`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`Under Armour Inc.,
`Petitioner
`
`v.
`
`adidas AG,
`Patent Owner
`
`
`
`
`Case No. IPR2015-00698
`
`Patent No. 8,092,345
`
`DECLARATION OF DR. MARK T. JONES
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`
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`1
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`Patent Owner adidas AG
`Exhibit 2003 - Page 1 of 47
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`
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`
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`I, Mark T. Jones declare as follows:
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`I.
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`Introduction
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`1.
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`I have prepared this Declaration for consideration by the Patent Trial
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`and Appeal Board in connection with the above-referenced inter partes review
`
`proceeding.
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`2.
`
`I am over eighteen years of age, and I would otherwise be competent
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`to testify as to the matters set forth herein if I am called upon to do so.
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`3.
`
`I have written this Declaration at the request of and have been retained
`
`by Kilpatrick Townsend & Stockton LLP, which represents Patent Owner adidas
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`AG in connection with the above-captioned inter partes review proceeding.
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`4.
`
`I am being compensated at the rate of $450 per hour for my time spent
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`working in connection with this matter.
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`II. Background & Qualifications
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`5.
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`In forming my opinions, I relied on my knowledge and experience in
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`the field and on documents and information referenced in this Declaration.
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`6.
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`I am a Professor of Electrical and Computer Engineering at Virginia
`
`Tech in Blacksburg, Virginia. I graduated summa cum laude from Clemson
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`University in 1986 with a B.S. in Computer Science and a minor in Computer
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`Engineering while holding a National Merit Scholarship and the R. F. Poole
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`2
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`Patent Owner adidas AG
`Exhibit 2003 - Page 2 of 47
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`
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`Scholarship. I then graduated from Duke University in 1990 with a PhD in
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`Computer Science while holding the Von Neumann Fellowship.
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`7.
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`Upon graduation, I joined the Department of Energy at their Argonne
`
`National Laboratory facility. My responsibilities there included the design and use
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`of software for computers with hundreds of processing elements. This software
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`was designed for compatibility with new parallel computer architectures as they
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`became available as well as with other large software components being written in
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`the Department of Energy. While with DOE, I received the IEEE Gordon Bell
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`Prize.
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`8.
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`In 1994, I joined the Computer Science faculty at the University of
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`Tennessee. My teaching responsibilities included computer architecture and
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`computer networking. My research interests included the design and use of
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`software that used the collective power of large groups of workstations. While at
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`the University of Tennessee, I received a CAREER Award from the National
`
`Science Foundation.
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`9.
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`In 1997, I joined the Electrical and Computer Engineering faculty at
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`Virginia Tech. My teaching responsibilities have included the design of embedded
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`systems, computer organization, computer architecture, a variety of programming
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`courses, and parallel computing. These courses have included material on data
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`storage systems, including RAID systems, as well as error detection and correction
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`3
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`Patent Owner adidas AG
`Exhibit 2003 - Page 3 of 47
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`
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`
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`techniques (e.g., parity bits). I have been cited multiple times on the College of
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`Engineering’s Dean’s List for teaching.
`
`10.
`
`In addition to the activities, education, and professional experience
`
`listed above, I have been involved in research projects that contribute to my
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`expertise relating to this declaration. While at Virginia Tech, I have been a primary
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`or co-investigator on government and industrial research grants and contracts in
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`excess of five million dollars.
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`11. The majority of the research contracts undertaken in the laboratory
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`have involved collaboration and coordination with other groups to build a larger
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`system. My responsibilities under the SLAAC project (a collaborative effort
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`funded by the Defense Advanced Research Projects Agency involving the
`
`University of Southern California, Sandia National Laboratory, Los Alamos
`
`National Laboratory, Brigham Young University, UCLA, Lockheed-Martin, and
`
`the Navy) included the development of a software system for monitoring,
`
`configuring, and controlling a networked collection of computers hosting
`
`specialized computer hardware. As part of the DSN project (a collaborative effort
`
`funded by the Defense Advanced Research Projects Agency involving UCLA and
`
`USC), I was responsible for designing algorithms and software for controlling and
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`monitoring a large network of autonomous computer sensor nodes. This software
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`4
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`Patent Owner adidas AG
`Exhibit 2003 - Page 4 of 47
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`
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`was integrated with software from several other teams around the country for a set
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`of field demonstrations over a three-year period.
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`12. Other projects have involved the close coupling of computer hardware
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`and software, including the writing of device drivers and simple operating systems,
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`the design of hardware circuits, the design of new system architectures integrating
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`low power data storage, architectures for secure computing, the modification of
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`complex operating systems, and software for mediating between complex software
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`packages. My work in e-textiles has focused on new architectures that integrate
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`fault tolerant networks. I have designed image transmission systems for reliably
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`transmitting images over wireless links using compression and error-correction
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`techniques.
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`13. A detailed record of my professional qualifications is set forth in
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`Attachment A to this, which is my curriculum vitae, including a list of
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`publications, awards, research grants, and professional activities.
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`III.
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`Information Considered
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`14.
`
`In forming my opinions, in addition to my knowledge and experience,
`
`I have considered a variety of documents and things that I have obtained, or that
`
`have been provided to me. This includes U.S. Patent No. 8,092,345, (“the ‘345
`
`patent”). In addition to the ‘345 patent, I have also considered U.S. Patent Nos.
`
`7,905,815, 7,931,562, 8,579,767, 8,725,276, 8,721,502, 8,652,009, 7,292,867,
`
`5
`
`Patent Owner adidas AG
`Exhibit 2003 - Page 5 of 47
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`
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`
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`7,805,149, 7,941,160, 7,957,752, 8,068,858, and 8,244,226 (collectively “the
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`Litigation Patents”). I have also considered the file histories of all of these patents.
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`15.
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`I studied publicly available information about Under Armour,
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`MapMyFitness, and their products, including user support sites and server API
`
`descriptions. I have reviewed papers in adidas AG v. Under Armour, Inc. and
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`MapMyFitness, Inc., Case 1:14-cv-00130-GWS (D. Del.), including briefs written
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`by the parties, the Court’s Orders, and written discovery responses.
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`16. Shortly after my engagement with Kilpatrick Townsend & Stockton
`
`LLP, I began to download and use the various MapMyFitness mobile applications.
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`I have downloaded and used the Android and iOS version each of the following
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`applications and their associated web interfaces; MapMyFitness, MapMyFitness+,
`
`MapMyRun, MapMyRun+, MapMyRide, MapMyRide+, MapMyHike,
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`MapMyHike+, MapMyDogWalk. I obtained a paid “MVP” subscription from
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`MapMyfitness that permitted me to use the premium features of each of the
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`accused MapMyFitness applications. I also obtained network captures that
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`permitted me to see what data is sent between the apps and servers.
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`17. A complete list of documents and things considered for purposes of
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`this Declaration can be found as Attachment B to this Declaration.
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`6
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`Patent Owner adidas AG
`Exhibit 2003 - Page 6 of 47
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`IV. Person of Ordinary Skill in the Art
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`18.
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`I have been informed that “a person of ordinary skill in the relevant
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`field” is a hypothetical person to whom an expert in the relevant field could assign
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`a routine task with reasonable confidence that the task would be successfully
`
`carried out. In my opinion, a person of ordinary skill in the art would have at least
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`a bachelor’s degree in electrical or computer engineering and three years of
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`practical experience with sensing, signaling, and embedded systems. As of the
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`relevant time period I was at least a person of ordinary skill in the art.
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`V. Claim Construction
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`19.
`
`I understand that for purposes of an inter partes review of an
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`unexpired patent, all claims are to be construed with the broadest reasonable
`
`interpretation in light of the specification. I have reviewed and considered the
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`Board’s discussion of the term “common file format” in the Institution Decision.
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`VI. Analysis
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`20. My primary task for purposes of this declaration was to determine
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`whether
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`the Under Armour MapMyFitness MapMyFitness, MapMyWalk,
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`MapMyHike, MapMyRun, MapMyRide, MapMyFitness+, MapMyWalk+,
`
`MapMyHike+, MapMyRun+, MapMyRide+, and MapMyDogwalk mobile
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`applications, their respective web interfaces and server software and associated
`
`7
`
`Patent Owner adidas AG
`Exhibit 2003 - Page 7 of 47
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`
`
`
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`products embody or practice the inventions of claims 1-3, 6-11, 15-17, and 20 of
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`the ‘345 patent.
`
`A. Overview of the ‘345 Patent
`
`21. The ‘345 patent describes a customizable, modular personal network
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`system wherein the individual components are designed to be worn, carried or
`
`used on or about the user. Ex. 1001 at Abstract. In particular, the ‘345 patent
`
`claims a portable electronic journal designed to be worn or carried by a user and a
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`method of providing said portable electronic journal. Ex. 1001 at 71:30-72:57.
`
`Independent claim 1 is an exemplary claim of the ‘345 patent:
`
`A portable electronic journal configured to be worn or carried
`
`by a user comprising a memory to store journal entries, journal
`
`software with which a user interacts and creates a new journal and is
`
`capable of creating individual text or audio journal entries for the
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`journal and optionally linking one or more images to the journal, a
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`user input device that is used in creating journal entries, wherein the
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`user input device is selected from the group consisting of a voice input
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`device and a text input device to create journal entries, a digital
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`camera that creates images to store with the created journal entries, a
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`clock to tag the journal entries with date and time, a communication
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`8
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`Patent Owner adidas AG
`Exhibit 2003 - Page 8 of 47
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`device to upload the journal entries to a personal computer, and
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`software to format the journal entries to a common file format.
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`Ex. 1001 at 71:30-43. Independent claim 20 covers a method of providing a
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`portable electronic journal that generally corresponds to the limitations of claim 1.
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`Id. at 72:43-57. Dependent claims 2-3, 6-11, and 15-17 include a variety of
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`limitations including the types of information collected by the journal, the manner
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`in which the information is collected, and how information is stored within the
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`portable electronic journal. Id. at 71:44-72:39.
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`22. The ‘345 patent issued from U.S. Patent App. No. 12/617,985 filed on
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`November 13, 2009. The ‘345 patent claims priority to U.S. Provisional
`
`Application No. 60,270,400, filed on February 20, 2001.
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`B. MapMyFitness Mobile Applications
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`23. The MapMyFitness products are mobile fitness applications and their
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`corresponding webpages. As described by the MapMyFitness webpage
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`http://about.mapmyfitness.com/brand/ (last accessed August 31, 2015)
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`24.
`
`I have reviewed and used both the free and paid versions of the
`
`MapMyFitness mobile application. I have also reviewed and used certain
`
`
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`9
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`Patent Owner adidas AG
`Exhibit 2003 - Page 9 of 47
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`peripheral devices, such as the Armour39. I have also used the websites related to
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`the applications.
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`25.
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`I have captured screenshots from the mobile applications and
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`webpage.
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`26. As stated above, I have used both the paid and free version of the
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`MMF Application. In my experience these two applications have substantially the
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`same features, however, the paid version does not have advertising. The
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`MapMyFitness webpage states that the difference between these two apps is “ad-
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`free experience, music controls within the app, and an integrated camera for
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`pausing
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`to
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`take
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`photos.”
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`https://support.mapmyfitness.com/hc/en-
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`us/articles/200118114-What-s-the-Difference-Between-the-Free-and-Apps-.
`
`
`
`I
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`believe this webpage is out of date, because the free version of the app I reviewed
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`included both music controls within the app and an integrated camera.
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`27. Based on my review of the MapMyFitness mobile applications, their
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`respective web interfaces and server software and associated products, it is my
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`opinion that the MapyMFitness-branded mobile applications within the same
`
`platform (e.g., the iOS versions of MapMyFitness, MapMyRun, MapMyWalk,
`
`MapMyHike, and MapMyDogWalk) substantially contain the same functionality
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`with respect to the claimed inventions of the ‘345 patent. Additionally, it is my
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`opinion that the MMF mobile applications generally have the same functionality
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`10
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`Patent Owner adidas AG
`Exhibit 2003 - Page 10 of 47
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`
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`
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`for Android and iOS with respect to the claimed inventions of the ‘345 patent. The
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`one distinction is that only MVP users of the Android versions of the applications
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`can use the in-app camera functionality.
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`28. As shown in the below chart, it is my opinion that the MMF mobile
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`applications for iOS and Android embody or practice at least claims 1, 6, 7, 8, 9,
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`10, and 20 of the ‘345 patent.
`
`Claims
`1. A portable
`electronic journal
`configured to be
`worn or carried by
`a user comprising
`
`MapMyFitness Mobile Applications
`The MMF mobile applications operate on a portable mobile
`device such as an Apple iPhone or Android phone, which is
`worn or carried by a user. When installed on one of these
`devices, all the MMF mobile application configure the device
`to act as an electronic fitness journal for tracking health and
`fitness-related activities and information.
`
`
`
`MapMyFitness, About Us, Ex. 2005
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`
`
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`11
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`Patent Owner adidas AG
`Exhibit 2003 - Page 11 of 47
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`[a] a memory to
`store journal
`entries,
`
`[b] journal
`software with
`which a user
`interacts and
`creates a new
`journal and is
`capable of
`creating
`individual text or
`audio journal
`entries for the
`journal and
`optionally linking
`one or more
`images to the
`
`
`
`
`MapMyFitness Help and Support, Mobile App Questions, Ex.
`2022
`The MMF mobile applications operate on a portable mobile
`device such as an Apple iPhone or Android phone, which
`includes a memory and/or hard disk, which stores fitness
`journal entries entered by the user, including logged workouts.
`
`See evidence cited for claim 1 preamble.
`The MMF mobile applications include software which permits
`the user to interactively create a new fitness journal by
`creating an MMF account. The MMF mobile applications
`also permit users to create text journal entries by using the
`touchscreen on their mobile device to select to record a
`workout, including textual entries reflecting the user’s
`performance, such as the user’s total distance and pace, during
`the workout. The user can also use the touchscreen on the
`mobile device to add textual comments to the recorded entry.
`Users can also optionally link a photograph to the recorded
`workout.
`
`
`12
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`Patent Owner adidas AG
`Exhibit 2003 - Page 12 of 47
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`
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`
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`journal,
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`
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`13
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`Patent Owner adidas AG
`Exhibit 2003 - Page 13 of 47
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`MapMyFitness Help and Support, Getting Started, Ex. 2010
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`14
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`Patent Owner adidas AG
`Exhibit 2003 - Page 14 of 47
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`15
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`Patent Owner adidas AG
`Exhibit 2003 - Page 15 of 47
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`16
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`Patent Owner adidas AG
`Exhibit 2003 - Page 16 of 47
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`MapMyFitness Help and Support, Change Profile Photo, Ex.
`2011
`As explained above, users of the MMF mobile applications
`can use the touchscreen on their mobile devices to create
`fitness journal entries and can use the touchscreen or the voice
`recognition on their mobile device to add textual comments to
`a record workout.
`
`See evidence cited for claim limitation 1[b].
`
`The MMF mobile applications include an “in-app camera”
`that permits users to use the digital camera on their mobile
`device to capture images and save them in connection with
`workouts or post them on their activity feed. The photos are
`stored with the created journal entries.
`
`
`[c] a user input
`device that is used
`in creating journal
`entries, wherein
`the user input
`device is selected
`from the group
`consisting of a
`voice input device
`and a text input
`device to create
`journal entries,
`[d] a digital
`camera that
`creates images to
`store with the
`created journal
`entries,
`
`17
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`Patent Owner adidas AG
`Exhibit 2003 - Page 17 of 47
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`18
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`Patent Owner adidas AG
`Exhibit 2003 - Page 18 of 47
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`MapMyFitness Help and Support, How to Save and View
`Photos using the In-App Camera, Ex. 2012
`The MMF mobile applications use a clock on the mobile
`device to tag each recorded workout with the date and time the
`workout was recorded.
`
`[e] a clock to tag
`the journal entries
`with date and
`time,
`
`19
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`Patent Owner adidas AG
`Exhibit 2003 - Page 19 of 47
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`[f] a
`communication
`device to upload
`the journal entries
`to a personal
`computer,
`
`
`
`
`The MMF mobile applications use the mobile device’s cellular
`connection to upload the user’s recorded workout information,
`as well as any comments entered by the user, to a server. The
`data may then be accessed on a personal computer, through
`MapMyFitness.com and other MMF-branded websites.
`
`
`20
`
`Patent Owner adidas AG
`Exhibit 2003 - Page 20 of 47
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`MapMyFitness Help and Support, Where are my Workouts
`and Routes, Ex. 2013
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`
`21
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`Patent Owner adidas AG
`Exhibit 2003 - Page 21 of 47
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`22
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`Patent Owner adidas AG
`Exhibit 2003 - Page 22 of 47
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`23
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`Patent Owner adidas AG
`Exhibit 2003 - Page 23 of 47
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`[g] and software
`to format the
`journal entries to
`a common file
`format.
`
`
`The MMF mobile applications includes software which
`converts collected data to JSON format, which is a common
`file format.
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`
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`24
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`Patent Owner adidas AG
`Exhibit 2003 - Page 24 of 47
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`6. The journal of
`claim 1 further
`comprising a
`database
`comprising a
`plurality of
`database entries
`wherein a journal
`entry may be
`tagged with one
`of the plurality of
`database entries.
`
`7. The journal of
`claim 6 wherein
`the database
`comprises an
`athletic database,
`a nutrition
`database, a
`treatment
`database, a
`diagnostic
`database, a patient
`database, a
`pharmaceutical
`
`Under Armour Connected Fitness, DOCS, Ex. 2014
`The MMF mobile applications allow users to tag workouts
`with an “activity type.” The various activity types are more
`likely than not stored as a database.
`
`
`
`
`
`
`
`
`
`See also, Under Armour Connected Fitness, Activity Type,
`Ex. 2015
`As discussed above, the MMF mobile applications include
`athletic databases.
`
`See evidence cited for claim 6.
`
`
`
`25
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`Patent Owner adidas AG
`Exhibit 2003 - Page 25 of 47
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`
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`database, an
`insurance
`database, a
`medical
`instrument
`database, a health
`alert database, a
`competition
`database, or a
`personal database.
`8. The journal of
`claim 6 further
`configured to
`make automatic
`calculations
`related to a
`journal entry and
`a linked database
`entry.
`
`9. The journal of
`claim 1 further
`comprising an
`athletic data
`collection device
`wherein a journal
`entry may be
`tagged with data
`collected using
`the athletic data
`collection device.
`
`The MMF mobile applications make several automatic
`calculations related to journal entries and linked database
`entries. For example, the MMF mobile applications
`automatically calculate calories spent based, inter alia, on the
`user’s logged workout information, such as distance and
`duration, and the selected activity type.
`
`See evidence cited for claim 6.
`
`See MapMyFitness, Incorrect Calorie Calculations, Ex. 2016
`The MMF mobile applications can collect performance
`information about an individual during the athletic activity
`from a plurality of different athletic data collection devices,
`including heart rate monitors, cadence monitors, the
`Armour39 system, and various other sensors and monitors.
`The MMF applications tag the recorded workout with the data
`collected from these devices.
`
`
`
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`
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`
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`26
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`Patent Owner adidas AG
`Exhibit 2003 - Page 26 of 47
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`27
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`Patent Owner adidas AG
`Exhibit 2003 - Page 27 of 47
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`28
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`Patent Owner adidas AG
`Exhibit 2003 - Page 28 of 47
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`10. The journal of
`claim 9 wherein
`the athletic data
`collection device
`comprises a heart
`rate monitor, a
`blood pressure
`monitor, or a
`stopwatch.
`20. A method of
`providing portable
`electronic
`journaling to a
`user comprising
`receiving voice or
`text input from a
`device worn or
`carried by the
`user,
`[a] creating a new
`journal using an
`interface with
`which the user
`interacts and
`which is capable
`of creating
`individual text or
`audio journal
`
`
`See evidence cited for Claim 9.
`
`See evidence cited for the preamble of claim 1.
`
`See evidence cited for claim limitation 1[b].
`
`29
`
`Patent Owner adidas AG
`Exhibit 2003 - Page 29 of 47
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`
`
`
`
`entries for the
`journal and
`optionally linking
`one or more
`images to the
`journal,
`[b] creating a
`journal entry
`based on the voice
`or text input,
`[c] storing the
`journal entry in a
`memory worn or
`carried by the
`user,
`[d] creating an
`image using a
`digital camera
`worn or carried by
`the user,
`[e] storing the
`image in the
`memory with the
`journal entry,
`[f] recording the
`date and time
`using a clock
`worn or carried by
`the user,
`[g] uploading the
`journal entry,
`image, date and
`time to a personal
`computer, and
`[h] formatting the
`journal entry to a
`common file
`format.
`
`
`See evidence cited for claim limitation 1[c].
`
`See evidence cited for claim limitation 1[a].
`
`See evidence cited for claim limitation 1[d].
`
`See evidence cited for claim limitation 1[d].
`
`See evidence cited for claim limitation 1[e].
`
`See evidence cited for claim limitation 1[f].
`
`See evidence cited for claim limitation 1[g].
`
`30
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`Patent Owner adidas AG
`Exhibit 2003 - Page 30 of 47
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`VII. Conclusion
`
`29. For the reasons discussed above, it is my opinion that the Under
`
`Armour MapMyFitness mobile applications for iOS and Android embody or
`
`practice at least claims 1, 6, 7, 8, 9, 10, and 20 of the ‘345 patent.
`
`30.
`
`I hereby declare that statements made herein of my own knowledge
`
`are true and that all statements made on information and belief are believed to be
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`true; and further that these statements were made with the knowledge that willful
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`false statements and the like so made are punishable by fine or imprisonment, or
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`both, under Section 1001 of Title 18 of the United States Code.
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`31.
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`I declare under penalty of perjury that the foregoing is true and
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`correct.
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`Executed on November 19, 2015
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`_________________________
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`Mark T. Jones
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`31
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`Patent Owner adidas AG
`Exhibit 2003 - Page 31 of 47
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`Attachment A
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`CV
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`Patent Owner adidas AG
`Exhibit 2003 - Page 32 of 47
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`Mark T. Jones
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`Curriculum Vitae
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`1
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`University Address:
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`302 Whittemore Hall
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`ECE Department
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`Virginia Tech
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`Blacksburg VA 24061-0111
`(540) 231-8849
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`mtj@vt.edu
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`Home Address:
`2906 Wakefield Drive
`Blacksburg VA 24060
`(540) 921-7477 (cell)
`marktjones25@me.com
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`Born March 15, 1965 in Newport News, VA
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`US Citizen
`Residence history: Newport News VA; Redlands CA; Dallas TX;
`Blacksburg VA; Clemson SC; Durham NC; Chicago IL;
`Knoxville TN; Blacksburg VA
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`Professor, Department of Electrical and Computer Engineering, Virginia Tech,
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`8/97-present (since 6/07 at the rank of Full Professor).
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`Chief Technology Advisor, Ocean Tomo, LLC, August 2013 to December 2013.
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`Professor, Department of Computer Science, University of Tennessee, 8/93-7/97
`(at the rank of Assistant Professor).
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`Assistant Computer Scientist, Mathematics and Computer Science Division,
`Argonne National Laboratory, Chicago, IL, 6/90 to 7/93.
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`Ph.D., Duke University, Computer Science, May 1990.
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`B.S., Clemson University, Computer Science, summa cum laude, May 1986.
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`Virginia Bioinformatics Faculty Fellow
`1st prize and Honorable Mention at AOL-CIT Research Day
`Virginia Tech College of Engineering Dean’s List for Teaching
`NSF CAREER Award
`University of Tennessee Science Alliance Award
`Atanasoff Best Paper Award
`Gordon Bell Prize
`Von Neumann Fellowship
`R. F. Poole Scholarship
`National Merit Scholar
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`Blackboard v. Desire2Learn
`United States District Court for the Eastern District of Texas
`Overview: Patent infringement case involving Internet-based educational
`software employing role-based access control
`Testified: Jury trial (infringement and validity), injunction hearing,
`contempt hearing, and deposition (4 times)
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`TechRadium v. Blackboard
`United States District Court for the Eastern District of Virginia
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`GENERAL
`INFORMATION
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`EMPLOYMENT
`EXPERIENCE
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`EDUCATION
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`RECOGNITION
`AND AWARDS
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`EXPERT
`TESTIMONY
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`Patent Owner adidas AG
`Exhibit 2003 - Page 33 of 47
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`Mark T. Jones
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`Curriculum Vitae
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`United States District Court for the Eastern District of Texas
`Overview: Patent infringement case involving network-based emergency
`notification systems
`Testified: Preliminary injunction hearing and deposition
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`Computer Associates v. Digex
`Circuit Court for Prince George’s County Maryland
`Overview: Contract dispute involving enterprise management systems
`Testified: Jury trial and deposition
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`Computer Associates v. Retired Persons Services
`United States District Court for the Eastern District of Virginia
`Overview: Contract dispute involving enterprise management systems
`Testified: Deposition
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`DVSI v. University of Phoenix and Walden University
`United States District Court for the Eastern District of Virginia
`Overview: Patent infringement case involving network-based educational
`software employing digital rights management
`Testified: Deposition (3 days)
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`VirnetX v. Microsoft
`United States District Court for the Eastern District of Texas
`Overview: Patent infringement case involving VPN software in Microsoft
`Windows and Microsoft’s Unified Communications software
`Testified: Jury trial (infringement and validity) and deposition (3 days)
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`TechRadium v. Twitter
`United States District Court for the Southern District of Texas
`Overview: Patent infringement case involving network-based notification
`systems
`Testimony: Deposition
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`Bedrock Computer Tech v. Softlayer et al
`United States District Court for the Eastern District of Texas
`Overview: Patent infringement case involving data structures in the Linux
`operating system’s network stack
`Testimony: Jury trial v. Google (infringement and validity), Jury trial v. Yahoo
`(infringement and validity) and deposition (3 days)
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`CEATS v. Continental Airlines et al
`United States District Court for the Eastern District of Texas
`Overview: Patent infringement case involving Web-based interactive seat maps
`Testimony: Jury trial (infringement and validity) and deposition (2 days)
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`VirnetX v. Cisco et al
`United States District Court for the Eastern District of Texas
`Overview: Patent infringement case involving secure communications, VPNs,
`and Voice-over-IP
`Testimony: Jury trial v. Apple (infringement and validity), Jury trial v. Cisco
`(validity), and deposition (3 days)
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`Summit6 v. Research In Motion et al
`United States District Court for the Northern District of Texas
`Overview: Patent infringement case involving network-based photo uploading
`tools on smartphones and web browsers
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`Patent Owner adidas AG
`Exhibit 2003 - Page 34 of 47
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`Mark T. Jones
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`Curriculum Vitae
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`Testimony: Jury trial v. Samsung (infringement and validity) and deposition (3
`days)
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`Ericsson v. Samsung
`International Trade Commission
`Overview: Patent infringement case involving Java technology and touchscreen
`technology on smartphones
`Testimony: Deposition
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`AT Engine Controls LTD. v. Goodrich Corp and Goodrich Pump & Engine
`Control Systems, Inc.
`United States District Court for the District of Connecticut
`Overview: Trade secret case involving an embedded computing system design
`for helicopter engine control
`Testimony: Deposition
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`SmartFlash LLC. v. Apple, et. al.
`SmartFlash LLC. v. Samsung, et. al.
`United States District Court for the Eastern District of Texas
`Overview: Patent infringement case involving digital rights management and
`content distribution
`Testimony: Jury trial v. Apple (infringement and validity) and deposition (4
`days)
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`Unwired Planet v. Apple
`United States District Court for the Northern District of California
`Overview: Patent infringement case involving several technologies related to
`mobile devices
`Testimony: Deposition (3 days); technology tutorial presentation to the Court
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`Facebook v. Rembrandt Social Media
`Patent Trial and Appeal Board
`Overview: Validity of a patent in the area of a web-based diary system
`Testimony: Deposition
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`Motorola Mobility v. Intellectual Ventures
`Patent Trial and Appeal Board
`Overview: Validity of a patent in the area transmitting and browsing
`preformatted information
`Testimony: Deposition
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`Summit6 v. Apple et al
`United States District Court for the Northern District of Texas
`Overview: Patent infringement case involving network-based photo uploading
`tools on smartphones and web browsers
`Testimony: Deposition
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`EMC v. Pure Storage et al
`United States District Court for the District of Delaware
`Overview: Patent infringement case memory systems
`Testimony: Deposition
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`Patent Owner adidas AG
`Exhibit 2003 - Page 35 of 47
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`Mark T. Jones
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`Curriculum Vitae
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`PUBLICATIONS
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`Journals
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`M. Blake, R. Younes, D. Jacob, T. Martin, and M. Jones, “A Wearable User-
`Independent and Sensor-Modality-Tolerant Activity Classifier,” IEEE
`Computer, to appear.
`Hawkins JB, Jones MT, Plassmann PE, Thorley-Lawson DA, “Chemotaxis in
`Densely Populated Tissue Determines Germinal Center Anatomy and Cell
`Motility: A New Paradigm for the Development of Complex Tissues,” PLoS
`ONE 6(12): e27650. doi:10.1371/journal.pone.0027650, 2011.
`Jian Liu, T. E. Lockhart, M. Jones, and T. Martin, “Local Dynamic Stability
`Assessment of Motion Impaired Elderly Using Electronic Textile Pants,” IEEE
`Transactions on Automation Science and Engineering, vol. 5, issue 4, pp. 696-
`702, October 2008.
`Madhup Chandra, Mark Jones, and Thomas Martin, “E-Textiles for
`Autonomous Location Awareness,” IEEE Transactions on Mobile Computing,
`vol. 6, issue 4, pp. 367-380, April 2007.
`Zahi Nakad, Mark Jones, Thomas Martin, and Ravi Shenoy, “Using Electronic
`Textiles to Implement an Acoustic Beamforming Array: A Case Study,”
`Pervasive and Mobile Computing Journal, vol. 3, issue 5, pp. 581-606, October
`2007.
`Mark Jones, Zahi Nakad, Paul Plassmann, Yanhua Yi, “The Use of
`Configurable Computing for Computational Kernels in Scientific Simulations,”
`Intern. Journal of Future Generation Computer Systems, 22 (1-2), pp. 67-79
`(2006).
`J.-R. Cheng, M. T. Jones, and P. E. Plassmann, “A Portable Software
`Architecture for Mesh-Independent Particle Tracking Algorithms,” Journal of
`Parallel Algorithms and Applications, 19 (2-3), 145-161, 2004.
`Jae H. Park, Gary Friedman and Mark Jones, “Geographical Feature Sensitive
`Sensor Placement,” Journal of Parallel and Distributed Computing, volume 64,
`2004, pp. 815-825.
`D. Marculescu, R. Marculescu, N. Zamora, P. Stanley-Marbell, P. K. Khosla, S.
`Park, S. Jayaraman, S. Jung, C. Lauterbach, W. Weber, T. Kirstein, D. Cottet, J.
`Grzyb, G. Tröster, M. Jones, T. Martin, Z. Nakad, “Electronic Textiles: A
`Platform for Pervasive Computing,” Proceedings of the IEEE, volume 91,
`number 12, December 2003, pp. 1995-2018.
`Kiran Puttegowda, David I. Lehn, Jae H. Park, P. Athanas and Mark Jones,
`“Context Switching in a Run-Time Reconfigurable System,” Journal of
`Supercomputing, Kluwer Academic Press, June 2003, pp 239-257.
`Mark Jones, Shashank Mehrotra, and Jae Hong Park, “Tasking Distributed
`Sensor