`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________
`
`SAMSUNG ELECTRONICS CO., LTD.
`Petitioner
`
`v.
`
`
`BROADPHONE LLC
`Patent Owner
`
`_________________
`
`Patent No. 10,341,811
`_________________
`
`DECLARATION OF DR. KEVIN C. ALMEROTH
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`Page 1 of 243
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`SAMSUNG EX-1002
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`Declaration of Dr. Kevin C. Almeroth
`U.S. Patent No. 10,341,811
`TABLE OF CONTENTS
`
`I.
`INTRODUCTION ........................................................................................... 1
`BACKGROUND AND QUALIFICATIONS ................................................. 2
`II.
`III. MATERIALS REVIEWED ..........................................................................16
`IV. PERSON OF ORDINARY SKILL IN THE ART ........................................21
`V.
`TECHNICAL BACKGROUND ...................................................................22
`A. Mobile Device Location Systems/Methods ........................................23
`B.
`Using
`Radio
`Frequency
`Fingerprints/Signatures
`to
`Detect/Determine Location .................................................................37
`VI. OVERVIEW OF THE ’811 PATENT ..........................................................43
`VII. CLAIM CONSTRUCTION ..........................................................................46
`VIII. OVERVIEW OF THE PRIOR ART .............................................................49
`A.
`Spain-I (Ex-1011) ................................................................................49
`B.
`Nanda (Ex-1006) .................................................................................53
`C.
`Tiwari (Ex-1203) .................................................................................58
`D. Othmer (Ex-1208) ...............................................................................60
`E.
`Blomqvist (Ex-1033)............................................................................63
`F.
`Hunzinger (Ex-1054) ...........................................................................67
`G.
`Bates (Ex-1212) ...................................................................................71
`IX. THE PRIOR ART DISCLOSES OR SUGGESTS ALL RECITED
`FEATURES OF CLAIMS 1, 4, 5, 8, 14-15, 18-19, 22, 24-25, AND 28
`OF THE ’811 PATENT .................................................................................75
`A.
`Spain-I in View of Hunzinger and Nanda Discloses and/or
`Suggests the Features of Claims 1, 8, 14, 15, 22, and 28....................75
`
`i
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`B.
`
`C.
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`Declaration of Dr. Kevin C. Almeroth
`U.S. Patent No. 10,341,811
`1.
`Claim 1 ......................................................................................75
`Claim 8 ....................................................................................169
`2.
`Claim 14 ..................................................................................181
`3.
`Claim 15 ..................................................................................186
`4.
`Claim 22 ..................................................................................193
`5.
`Claim 28 ..................................................................................194
`6.
`Spain-I in View of Hunzinger, Nanda, and Blomqvist Discloses
`and/or Suggests the Features of Claims 4 and 18 .............................194
`1.
`Claim 4 ....................................................................................194
`2.
`Claim 18 ..................................................................................205
`Spain-I in View of Hunzinger, Nanda, and Tiwari Discloses
`and/or Suggests the Features of Claims 5 and 19 .............................206
`1.
`Claim 5 ....................................................................................206
`2.
`Claim 19 ..................................................................................216
`Spain-I in View of Hunzinger, Nanda, and Othmer Discloses
`and/or Suggests the Features of Claim 24 .........................................216
`1.
`Claim 24 ..................................................................................216
`Spain-I in View of Hunzinger, Nanda, and Bates Discloses
`and/or Suggests the Features of Claim 25 .........................................226
`1.
`Claim 25 ..................................................................................226
`CONCLUSION ............................................................................................240
`
`
`D.
`
`E.
`
`X.
`
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`ii
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`Declaration of Dr. Kevin C. Almeroth
`U.S. Patent No. 10,341,811
`
`I, Kevin C. Almeroth, declare as follows:
`
`I.
`
`INTRODUCTION
`I have been retained by Samsung Electronics Co., Ltd. as an
`1.
`
`independent expert consultant in this proceeding before the United States Patent and
`
`Trademark Office against Broadphone LLC regarding U.S. Patent No. 10,341,811
`
`(“the ’811 patent”) (Ex-1001).1 I have been asked to consider whether the prior art
`
`discloses or suggests the features recited in claims 1, 4, 5, 8, 14-15, 18-19, 22, 24-
`
`25, and 28 (“the challenged claims”) of the ’811 patent. My opinions are set forth
`
`below.
`
`2.
`
`I am being compensated at my standard rate for my work in this
`
`proceeding. My compensation is in no way contingent on the nature of my findings,
`
`the presentation of my findings in testimony, or the outcome of this or any other
`
`proceeding. I have no other interest in this proceeding.
`
`
`
`
`
`
`1 Where appropriate, I refer to exhibits that I understand are to be attached to the
`
`petition for Inter Partes Review of the ’811 patent.
`
`1
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`Declaration of Dr. Kevin C. Almeroth
`U.S. Patent No. 10,341,811
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`II. BACKGROUND AND QUALIFICATIONS
`I am currently a Professor Emeritus in the Department of Computer
`3.
`
`Science at the University of California, Santa Barbara (UCSB). While at UCSB, I
`
`held faculty appointments and was a founding member of the Computer Engineering
`
`(CE) Program, Media Arts and Technology (MAT) Program, and the Technology
`
`Management Program (TMP). I also served as the Associate Director of the Center
`
`for Information Technology and Society (CITS) from 1999 to 2012. I have been a
`
`faculty member at UCSB since July 1997.
`
`4.
`
`I hold three degrees from the Georgia Institute of Technology: (1) a
`
`Bachelor of Science degree in Information and Computer Science (with minors in
`
`Economics, Technical Communication, and American Literature) earned in June
`
`1992; (2) a Master of Science degree in Computer Science (with specialization in
`
`Networking and Systems) earned in June 1994; and (3) a Doctor of Philosophy
`
`(Ph.D.) degree in Computer Science (Dissertation Title: Networking and System
`
`Support for the Efficient, Scalable Delivery of Services in Interactive Multimedia
`
`System, minor in Telecommunications Public Policy) earned in June 1997. During
`
`my education, I took a wide variety of courses as demonstrated by my minor. My
`
`undergraduate degree also included a number of courses more typical of a degree in
`
`
`
`2
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`electrical
`
`engineering
`
`Declaration of Dr. Kevin C. Almeroth
`U.S. Patent No. 10,341,811
`signal processing,
`and
`
`logic,
`
`including digital
`
`telecommunications theory.
`
`5.
`
`One of the major concentrations of my research over the past 30+ years
`
`has been the delivery of multimedia content and data between computing devices,
`
`including through various network architectures. In my research, I have studied
`
`large-scale content delivery systems, and the use of servers located in a variety of
`
`geographic locations to provide scalable delivery to hundreds or thousands of users
`
`simultaneously. I have also studied smaller-scale content delivery systems in which
`
`content is exchanged between individual computers and portable devices. My work
`
`has emphasized the exchange of content more efficiently across computer networks,
`
`including the scalable delivery of content to many users, mobile computing, satellite
`
`networking, delivering content to mobile devices, and network support for data
`
`delivery in wireless networks.
`
`6.
`
`In 1992, the initial focus of my research was on the provision of
`
`interactive functions (e.g., VCR-style functions like pause, rewind, and fast-forward)
`
`for near video-on-demand systems in cable systems; in particular, how to aggregate
`
`requests for movies at a cable head-end and then how to satisfy a multitude of
`
`requests using one audio/video stream broadcast
`
`to multiple
`
`receivers
`
`simultaneously. This research has continually evolved and resulted in the
`
`
`
`3
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`Declaration of Dr. Kevin C. Almeroth
`U.S. Patent No. 10,341,811
`development of techniques to scalably deliver on-demand content, including audio,
`
`video, web documents, and other types of data, through the Internet and over other
`
`types of networks, including over cable systems, broadband telephone lines, and
`
`satellite links.
`
`7.
`
`An important component of my research has been investigating the
`
`challenges of communicating multimedia content, including video, between
`
`computers and across networks including the Internet. Although the early Internet
`
`was used mostly for text-based, non-real time applications, the interest in sharing
`
`multimedia content, such as video, quickly developed. Multimedia-based
`
`applications ranged from downloading content to a device to streaming multimedia
`
`content to be instantly used. One of the challenges was that multimedia content is
`
`typically larger than text-only content, but there are also opportunities to use
`
`different delivery techniques since multimedia content is more resilient to errors. I
`
`have worked on a variety of research problems and used a number of systems that
`
`were developed to deliver multimedia content to users. One content-delivery method
`
`I have researched is the one-to-many communication facility called “multicast,” first
`
`deployed as the Multicast Backbone, a virtual overlay network supporting one-to-
`
`many communication. Multicast is one technique that can be used on the Internet to
`
`provide streaming media support for complex applications like video-on-demand,
`
`
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`U.S. Patent No. 10,341,811
`distance learning, distributed collaboration, distributed games, and large-scale
`
`wireless communication. The delivery of media through multicast often involves
`
`using Internet infrastructure, devices and protocols, including protocols for routing
`
`and TCP/IP.
`
`8.
`
`Starting in 1997, I worked on a project to integrate the streaming media
`
`capabilities of the Internet together with the interactivity of the web. I developed a
`
`project called the Interactive Multimedia Jukebox (IMJ). Users would visit a web
`
`page and select content to view. The content would then be scheduled on one of a
`
`number of channels, including delivery to students in Georgia Tech dorms delivered
`
`via the campus cable plant. The content of each channel was delivered using
`
`multicast communication.
`
`9.
`
`In the IMJ, the number of channels varied depending on the capabilities
`
`of the server including the available bandwidth of its connection to the Internet. If
`
`one of the channels was idle, the requesting user would be able to watch their
`
`selection immediately. If all channels were streaming previously selected content,
`
`the user’s selection would be queued on the channel with the shortest wait time. In
`
`the meantime, the user would see what content was currently playing on other
`
`channels, and because of the use of multicast, would be able to join one of the
`
`
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`5
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`U.S. Patent No. 10,341,811
`existing channels and watch the content at the point it was currently being
`
`transmitted.
`
`10. The IMJ service combined the interactivity of the web with the
`
`streaming capabilities of the Internet to create a jukebox-like service. It supported
`
`true Video-on-Demand when capacity allowed, but scaled to any number of users
`
`based on queuing requested programs. As part of the project, we obtained
`
`permission from Turner Broadcasting to transmit cartoons and other short-subject
`
`content. We also connected the IMJ into the Georgia Tech campus cable television
`
`network so that students in their dorms could use the web to request content and then
`
`view that content on one of the campus’s public access channels.
`
`11. More recently, I have also studied issues concerning how users choose
`
`content, especially when considering the price of that content. My research has
`
`examined how dynamic content pricing can be used to control system load. By
`
`raising prices when systems start to become overloaded (i.e., when all available
`
`resources are fully utilized) and reducing prices when system capacity is readily
`
`available, users’ capacity to pay as well as their willingness can be used as factors
`
`in stabilizing the response time of a system. This capability is particularly useful in
`
`systems where content is downloaded or streamed on-demand to users.
`
`
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`U.S. Patent No. 10,341,811
`12. As a parallel research theme, starting in 1997, I began researching
`
`issues related to wireless devices and sensors. In particular, I was interested in
`
`showing how to provide greater communication capability to “lightweight devices,”
`
`i.e., small form-factor, resource-constrained (e.g., CPU, memory, networking, and
`
`power) devices. Starting in 1998, I published several papers on my work to develop
`
`a flexible, lightweight, battery-aware network protocol stack. The lightweight
`
`protocols we envisioned were similar in nature to protocols like Bluetooth, Universal
`
`Plug and Play (UPnP) and Digital Living Network Alliance (DLNA).
`
`13. From this initial work, I have made wireless networking—including ad
`
`hoc, mesh networks and wireless devices—one of the major themes of my research.
`
`My work in wireless networks spans the protocol stack from applications through to
`
`the encoding and exchange of data at the data link and physical layers.
`
`14. At the application layer, even before the large-scale “app stores” were
`
`available, my research looked at building, installing, and using apps for a variety of
`
`purposes, from network monitoring to support for traditional computer-based
`
`applications (e.g., content retrieval) to new applications enabled by ubiquitous,
`
`mobile devices. For example, my research has looked at developing applications for
`
`virally exchanging and tracking “coupons” through “opportunistic contact” among
`
`mobile wireless devices (i.e., communication among devices moving into
`
`
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`U.S. Patent No. 10,341,811
`communication range with each other). In many of the courses I have taught there
`
`is a project component. Through these projects I have supervised numerous efforts
`
`to develop new “apps” for download and use across a variety of mobile platforms.
`
`15. Toward the middle of the protocol stack, my research has also looked
`
`to build wireless infrastructure support to enable communication among a set of
`
`mobile devices unaided by any other kind of network infrastructure. These kinds of
`
`networks are useful either in challenged network environments (e.g., when a natural
`
`disaster has destroyed existing infrastructure) or when suitable support for network
`
`communication never existed. The deployment of such networks (or even the use
`
`of traditional network support) are critical to support services like disaster relief,
`
`catastrophic event coordination, and emergency services deployment.
`
`16. Yet another theme is monitoring wireless networks, in particular
`
`different variants of IEEE 802.11 compliant networks, to (1) understand the
`
`operation of the various protocols used in real-world deployments, (2) use these
`
`measurements to characterize use of the networks and identify protocol limitations
`
`and weaknesses, and (3) propose and evaluate solutions to these problems. I have
`
`successfully used monitoring techniques to study wireless data link layer protocol
`
`operation and to improve performance by enhancing the operation of such protocols.
`
`
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`U.S. Patent No. 10,341,811
`For wireless protocols, this research includes functions like network acquisition and
`
`channel bonding.
`
`17. One theme in my wireless network research has been cross-layer
`
`solutions and innovations. As mentioned above, with greater wireless device use
`
`and network support, we envisioned new application paradigms and services, for
`
`example, when mobile devices come into contact with each other. Instead of relying
`
`on existing infrastructure to relay communication, the devices are able to discover
`
`each other and communicate directly. Other examples include discovering and using
`
`location information to enhance users’ experiences. Network support and novel
`
`applications span use a variety of network architectures supporting users on foot, in
`
`vehicles, and across varying terrains and environments. Finally, we studied how
`
`communication efficiency can be supported through intelligent handoffs as well as
`
`location and movement prediction.
`
`18. Protecting networks, including their operation and content, has been an
`
`underlying theme of my research almost since the beginning of my research career.
`
`Starting in 2000, I have been involved in several projects that specifically address
`
`security, network protection, and firewalls. After significant background work, a
`
`team on which I was a member successfully submitted a $4.3M grant proposal to the
`
`Army Research Office (ARO) at the Department of Defense to propose and develop
`
`
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`U.S. Patent No. 10,341,811
`a high-speed intrusion detection system. Key aspects of the system included
`
`associating streams of packets and analyzing them for viruses and other malware.
`
`Once the grant was awarded, we spent several years developing and meeting the
`
`milestones of the project. A number of my students worked on related projects and
`
`published papers on topics ranging from intrusion detection to developing advanced
`
`techniques to be incorporated into firewalls. I have also used firewalls, including
`
`their associated malware detection features, in developing techniques for the
`
`classroom to ensure that students are not distracted by online content.
`
`19. My recent work ties some of the various threads of my past research
`
`together. I have investigated content delivery in online social networks and
`
`proposed reputation management systems in large-scale social networks and
`
`marketplaces. On the content delivery side, I have looked at issues of caching and
`
`cache placement, especially when content being shared and the cache has
`
`geographical relevance. We were able to show that effective caching strategies can
`
`greatly improve performance and reduce deployment costs. Our work on reputation
`
`systems showed that reputations have economic value, and as such, creates a
`
`motivation to manipulate reputations. In response, we developed a variety of
`
`solutions to protect the integrity of reputations in online social networks. The
`
`techniques we developed for content delivery and reputation management were
`
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`U.S. Patent No. 10,341,811
`particularly relevant in peer-to-peer communication and recommendations for
`
`downloadable “apps.”
`
`20. As an important component of my research program, I have been
`
`involved in the development of academic research into available technology in the
`
`market place. One aspect of this work is my involvement in the Internet Engineering
`
`Task Force (IETF). The IETF is a large and open international community of
`
`network designers, operators, vendors, and researchers concerned with the evolution
`
`of the Internet architecture and the smooth operation of the Internet. I have been
`
`involved in various IETF groups including many content delivery-related working
`
`groups like the Audio Video Transport (AVT) group, the MBone Deployment
`
`(MBONED) group, Source Specific Multicast (SSM) group, the Inter-Domain
`
`Multicast Routing (IDMR) group, the Reliable Multicast Transport (RMT) group,
`
`the Protocol Independent Multicast (PIM) group, etc. I have also served as a member
`
`of the Multicast Directorate (MADDOGS), which oversaw the standardization of all
`
`things related to multicast in the IETF. Finally, I was the Chair of the Internet2
`
`Multicast Working Group for seven years.
`
`21. My involvement in the research community extends to leadership
`
`positions for several academic journals and conferences. I am the co-chair of the
`
`Steering Committee for the ACM Network and System Support for Digital Audio
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`U.S. Patent No. 10,341,811
`and Video (NOSSDAV) workshop and on the Steering Committees for the
`
`International Conference on Network Protocols (ICNP), ACM Sigcomm Workshop
`
`on Challenged Networks (CHANTS), and IEEE Global Internet (GI) Symposium. I
`
`have served or am serving on the Editorial Boards of IEEE/ACM Transactions on
`
`Networking, IEEE Transactions on Mobile Computing, IEEE Network, ACM
`
`Computers in Entertainment, AACE Journal of Interactive Learning Research
`
`(JILR), and ACM Computer Communications Review. I have co-chaired a number
`
`of conferences and workshops including the IEEE International Conference on
`
`Network Protocols (ICNP), IEEE Conference on Sensor, Mesh and Ad Hoc
`
`Communications and Networks
`
`(SECON),
`
`International Conference on
`
`Communication Systems and Networks (COMSNETS), IFIP/IEEE International
`
`Conference on Management of Multimedia Networks and Services (MMNS), the
`
`International Workshop On Wireless Network Measurement (WiNMee), ACM
`
`Sigcomm Workshop on Challenged Networks (CHANTS), the Network Group
`
`Communication (NGC) workshop, and the Global Internet Symposium, and I have
`
`served on the program committees for numerous conferences.
`
`22. Furthermore, in the courses I taught at UCSB, a significant portion of
`
`my curriculum covered aspects of the Internet and network communication
`
`including the physical and data link layers of the Open System Interconnect (OSI)
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`U.S. Patent No. 10,341,811
`protocol stack, and standardized protocols for communicating across a variety of
`
`physical media such as cable systems, telephone lines, wireless, and high-speed
`
`Local Area Networks (LANs). The courses I have taught also cover most major
`
`topics in Internet communication, including data communication, multimedia
`
`encoding, and mobile application design. My research and courses have covered a
`
`range of physical infrastructures for delivering content over networks, including
`
`cable, Integrated Services Digital Network (ISDN), Ethernet, Asynchronous
`
`Transfer Mode (ATM), fiber, and Digital Subscriber Line (DSL). For a complete list
`
`of courses I have taught, see my curriculum vitae (CV).
`
`23.
`
`In addition, I co-founded a technology company called Santa Barbara
`
`Labs that was working under a sub-contract from the U.S. Air Force to develop very
`
`accurate emulation systems for the military’s next generation internetwork. Santa
`
`Barbara Labs’ focus was in developing an emulation platform to test the
`
`performance characteristics of the network architecture in the variety of
`
`environments in which it was expected to operate, and, in particular, for network
`
`services including IPv6, multicast, Quality of Service (QoS), satellite-based
`
`communication, and security. Applications for this emulation program included
`
`communication of a variety of multimedia-based services, including video
`
`conferencing and video-on-demand.
`
`13
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`U.S. Patent No. 10,341,811
`In addition to having co-founded a technology company myself, I have
`
`24.
`
`worked for, consulted with, and collaborated with companies for nearly 30 years.
`
`These companies range from well-established companies to start-ups and include
`
`IBM, Hitachi Telecom, Turner Broadcasting System (TBS), Bell South, Digital
`
`Fountain, RealNetworks, Intel Research, Cisco Systems, and Lockheed Martin.
`
`25. Through my graduate education, leadership with CITS, involvement in
`
`TMP, role in the development of the Internet2 infrastructure, and consulting with
`
`ISPs, I have gained a strong understanding in the role of the Internet in our society
`
`and the challenges of deploying large-scale production networking infrastructure.
`
`CITS, since its inception, has looked at the role of the Internet in society, including
`
`how the evolution of technology have created communication opportunities and
`
`challenges, including, for example through disruptive technologies like P2P. TMP
`
`looks to focus on non-purely technical issues, including, for example, state-of-the-
`
`art business methods, strategies for successful technology commercialization, new
`
`venture creation, and best practices for fostering innovation. Through my industry
`
`collaborations and Internet2 work, I have developed significant experience in the
`
`challenges of deploying, monitoring, managing, and scaling communication
`
`infrastructure to support evolving Internet services like streaming media,
`
`conferencing, content exchange, social networking, and e-commerce.
`
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`Declaration of Dr. Kevin C. Almeroth
`U.S. Patent No. 10,341,811
`I am a Member of the Association of Computing Machinery (ACM)
`
`26.
`
`and a Fellow of the Institute of Electrical and Electronics Engineers (IEEE).
`
`27. Additional details about my employment history, fields of expertise,
`
`courses taught, and publications are further included in my CV (Ex-1003).
`
`28.
`
`I am not an attorney and offer no legal opinions, but in the course of
`
`my work, I have had experience studying and analyzing patents and patent claims
`
`from the perspective of a person skilled in the art.
`
`
`
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`Declaration of Dr. Kevin C. Almeroth
`U.S. Patent No. 10,341,811
`
`III. MATERIALS REVIEWED
`29. The opinions in this declaration are based on the documents I reviewed,
`
`my knowledge and experience, and professional judgment. In forming my opinions
`
`expressed in this declaration, I have reviewed the following materials:
`
`Ex-1001 U.S. Patent No. 10,341,811 (“Shkedi”)
`Ex-1004 Prosecution History of U.S. Patent No. 10,341,811
`Ex-1005 U.S. Patent No. 6,269,246 (“Rao-I”)
`Ex-1006 U.S. Patent No. 8,477,731(“Nanda”)
`Ex-1007 U.S. Patent Application Publication 2001/0022558 (“Karr”)
`
`Ex-1008 U.S. Patent No. 7,116,987 (“Spain-II”)
`Ex-1009 U.S. Patent No. 6,782,265 (“Perez-Breva-II”)
`
`Ex-1010 U.S. Patent No. 6,393,294 (“Perez-Breva-I”)
`Ex-1011 U.S. Patent No. 6,944,465 (“Spain-I”)
`Ex-1012 T Suzuki, et al., The Moving-body Position Detection Method;
`JP Patent Application (shown as 63-195800), August 1988
`Ex-1013 M. Hellebrandt, et al., Estimating Position and Velocity of
`Mobiles in a Cellular Radio Network, IEEE Trans. On Vehicular
`Technology, Vol. 46, No. 1, pp. 65-71
`I Gaspard, et al., Position Assignment in Digital Cellular Mobile
`Radio Networks (e.g., GSM) Derived from Measurements at the
`Protocol Interface, IEEE Journal, pp. 592-596, March 1997
`J. Jimenez et al., Mobile Location Using Coverage Information:
`Theoretical Analysis and Results, COST 259 TD (98), April
`1999
`
`Ex-1015
`
`Ex-1014
`
`16
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`Page 19 of 243
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`

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`Declaration of Dr. Kevin C. Almeroth
`U.S. Patent No. 10,341,811
`Ex-1016 U.S. Patent No. 7,848,765 (“Phillips”)
`Ex-1017 U.S. Patent No. 7,213,057 (“Trethewey”)
`Ex-1018 U.S. Patent Application Publication No. 2004/0203768
`(“Ylitalo”)
`Ex-1019 U.S. Patent Application Publication No. 2009/0075651
`(“MacNaughton”)
`Ex-1020 U.S. Patent Application Publication No. 2005/0185618
`(“Friday”)
`Ex-1026 U.S. Patent No. 6,167,274 (“Smith-I”)
`Ex-1027 U.S. Patent Application Publication No. 2004/0152471
`(“MacDonald”)
`Ex-1028 U.S. Patent No. 7,346,359 (“Damarla”)
`Ex-1029 U.S. Patent No. 6,052,598 (“Rudrapatna”)
`Ex-1030 U.S. Patent Application Publication No. 2004/0236850
`(“Krumm”)
`Ex-1031 Prosecution History of U.S. Patent No. 8,594,698
`Ex-1032 U.S. Patent No. 7,397,424 (“Houri”)
`Ex-1033 U.S. Patent No. 7,305,244 (“Blomqvist”)
`Ex-1045 U.S. Patent No. 7,286,835 (“Dietrich”)
`
`Ex-1047 U.S. Patent No. 7,312,752 (“Smith-II”)
`
`Ex-1053 U.S. Patent Application Publication No. 2005/0159174 (“Bar-
`On”)
`Ex-1054 U.S. Patent No. 6,957,076 (“Hunzinger”)
`
`17
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`Declaration of Dr. Kevin C. Almeroth
`U.S. Patent No. 10,341,811
`
`Ex-1055 U.S. Patent No. 7,263,441 (“Janky”)
`
`Ex-1056 U.S. Patent Application Publication No. 2005/0136845
`(“Masuoka”)
`Ex-1057 U.S. Patent Application Publication No. 2004/0198386
`(“Dupray”)
`Ex-1058 U.S. Patent Application Publication No. 2005/0282557 (“Mikko”)
`Ex-1059 U.S. Patent No. 7,474,897 (“Morgan-I”)
`Ex-1060 U.S. Patent No. 6,714,865 (“Angwin”)
`Ex-1061 U.S. Patent No. 7,525,425 (“Diem”)
`Ex-1062 U.S. Patent No. 7,433,693 (“Sheynblat-I”)
`Ex-1063 U.S. Patent Application Publication No. 2007/0013584 (“Camp”)
`Ex-1064 U.S. Patent Application Publication No. 2008/0139219
`(“Boeiro”)
`Ex-1065 U.S. Patent Application Publication No. 2006/0240841
`(“Bhattacharya”)
`Ex-1066 U.S. Patent Application Publication No. 2006/0095349
`(“Morgan-II”)
`Ex-1067 U.S. Patent No. 6,915,123 (“Daudelin”)
`Ex-1068 U.S. Patent Application Publication No. 2007/0010956
`(“Nerguizian”)
`Ex-1069 U.S. Patent Application Publication No. 2005/0195761
`(“Alicherry”)
`Ex-1070 U.S. Patent Application Publication No. 2007/0133487 (“Wang”)
`
`18
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`Page 21 of 243
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`

`

`Declaration of Dr. Kevin C. Almeroth
`U.S. Patent No. 10,341,811
`Ex-1071 U.S. Patent Application Publication No. 2006/0089153
`(“Sheynblat-II”)
`Ex-1072 U.S. Patent Application Publication No. 2007/0249365
`(“Jendbro”)
`Ex-1073 U.S. Patent No. 7,941,656 (“Hans”)
`Ex-1074 U.S. Patent No. 7,454,608 (“Gopalakrishnan”)
`Ex-1075 U.S. Patent No. 8,948,785 (“Grindeland”)
`Ex-1076 U.S. Patent No. 8,725,406 (“Kitajima”)
`Ex-1201 U.S. Patent Application Publication No. 2006/0009235
`(“Sheynblat-III”)
`Ex-1202 U.S. Patent Application Publication No. 2004/0259573
`(“Cheng”)
`Ex-1203 U.S. Patent No. 7,359,713 (“Tiwari”)
`Ex-1204 U.S. Patent Application Publication No. 2003/0129995 (“Niwa”)
`Ex-1205 U.S. Patent No. 8,509,814 (“Parker”)
`Ex-1206 U.S. Patent Application Publication No. 2002/0102993
`(“Hendrey”)
`Ex-1207 U.S. Patent No. 7,072,666 (“Kullman”)
`Ex-1208 U.S. Patent No. 7,343,564 (“Othmer”)
`Ex-1209 U.S. Patent Application Publication No. 2005/0215243 (“Black”)
`Ex-1210 U.S. Patent No. 5,978,673 (“Alperovich”)
`Ex-1211 U.S. Patent No. 6,038,451 (“Syed”)
`Ex-1212 U.S. Patent Application Publication No. 2001/0055974 (“Bates”)
`
`19
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`Page 22 of 243
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`

`Declaration of Dr. Kevin C. Almeroth
`U.S. Patent No. 10,341,811
`and any other materials I refer to in this declaration in support of my opinions.
`
`30.
`
`I base my opinions in this Declaration on the materials I reviewed, my
`
`experience, knowledge, and professional judgment. My opinions have also been
`
`guided by my appreciation of how a person of ordinary skill in the art would have
`
`understood the claims and the specification of the ’811 patent at the time of the
`
`alleged invention, which I have been asked to consider as September 19, 2006. My
`
`opinions reflect how one of ordinary skill in the art would have understood the ’811
`
`patent, including the challenged claims, the prior art to the patent and those claims,
`
`and the state of the art known to a person of ordinary skill in the art at the time of
`
`the alleged invention.
`
`
`
`
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`20
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`Page 23 of 243
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`Declaration of Dr. Kevin C. Almeroth
`U.S. Patent No. 10,341,811
`IV. PERSON OF ORDINARY SKILL IN THE ART
`31. Based on my knowledge and experience, I understand what a person of
`
`ordinary skill in the art would have known at the time of the alleged invention, which
`
`I discussed above as being around September 19, 2006. My opinions herein are,
`
`where appropriate, based on my understandings as to a person of ordinary skill in
`
`the art at that time. In my opinion, based on the materials and information I have
`
`reviewed, and based