout 2.4 GHz frequency hopping
`
`wireless LAN adapters” (1996) (Ex. 1018);
`
`• Shawn Willett, “Digital ships tools for mobile clients,” InfoWorld,
`
`February 7, 1994 (Ex. 1019);
`
`• U.S. Patent No. 5,961,451 (“Reber”) (Ex. 1020);
`
`• Distributed Sensor Networks, Proceedings of a Workshop held at
`
`Carnegie-Mellon University December 7-8, 1978 (available at
`
`https://resenv.media.mit.edu/classarchive/MAS961/readings/DSN_
`
`CMU_1978.pdf) (Ex. 1021);
`
`• ‘Sensor networks: evolution, opportunities, and challenges,” IEEE
`
`Proceedings, Aug. 2003 (Ex. 1022);
`
`• Mark Weiser, “The Computer for the 21st Century,” Scientific
`
`American (1991) (Ex. 1023);
`
`• Richard S. Johnston et al., “Biomedical Results of Apollo” (1975)
`
`(available at http://history.nasa.gov/SP-368/sp368.htm) (Ex.
`
`1024);
`
`• Steve Mann, “Wearable computing: A first step toward personal
`
`imaging”, IEEE Computer vol. 30 no. 2, pgs. 25-32 (Feb. 1997)
`
`(Ex. 1025);
`
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`Declaration of Dr. Joseph Paradiso
`U.S. Patent No. 7,088,233
`
`
`• Steve Feiner, “A Touring Machine: Prototyping 3D Mobile
`
`Augmented Reality Systems for Exploring the Urban
`
`Environment,” Personal Technologies, pgs. 208-217 (1997) (Ex.
`
`1026);
`
`• Kris Goodfellow, One Digital Day in Her Life, N.Y. Times, Apr.
`
`16, 1998 (available at:
`
`http://www.nytimes.com/1998/04/16/technology/one-digital-day-
`
`in-her-life.html) (Ex. 1027);
`
`• Maria S. Redin, “Marathon Man” thesis, MIT Media Laboratory,
`
`June 15, 1998 (Ex. 1029);
`
`• Brian Clarkson and Alex Pentland, “Predicting Daily Behavior via
`
`Wearable Sensors,” Technical report, MIT Media Laboratory, July
`
`2001 (available at
`
`https://pdfs.semanticscholar.org/2fd4/7fe8b3c65bfb32ffe91c61686
`
`9e071c4894a.pdf) (Ex. 1031);
`
`• Brian Clarkson and Alex Pentland, “Unsupervised Clustering of
`
`Ambulatory Audio and Video,” ICASSP, March 1999 (Ex. 1032);
`
`• Joseph Paradiso, “Expressive footwear for computer-augmented
`
`dance performance,” ISWC ’97: Proceedings of the 1st IEEE
`
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`Declaration of Dr. Joseph Paradiso
`U.S. Patent No. 7,088,233
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`
`International Symposium on Wearable Computers, October 1997
`
`(Ex. 1033);
`
`• Robert Poor, “Hyphos: A Self-Organizing, Wireless Network,”
`
`MIT Master’s thesis, 1997 (Ex. 1034);
`
`• Per Johansson et al., “Short Range Radio Based Ad-hoc
`
`Networking: Performance and Properties,” ICC’99, 1999 (Ex.
`
`1036);
`
`• Application no. 09/384,165 (Ex. 1038);
`
`• U.S. Patent No. 6,160,986 (“Gabai”) (Ex. 1040);
`
`• U.S. Patent No. 6,026,165 (“Marino”) (Ex. 1041);
`
`• U.S. Patent No. 5,408,250 (“Bier”) (Ex. 1042)
`
`My opinions are additionally guided by my appreciation of how a person of
`
`ordinary skill in the art would have understood the claims of the ’233 patent at the
`
`time of the alleged inventions.
`
`14. Based on my experience and expertise, it is my opinion that certain
`
`references disclose or suggest all the features recited in claims 1, 7-10, 13-16, 22,
`
`24-26 of the ’233 patent.
`
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`Declaration of Dr. Joseph Paradiso
`U.S. Patent No. 7,088,233
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`
`IV. LEVEL OF ORDINARY SKILL IN THE ART
`15. At the time of the alleged inventions a person of ordinary skill in the
`
`art (“POSITA”) would have had at least a B.S. in computer science, electrical
`
`engineering, or an equivalent, and at least two years of experience in the relevant
`
`field, i.e., wireless communications. More education can substitute for practical
`
`experience and vice versa. I apply this understanding in my analysis herein.
`
`16.
`
`In determining the level of ordinary skill, I have considered, for
`
`example, the types of problems encountered in the art and prior solutions to these
`
`problems,
`
`the rapidity with which
`
`innovations are
`
`typically made,
`
`the
`
`sophistication of the technology, and the educational level and experience of
`
`workers in the field.
`
`17. My analysis of the ’233 patent and my opinions in this declaration are
`
`from the perspective of a POSITA, as I have defined it above, during the relevant
`
`time frame (see section VI.B). During this time frame, I possessed at least the
`
`qualifications of a POSITA, as defined above.
`
`V.
`
` TECHNOLOGICAL BACKGROUND
`In this section, I provide an overview of certain technologies, systems,
`18.
`
`and concepts that were known in the art at or before the dates of the alleged
`
`inventions of the ’233 patent. I believe the technologies and concepts I describe
`
`below were widely known and appreciated by POSITAs at or before that time. I
`
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`Declaration of Dr. Joseph Paradiso
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`rely on at least the discussions below (including references cited therein) to
`
`demonstrate the state of the art known to POSITAs at that time, which supports my
`
`opinions and analysis regarding the ’233 patent and my opinions and analysis
`
`provided in section IX
`
`A. Electronic sensing and computer networks in the 1970s and 1980s
`19. Personal monitoring with electronic sensors has been well-known
`
`since at least the second half of the 20th century. Early examples of practical
`
`electronic sensing in the context of personal monitoring grew out of NASA’s space
`
`program. Crewman of the Apollo missions, for example, “wore a biosensor
`
`harness which provided a means of transmitting critical physiological data to the
`
`ground.” Ex. 1024, 61. The harness, which provided “real-time telemetry of vital
`
`biomedical information,” included sensors for obtaining an “electrocardiogram,
`
`heart rate, and respiratory pattern and rate data.” Id. The wearable sensors also
`
`included sensing means
`
`for
`
`recording and
`
`transmitting media: “Voice
`
`communications and real-time television observations, coupled with monitoring of
`
`the vital signs, provided the medical basis for an inflight clinical profile of the
`
`Apollo astronauts.” Id. The data obtained from wearable sensors was displayed on
`
`remote monitors at the launch and at mission control centers. Id.; see also id. at
`
`485-93.
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`IPR2020-00783
`
`Fitbit, Inc. Ex. 1002 Page 0017
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`Declaration of Dr. Joseph Paradiso
`U.S. Patent No. 7,088,233
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`Example of a biobelt from the Apollo missions being worn with the electrode
`sensors in place. Id. at 491
`Around the same time, advancements in computer networking research were
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`yielding practical applications. The precursor for the Internet—i.e., ARPANET—
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`was built by DARPA and successfully implemented in the late 1960s.
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`20. The combination of the distributed sensors and computer networking,
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`i.e., sensor networks, were gestated mainly under DARPA funding, starting in the
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`1970s. See Ex. 1021. These sensor networks were described as “a group of sensor
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`devices connected by a communications networking trying to achieve a common
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`goal—deriving an accurate world picture.” Id. at 38. As compact wireless
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`networking technologies and capable microcomputer scaling were still fairly
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`undeveloped at that time, these systems were mainly wired or hypothetical until the
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`1990s, when building practical wireless systems began to be feasible. Again, much
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`IPR2020-00783
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`Declaration of Dr. Joseph Paradiso
`U.S. Patent No. 7,088,233
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`of this work was spurred by DARPA, this time under its SensIT program. Many
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`papers from this program appeared in the 90s and made their way into the popular
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`press at the time. See e.g., Ex. 1022.
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`21. The idea of ubiquitously networking artifacts of daily life to form a
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`new paradigm in Human-Computer Interfaces was first and famously elucidated by
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`Mark Weiser of Xerox PARC in his visionary article ‘The Computer for the 21st
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`Century’ published in Scientific American in 1989. Ex. 1023. This article spoke
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`of what Weiser called Ubiquitous Computing, where processing, networking and
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`sensing would be in essentially everything, fundamentally changing the way we
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`interact with things and information. Weiser punctuates the article with examples
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`drawn from his group at PARC that pointed at possibilities extrapolated from the
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`technology available at the time. This article (and the enormous flood of research
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`that it inspired) foreshadowed the Internet of Things.
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`B. Communicatively-coupled portable and wearable computing in
`the 1990s
`22. By the 1990s, researchers had begun development of the concept of
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`wearable computing. These pioneers were living in a world of distributed sensing,
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`interface, and display, all arrayed on-body. They believed even then that the future
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`of computing was to be up close and personal, always on, and with capabilities at
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`the right place—e.g., a display at the eyes and an interface near the hands,
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`IPR2020-00783
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`Fitbit, Inc. Ex. 1002 Page 0019
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`Declaration of Dr. Joseph Paradiso
`U.S. Patent No. 7,088,233
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`ubiquitously networked to nearby and remote artifacts and resources with wireless
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`and cellular links, etc. These researchers did not just speculate, patent, or write
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`about it these concepts; they developed and lived with these systems. Several of
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`them were close colleagues of mine at the MIT Media Lab at the time (see image
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`below). Steve Mann, now a longstanding professor at the University of Toronto,
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`was (and still is) one of the field’s most poignant visionaries, and Thad Starner,
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`now a professor at Georgia Tech, went on to be one of the chief developers of
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`Google Glass. Steve Mann traces his fielded wearable systems back to 1980 in his
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`landmark survey article “Wearable computing: A first step toward personal
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`imaging”, IEEE Computer Feb. 1997. Ex. 1025. Steve’s wearable rig back then
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`incorporated many of the challenged claims’ features, including wearable user
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`interfaces, heart-rate and other monitors, GPS and other localization systems, and a
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`variety of wireless links.
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`IPR2020-00783
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`Declaration of Dr. Joseph Paradiso
`U.S. Patent No. 7,088,233
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`MIT Wearable Computing Evangelists outside the Media Lab in the mid 90s – note
`Steve Mann at left and Thad Starner at right.
`23. The MIT Media Lab’s wearable researchers openly published and
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`posted profusely during the 1990s, and many of their papers (and selected papers
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`from other groups) are listed and linked on the Media Lab’s website. See
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`http://www.media.mit.edu/wearables/papers.html.
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`24. The Media Lab hosted the world’s first conference dedicated to
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`Wearable Computing (ISWC) at MIT back in October of 1997, an event that is
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`continuing to this day. One of many papers of note at the 1997 symposium was
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`written by Prof. Steve Feiner and his team from Columbia University: ‘A Touring
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`Machine: Prototyping 3D Mobile Augmented Reality Systems for Exploring the
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`Urban Environment’. Ex. 1026. This paper describes classic, well-known
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`Declaration of Dr. Joseph Paradiso
`U.S. Patent No. 7,088,233
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`pioneering work in mobile augmented reality, where his subjects would walk
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`around Manhattan with a wearable computer then in a backpack, coupled to a
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`separate GPS receiver, and including a “head-tracked, see-through, headworn, 3D
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`display, and an untracked, opaque, handheld, 2D display with stylus and trackpad”
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`with a RF wireless network link. A comprehensive history of significant mobile
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`AR
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`research
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`and
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`development
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`is
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`presented
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`here:
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`https://www.icg.tugraz.at/~daniel/HistoryOfMobileAR/
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`25. The wearable community also explored physiological and health-
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`related monitoring in their prototype systems back in the 1990s. In addition to
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`Mann, researchers like Rosalind Picard (Mann’s advisor) and Dr. Jenn Healey used
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`distributed biosensors in wearable systems for pioneering research in affective
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`computing and e-health. Dr. Healey’s work on affective wearables was featured in
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`the New York Times. See Ex. 1027. Dr. Picard’s group web page from 1997
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`includes articles on many other related projects conducted by the group around this
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`time, including those using a multip