Date Filed: Sep 6, 2017
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`________________
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`ULTRATEC, INC.
`Petitioner
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`v.
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`SORENSON IP HOLDINGS, LLC
`Patent Owner
`________________
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`Case IPR2017-01394
`________________
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`Patent No. 9,336,689
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`DECLARATION OF BENEDICT J. OCCHIOGROSSO IN SUPPORT OF
`PATENT OWNER’S PRELIMINARY RESPONSE
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`Sorenson IP Holdings Exhibit 2001
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`________________
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`ULTRATEC, INC.
`Petitioner
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`v.
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`SORENSON IP HOLDINGS, LLC
`Patent Owner
`________________
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`Case IPR2017-01394
`________________
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`Patent No. 9,336,689
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`DECLARATION OF BENEDICT J. OCCHIOGROSSO IN SUPPORT OF
`PATENT OWNER’S PRELIMINARY RESPONSE
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`Declaration of Benedict J. Occhiogrosso
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`I, Benedict J. Occhiogrosso, declare as follows:
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`1.
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`I make this declaration based upon my own personal knowledge and,
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`if called upon to testify, would testify competently to the matters contained herein.
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`2.
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`I have been asked to provide technical assistance in the above-
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`captioned inter partes review (“IPR”) proceeding (Case IPR2017-01394).
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`3.
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`This declaration is a statement of my opinions on issues related to the
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`patentability of claims 1-12 and 19 of U.S. Patent No. 9,336,689 (the “’689
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`Patent”) (Ex. 1003).
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`I.
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`Background and Qualifications
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`4. My qualifications are stated more fully in my curriculum vitae. Ex.
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`2002. Here, I provide a brief summary of my qualifications:
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`5.
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`I hold a Bachelor of Science Degree in Electrical Engineering as well
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`as a Master of Science Degree in Electrical Engineering, both from the Polytechnic
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`Institute of Brooklyn.
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`6.
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`I have authored or co-authored nearly three dozen articles in peer-
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`reviewed journals, conference proceedings, texts, industry trade publications, and
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`monographs. These publications span a range of topics including: Integrated
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`Voice–Data Communications/Switching, Integrated Packet-Circuit Switching,
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`Voice Digitization, Packet Voice, Indoor Wireless distribution, Disaster Recovery
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`and Business Continuity, Data Center Engineering, Switching Processor
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`Architecture, Telephone and Voice Mail Systems, PBX & LAN switching
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`premises-based systems and related technologies and Internet of Things (IoT).
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`7.
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`I have more than 40 years of telecommunications and information
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`technology experience.
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`I am
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`the co-founder and President of DVI
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`Communications Inc., a telecommunications and information technology and
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`business consulting firm. Since the establishment of DVI in 1979, I have planned,
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`designed, implemented, and managed large scale projects involving wired and
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`wireless communications systems, which included transmission of voice and data.
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`Prior to founding DVI and for several years thereafter, I held a Department of
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`Defense security clearance and worked on several classified programs within the
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`defense industry, where I supported the development of several pioneering
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`technologies that have served as the prototypes for many telecommunications and
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`IT systems later utilized in commercial practice.
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`8.
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`I have served in numerous leadership positions including Project and
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`Program Manager for both research & development and consulting projects for
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`various organizations including: U.S. Department of Defense’s Defense Advanced
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`Research Projects Agency (DARPA); the Defense Communications Agency;
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`Xerox; United Technologies - Norden Systems; AT&T; Citicorp; Con-Edison and
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`various financial services, healthcare, utility and educational institutions. I also
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`headed an Engineering team to develop a voice mail product, which was
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`successfully integrated and commercially produced with an off-the-shelf PBX
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`manufacturer’s product offerings.
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`9.
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`I have extensive expertise in voice-data video switching, transmission
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`systems deployed in networks, including both circuit switching and packet
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`switching using wireline and wireless distribution methods (including Land Mobile
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`radio, Satellite, microwave, cellular and Wi-Fi). In addition, I have developed
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`various applications systems including voicemail, e-mail, unified messaging, and
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`audio/video recording for a variety of facility types including call-contact centers,
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`data centers, trading floors, and mission-critical communications centers. I have
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`detailed knowledge of Internet Protocol (IP) technology in general and also Voice
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`over Internet Protocol (VoIP). I have extensive expertise in voice digitization,
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`buffering, relay and delay techniques, as well as digital signal processing of voice
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`signals. At present, my primary responsibilities encompass strategic planning and
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`systems design of client IT Infrastructures and program management for major
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`projects undertaken by DVI.
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`10.
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`I have also developed
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`technical expertise with
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`regard
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`to
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`telecommunication applications utilizing speech recognition, including call center
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`and interactive voice response applications. I have supported numerous enterprise
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`and institutional clients in the design of their call centers. My experience in this
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`field includes the use of both speaker-independent and speaker-dependent speech
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`recognition algorithms
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`in different applications utilizing
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`isolated speech
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`recognition and continuous speech recognition.
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`11.
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`I have also worked on behalf of the Metropolitan Transportation
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`Authority (MTA) on relay services and assistive technologies. For example, I
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`worked on voice processing for captioning of live meeting proceedings, which are
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`then made available for the deaf and hard of hearing. I have also worked on
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`captioning or transcription of previously recorded information for compliance and
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`record-keeping purposes. Additionally, I have designed a telecommunication relay
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`service for multilingual translation for the United Nations, and have also deployed
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`audio conferencing systems with transcription services for various member firms
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`in the financial services community supporting multiple applications. (e.g.,
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`investor conference, morning call, and alert purposes).
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`12. As mentioned above, on behalf of the United Nations, I designed a
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`telecommunications relay service for multilingual translation. The project
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`included design of a system that allowed the audio from a representative to be
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`routed to multiple translators who could repeat what was being said in other
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`languages. The translated speech channels could then be transmitted to and
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`accessed by individuals in real-time who needed language assistance to understand
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`the speaker. Non–real time transcriptions of the audio were subsequently
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`generated into proceedings in the UN’s official languages.
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`13. Also, as mentioned above, on behalf of the MTA, I implemented a
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`system for captioning live meetings’ proceedings for the deaf and hard of hearing
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`in compliance with the Americans with Disabilities Act (ADA). The project
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`included logistics, audio routing, voice processing, video display and captioning to
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`generate a transcription of a speaker’s voice at a public meeting, and display of the
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`resulting transcription on television monitors in the boardroom as well as over
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`institutional broadcast channels and Internet feeds. In–line corrections would be
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`generated and displayed by the transcriptionist during the proceedings.
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`14. Furthermore, I have over 40 years of experience working with and
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`developing
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`the constituent
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`technologies
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`to
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`the ’689 Patent’s
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`invention:
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`telecommunication services and associated devices, speech recognition technology,
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`telephone call routing and switching (both plain old telephone system (“POTS”)
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`and IP-based telephony), the transmission of voice and data over POTS lines,
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`digital transmission facilities (wired and wireless) or IP-based communications,
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`digitization of voice, relay systems, assistive technologies for the deaf or hard of
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`hearing, and error detection and error correction technologies (from transmission,
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`format and up to content levels) for both real time and non-real time applications.
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`15. For example, with telecommunication services and associated devices
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`for the switching and transmission of voice and data over POTS lines, digital
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`transmission facilities (such as T1, E1 and ISDN PRI and BRI), cellular voice and
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`data and other wireless–based technologies (Line of Sight Microwave, Land
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`Mobile Radio, Satellite) and IP- and VoIP-based communications, I have deployed
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`various types of switching and routing systems (supporting various voice and data
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`communications networks) at major institutional clients such as Citicorp NY, City
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`University of New York, Bear Stearns, Societe Generale, RPCI and Bertelsmann.
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`See Ex. 2002 at 2-5. For these projects, among other things, I had to understand
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`the technical implications, shortcomings, and advantages of deploying different
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`types of switching systems interconnecting voice and data channels, and the
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`manner in which various communication protocols transmit voice and data and
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`would use available bandwidth on different transmission facilities.
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` The
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`transmission facilities included both terrestrial (wired and wireless) as well as
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`satellite-based communications. I also had to understand the compatibility issues
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`with various end-user devices and central network components, both at my client’s
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`locale as well as with the telephone provider/network provider’s switching
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`systems. This encompassed both signaling and switching protocols and interfaces
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`to support compatibility and interoperability.
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`16. With respect to speech recognition technology, I have worked on
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`numerous projects that incorporated speech recognition technology in interactive
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`voice response, dictation, and messaging systems. For example, some of my
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`clients used speech recognition software to convert voice messages into text that
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`can be sent to the recipient via email or a text message (so-called unified
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`messaging systems). For numerous clients, I deployed speech recognition
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`technology into Interactive Voice Response (IVR) systems, improving the user
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`experience as well as (in many instances) expediting the process flow for various
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`real-time inquiry/response and transaction processing applications. For another of
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`my clients, I worked on refining speech recognition protocols to be used in their
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`telecommunications system for directory assistance. Other applications included
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`use of speech recognition for medical transcription as well as record–keeping and
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`compliance purposes.
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` I applied multiple speaker-dependent and speaker-
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`independent products.
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`17. As an example of telephone call routing and switching, I have worked
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`on countless PBX systems (TDM and VoIP) and other business-wide voice and
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`data communications (transmission and switching) technologies. These projects
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`have often included thousands of extensions deployed across multiple physical
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`locations. For these projects, I employed detailed knowledge of the switching and
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`signaling protocols and products available for routing POTS and VoIP calls among
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`the various end-user locations. Additionally, as described above, the implications
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`and interaction of voice and data on bandwidth and call-routing across these
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`multiple locations and numerous extensions was an important consideration.
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`18.
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`I also have extensive experience related to the digitization of voice.
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`For many of my projects related to call routing and switching, calls can come into
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`the systems as digital communications or as analog POTS calls. I have frequently
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`designed and implemented systems that can detect the digital or analog nature of
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`the incoming voice and when analog, utilize an appropriate sample rate and codec
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`to convert the analog voice into digital transmission. Under the same umbrella, I
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`have designed and implemented voice messaging systems that digitally record an
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`analog voice message in order to record or perform other digital processing on the
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`voice signal as described above. For example, for DARPA (Defense Advanced
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`Research Projects Agency), I performed comparisons among various voice
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`digitization algorithms’ performance in the presence of noise and jamming. As
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`another example, for both DARPA and Defense Communications Agency (DCA),
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`I conducted studies comparing circuit, packet and hybrid or
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`integrated
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`(circuit/packet) switching systems of voice and data traffic comparing them
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`relative
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`to
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`cost,
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`expandability,
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`complexity,
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`performance
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`and
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`reliability/survivability. As part of typical reliability considerations, I would
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`deploy manual and automatic recovery processes which provided fault – tolerant
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`and resilient voice and data networking offering graceful degradation in the
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`presence of errors or failures.
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` Techniques employed encompassed error
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`detection/retransmission, vigilant monitoring of correct operation coupled with
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`switchover to backup, bypass and/or rerouting around failed switching and
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`transmission facilities and reconnection.
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`19. As described above, I have experience developing and implementing
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`captioning communication systems and methods and have worked to develop
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`captioning systems, methods, and devices. In addition, I have served as an expert
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`in many legal and administrative proceedings involving text captioning systems
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`involving both inline and traditional captioning.
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`20. As previously outlined, I have supported the deployment of several
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`systems for generating transcriptions of previously recorded and real–time audio.
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`For example, to support a medical dictation application, I deployed a system that
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`used speech recognition to generate transcripts for medical dictation, both manual
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`correction and auto text correction, of medical terms that were used, to correct the
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`medical practitioner’s dictation. For ADA-compliant broadcast of textual
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`messages for the deaf and hard of hearing public at MTA meetings, I designed,
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`selected, and deployed remote text captioning of meetings with remote in–line
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`manual correction of errors in real-time. I also assessed captioning service
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`accuracy and latency with the goal of improving service levels.
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`21. As described above, I also have extensive experience developing and
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`implementing error correction systems and methods and have worked to develop
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`systems and methods for error correction throughout my career. In addition, I have
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`served as an expert in several legal and administrative proceedings involving error
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`correction systems and methods. As described above, for the MTA, I worked on
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`voice processing for captioning of live meeting proceedings, which are then made
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`available for the deaf and hard of hearing. I have also worked on captioning or
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`transcription of previously recorded information for compliance and record-
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`keeping purposes. Additionally, I have designed a telecommunication relay
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`service for multilingual translation for the United Nations, and have also deployed
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`audio conferencing systems with transcription services for various member firms
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`in the financial services community supporting multiple applications. (e.g.,
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`investor conference, morning call, and alert purposes). I have also used speech
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`recognition for medical transcription as well as record–keeping and compliance
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`purposes. Finally, I have served as an expert for CaptionCall in validity and
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`infringement proceedings
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`involving U.S. Patent No. 8,379,801,
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`including
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`IPR2013-00288 in which the Board found that I was “qualified to testify as to
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`matters concerning text caption communications systems, including ‘the electronic
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`generation, correction, and display of transcribed or captioned text that is
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`transmitted to and displayed on an electronic device.’” See Ex. 1011 at 27.
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`II. Legal Understanding
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`22. My opinions are also informed by my understanding of the relevant
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`law. I understand that patentability analysis is conducted on a claim-by-claim
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`basis and that there are several possible reasons that a patent claim may be found
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`unpatentable.
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`A. Anticipation
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`21.
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`I understand that for a patent claim to be anticipated, each and every
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`element of the claim must be disclosed, either expressly or inherently, in a single
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`prior art reference, and that the prior art reference must disclose all of the elements
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`of the claim arranged in the same way as the claim.
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`22.
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`I understand that for the prior art to anticipate a claim when a claim
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`element is missing from the prior art, the prior art reference must make clear that
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`the missing claim element is necessarily present in the prior art reference, and that
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`it would be so recognized by persons of ordinary skill.
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`23.
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`I understand that to anticipate a claim, the prior art reference must
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`enable the person of ordinary skill in the art to make and use the invention as
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`claimed. The reference must put those skilled in the art in possession of the
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`invention as claimed.
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`B. Non-obviousness
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`24.
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`I understand that in order to invalidate a patent claim as obvious, there
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`must be evidence that the claimed invention as a whole would have been obvious
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`to a person of ordinary skill in the relevant art at the time the invention was made.
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`25.
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`I understand that the non-obviousness of a claim over the prior art is a
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`question of law based on the following underlying factual inquiries: (a) the scope
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`and content of the prior art, (b) ascertaining the differences between the claimed
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`invention and the prior art, (c) the level of ordinary skill in the art, and (d)
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`secondary considerations (also called objective indicia) of non-obviousness.
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`26.
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`I understand that an invention may not be obvious when there is a
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`suggestion to explore a new technology or general approach that seemed to be a
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`promising field of experimentation, but where the prior art references gave only
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`general guidance as to the particular form of the claimed invention or how to
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`achieve it.
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`27.
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`I understand that a petitioner must specify where each element of the
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`patent claim is found in the prior art. It is the petitioner’s burden to explain the
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`prior art evidence and not the Board’s responsibility to search through the prior art
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`references to support allegations of anticipation or obviousness. I also understand
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`that the Board resolves vagueness and ambiguity in the petition against the
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`petitioner, and that petitions that fail to specify where each element is found in the
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`prior art or fail to explain the cited evidence may be denied by the Board.
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`28.
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`I understand that it is wrong to use hindsight in evaluating
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`obviousness. For example, it is wrong to use the ’689 Patent as a guide to combine
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`the disclosures in the prior art in the right way so as to achieve the result of the
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`’689 Patent claims. Instead, I understand that there must be a motivation as to why
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`the person of ordinary skill in the art would combine the prior art references to
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`arrive at the claimed invention. It is important to identify why the person of
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`ordinary skill in the art would combine the prior art references, not just that they
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`could be combined. I also understand that the person of ordinary skill in the art
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`would need to have a reasonable expectation of success when combining such
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`references. Specifically, the requirement that a person of ordinary skill in the art
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`have a reasonable expectation of success refers to the likelihood of success when
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`combining references to meet the limitations of the claimed invention. The inquiry
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`is not whether one would expect the prior art references to operate as intended
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`once combined. Instead, one must have a motivation to combine the references
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`and an expectation of achieving what is claimed in the patent-in-suit.
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`C.
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`Person Of Ordinary Skill In The Art
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`29.
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`I understand that the issues related to whether the claims of the ’689
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`Patent are valid in light of the prior art are considered from the perspective of what
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`would have been known or understood by someone of ordinary skill in the art at
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`the time of the invention.
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`30.
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`I understand that the priority date of the ’689 Patent is November 24,
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`2009. Based upon my education and experience, I am very familiar with the level
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`of relevant knowledge about the technology at issue that one of ordinary skill in
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`the art would have possessed as of November 24, 2009.
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`31. As an engineer and consultant who has been heavily involved with the
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`telecommunication industry, I was involved with the design and implementation of
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`various telecommunication systems, speech recognition technologies, and error
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`correction methods used in 2009, and I am personally familiar with the state of the
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`art in the technological field of the ’689 Patent around November 24, 2009.
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`32. The specification of
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`the ’689 Patent describes
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`the relevant
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`technological field as follows: “Embodiments of the disclosure relate generally to
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`text captioning and more specifically to correction of errors within a text caption.”
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`Ex. 1003 at 1:16-18. In IPR2013-00288, the Board considered U.S. Patent No.
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`8,379,801 (the “’801 Patent”) and determined that “the problem addressed by the
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`’801 patent is correcting errors in a transcript displayed in a text caption
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`communication system, regardless of whether the prospective recipient of the
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`corrected transcript is deaf or hearing-impaired.” Ex. 1011 at 9. The ’801 Patent
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`shares a specification with the ’689 Patent (Ex. 1003 at (63)) and addresses the
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`same general concept. For purposes of this proceeding, I have adopted the Board’s
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`definition from IPR2013-00288, with the additional consideration that someone
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`with less technical education but more experience or more technical education but
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`less experience would also have been a person of ordinary skill in the art.
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`III. The ’689 Patent
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`33. The “’689 Patent,” entitled “Methods and Apparatuses Related to Text
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`Caption Error Correction,” was filed on October 31, 2014 and issued on May 10,
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`2016.
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`34. The technology of the ’689 Patent relates “generally to text
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`captioning.” Ex. 1003 at 1:16-17. It includes 20 claims (2 independent claims and
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`18 dependent claims) addressed to systems and methods designed for “correction
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`of errors within a text caption.” Ex. 1003 at 1:17-18.
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`35. The specification of the ’689 Patent describes a communication
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`system “configured to facilitate a communication session between a hearing-
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`impaired user and a hearing-capable user” (Ex. 1003 at 3:40-42) as depicted in
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`Figure 1.
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`Ex. 1003 at Figure 1. Specifically, the system provides for communication
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`“between a hearing-impaired user 140 and a hearing-capable user 160.” Ex. 1003
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`at 3:66-67. When a hearing-impaired user utilizes this system, “hearing-capable
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`user 160 may interact in a conventional manner with communication device 120,”
`
`(Ex. 1003 at 4:2-3) while “[t]he voice of hearing-capable user 160 may be . . .
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`transmitted over network 180 to communication device 120.” Ex. 1003 at 4:5-8.
`
`The hearing-capable user’s voice may then “be transmitted through communication
`
`device 120, over network 170, and to relay service 110.” Ex. 1003 at 4:9-10. The
`
`“[h]earing-impaired user 140 may interact in a conventional manner with
`
`communication device 190 through the use of a voice-based dialogue conveyed
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`Sorenson IP Holdings Exhibit 2001
`Ultratec v. Sorenson IP Holdings IPR2017-01394
`Page 17 of 46
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`over communication device 120.”
`
` Ex. 1003 at 4:14-17.
`
` Additionally,
`
`“communication device 120 may be configured to receive and display a text
`
`transcription of a voice signal sent from relay service 110 via network 170.” Ex.
`
`1003 at 4:18-21.
`
`36. The hearing-impaired communication system depicted in Figure 1 is
`
`further illustrated in the block diagram of Figure 2. See Ex. 1003 at 2:53-54.
`
`
`
`Ex. 1003 at Figure 2. Figure 2 is a “block diagram of communication system 100.”
`
`Ex. 1003 at 4:44-45. It depicts the same relay service 110, hearing-impaired user’s
`
`device 120, and hearing-capable user’s device 190 as depicted in Figure 1. The
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`Ultratec v. Sorenson IP Holdings IPR2017-01394
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`relay service “may include a display device 132 coupled to a processor-based
`
`device 102 comprising a processor 104 and a memory 106 . . . [and] an application
`
`program 108.” Ex. 1003 at 4:45-50. The hearing-impaired user’s device,
`
`“[c]ommunication device 120 may include a display device 134 and a processor-
`
`based device 152 comprising a processor 154 and a memory 156 . . . [and] an
`
`application program 118.” Ex. 1003 at 4:55-59. A person of ordinary skill in the
`
`art would recognize Figure 2 to disclose a single processor, 104, at the relay and a
`
`single processor, 154, at the hearing-impaired user’s device. In “operation of
`
`communication system 100, hearing-capable user 160 [] may convey speech into
`
`communication device 190, which may then transmit an associated voice signal to
`
`communication device 120 over network 180. Communication device 120 may
`
`then transmit the voice signal to relay service 110. Upon receipt of a voice signal,
`
`a human call assistant . . . may listen to the voice signal . . . and “revoice” the
`
`words to a speech recognition computer program . . . [which] may then output a
`
`text transcription . . . [which is] transmitted to communication device 120 via
`
`network 170.” Ex. 1003 at 4:64-5:13.
`
`37. As described above, the relay service 110 receives the voice signal of
`
`the hearing-capable user from the hearing-impaired user’s device 120 and
`
`generates a transcription of those words. Specifically, “upon receipt of a voice
`
`signal, a human call assistant [] positioned within relay service 110, may listen to
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`Sorenson IP Holdings Exhibit 2001
`Ultratec v. Sorenson IP Holdings IPR2017-01394
`Page 19 of 46
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`IPR2017-01394
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`the voice signal transmitted from communication device 120 and “revoice” the
`
`words to a speech recognition computer program [] within relay service 110.” Ex.
`
`1003 at 5:2-7. During revoicing, “the call assistant repeats the words she or he
`
`hears upon receipt of the voice signal” and “[t]he speech recognition program . . .
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`output[s] a text transcription of the call assistant’s spoken words.” Ex. 1003 at 5:8-
`
`11. This “text transcription may be transmitted to” the hearing-impaired user’s
`
`device for use by the hearing-impaired user during a conversation with the hearing-
`
`capable user. Ex. 1003 at 5:12-13.
`
`38. The ’689 Patent describes a “text transcription output” from a speech
`
`recognition program “as a ‘block’ of text.” Ex. 1003 at 5:14-15. Specifically, “a
`
`block of text may comprise one or more words, one or more sentences, one or
`
`more lines of text, or any combination thereof.” Ex. 1003 at 5:16-18. A person of
`
`ordinary skill in the art would understand that a speech recognition program would
`
`typically break the revoiced speech into blocks of limited size. Block size may be
`
`determined by a call assistant’s pauses during revoicing, the size of any provided
`
`transcription buffer, or the system preferences for providing the transcription to the
`
`hearing-impaired user with minimal delay. For example, a person of ordinary skill
`
`in the art could design a system that starts a new block each time the call assistant
`
`pauses for longer than a specified number of seconds. Alternatively, a system
`
`could be designed that starts new blocks at consistent time intervals, for example,
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`Sorenson IP Holdings Exhibit 2001
`Ultratec v. Sorenson IP Holdings IPR2017-01394
`Page 20 of 46
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`every five seconds during revoicing. Relatedly, the size of a block may be limited
`
`by the size of the device’s transcription buffer. Specifically, a block cannot be
`
`larger than the maximum size of the device’s transcription buffer because a
`
`transcription that exceeded that size would result in overflow and the loss of a
`
`portion of the transcription block. Similarly, blocks that are too large may impose
`
`excessive latency on the subsequent transmission of the text. This process will
`
`result in delay while the system waits for the full accumulation of the text
`
`comprising the block. Once the blocks of text have been generated by the speech
`
`recognition program they are “transmitted . . . [and] displayed within a text caption
`
`on display device 134,” at the hearing-impaired user’s device. Ex. 1003 at 5:23-
`
`25. The blocks “may also be displayed within a text caption displayed on display
`
`device 132,” at the relay. Ex. 1003 at 5:41-42.
`
`39. The ’689 Patent explains that the blocks of text may be displayed at
`
`the relay, and “any errors that may exist in the text caption displayed on display
`
`device 134 may also be visible to the” call assistant. Ex. 1003 at 5:45-47.
`
`Traditionally, there were two approaches to correcting errors within a text caption.
`
`A system could provide for correction by either (1) “backspacing an error in a text
`
`caption and displaying corrected text” or (2) “providing a corrected portion (e.g., a
`
`word or a sentence) at the end of a previously provided text caption.” Ex. 1003 at
`
`1:57-61. Each of these options presents challenges for the hearing-impaired user.
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`Sorenson IP Holdings Exhibit 2001
`Ultratec v. Sorenson IP Holdings IPR2017-01394
`Page 21 of 46
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`40. A person of ordinary skill in the art would understand the ’689
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`Patent’s description of backspacing an error to be similar to corrections in a word
`
`processing program. Specifically, backspacing an error would involve selecting a
`
`specific portion of the text caption that includes an error, and using a backspace or
`
`delete key at the call assistant’s station to remove that error. While this method
`
`allows for correction of some types of errors, it also has some shortcomings. For
`
`example, the ’689 Patent explains that “backspacing an error in a text caption and
`
`displaying corrected text may provide a hearing-impaired user with a context for
`
`the correction . .
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