UNITED STATES PATENT AND TRADEMARK OFFICE
`
`________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________________
`
`LUTRON ELECTRONICS CO., INC.
`
`Petitioner
`
`v.
`
`GEIGTECH EAST BAY LLC
`
`Patent Owner
`
`_______________________
`
`U.S. Patent No. 10,294,717
`
`DECLARATION OF JAMES GEIGER IN SUPPORT OF
`0$3’.3 /5.’192 01’,*-*.$16 1’20/.2’
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`GeigTech East Bay LLC Ex. 200!
`U.S. Patent No. 10,294,717
`
`
`
`________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________________
`
`LUTRON ELECTRONICS CO., INC.
`
`Petitioner
`
`v.
`
`GEIGTECH EAST BAY LLC
`
`Patent Owner
`
`_______________________
`
`U.S. Patent No. 10,294,717
`
`DECLARATION OF JAMES GEIGER IN SUPPORT OF
`0$3’.3 /5.’192 01’,*-*.$16 1’20/.2’
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`GeigTech East Bay LLC Ex. 200!
`U.S. Patent No. 10,294,717
`
`
`
`Case IPR2020-00957, -00958
`Patent 10,294,717
`
`My name is James Geiger, and I declare as follows:
`
`1.
`
`I am the founder and president of GeigTech East Bay LLC, doing business as
`
`J. Geiger Shading.
`
`2.
`
`= NZ ‘UR _\YR V[bR[‘\^ \S H)F) DN‘R[‘ BaZOR^ +*’,3.’1+1 R[‘V‘YRQ gFUNQR
`
`6^NPXR‘ cV‘U 7\[PRNYRQ JV^V[T)h
`
`3.
`
`GUR i1+1 ]N‘R[‘ V_ ]N^‘ \S N YN^TR^ ]\^‘S\YV\ \S ]N‘R[‘_ ^elated to exposed
`
`window shade systems and related hardware.
`
`4.
`
`I graduated college in 1998 with a B.S. in Business Administration from The
`
`College of Charleston.
`
`5.
`
`I have over 20 years of experience in home electronic systems and technology,
`
`including designing, manufacturing, and installing window shade systems.
`
`6.
`
`I started my own AV integration company in 2003 (HeAVi LLC). AV
`
`integration involves the installation and coordination of various types of home
`
`electronic systems and technology, such as home theater, audio systems, lighting
`
`systems, and window shades. I first began installing window shades as an integrator
`
`around 1999.
`
`7.
`
`In 2007, HeAVi was awarded Best Hidden Installation by the Custom
`
`Electronic Design & Installation Association (CEDIA) for a hidden television design
`
`and installation that I was responsible for.
`
`1
`
`
`
`Case IPR2020-00957, -00958
`Patent 10,294,717
`
`8.
`
`Traditionally, the shade assemblies themselves were a design afterthought.
`
`That is because V‘ cN_ _‘N[QN^Q ‘\ P\[PRNY Z\a[‘V[T UN^QcN^R cV‘U N gPRVYV[T
`
`]\PXR‘’h gbNYN[PR’h \^ gSN_PVN)h 5^\a[Q ,*++’ = QRbV_RQ N [Rc _\Ya‘V\[ S\^
`
`concealing screws, wires, and other hardware. My concept involved exposed
`
`window roller shades without any visible screws, wires, or other unsightly hardware.
`
`GUV_ P\[PR]‘ c\aYQ aY‘VZN‘RYe ORP\ZR ‘UR g> ;RVTR^ FUNQV[T Fe_‘RZh and is
`
`RZO\QVRQ V[ ‘UR i1+1 ]N‘R[‘)
`
`9.
`
`I have reviewed the Petitions in IPR2020-00957 and IPR"!"!-00958.
`
`10.
`
`This declaration focuses on a few technical aspects of how the Petition alleges
`
`7\Y_\[i_ :VTa^R + Sa[P‘V\[_ V[ IPR2020-00957, and IPR"!"!-00958. I reserve the right
`
`to provide additional opinions on either post-grant review petition later, if necessary.
`
`11. <R^R V_ 7\Y_\[i_ :VTa^R + N_ V‘ N]]RN^_ V[ ‘UR ^RSR^R[PR cV‘U Ze [\‘R_ N[Q
`
`cV‘U\a‘ DR‘V‘V\[R^i_ N[[\‘N‘V\[_) EX1005, FIG. 1.
`
`2
`
`
`
`Case IPR2020-00957, -00958
`Patent 10,294,717
`
`The wire is outside the
`
`bracket. There is a clear
`
`gap between the wire
`
`and the bracket.
`
`Drill bits cannot drill a
`
`sweeping turn like this.
`
`12.
`
`Petitioner alleges the wires 130 pass inside the bracket, make a sweeping turn,
`
`and then enter the frame 120. See, e.g., IPR2020-00957 Petition at 34.
`
`13.
`
`This cannot be true, and a POSITA with actual experience designing or
`
`installing window shade assemblies would immediately recognize the wires run
`
`outside the bracket. First, given my experience in the industry designing,
`
`manufacturing, and installing shade assemblies, the wires do not, and cannot, pass
`
`through the bracket as Petitioner alleges. The bracket does not have enough depth
`
`(from left to right above) for there to be such a passage. The passage would need to
`
`3
`
`
`
`Case IPR2020-00957, -00958
`Patent 10,294,717
`
`be larger than the wire (which the figure does not show), and there is no room to
`
`Q^VYY _aPU N ]N__NTR V[ ‘UR O^NPXR‘ \S 7\Y_\[i_ Figure 1. I have drilled many such
`
`passages and worked with others to do the same. It simply cannot be done. The
`
`bracket would break or crack if you tried to drill such a passage.
`
`14. And second, it is not possible to drill a passage with the sweeping turn the
`
`wire and the passage allegedly makes in the illustration above. There is no such drill
`
`or drill bit that would allow someone to drill a path as Petitioner alleges. So even if
`
`V‘ cN_ ]\__VOYR ‘\ Q^VYY _\ZR _\^‘ \S ]N__NTR V[ ‘UR O^NPXR‘ \S 7\Y_\[i_ :VTa^R + %V‘
`
`V_[i‘&’ ‘UR^R V_ [\ cNe TVbR[ RbR[ Pa^^R[‘ ‘RPU[\Y\Te’ YR‘ NY\[R ‘RPU[\Y\Te N‘ ‘UR
`
`‘VZR \S ‘UR i1+1 ]N‘R[‘’ ‘\ Q^VYl a passage that makes such a sweeping turn.
`
`DR‘V‘V\[R^i_ NYYRTRQ ]N__NTR PN[[\‘ RdV_‘ N_ V‘ c\aYQ OR VZ]\__VOYR ‘\ Q^VYY _aPU N
`
`passage.
`
`15.
`
`Third, there is no basis from a design perspective that would run one wire
`
`through the bracket and one wire outside the bracket as NYYRTRQYe _U\c[ V[ 7\Y_\[i_
`
`Figure 1. There would be no benefit to run less than all the wires through the bracket
`
`because wire would still be exposed, defeating the whole purpose of running any
`
`wire through the bracket in the first place. So a designer would not go through the
`
`engineering effort and expense involved to drill a passage for less than all the wire.
`
`Someone designing a shade system would either run both wires or none of the wires
`
`through the bracket. Because the wire on the right is clearly not passing through the
`
`4
`
`
`
`Case IPR2020-00957, -00958
`Patent 10,294,717
`
`bracket, there is no reason to assume the first wire is. Instead, both wires are outside
`
`the bracket.
`
`16. Not only is it technically impossible for both wires to extend through a
`
`]N__NTR V[ ‘UR O^NPXR‘ \S 7\Y_\[i_ :VTa^R +’ Oa‘ ‘UN‘ c\aYQ OR V[P\[_V_‘R[‘ cV‘U ‘UR
`
`drawing in general and the way the industry was operating before I invented my
`
`exposed shade systeZ) 5_ V_ _U\c[ V[ 7\Y_\[i_ :VTa^R +’ ‘UR _P^Rc N‘‘NPUV[T ‘UR
`
`bracket to the wall or other surface is exposed. In addition to the wiring, this is
`
`another indication that this bracket was not mean to be exposed. Instead, it would be
`
`hidden behind N gPRVYV[T ]\PXR‘’h gbNYN[PR’h \^ gSN_PVN)h For example, the following
`
`V_ S^\Z N @a‘^\[ ZN[aNY N[Q V_ P\[_V_‘R[‘ cV‘U ‘UR QV_PY\_a^R V[ 7\Y_\[i_ :VTa^R +)
`
`EX. 2003 at 10.
`
`5
`
`
`
`Case IPR2020-00957, -00958
`Patent 10,294,717
`
`As you can see, the wires do not run through the bracket. And the screws are exposed
`
`just like Colson, which is an indication the bracket was intended to be hidden behind
`
`another structure.
`
`17.
`
`:V[NYYe’ ‘UR^R V_ [\‘UV[T NO\a‘ 7\Y_\[i_ :VTa^R + ‘\ _aTTR_‘ ‘UR cV^R ]N__R_
`
`through the bracket. The wire is not shaded, cross-hatched, or otherwise changed to
`
`V[QVPN‘R ‘UN‘ V‘ V_ UVQQR[ cV‘UV[ ‘UR O^NPXR‘) GUV_ V_ V[ _‘N^X P\[‘^N_‘ ‘\ ‘UR i1+1 ]N‘R[‘
`
`as shown below and technical drawings generally.
`
`18.
`
`=[ ‘UR R[Q’ DR‘V‘V\[R^ V_ \[Ye NOYR ‘\ ZNXR V‘_ N^TaZR[‘ ORPNa_R 7\Y_\[i_
`
`Figure 1 is a two-dimensional drawing that obscures depth. If shown in three-
`
`QVZR[_V\[_’ 7\Y_\[i_ :VTa^R + c\aYQ Y\\X YVXR ‘UR @a‘^\[ VZNTR NO\bR) =‘ PR^‘NV[Ye
`
`c\aYQ [\‘ Y\\X YVXR ‘UR VZNTR S^\Z ‘UR i1+1 ]N‘R[‘ _U\c[ ORY\c’ cUR^R ‘UR^R V_ N
`
`clearly marked passage for the wire to pass through. EX 1001, Fig. 21.
`
`19.
`
`:\^ N‘ YRN_‘ ‘UR_R ^RN_\[_’ ‘UR cV^R_ V[ 7\Y_\[i_ :VTa^R + Za_‘ ]N__ \a‘_VQR ‘UR
`
`O^NPXR‘ N[Q DR‘V‘V\[R^i_ g]N__NTRh PN[[\‘ RdV_‘ N_ ]N^‘ \S 7\Y_\[i_ :VTa^R +)
`
`6
`
`
`
`I declare that the above is true and correct to the best of my knowledge. I make this
`
`Case IPR2020-00957, -00958
`Patent 10,294,717
`
`declaration under the penalty of perjury.
`
`Executed on June "#, 2020.
`
`_________________________________________
`James Geiger
`
`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
