`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`GOOGLE LLC,
`Petitioner,
`v.
`
`SECURE COMMUNICATION TECHNOLOGIES, LLC,
`Patent Owner.
`____________
`Case IPR2026-00098
`Patent No. 11,995,685
`____________
`DECLARATION OF MARK LANNING IN SUPPORT
`OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 11,995,685
`
`
`Google Exhibit 1003
`Google v. SecCommTech
`
`
`
`
`
`
`
`U.S. Patent No. 11,995,685
`IPR2026-00098
`
`i
`
`TABLE OF CONTENTS
`I. INTRODUCTION ............................................................................................ 1
`II. QUALIFICATIONS ........................................................................................ 5
`III. LEGAL UNDERSTANDINGS ................................................................... 9
`A. My Understanding of Claim Construction ..................................................... 9
`B. My Understanding of Anticipation .............................................................. 10
`C. My Understanding of Obviousness .............................................................. 12
`IV. TECHNOLOGY BACKGROUND AND STATE OF THE ART ......... 15
`A. The ’685 Patent’s Short Range or Bluetooth Wireless Protocol ................. 15
`B. The Bluetooth Standard ............................................................................... 16
`a. Many Technology Companies and Engineers Were/Are Involved with
`Defining the Different Versions of the Bluetooth Specification ..................... 17
`b. Bluetooth General Description ................................................................ 18
`c. Overview of Operation ............................................................................ 18
`d. Topology and Communications ............................................................... 21
`e. Bluetooth Operational Procedures and Modes ........................................ 23
`i) Inquiry (Discovering) Procedure ......................................................... 23
`ii) The Inquiry Response Message Contains the Device Address, Class of
`Device and Extended Response Information ............................................... 24
`iii) The Bluetooth Device Address Provided in an Inquiry Response
`Message is the Same as a MAC Address ..................................................... 28
`iv) The Class of Device Information Field in the Inquiry Response
`Defines the Type of Bluetooth Device and the Services it Offers ............... 29
`v) The Extended Inquiry Response Fields Define the Responding
`Device’s Local Name and its Supported Services. ...................................... 34
`vi) Service Class UUIDs Can Be Included in the Inquiry Response
`Message ........................................................................................................ 37
`vii) The Paging (Connecting) Procedure ................................................ 38
`V. THE ‘685 PATENT ........................................................................................ 38
`A. Overview of the ‘685 patent ........................................................................ 38
`
`
`
`
`
`
`
`U.S. Patent No. 11,995,685
`IPR2026-00098
`
`ii
`
`B. The Prosecution History .............................................................................. 42
`C. Priority Date of the Claims .......................................................................... 42
`VI. LEVEL OF ORDINARY SKILL IN THE ART ..................................... 42
`VII. CLAIM CONSTRUCTION ...................................................................... 44
`VIII. GROUNDS OF UNPATENTABILITY ............................................... 44
`IX. DETAILED ANALYSIS OF GROUNDS FOR CHALLENGE ............ 45
`A. GROUND 1: EAGLE IN VIEW OF BEHRENS, AND FURTHER IN
`VIEW OF OLKKONEN, RENDERS OBVIOUS CLAIMS 1-8, 10, 12-16, 19,
`22-23, 26-27, 31-41, 44-48, 52-54, 57-58, 60-64, 67-71, 73, 76-77, 79-81, AND
`85-86..................................................................................................................... 46
`a. Overview of Eagle (EX1005) .................................................................. 46
`b. Overview of Behrens (EX1006) .............................................................. 48
`c. Overview of Olkkonen (EX1007) ............................................................ 49
`d. Overview of Eagle’s, Behrens’, and Olkkonen’s combined teachings ... 51
`i) Eagle, Behrens, and Olkkonen are analogous art and their combined
`teachings renders obvious claims of the ’685 patent ................................... 51
`ii) Behrens teaches combined and changing UIDs ................................... 53
`iii) Eagle and Olkkonen teach filtering beacon service identifiers ....... 58
`iv) Eagle, Behren, and Olkkonen teach performing actions ..................... 63
`e. The ‘685 Patent Claims ............................................................................ 66
`i) Claim 1 ................................................................................................. 66
`ii) Claim 2 ................................................................................................. 79
`iii) Claim 3 ............................................................................................. 86
`iv) Claim 4: “The method of claim 3 wherein the second further action is
`based upon a function currently being performed on a device associated
`with the wireless beacon service.” ............................................................... 89
`v) Claim 5: “The method of claim 4 wherein the function is related to a
`current phone call.” ...................................................................................... 91
`vi) Claim 6: “The method of claim 2 wherein the first or the second
`further action is related to receiving advertising information for
`presentation to a user of the wireless device, based upon the first or the
`
`
`
`
`
`
`
`U.S. Patent No. 11,995,685
`IPR2026-00098
`
`iii
`
`second unique identifier, or information derived from the first or second
`unique identifier.” ........................................................................................ 91
`vii) Claim 7: “The method of claim 2 wherein one or more of the first
`and the second further action includes receiving content from a server
`based upon information derived from either the first unique identifier or the
`second unique identifier.” ............................................................................ 92
`
`viii) Claim 8: “The method of claim 2, wherein the first or second further
`action includes sending a message to another device associated with an
`account related to the first and the second unique identifiers.” ................... 93
`
`ix) Claim 10: “The method of claim 2 wherein the second further action
`includes preventing sending of the second unique identifier or information
`derived from the second unique identifier by the wireless device to at least
`one of the one or more servers.” .................................................................. 94
`x) Claim 12: “The method of claim 2 wherein the taking first further
`action includes causing the wireless device, to: send the first unique
`identifier or information derived from the first unique identifier to at least
`one of the one or more servers, and receive the stored information in
`response.” ..................................................................................................... 95
`xi) Claim 13: “The method of claim 2 wherein the stored information is
`received at the wireless device from at least one of the one or more servers
`prior to the taking of the first further action.” .............................................. 95
`
`xii) Claim 14: “The method of claim 2 wherein the stored information is
`received at the wireless device from at least one of the one or more servers
`prior to performing the second further action.” ........................................... 96
`xiii) Claim 15: “The method of claim 1 further comprising: using the
`stored information to determine if the first unique identifier is present
`among the first selected one or more unique identifiers.” ........................... 96
`
`xiv) Claim 16: “The method of claim 2 wherein all beacon transmitter
`devices participating in the particular wireless beacon service have the
`same particular beacon service identifier.” .................................................. 97
`
`xv) Claim 19: “The method of claim 2 wherein the second further action
`is related to either a product tied to a location or an advertisement tied to a
`location.” ...................................................................................................... 98
`xvi) Claim 22: “The method of claim 2 wherein the second further action
`includes allowing a user associated with the wireless device to be provided
`
`
`
`
`
`
`
`U.S. Patent No. 11,995,685
`IPR2026-00098
`
`iv
`
`access to an object or device associated with the wireless beacon service.”
` 98
`xvii) Claim 23: “[23.A] The method of claim 3 wherein the taking second
`further action additionally comprises: controlling further communications
`between the wireless device and at least one device or server associated
`with an entity or object in proximity to the wireless device, and [23.B]
`wherein the stored information includes contact information of the entity in
`proximity utilized to determine the presence of the second unique identifier
`prior to taking the second further action.” ................................................... 99
`
`xviii) Claim 26: “The method of claim 1 wherein the first further action
`is related to receiving advertising information for presentation to a user of
`the wireless device, based upon the first unique identifier, or information
`derived from the first unique identifier.” ...................................................102
`xix) Claim 27: “The method of claim 1 wherein the first further action
`includes receiving content from a server based upon information derived
`from the first unique identifier.” ................................................................102
`xx) Claim 31: “The method of claim 1 wherein the first further action is
`related to either a product tied to a location or an advertisement tied to a
`location.” ....................................................................................................102
`
`xxi) Claim 32: “The method of claim 3 wherein the taking second
`further action additionally comprises: controlling further communications
`between the wireless device and at least one device or server associated
`with an entity or object in proximity to the wireless device.” ...................103
`xxii) Claim 33: “The method of claim 2 further comprising: using the
`stored information to determine if the second unique identifier is present
`among the selected one or more of the unique identifiers from the second
`plurality of beacon transmissions.” ............................................................103
`
`xxiii) Claim 34 .....................................................................................103
`xxiv) Claim 35 .........................................................................................108
`xxv) Claim 36 .........................................................................................110
`xxvi) Claim 37: “The mobile wireless device of claim 34 wherein a
`plurality of beacon transmissions including the particular beacon service
`identifier and the first unique identifier are received in the first time period,
`and no beacon transmissions including the same particular beacon service
`
`
`
`
`
`
`
`U.S. Patent No. 11,995,685
`IPR2026-00098
`
`v
`
`identifier and the second unique identifier are received in the first time
`period.” .......................................................................................................112
`xxvii) Claim 38: “The mobile wireless device of claim 37 wherein the
`second further action is based upon a function currently being performed on
`a device associated with the wireless beacon service.” .............................112
`xxviii) Claim 39: “The mobile wireless device of claim 38 wherein the
`function is related to a current phone call.” ...............................................112
`xxix) Claim 40: “The mobile wireless device of claim 37 wherein one or
`more of the first further action and the second further action includes
`receiving content from a server based upon information derived from either
`the first unique identifier or the second unique identifier.” .......................112
`xxx) Claim 41: “The mobile wireless device of claim 37, wherein the
`first or second further action includes sending a message to another device
`associated with an account related to the first and the second unique
`identifiers.” .................................................................................................113
`xxxi) Claim 44: “The mobile wireless device of claim 37 wherein the
`taking first further action includes causing the wireless device, to: send the
`first unique identifier or information derived from the first unique identifier
`to at least one of the one or more servers, and receive the stored
`information in response.” ...........................................................................113
`
`xxxii) Claim 45: “The mobile wireless device of claim 37 wherein the
`stored information is received at the wireless device from at least one of the
`one or more servers prior to the taking of the first further action.” ...........113
`xxxiii) Claim 46: “The mobile wireless device of claim 39 wherein the
`stored information is received at the wireless device from at least one of the
`one or more servers prior to performing one or more of the first and the
`second further action.” ...............................................................................113
`
`xxxiv) Claim 47: “The mobile wireless device of claim 45 further
`comprising: using the stored information to determine if the first unique
`identifier is present among the first selected one or more unique
`identifiers.” .................................................................................................114
`xxxv) Claim 48: “The mobile wireless device of claim 37 wherein all
`beacon transmitter devices participating in the particular wireless beacon
`service have the same particular beacon service identifier.” .....................114
`
`
`
`
`
`
`
`U.S. Patent No. 11,995,685
`IPR2026-00098
`
`vi
`
`xxxvi) Claim 52: “The mobile wireless device of claim 37 wherein the
`second further action includes allowing a user associated with the wireless
`device to be provided access to an object or device associated with the
`wireless beacon service.” ...........................................................................114
`xxxvii) Claim 53: “The mobile wireless device of claim 37 wherein the
`taking second further action additionally comprises: controlling further
`communications between the wireless device and at least one device or
`server associated with an entity in proximity to the wireless device, and
`wherein the stored information includes contact information of the entity in
`proximity utilized to determine the presence of the second unique identifier
`prior to taking the second further action.” .................................................114
`xxxviii) Claim 54: “The mobile wireless device of claim 37 further
`comprising: using the stored information to determine if the second unique
`identifier is present among the selected one or more of the unique
`identifiers from the second plurality of beacon transmissions.”................115
`
`xxxix) Claim 57: “The mobile wireless device of claim 37 wherein the
`taking second further action additionally comprises: controlling further
`communications between the wireless device and at least one device or
`server associated with an entity or object in proximity to the wireless
`device.” 115
`
`xl) Claim 58: “The mobile wireless device of claim 37 further
`comprising: using the stored information to determine if the second unique
`identifier is present among the selected one or more of the unique
`identifiers from the second plurality of beacon transmissions.”................115
`
`xli) Claim 60: “The computer program product of claim 36 wherein the
`MAC address received in a beacon transmission including the second
`unique identifier is different from the MAC address received in a beacon
`transmission including the first unique identifier, but each such beacon
`transmission includes the same particular beacon service identifier, and
`wherein a plurality of beacon transmissions including the particular beacon
`service identifier and the first unique identifier are received in the first time
`period, and no beacon transmissions including the same particular beacon
`service identifier and the second unique identifier are received in the first
`time period.” ...............................................................................................116
`xlii) Claim 61: “The computer program product of claim 60 wherein the
`second further action is based upon a function currently being performed on
`a device associated with the wireless beacon service.” .............................116
`
`
`
`
`
`
`
`
`U.S. Patent No. 11,995,685
`IPR2026-00098
`
`vii
`
`xliii) Claim 62: “The computer program product of claim 61 wherein the
`function is related to a current phone call.” ...............................................116
`xliv) Claim 63: “The computer program product of claim 60 wherein one
`or more of the first further action and the second further action includes
`receiving content from a server based upon information derived from either
`the first unique identifier or the second unique identifier.” .......................116
`
`xlv) Claim 64: “The computer program product of claim 60, wherein the
`first or second further action includes sending a message to another device
`associated with an account related to the first and the second unique
`identifiers.” .................................................................................................117
`
`xlvi) Claim 67: “The computer program product of claim 60 wherein the
`taking first further action further includes causing the wireless device to:
`send the first unique identifier or information derived from the first unique
`identifier to at least one of the one or more servers, and receive the stored
`information in response.” ...........................................................................117
`xlvii) Claim 68: “The computer program product of claim 60 wherein
`the stored information is received at the wireless device from at least one of
`the one or more servers prior to the taking of the first further action.” .....117
`
`xlviii) Claim 69: “The computer program product of claim 62 wherein
`the stored information is received at the wireless device from at least one of
`the one or more servers prior to performing one or more of the first and the
`second further action.” ...............................................................................117
`
`xlix) Claim 70: “The computer program product of claim 68 further
`comprising: using the stored information to determine if the first unique
`identifier is present among the first selected one or more unique
`identifiers.” .................................................................................................118
`l) Claim 71: “The computer program product of claim 60 wherein all
`beacon transmitter devices participating in the particular wireless beacon
`service have the same particular beacon service identifier.” .....................118
`
`li) Claim 73: “The computer program product of claim 60 wherein the
`second further action is related to either a product tied to a location or an
`advertisement tied to a location.” ...............................................................118
`lii) Claim 76: “The computer program product of claim 60 wherein the
`second further action includes allowing a user associated with the wireless
`device to be provided access to an object or device associated with the
`wireless beacon service.” ...........................................................................118
`
`
`
`
`
`
`
`U.S. Patent No. 11,995,685
`IPR2026-00098
`
`viii
`
`liii) Claim 77: “The computer program product of claim 60 wherein the
`taking second further action additionally comprises: controlling further
`communications between the wireless device and at least one other device
`or server associated with an entity in proximity to the wireless device, and
`wherein the stored information includes contact information of the entity in
`proximity utilized to determine the presence of the second unique identifier
`prior to taking the second further action.” .................................................119
`liv) Claim 79: “The computer program product of claim 60 further
`comprising: using the stored information to determine if the second unique
`identifier is present among the selected one or more of the unique
`identifiers from the second plurality of beacon transmissions.”................119
`lv) Claim 80: “The computer program product of claim 60 wherein the
`first further action is related to receiving advertising information for
`presentation to a user of the wireless device, based upon the first unique
`identifier, or information derived from the first unique identifier.” ..........119
`lvi) Claim 81: “The computer program product of claim 60 wherein the
`first further action includes receiving content from a server based upon
`information derived from the first unique identifier.” ...............................119
`
`lvii) Claim 85: “The computer program product of claim 60 wherein the
`taking second further action additionally comprises: controlling further
`communications between the wireless device and at least one device or
`server associated with an entity or object in proximity to the wireless
`device.” .......................................................................................................120
`
`lviii) Claim 86: “The computer program product of claim 60 further
`comprising: using the stored information to determine if the second unique
`identifier is present among the selected one or more of the unique
`identifiers from the second plurality of beacon transmissions.”................120
`
`B. GROUND 2: EAGLE IN VIEW OF BEHRENS, OLKKONEN, AND
`KALLIO RENDERS OBVIOUS CLAIMS 25, 55, AND 78 ............................120
`C. GROUND 3: EAGLE IN VIEW OF BEHRENS, OLKKONEN, AND
`JONES RENDERS OBVIOUS CLAIMS 53 AND 59 ......................................123
`D. GROUND 4: EAGLE IN VIEW OF BEHRENS, OLKKONEN, KALLIO,
`AND JONES RENDERS OBVIOUS CLAIM 87 .............................................130
`X. SECONDARY CONSIDERATIONS .........................................................131
`XI. CONCLUSION .........................................................................................132
`
`
`
`
`
`
`
`U.S. Patent No. 11,995,685
`IPR2026-00098
`
`1
`
`I. INTRODUCTION
`1. My name is Mark R. Lanning and I am currently the President of
`Telecom Architects, Inc., and Reticle Consulting, LLC. I have been retained on
`behalf of Google LLC (“Google” or “Petitioner”), to provide my opinions on
`certain issues related to U.S. Patent No. 11,995,685 (“the ‘685 patent”) in
`connection with the above-captioned inter partes review (IPR) proceeding. In
`particular, I have been asked to provide my insights, analysis, and opinions
`regarding whether claims 1-8, 10, 12-16, 19, 22-23, 25-27, 31-41, 44-48, 52-55,
`57-64, 67-71, 73, 76-81, and 85-87 of the ‘685 patent (“Challenged Claims”) are
`obvious over the prior art references identified below.
`2. The ‘685 patent is titled “EFFICIENT AND SECURE
`COMMUNICATION USING WIRELESS SERVICE IDENTIFIERS,” names as
`inventors James A. Proctor, Jr. and James Arthur Proctor, III, and is currently
`owned by Secure Communication Technologies, LLC. I have considered the ‘685
`patent. I understand that the ‘685 patent has been provided as EX1001.
`3. The file history of the ‘685 patent has been provided as EX1002. I
`have considered this file history, and I will refer to it as the “‘685 File History” or
`by its exhibit number.
`4. I understand that the ‘685 patent claims to be a continuation of many
`patent applications (as shown on the first two pages of EX1001) and also claims
`
`
`
`
`
`
`
`U.S. Patent No. 11,995,685
`IPR2026-00098
`
`2
`
`priority to provisional application Nos. 61/095,359 (filed September 9, 2008) and
`61/095,001 (filed September 8, 2008) (“’the Provisional Applications”). I have
`been asked to assume the Challenged Claims are entitled to the September 8, 2008
`filing date for the purposes of rendering my opinions in this declaration.
`5. My analysis and conclusions set forth in this declaration are based on
`my educational background and experiences in the field (see Section II). I am
`qualified to opine concerning what a person of ordinary skill in the art would have
`known and understood during that time. Before September 8, 2008, my level of
`skill in the art was at least that of a person of ordinary skill. I am qualified to opine
`concerning what a person of ordinary skill in the art would have known and
`understood at the time of the ‘685 patent’s purported invention. My analysis and
`conclusions herein are from the perspective of a person of ordinary skill in the art
`as of September 8, 2008.
`6. As part of my independent analysis for this declaration, I have
`considered the following: the background knowledge/technologies that were
`commonly known to persons of ordinary skill in this art during the time before the
`earliest claimed priority date for the ‘685 patent; my own knowledge and
`experiences gained from my work experience in the field of the ‘685 patent and
`related disciplines; and my experience in working with others involved in this field
`and related disciplines.
`
`
`
`
`
`
`
`U.S. Patent No. 11,995,685
`IPR2026-00098
`
`3
`
`7. I have considered the following non-exhaustive list of references in
`preparing my declaration. I have been instructed to assume that each of these
`references qualifies as prior art.
`8. U.S. Patent Application Publication No. 2005/0250552 to Eagle et al.,
`titled “COMBINED SHORT RANGE RADIO NETWORK AND CELLULAR
`TELEPHONE NETWORK FOR INTERPERSONAL COMMUNICATIONS”
`filed on May 5, 2005 and published on November 10, 2005. I understand that a
`copy of this reference has been designated as Exhibit EX1005. Throughout my
`declaration, references to “Eagle” are to Exhibit EX1005.
`9. U.S. Patent Application Publication No. 2010/0138481 to Behrens,
`titled “DEVICE AND METHOD FOR ESTABLISHING SOCIAL NETWORKS
`THROUGH THE USE OF WIRELESS TECHNOLOGY” filed on April 30, 2008
`and published on June 3, 2010. I understand that a copy of this reference has been
`designated as EX1006. Throughout my declaration, references to “Behrens” are to
`EX1006.
`10. U.S. Patent No. 7,590,086 to Olkkonen et al., titled “AD HOC
`NETWORK DISCOVERY MENU,” filed on November 3, 2004 and issued on
`September 15, 2009. I understand that a copy of this reference has been designated
`as Exhibit EX1007. Throughout my declaration, references to “Olkkonen” are to
`EX1007.
`
`
`
`
`
`
`
`U.S. Patent No. 11,995,685
`IPR2026-00098
`
`4
`
`11. U.S. Patent Application Publication No. 2003/0224756 to Kallio,
`titled “SYSTEM AND METHOD FOR SERVICES ACCESS” filed on May 30,
`2002 and published on December 4, 2003. I understand that a copy of this
`reference has been designated as EX1047. Throughout my declaration, references
`to “Kallio” are to EX1047.
`12. U.S. Patent Application Publication No. 2007/0264991 to Jones, titled
`“SERVICES NEAR ME: DISCOVERING AND CONNECTING TO
`AVAILABLE WIRELESS SERVICES UTILIZING PROXIMITY DISCOVERY”
`filed on May 15, 2006 and published on November 15, 2007. I understand that a
`copy of this reference has been designated as EX1038. Throughout my declaration,
`references to “Jones” are to EX1038.
`13. I am being compensated by Google at my standard hourly consulting
`rate of $550 for my time on this matter. My compensation is not dependent on the
`outcome of this proceeding or any other proceeding between the parties.
`14. In forming my opinions, I relied on the documents cited in this
`declaration and the documents identified in the table below. These documents
`comprise patents, file histories, printed publications, and other related documents.
`As I discuss below, each document is a type that experts in my field would have
`reasonably relied upon when forming their opinions. Further, a person of ordinary
`skill in the art (“POSITA”) would have had access to each document either through
`
`
`
`
`
`
`
`U.S. Patent No. 11,995,685
`IPR2026-00098
`
`5
`
`the applicable patent offices and/or well-known libraries, conferences, or
`publications in the field. My opinions are also based upon my personal and
`professional experience.
`Exhibit Description
`1001 U.S. Patent No. 11,995,685
`1002 Prosecution History of U.S. Patent No. 11,995,685
`1005 U.S. Patent Application No. 2005/0250552 (“Eagle”)
`1006 U.S. Patent Application Publication No. 2010/0138481 (“Behrens”)
`1007 U.S. Patent No. 7,590,086 (“Olkkonen”)
`1008 Bluetooth Special Interest Group, Bluetooth Core Specification Version
`2.1 + EDR (July 26, 2007)
`1009 Bluetooth Special Interest Group, Assigned Numbers (December 14,
`2002)
`(https://web.archive.org/web/20021214114356/http://www.bluetooth.or
`g/assigned-numbers/baseband.htm)
`1010 U.S. Patent Application Publication No. 2002/0131445
`1011 U.S. Patent Application Publication No. 2002/0174364
`1012 U.S. Patent Application Publication No. 2005/0164717
`1013 U.S. Patent Application Publication No. 2006/0165100
`1035 Apple Inc., iPhone 3G Technical Specifications
`(https://web.archive.org/web/20080725084414/http://www.apple.com/ip
`hone/specs.html)
`1036 Apple Inc., iPhone User Guide for iPhone OS 3.1 Software
`(https://cdsassets.apple.com/live/6GJYWVAV/user/ma616_iphone_ios3
`_1_user_guide.pdf)
`1038 U.S. Patent Application Publication No. 2007/0264991 (“Jones”)
`1047 U.S. Patent Application Publication No. 2003/0224756 (“Kallio”)
`
`II. QUALIFICATIONS
`15. I am qualified by education and experience to testify as an expert in
`the field of telecommunications including circuit-switched networks, multiple
`generations of cellular networks, and packet-switched networks. The following
`
`
`
`
`
`
`
`U.S. Patent No. 11,995,685
`IPR2026-00098
`
`6
`
`overview of my background pertains to my qualifications for providing expert
`testimony in this matter.
`16. I am currently the president of two consulting companies: Telecom
`Architects, Inc. and Reticle Consulting, LLC. Telecom Architects provides
`consulting services to fixed and wireless telecom service providers and their
`equipment suppliers. I have been President of Telecom Architects since 1999.
`17. I have over 40 years of experience working in the telecommunications
`industry that began in the U.S. Army Signal Corp. My experience relevant to this
`case includes my work as an architect of various telecommunications systems and
`my work developing equipment used in telecommunications systems. This
`experience includes extensive design, implementation and testing work on the
`wireless interface functionality (between the base station and mobile phones) for
`multiple generations of cellular standards.
`18. I received a B.S. in Computer Science from Southern Methodist
`University (SMU) in 1983.
`19. DSC, now a part of Alcatel, hired me in 1983 where I was a software
`development manager on the team responsible for updating DSC’s PSTN
`telephone switch into a Mobile Switching Center (MSC) for Motorola to sell as a
`part of their cellular product offering in the U.S. and many other countries.
`20. In 1991, I began working as a consultant to Motorola for its
`
`
`
`
`
`
`
`U.S. Patent No. 11,995,685
`IPR2026-00098
`
`7
`
`“SuperCell” base station product and as a consultant to British Telecom to upgrade
`its current analog cellular network, and I was one of the network architects
`responsible for the design and rollout of its Global System for Mobile
`Communications (GSM) network known as Cellnet. Beginning in the early 1990s,
`I was responsible for implementation of the SMS service, including working with
`suppliers of the SMS Center (SMSC), Mobile Switching Centers (MSCs) and
`cellular phones to define and roll out the functionality that was to be provided.
`21. I was personally involved with Nokia, Ericsson, Motorola and other