`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`RED.COM, LLC,
`Patent Owner.
`__________________________________
`
`Case No. IPR2019-01065
`Patent No. 9,245,314
`__________________________________
`
`DECLARATION OF DAVID MACINTOSH IN SUPPORT OF
`PATENT OWNER RED.COM, LLC’S PRELIMINARY RESPONSE
`
`
`
`
`RED.COM Ex. 2022
`Apple v. RED.COM
`IPR2019-01065
`
`
`
`Apple v. RED.COM
`Declaration of David Macintosh re POPR - IPR2019-01064 and IPR2019-01065
`
`
`I, David Macintosh, declare and state as follows:
`
`1.
`
`I am Product Development Manager at Clyde Space Ltd. in Glasgow,
`
`Scotland. Clyde Space is a leading worldwide provider of CubeSat and small
`
`satellite spacecraft. I am submitting this declaration in connection with Patent
`
`Owner Preliminary Responses to IPR2019-01064 and IPR2019-01065, filed by
`
`Petitioner Apple Inc., relating to U.S. Patent Nos. 9,230,299 (“the ’299 patent”)
`
`and 9,245,314 (the ’314 patent), respectively, assigned to RED.COM (“RED”).
`
`2.
`
`I began working with RED in 2005 and was involved in the RED
`
`ONE development project from its early stages. My title on the RED ONE project
`
`was Master Blaster, which referred to my primary responsibility of making sure
`
`that project assignments remained on schedule. This included directing Wind
`
`River, the contract engineering company that worked for RED on the RED ONE
`
`project, to ensure they followed our design instructions.
`
`3.
`
`I had personal involvement with the testing of the Boris RED ONE
`
`motion picture camera in March 2007 at RED headquarters in Lake Forest,
`
`California, that took place in preparation for the NAB 2007 show. Members of the
`
`RED Team who were present for that event included Jim Jannard, Graeme
`
`Nattress, Jarred Land, Ted Schilowitz and Stuart English. I recall Graeme Nattress
`
`taking pictures of that event. I have reviewed Exhibits 2002-2008 that I
`
`understand are attached to Mr. Nattress’s declaration that is also being submitted
`
`-1-
`
`
`
`Apple v. RED.COM
`Declaration of David Macintosh re POPR - IPR2019-01064 and IPR2019-01065
`
`with these Patent Owner Preliminary Responses to IPR2019-01064 and IPR2019-
`
`01065. Exhibits 2002-2008, reproduced below, were taken during the March 2007
`
`testing of the Boris RED ONE motion picture camera at RED headquarters. I am
`
`the individual in Exhibits 2003, 2004, 2005 and 2008 with a beard and wearing a
`
`brown shirt and dark blue jeans.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Ex. 2002.
`
`
`
`
`
`
`
`
`
`
`
`-2-
`
`
`
`Apple v. RED.COM
`Declaration of David Macintosh re POPR - IPR2019-01064 and IPR2019-01065
`
`
`
`
`
`
`
`
`
`
`
`
`
` Ex. 2003
`
`
`
`
`
`Ex. 2003.
`
`
`
`
`
`
`
`
`
`
`
`
`
` Ex. 2004
`
`
`
`
`
`Ex. 2004.
`
`
`
`-3-
`
`
`
`Apple v. RED.COM
`Declaration of David Macintosh re POPR - IPR2019-01064 and IPR2019-01065
`
`
`Ex. 2004
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Ex. 2005.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Ex. 2006.
`
`-4-
`
`
`
`Apple v. RED.COM
`Declaration of David Macintosh re POPR - IPR2019-01064 and IPR2019-01065
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Ex. 2007
`
`Ex. 2007.
`
`
`4. With regard to Exhibit 2008, reproduced below with annotations, I
`
`recall sitting for the footage shown in Exhibit 2008. I also recall viewing the
`
`output of that test video and confirming upon visual inspection that the raw
`
`compressed Bayer-pattern video shot by Boris displayed as visually lossless when
`
`decompressed and demosaiced. The program used to display Boris’s test footage
`
`also reported that video taken by Boris achieved 4K resolution at 24 frames per
`
`second, as the enlargement of the information indicated by the yellow annotations
`
`in Exhibit 2008 shows.
`
`
`
`
`
`-5-
`
`
`
`Apple v. RED.COM
`Declaration of David Macintosh re POPR - IPR2019-01064 and IPR2019-01065
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Ex. 2008 (with annotations).
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Ex. 2008 (enlargement).
`
`-6-
`
`
`
`Apple v. RED.COM
`Declaration of David Macintosh re POPR - IPR2019-01064 and IPR2019-01065
`
`5.
`
`In connection with my work on the RED ONE project, I had basic
`
`familiarity with how the RED ONE cameras operated, including the Boris camera
`
`we tested at RED in March 2007. In particular, like all RED ONE cameras, Boris
`
`operated by sending raw Bayer-pattern image sensor data to a processing module,
`
`where pre-compression processing took place. From the processing module, the
`
`raw Bayer-pattern image data was sent to a compression module, and then to the
`
`memory device where compressed raw Bayer-pattern image data files were stored.
`
`These files then could be decompressed and demosaiced for visually lossless
`
`playback.
`
`I declare that all statements made herein of my own knowledge are true and
`
`that all statements made on information and belief are believed to be true, and
`
`further that these statements were made with the knowledge that willful, false
`
`statements and the like so made are punishable by fine or imprisonment, or both,
`
`under Section 1001 of Title 18 of the United States Code.
`
`Executed on August t "f- , 2019 at Inverkeithing, Fife, Scotland.
`
`30883873
`
`David Macintosh
`
`-7-
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
