Exhibit 2019
`Bradium Technologies LLC - patent owner
`Microsoft Corporation - petitioner
`IPR2016-00449
`1
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`19-JRN-E266 l3T=51P FROM:
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`TU:@121571E7383lZl3
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`P:5
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`3.
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`The herein invention was first defined in October 1999, we had a working model in
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`December 1999 and we can establish that we had the first working product on about 24 January
`2000.
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`The screenshot evidence of Exhibit A, relied upon when making the above assertion, is a proof of
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`actual reduction to practice which requires a showing that the apparatus actually existed and
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`worked for its intended purpose (MPEP 7i5.07[l|). The screenshots in Exhibit A further establish
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`possession of the whole invention claimed as it was part of it released product prepared in
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`January 2000 and modified thereafter.-
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`The image of Exhibit 13 illustrates a web based application created at the end of 1999 where by
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`the invention is an integral part of‘ the web solution and shown in upper left window as.
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`“Proprietary Flyover“ — 3D Airfield Imagery”.
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`Exhibit C shows files confirming that the Invention was introduced in Word Document named
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`“GA Centrai.- Executive Summar-y.doc" dated 3/20/2000 and Power Point presentation named
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`GA Ccntral2.ppt dated 5/] 3/2000. ..
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`Exhibit D is one slide fi'om the PowerPoint presentation listed in Exhibit C. Exhibit D presents
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`“The FiyOvcr'”" A 30 Visualization Technology” as an explanation of the invention ofimagc
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`delivery with dynamic viewing frustum of six degrees of freedom optimized for narrowband
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`communication channels as low as 4 kilobytc per second, where by the image is a screenshot
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`captured at the end of 1999 of the application bascd.on the invention.
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`Exhibit ‘:3 illustrate the preprocessor subdivides the image into a quad—tree of compressed images.
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`The images in the Exhibit E are scxeenshotcapttu-ed by running the application based on the
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`patent as of late 1999.
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`1a—JqN—a@@5 a7: 51P r-‘seam:
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`' This process can be alternate]y described as the source image data is preferably pre-processed to
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`obtain a series K1-N ofderivazive images of progressively lower image resolution. The source
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`image data, corresponding to the series image Ko,
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`is also subdivided into a regular array such
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`that each resulting image parcel of thearray has a 64 by 64 pixel resolution where the image data ,
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`has a color.or bit per pixel depth of l6 bits, which represents a data parcel size of8K‘bytes. The
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`resolution of the series Kr-ea of derivative images is preferably related to that of the source image
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`data or predecessor image in the series by.a factor of four. The array subdivision is likewise
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`related by a factor of four such that each image parcel is ofa fixed SK byte size, as is explained
`in the patent application.
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`This is further illustrated in Exhibit F where the images are screenshots from the patent I999.
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`The viewer (client) uses the patent application's method to optimize the sheathing of network
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`image over narmwband communication. The client included a 3D renderer that provided views
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`of the image from arbitrary location with full maneuverability -— Dynamic Viewing Fmstum.
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`We assert that the initial implementation of the invention has been completed in 1999. it was
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`used to provide a perspective 3D view ofimagery and allowed the user to “fly over” the image
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`interactively. All principles and implementation details disclosed in the patent were in use by this
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`program.
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`The technology is illustrated again in the screenshots and presentation in Exhibit Ci taken by the
`actual invention as of late~199-9.
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`These screenshots illustrate the invention, fully functional, as described in our patent applications
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`and as was implemented and presented from late i999.
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`18-JRN-2986 BT:51P FROM:
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`T0:0121§r'12?383E!El
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`Exhibit H is a series ofimages l, 2, 3. and 4 on a timeline where l is the earliest and 4 is the
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`latest. for the same operator controlled image viewpoint frusturn, where the update image parcel
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`is clearly noticeable from image I through 2 and 3 to image 4. The update picture parcel is
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`requested by the client and associated, with a request queue. The issuing of said request is over a
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`limited bandwidth communications channel. Such picture parcel request queue ovcr namowband
`bandwidth communication channel as illustrated in Exhibit G, is shown in the timeline images in
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`Exhibit G. ‘Whereby,-within time {pictures} to 4 in Exhibit I-l),.thc picture parcel request from
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`the controlled image viewpoint is progressively building the picture parcels from 64 by 65/ pixels
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`tiles, until the image reached its full resolution as in image 4 of Exhibit G. This is explaining
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`several claims of our patent, including l, 2, 3, 4, 5, 6, 8, I l, and l2. Other claims that have to do
`with the portable display client system such as, image compression, display resolution. video
`memory ma navigational controls (for example), are illustrated in Exhibits E, 1-‘, and G. And the
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`same Exhibits E, F, G covers the packet dam streaming over communication network as in the
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`related claims. Some ofour claims are internal calculations, such as the prcprocessing of the
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`image and the compression, which can be illustrated only, with no scrccnshot to show them.
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`The statement of fact above establishes that the claimed subject matter has been relied upon and
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`existed prior to Skollreference;
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`4.
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`Our company was originally formed as GACen1'.ral.oom, Inc. change its name to l~‘lyOver
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`Technologies, Inc. in early 2000 and changed it name again to BDVU Inc. relatively recently, so
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`the original materials bear the company names GACentral.com and I"lyOver Technologies.
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`5.
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`In August 2000, we first met with the patent attorney Gerald B- Rosenberg,
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`NewTechLaw, Suite 520, 285 Hamilton Avenue, Palo Alto, California 9430l, to discuss this
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`invention, companion inventions and preparation of patent applications. Over the succeeding
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`months, Mr. Rosenberg prepared the provisional applications, which was filed by his office on 27
`December 2000.
`'
`'
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`12-JRN-E886 B7:S1P FROM:
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`TD:@1E1S71E7383B2
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`P:8
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`6.
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`The evidence submitted is sufficient to establish a reduction to practice 0|-‘the invention
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`in the US or a NA]-‘TA or WTO member counwy prior to the effective date of the Skoll reference.
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`7.
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`We here_by declare that all statemenm made herein 01' our own knowledge are true and
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`that all statements made on inrormmion and belierane believed to be true; and further that these
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`statements were made with the knowledge that willfial false statements and the like so made are
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`punishable by fine or imprisonment, or both, under Section 1001 ofTitle 18 of the United States
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`Code and that such willful false statements may jeopardize the validity of the application or any
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`patent issued thereon.
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`Isaac Levanon
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`Yoni Lavi
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`Dated: December 27, 2005
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`Dated: December 27, 2005
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`1B-JFIN-212186 @7152!” FROM:
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`TO: 61215712738388
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`P: 9
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`BEST AVAILABLE COPY
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`1B-JRN-2936 B7:SEP FROM:
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`Exhibit B
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`Visual wpur-::ch
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`18-JFIN-E886 @7:SE’P FROM:
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`TlJ:01E1571E?383BB
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`P:11
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`Exhibit D
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`“’“""’""
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`The F|yOver "‘
`A 3D Visualization Technology
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`Proprietary 3D ‘
`engine streaming
`high-resolution _
`A image (satellite 0
`aerial) over the
`Internet at about
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`4kIsec. with six
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`degrees of
`freedom
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`Exhibit E
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`1B-JRN-E926 B7: 53P FROM:
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`TD:B121S7127383BB
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`BEST AVAILABLE COPY
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`19-JRN-2886 lZ?:53P FROM:
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`Tl3:B121571E’?383BB
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`P: 14
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`Exhibit F
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`BEST AVAILABLE COPY
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`Tin Ffloveris aprurrkqlmayekleluwg lvcflrnbgflmvmy mcsdhdflan nf3’D
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`Proprietary 3D onglno stnaming high-
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`. photograph) ovor the lnurnet at about dklsec.
`of with six dogmas of froodom
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`Appiiances 8- Cell
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`DELIVERY WITH
`DYNAMIC VIEWING
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`FRUSTUM OPTIMIZED
`FOR NARROWBAND
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`COMMUNICATDN
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`CHANNELS
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`enuplal ta d'lI::luIt3D angina, daeodu and run!-flan flint‘:
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`18-JFIN-8886 B7:54P FROM:
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`Exhibit H
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`lmaie 1
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`13
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`1B-JQN-8886 B7=54F’ FROM:
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`BEST AVAELABLE COPY
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`14
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