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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Patent No.: 9,438,782
`Filed: April 9, 2015
`Issued: September 6, 2016
`Title: OMNIDIRECTIONAL USER CONFIGURABLE
`MULTI-CAMERA HOUSING
`Post Grant Review No. ____________
`
`DECLARATION OF STANLEY R. STEINGOLD
`IN SUPPORT OF PETITION FOR POST GRANT REVIEW
`OF U.S. PATENT NO. 9,438,782
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`
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`1
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`AXIS EXHIBIT 1016-1
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`I, Stanley R. Steingold, hereby declare, affirm and state the following:
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`Introduction and Background
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`1.
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`I am over the age of eighteen and otherwise competent to make
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`this Declaration.
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`2.
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`The facts set forth below are known to me personally, and I
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`have firsthand knowledge of them.
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`3.
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`I make this Declaration in support of the above-captioned
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`petition (“Petition”) for Post Grant Review (“PGR”) of U.S. Patent No. 9,438,782
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`(the “‘782 Patent”). I have reviewed the ‘782 Patent to assess its patentability. The
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`following is my report regarding my assessment.
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`4.
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`I have been retained by Volpe & Koenig, P.C. on behalf of Axis
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`Communications AB, the Petitioner.
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`5.
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`I have been asked to provide my technical review, analysis,
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`insights, and opinions regarding the noted prior art references that form the basis
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`for the grounds of rejection set forth in the Petition for Post Grant Review of the
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`‘782 Patent (“Petition”).
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`Qualifications and Compensation
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`6.
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`I received my B.S. in Mechanical Engineering from the
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`University of California, Santa Barbara in 1982 and my M.B.A. from Georgia
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`State University in 1995.
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`2
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`AXIS EXHIBIT 1016-2
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`7.
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`Since approximately 1983,
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`I have acquired extensive
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`experience in mechanisms, materials, and mechanical product design. I gained this
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`experience through working in the aerospace, construction, electronics, opto-
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`mechanical mounting design, and furniture industries in various roles, including as
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`a Mechanical Engineer, and Production Support Engineer.
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`8.
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`Since approximately 2007, I had several years of designing and
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`modifying injection molded parts and sheet metal components for the lighting and
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`electronic industry with Cooper Lighting.
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`9.
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`In the 1980s, I worked for Hughes Aircraft Company as a
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`design engineer and designed optical mounts and kinematic mounting systems for
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`lenses and optics. I also designed and tested opto-mechanical systems for
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`communication satellites with Hughes.
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`10.
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`I was a winner of the ASME Student Speech Award at my alma
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`mater, UCSB. Each of the 3 winners went on to the National Competition at the
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`University of Hawaii.
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`11.
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`I am a Licensed Mechanical Engineer in the State of California,
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`and a Professional Engineer in the State of Georgia.
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`12.
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`I am a patent agent registered to practice before the United
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`States Patent and Trademark Office, but I am not currently in active practice.
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`3
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`AXIS EXHIBIT 1016-3
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`13. An expanded list of my experience and credentials is included
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`in my Curriculum Vitae, a copy of which is submitted herewith as Exhibit 1017.
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`14.
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`I am being compensated at my standard hourly rates of $330
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`and $430 for my work in connection with this matter, through an agency named
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`TASA (Technical Advisory Service for Attorneys). My compensation in this
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`matter is not dependent in any way on the contents of this Declaration, the
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`substance of any further opinions or testimony that I may provide, or the ultimate
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`outcome of this matter.
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`Materials Considered
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`15.
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`I have been advised that whether a claim of a patent is obvious
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`is controlled by the Patent Act, 35 U.S.C. § 103, which states, “A patent for a
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`claimed invention may not be obtained, notwithstanding that the claimed invention
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`is not identically disclosed as set forth in section 102 , if the differences between
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`the claimed invention and the prior art are such that the claimed invention as a
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`whole would have been obvious before the effective filing date of the claimed
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`invention to a person having ordinary skill in the art to which the claimed
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`invention pertains. Patentability shall not be negated by the manner in which the
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`invention was made.” It is also my understanding that an obviousness analysis
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`takes into consideration factual inquiries such as the level of ordinary skill in the
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`4
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`AXIS EXHIBIT 1016-4
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`art, the scope and content of the prior art, and the differences between the prior art
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`and the patent claim.
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`16.
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`I have been advised that determining whether a claim of a
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`patent is obvious is guided by the following principles:
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`a.
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`Obviousness may be considered by applying a teaching-
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`suggestion-motivation (TSM) test in a non-formulaic way.
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`b.
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`The combination of familiar elements according to
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`known methods is likely to be obvious when it does no more than yield predictable
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`results.
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`c. When a patent simply arranges old elements with each
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`performing the same function it had been known to perform and yields no more
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`than one would expect from such an arrangement, the combination is obvious.
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`d.
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`Exemplary rationales that may support a conclusion of
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`obviousness include:
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`i.
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`Combining prior art elements according to known
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`methods to yield predictable results;
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`ii.
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`Simple substitution of one known element for
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`another to obtain predictable results;
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`iii.
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`Use of known technique to improve similar
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`devices (methods, or products) in the same way;
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`5
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`AXIS EXHIBIT 1016-5
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`iv.
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`Applying a known technique to a known device
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`(method, or product) ready for improvement to yield predictable results;
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`v.
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` “Obvious to try” – choosing from a finite number
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`of identified, predictable solutions, with a reasonable expectation of success;
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`vi.
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`Known work in one field of endeavor may prompt
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`variations of it for use in either the same field or a different one based on design
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`incentives or other market forces if the variations are predictable to one of ordinary
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`skill in the art; and,
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`vii.
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`Some teaching, suggestion, or motivation in the
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`prior art that would have led one of ordinary skill to modify the prior art reference
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`or to combine prior art reference teachings to arrive at the claimed invention.
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`17.
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`I have reviewed the ‘782 Patent and its file history and
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`considered each of the documents cited herein, in light of general knowledge in the
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`art. In formulating my opinions, I relied upon my experience in the relevant artand
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`considered the viewpoint of a person of ordinary skill in the art as of June 9, 2014,
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`the priority date of the ‘782 Patent.
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`18. Below is a list of documents attached to the subject Petition for
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`Post Grant Review, that I considered in formulating my opinions:
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`Exhibit No.
`Ex. 1001
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`Ex. 1002
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`Description
`United States Patent No. 9,438,782 to Donaldson (“‘782
`Patent”)
`Prosecution History for United States Patent No. 9,438,782
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`
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`6
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`AXIS EXHIBIT 1016-6
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`Exhibit No.
`Ex. 1004
`Ex. 1007
`Ex. 1008
`Ex. 1009
`Ex. 1010
`Ex. 1011
`Ex. 1012
`Ex. 1013
`Ex. 1014
`Ex. 1015
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`Description
`U.S. Patent Publication No. US 2015/0177596 (“Bergsten”)
`U.S. Publication No. 2012/0092504 (“Murphy I”)
`PCT Publication No. WO 2004/095386 (“Murphy II”)
`U.S. Patent No. 2001/0022627 (“Bernhardt”)
`U.S. Patent No. 5,111,128 (“Blackshear”)
`U.S. Patent No. 7,614,804 (“Kim”)
`U.S. Patent No. 8,376,592 (“Engstrom”)
`U.S. Patent No. 6,268,882 (“Elberbaum”)
`U.S. Patent No. 6,064,430 (“Lefkowitz”)
`U.S. Publication No. 2014/0015981 (“Dietl”)
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`Claim Construction
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`19.
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`I have been advised
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`to apply
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`the broadest reasonable
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`interpretation consistent with the specification to the claim terms of the ‘782
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`Patent. I have reviewed and agree with the following claim constructions:
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`a.
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`b.
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`“top plate”: An upper portion of the housing.
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`“track plate”: A part of a housing configured for carrying
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`one or more brackets.
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`c.
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`“trim plate”: A lower part of a housing configured for
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`attaching a transparent dome to the housing.
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`d.
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`“a plurality of camera assemblies movably installed on
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`the track plate and within the top plate”: A plurality of camera assemblies that can
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`be repositioned on the track plate within an area defined by the top plate.
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`7
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`AXIS EXHIBIT 1016-7
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`e.
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`“a plurality of [first/second] index holes around a center
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`of the track plate for configurably indexing a positioning and an alignment of a
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`[first/second] portion of the plurality of camera assemblies”: Openings in the track
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`plate for attaching a bracket to the track plate in a selected position and facing in a
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`selected direction.
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`f.
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`“loosen”: Loosened.
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`20.
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`I have given all other claim terms their broadest reasonable
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`ordinary and customary meaning.
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`Description of the Relevant Field and the Relevant Timeframe
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`21. Based upon my review of the above materials, I believe that the
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`relevant field for purposes of the ‘782 Patent is housing and mounting components.
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`22.
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`I have been informed that the relevant time period of the
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`alleged invention is before June 9, 2014. Well before June 9, 2014, the camera
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`mounting systems of the type described in the ‘782 Patent were known. Moreover,
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`it is my opinion that a person having ordinary skill in the art (“PHOSITA”) of
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`housing and mounting components would have found the claims of the ‘782 Patent
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`to have been obvious as of June 9, 2014.
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`23.
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`In my opinion, the ‘782 Patent claims are drawn to specific
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`variations of known elements for camera or fixture mounting systems that were
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`known by or obvious to a PHOSITA.
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`8
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`AXIS EXHIBIT 1016-8
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`Level of Ordinary Skill in the Art
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`24. Based upon my review of the ‘782 Patent and its prosecution
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`history, it is my opinion that a PHOSITA at the relevant time to the ‘782 Patent
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`would have at least a two (2) year associate’s degree in Mechanical Engineering,
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`or an equivalent field, or two (2) years of practical experience in an industry
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`relating to mountable housings or fixtures. I have an understanding of the
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`capabilities of a person of ordinary skill in the relevant field, and believe I had the
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`capabilities of at least a PHOSITA at the relevant time. I have acted as and worked
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`with many such persons over the course of my career.
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`Grounds of Invalidity
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`Ground 1: Claims 1, 3, 4, 6, 7, 9 Are Invalid as Obvious Under 35 U.S.C.
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`§ 103 over Murphy I in view of Murphy II, Bernhardt, Kim and
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`Engstrom (the “Ground 1 Prior Art”)
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`25.
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`Independent claim 1 of the ‘782 Patent is presented below with
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`the individual elements referred to as follows:
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`a.
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`Preamble 1(a): “An omnidirectional user configurable
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`multi-camera housing comprising:…”
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`b.
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`Claim Element 1(b): “a top plate including one or more
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`electronic circuit boards thereon;…”
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`9
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`AXIS EXHIBIT 1016-9
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`c.
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`Claim Element 1(c): “a track plate secured to the top
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`plate by a plurality of first fasteners, wherein the track plate is rotationally movable
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`with respect to the top plate, when the first fasteners are loosen;…”
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`d.
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`Claim Element 1(d): “a plurality of camera assemblies
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`movably installed on the track plate and within the top plate, each comprising: a
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`bracket movably secured to the track plate, a camera movably secured to the
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`bracket, wherein the camera is rotatable in a plane perpendicular to the track plate,
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`and a second fastener for movably securing the bracket to the track plate;…”
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`e.
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`Claim Element 1(e): “a transparent cover for covering
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`the plurality of camera assemblies installed on the track plate; …”
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`f.
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`Claim Element 1(f): “and a trim plate for securing the
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`transparent cover to the top plate with a plurality of third fasteners,…”
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`g.
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`Claim Element 1(g): “wherein the track plate includes: a
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`plurality of first index holes around a perimeter of the track plate for configurably
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`indexing a positioning and an alignment of a first portion of the plurality of camera
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`assemblies, a plurality of second index holes around a center of the track plate for
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`configurably indexing a positioning and an alignment of a second portion of the
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`plurality of camera assemblies, …”
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`h.
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`Claim Element 1(h): “a plurality of curve-shaped
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`openings to accommodate the plurality of first fasteners and allow movement of
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`10
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`AXIS EXHIBIT 1016-10
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`the plurality of first fasteners within the curve-shaped openings, respectively, for
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`rotational movement of the track plate with respect to the top plate, when the
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`plurality of first fasteners are loosen, …”
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`i.
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`Claim Element 1(i): “an opening for a cable coupled to
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`the one or more electronic circuit boards.”
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`26.
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`Introductory Review of U.S. Publication No. 2012/0092504
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`A1 (Murphy I): Murphy I teaches a top plate, defined as upper secondary shell 73.
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`Mounting disc 93 is supplied as a track plate. A set of first fasteners is defined by
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`removable band 77 holding the track plate and top plate together. A camera 6 is
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`shown attached to a mounting bracket 95. The brackets fasteners for attaching the
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`bracket to the track plate are illustrated as screws 109. A lower secondary shell is
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`shown as transparent cover 68 and the index holes are two rows of mounting
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`openings 94, as in Figure 23. A cooling fan 130 is described for cooling the
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`housing. A connection for a cable 105 is pin connector socket 106 in Figure 23.
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`27.
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`Introductory Review of PCT Publication No. WO
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`2004/095386 (“Murphy II”): Murphy II, in Figure 2, illustrates a top plate as a cap
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`4 and solar circuit 5 on the top plate. A track plate is shown as a combined plate 7
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`with camera support ring 12. Camera assemblies 13 are adjustably attached by
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`brackets 14 to camera support ring 12. A transparent dome is shown as cover 3.
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`11
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`AXIS EXHIBIT 1016-11
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`Electronic cable connection is through central stub tube 10. Cooling fans are
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`described at Page 12, Line 27.
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`28.
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`Introductory Review of U.S. Patent No. 2001/0022627
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`(Bernhardt): Bernhardt discloses a video camera 14 adjustable about a vertical
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`axis attached to a plate system 6, with electrical components within the housing.
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`The top plate of Bernhardt is a combination of top flange 3 and housing jacket 20,
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`as an assembly. The camera 14 is held in a camera housing 15 and attached to plate
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`8 which act together as a bracket. A plate system is shown as item 6 having an
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`upper part 7 with curved openings 36. Figure 8, and Paragraph [0061] shows screw
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`heads 37, designed to hold the keyhole shaped openings 36 and thereby capture the
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`plate 7. A circuit 40 board, Paragraph [0062], is positioned inside the top plate. A
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`dome 21 is shown in Figure 3. A sealing ring 29 is positioned between the dome
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`and housing jacket 20. Blower 11 is a fan, and is described in Paragraph [0060].
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`29.
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`Introductory Review of U.S. Patent No. 7,614,804 (Kim): Kim
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`shows a surface mounting plate 20 in Figure 5, equivalent to a top plate. The base
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`12 is a track plate and as shown in Figure 5 that holds a camera bracket 30 (gimbal
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`base). A camera 64 is held within the gimbal base. A trim plate is cover 14. A
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`dome 16 is a transparent cover. Knockout side access hole 22 provides full access
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`for cables to communicate to the apparatus interior. The floor 34 of the base can
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`include a circuit board.
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`12
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`AXIS EXHIBIT 1016-12
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`30.
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`Introductory Review of U.S. Patent No. 8,376,592 (Engstrom):
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`Engstrom, teaches a mounting base 2 with curved-shaped slots 10. Figures 1 and 2
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`shows the curved fastener holes or curved slots 10 through the mounting base 2. I
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`would rely on the teachings of Engstrom in modifying a surveillance camera
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`housing, as Engstrom is directed to the same general field of mounting fixtures to
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`surfaces, and provides a useful way to incorporate rotational adjustment. This is a
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`common type of plate system. For example, smoke alarm housings have been
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`using such rotational adjustment plates for years.
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`Ground 1 Prior Art- Applied to Claim 1
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`31. Preamble 1(a): “An omnidirectional user configurable
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`multi-camera housing comprising:…”: Configuring a group of movable and
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`adjustable cameras on a plate was known and demonstrated by Murphy I as shown
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`in Figures 5 and 6 and Murphy II as shown in Figure 3. Adjustably mounted
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`cameras are shown on a slotted track plate in Murphy I and on an annular plate in
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`Murphy II. Adjusting surveillance cameras is necessary since the cameras are
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`suspended in the field. The desired angle of a camera, for optimum viewing, is not
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`fully determined until it is securely mounted. It is my experience that field installed
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`mounts will often require a final field adjustment or calibration. This is the use of
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`known techniques to improve a similar device in the same, known way as claimed
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`in the ‘782 Patent.
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`13
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`AXIS EXHIBIT 1016-13
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`32. Claim Element 1(b): “a top plate including one or more
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`electronic circuit boards thereon;…”: Murphy I discloses an omnidirectional
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`user configurable multi camera housing having a top plate, or upper secondary
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`shell 73 and a circuit within the interior housing. Murphy II, Figure 2, illustrates a
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`top plate cap 4 and solar circuit 5. Bernhardt shows a top plate as top flange 3 and
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`housing jacket 20, as an assembly, with a circuit board 40 inside this top plate.
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`Kim states that circuit boards can be mounted within the housing, such as on the
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`floor 34 of the base 12 positioned within the surface mounting plate 20. Electronics
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`can fail and need replacing. Attaching the circuit to the top plate allows for the
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`entire assembly to be accessible and removed for service or upgrades. A circuit
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`board located inside the housing is also protected from elements. A skilled person
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`would reasonably have enclosed the circuit board, and also adjacent the top plate
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`for protection, ease of removal, and to simplify connections. This is the use of
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`known techniques to improve a similar device in the same, known way as claimed
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`in the ‘782 Patent.
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`33. Claim Element 1(c): “a track plate secured to the top plate
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`by a plurality of first fasteners, wherein the track plate is rotationally movable
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`with respect to the top plate, when the first fasteners are loosen;…”:
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`Combining a track plate to a top plate in a rotationally movable manner would
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`have been obvious in light of several references. Murphy I teaches of a top plate,
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`14
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`AXIS EXHIBIT 1016-14
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`
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`defined as upper secondary shell 73. Mounting disc 93 is a track plate. A set of
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`first fasteners is defined by removable band 77 that can be loosened. Bernhardt
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`also shows plate 6 having an upper part 7 with curved openings 36 into which
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`screw heads 37 are captured. Engstrom shows a track plate 2, which has curved
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`slots 10. Kim discusses attaching a top plate 20 to a track plate 12 with fasteners
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`26, and shows this in Figure 5. The use of mutually adjustable plates is common in
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`mounting and allows for affixing to a surface prior to final adjustment, since the
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`mounting plate can be installed independently. This is an obvious solution where
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`surface or suspended mounts are needed. A top plate can be affixed to the structure
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`with little obstruction. Then, the track plate and remaining items can be attached.
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`Adjustments of plate systems is a fundamental concept in mounting for purposes of
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`adjusting coverage areas, removing the cameras for service, and ease of initial
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`installation and upgrades. This combination amounts to the application of a known
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`technique to improve a similar device in the same, known way as claimed in the
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`‘782 Patent.
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`34. Claim Element 1(d): “a plurality of camera assemblies
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`movably installed on the track plate and within the top plate, each
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`comprising: a bracket movably secured to the track plate, a camera movably
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`secured to the bracket, wherein the camera is rotatable in a plane
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`perpendicular to the track plate, and a second fastener for movably securing
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`15
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`AXIS EXHIBIT 1016-15
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`
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`the bracket to the track plate;…”: Combining a group of movable and adjustable
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`cameras on a plate was obvious and demonstrated by Murphy I and Murphy II.
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`Murphy I shows this in Figure 23 and Murphy II shows this in Figures 2-3, 8-10.
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`Adjustably mounted cameras are shown on a slotted track plate in Murphy I, and
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`on an annular plate in Murphy II. With respect to Bernhardt, a camera 14 is held in
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`a housing 15 having various electronic components for moving the camera, see
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`Paragraph [0050], and attached to a plate system 6, see Figures 1-2. Kim shows
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`camera brackets as the gimbal base 30 and 32. Surveillance often requires directing
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`a camera at a selected target. This can involve using adjustable camera mounts or
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`brackets. Brackets, which can take many forms, are commonly used, and can take
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`many forms, and are designed to connect two objects lying in different planes. The
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`camera brackets described in Murphy I, Murphy II, Bernhardt and Kim all allow
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`for selective movement and positioning of the cameras. The combination of the
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`brackets and track plates above would have made the combination obvious to one
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`skilled in the art. The ‘782 Patent uses known techniques in the same, known way
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`as claimed in the ‘782 Patent.
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`35. Claim Element 1(e): “a transparent cover for covering the
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`plurality of camera assemblies installed on the track plate; …”: Murphy I has
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`a transparent cover 68, held by the removable band 77. With regard to Kim’s dome
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`16 and cover 14, cameras, circuits, and electronics are all protected from the
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`16
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`AXIS EXHIBIT 1016-16
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`
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`elements. Bernhardt shows a dome as item 21, and it completes a fully enclosed
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`apparatus. I am personally aware of protective domes used over cameras prior to
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`2013, and have seen such systems installed on aircraft and pole mounted cameras.
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`Protection of cameras and electronics is important for their continued function.
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`Environmental or mechanical conditions can damage optics and electronics. The
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`use of domes would have been obvious to a PHOSITA. This combination amounts
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`to use of a known technique to improve a similar device in the same, known way
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`as claimed in the ‘782 Patent.
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`36. Claim Element 1(f): “and a trim plate for securing the
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`transparent cover to the top plate with a plurality of third fasteners,…”: Kim
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`discloses a cover or trim plate (Figure 5, cover 14). With the cover attached to the
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`mounting plate 20 of Kim, a shoulder is formed and is useful in flush mounting.
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`This is also useful as a means for offering protection and appropriate fitment. One
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`skilled in the art would have concluded as obvious the use of a trim plate to secure
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`the transparent cover. This use of a trim plate allows for the easy removal of the
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`cover, access to the camera, and a simple clamping method for the affixing of the
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`cover. The trim plate can also protect the perimeter or edges of an attached dome.
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`This combination of known elements would have been apparent to a PHOSITA of
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`fixtures.
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`17
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`AXIS EXHIBIT 1016-17
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`37. Claim Element 1(g): “wherein the track plate includes: a
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`plurality of first index holes around a perimeter of the track plate for
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`configurably indexing a positioning and an alignment of a first portion of the
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`plurality of camera assemblies, a plurality of second index holes around a
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`center of the track plate for configurably indexing a positioning and an
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`alignment of a second portion of the plurality of camera assemblies, …”:
`
`Murphy I shows pluralities of indexing holes 94, in outer and inner rows, see
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`Figure 23, from which camera brackets may be suspended. The cameras may be
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`indexed at different angles as discussed in Paragraph [0091]. Cameras have limited
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`fields of view and depending on the real-life conditions it is usually necessary to
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`adjust their positions upon installation. A track plate having multiple index
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`openings allows for adjustable positioning of cameras. Cameras may be affixed to
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`the track plate separately before being affixed to the structure; and, camera
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`brackets can be swapped with fewer steps. Murphy I yields an obvious solution for
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`mounting multiple cameras to cover a large field of view. When mounting the
`
`camera assembly near or on a building, an entire quadrant (that blocked by a wall
`
`or structure) need not be viewed. This amounts to use of a known technique that
`
`would be used to improve a similar device in the same, known way as claimed in
`
`the ‘782 Patent.
`
`
`
`18
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`AXIS EXHIBIT 1016-18
`
`
`
`
`
`38. Claim Element 1(h): “a plurality of curve-shaped openings
`
`to accommodate the plurality of first fasteners and allow movement of the
`
`plurality of first fasteners within the curve-shaped openings, respectively, for
`
`rotational movement of the track plate with respect to the top plate, when the
`
`plurality of first fasteners are loosen, …”: Curved-shaped slots for adjusting a
`
`track plate with respect to a central axis were personally known to me before 2014,
`
`and more specifically as a means for mounting standard household smoke detectors
`
`and lighting fixtures. This technique, including slots, keyholes, and the like, has
`
`been well known to a PHOSITA. Bernhardt discloses curved openings 36, wherein
`
`fasteners 37 allow for rotation of the plate when the fasteners are loosened. Curved
`
`slots, wherein the center of rotation is coincident with the center of a circular plate,
`
`allow for symmetric and repeatable rotation. When a camera or lens is pointed at a
`
`field of view or specific object, symmetry of rotation can be beneficial.
`
`Adjustability of a group of cameras to view various scenes and the flexibility to
`
`detach/attach a track plate for easy service and replacement simplifies service time.
`
`Attaching a track plate to a top plate in a rotationally movable manner would have
`
`been obvious in light of Engstrom’s mounting ring 2. Engstrom’s mounting ring
`
`has curved slots, is planar, and provides a technique for loosening fasteners within
`
`the curved slots and adjusting the plate. This combination amounts to use of a
`
`
`
`19
`
`AXIS EXHIBIT 1016-19
`
`
`
`
`
`known technique to improve a similar device in the same, known way as claimed
`
`in the ‘782 Patent.
`
`39. Claim Element 1(i): “an opening for a cable coupled to the
`
`one or more electronic circuit boards.”: Providing openings in a plate for
`
`allowing wires or cables to pass is a known technique widely used with many
`
`electronic housings. Murphy I has holes in mounting disc 93 for pin connectors
`
`106 attached to cables 105, see Paragraph [0092], and additional holes such as a
`
`central opening and openings 135. Kim has an opening 18, see Figure 1, provided
`
`for electrical conductors to pass from within the security camera for connection to
`
`circuitry, and openings in the track plate 12 shown in Figure 6. Bernhardt’s shows
`
`a pipe 1 for passing conductors of signal and power to the camera. The pipe 1 is
`
`aligned to allow wires to pass directly through the multiple plate system. The
`
`teachings of the cited art would have made passing cables through an opening in
`
`track plates obvious to a person skilled in the art at the time. This combination
`
`amounts to use of a known technique to improve a similar device in the same,
`
`known way as claimed in the ‘782 Patent.
`
`40. Summary, Analysis, Motivations to Combine:
`
`a.
`
`Providing a highly adjustable field of view for mounted
`
`cameras. Murphy I and Murphy III both show an omnidirectional user
`
`
`
`20
`
`AXIS EXHIBIT 1016-20
`
`
`
`
`
`configurable multi-camera housing, with cameras configurable
`
`in various
`
`directions.
`
`b.
`
`Protecting electronics and optics from damage. Murphy
`
`I, Murphy II, Kim and Bernhardt show circuits protected within top plates of
`
`camera housing.
`
`c.
`
`Securing a base to a structure, and attaching a camera
`
`assembly to a movable track plate separately. This provides freer tool access to the
`
`structure and base and facilitates installation, service and adjustment. Applying the
`
`teachings of the Murphy I track plate 73 and fasteners 77, Bernhardt’s track plate
`
`having curved openings 36, or Engstrom’s mounting plate having curved openings
`
`10, as well as Kim’s attachment of the top plate 20 and track plate 12, would have
`
`resulted in securing the top plate and track plate while allowing for rotational
`
`movement when the fasteners are loosened.
`
`d. Mounting and positioning cameras in an easy manner by
`
`use of a bracket. Often the cameras must point at obscure angles with respect to the
`
`mounting surface for full visual coverage. This is clear from the disclosure of
`
`Murphy I bracket 95 attached around mounting disc 93, Kim’s base 20, and
`
`Murphy II item 14.
`
`
`
`21
`
`AXIS EXHIBIT 1016-21
`
`
`
`
`
`e.
`
`Protecting optics and electronics
`
`from potentially
`
`damaging elements and vandalism. Protective domes are seen in each of the prior
`
`art camera housings.
`
`f.
`
`Adjusting camera positions when it is necessary to
`
`monitor a specific area. Murphy I and Murphy II show track plates with multiple
`
`camera assemblies on brackets to fulfill the need for 360 degree monitoring, and
`
`the holes 94 in mounting disc 93 of Murphy I allow selective positioning of the
`
`brackets 95. Kim and Bernhard also show adjustable cameras. When potential 360
`
`degree views are needed at the same time, an obvious solution is to use multiple
`
`cameras, and all these references combine to suggest this obvious solution to a
`
`PHOSITA.
`
`g.
`
`Limiting or eliminating special tools needed for camera
`
`maintenance and adjustment. The track plates having curved openings such as
`
`Bernhardt and Engstrom, as well as the movable track plates of Murphy I and Kim,
`
`teach the solution to adjustability.
`
`h.
`
`Electronic communication with a circuit, while
`
`minimizing damage to wires and simplifying installation. A passage is the most
`
`obvious means for passing wire through a plate. This is shown, for example, in
`
`Murphy I with various holes in the track plate 93, and in Bernhardt through the
`
`
`
`22
`
`AXIS EXHIBIT 1016-22
`
`
`
`
`
`plate system 6. The references give a PHOSITA ample reason to provide a known
`
`cable passage in a track plate.
`
`41. The combination of all the previously disclosed prior art would
`
`have made the claimed solutions in the ‘782 Patent obvious to one skilled in the
`
`arts of component mounting technologies at a date prior to June 9, 2014.
`
`42. Each element of the above Claim 1 was disclosed and known
`
`prior to 2014. Combining all of these elements together would have been obvious
`
`to a PHOSITA, as the elements already had been combined to solve needs in the
`
`relevant field.
`
`Ground 1 Prior Art- Applied to Claim 3, “3. The omnidirectional
`
`user configurable multi-camera housing of claim 1, further
`
`comprising a cover gasket attached to the top plate for a
`
`weatherproof seal between the top plate and the cover.”
`
`43. My prior discussion of the Ground 1 Prior Art applied to Claim
`
`1 is incorporated herein.
`
`44. Bernhardt, Figure 1, shows sealing ring 29 between dome 21
`
`and housing jacket 20, for sealing between the top plate assembly and dome cover.
`
`Bernhardt’s gasket between the top plate and dome cover solves a problem of
`
`water or dirt infiltration inside the camera enclosure. Murphy II at Page 12, Lines
`
`17-19, teaches the lower cover (transparent dome) 3 and upper cover (top plate) 4
`
`
`
`23
`
`AXIS EXHIBIT 1016-23
`
`
`
`
`
`are provided with peripheral rims which are bolted to the platform 7 with the
`
`interposition of resilient sealing rings.
`
`45. My experience in the manufacture of optical equipment in the
`
`early 1980s taught me of the use of elastomer seals or gaskets, sometimes seated in
`
`annular grooves, to close a parting line. This technology, and its many variations,
`
`has been known to those skilled in the art before the stated invention date.
`
`Ground 1 Prior Art- Applied to Claim 4, “4. The omnidirectional
`
`user configurable multi-camera housing of claim 1, wherein the
`
`top plate includes a national pipe thread (NPT) port for cabling
`
`from the side of the camera assemblies.”
`
`46. My prior discussion of the Ground 1 Prior Art applied to Claim
`
`1 is incorporated herein.
`
`47. Kim, approximately in Column 2, Line 60, and in Figure 3,
`
`shows a knock-out access hole 22 for side electrical connections to be made to the
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`security camera housed within.
`
`48.
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`Installers of housings sometimes have options for mounting
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`surfaces (e.g., wall, soffit, fascia, or roof), depending on field conditions.
`
`Flexibility in housing mounting options is very desirable. A side acc
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