UNITED STATES PATENT AND TRADEMARK OFFICE
`
`________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________________
`
`LUTRON ELECTRONICS CO., INC.
`
`Petitioner
`
`v.
`
`GEIGTECH EAST BAY LLC
`
`Patent Owner
`
`_______________________
`
`U.S. Patent No. 10,294,717
`
`DECLARATION OF JAMES GEIGER IN SUPPORT OF
`0$3’.3 /5.’192 01’,*-*.$16 1’20/.2’
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`GeigTech East Bay LLC Ex. 2001
`U.S. Patent No. 10,294,717
`
`
`
`________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________________
`
`LUTRON ELECTRONICS CO., INC.
`
`Petitioner
`
`v.
`
`GEIGTECH EAST BAY LLC
`
`Patent Owner
`
`_______________________
`
`U.S. Patent No. 10,294,717
`
`DECLARATION OF JAMES GEIGER IN SUPPORT OF
`0$3’.3 /5.’192 01’,*-*.$16 1’20/.2’
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`GeigTech East Bay LLC Ex. 2001
`U.S. Patent No. 10,294,717
`
`
`
`Case PGR2020-00012
`Patent 10,294,717
`
`My name is James Geiger, and I declare as follows:
`
`1.
`
`I am the founder and president of GeigTech East Bay LLC, doing business as
`
`J. Geiger Shading.
`
`2.
`
`= NZ ‘UR _\YR V[bR[‘\^ \S H)F) DN‘R[‘ BaZOR^ +*’,3.’1+1 R[‘V‘YRQ gFUNQR
`
`6^NPXR‘ cV‘U 7\[PRNYRQ JV^V[T)h
`
`3.
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`GUR i1+1 ]N‘R[‘ V_ ]N^‘ \S N YN^TR^ ]\^‘S\YV\ \S patents related to exposed
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`window shade systems and related hardware.
`
`4.
`
`I graduated college in 1998 with a B.S. in Business Administration from The
`
`College of Charleston.
`
`5.
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`I have over 20 years of experience in home electronic systems and technology,
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`including designing, manufacturing, and installing window shade systems.
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`6.
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`I started my own AV integration company in 2003 (HeAVi LLC). AV
`
`integration involves the installation and coordination of various types of home
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`electronic systems and technology, such as home theater, audio systems, lighting
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`systems, and window shades. I first began installing window shades as an integrator
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`around 1999.
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`7.
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`In 2007, HeAVi was awarded Best Hidden Installation by the Custom
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`Electronic Design & Installation Association (CEDIA) for a hidden television design
`
`and installation that I was responsible for.
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`1
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`
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`Case PGR2020-00012
`Patent 10,294,717
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`8.
`
`Traditionally, the shade assemblies themselves were a design afterthought.
`
`That is because V‘ cN_ _‘N[QN^Q ‘\ P\[PRNY Z\a[‘V[T UN^QcN^R cV‘U N gPRVYV[T
`
`]\PXR‘’h gbNYN[PR’h \^ gSN_PVN)h Around 2011, I devised a new solution for
`
`concealing screws, wires, and other hardware. My concept involved exposed
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`window roller shades without any visible screws, wires, or other unsightly hardware.
`
`GUV_ P\[PR]‘ c\aYQ aY‘VZN‘RYe ORP\ZR ‘UR g> ;RVTR^ FUNQV[T Fe_‘RZh and is
`
`RZO\QVRQ V[ ‘UR i1+1 ]N‘R[‘)
`
`9.
`
`I have reviewed the Petition in both PGR2020-00012 and PGR2020-00013.
`
`10.
`
`This declaration focuses on a few technical aspects of how the Petition alleges
`
`7\Y_\[i_ :VTa^R + Sa[P‘V\[_ V[ D;E,*,*-0012. I reserve the right to provide
`
`additional opinions on either post-grant review petition later, if necessary.
`
`11. <R^R V_ 7\Y_\[i_ :VTa^R + N_ V‘ N]]RN^_ V[ ‘UR ^RSR^R[PR cV‘U Ze [\‘R_ N[Q
`
`cV‘U\a‘ DR‘V‘V\[R^i_ N[[\‘N‘V\[_) EX1005, FIG. 1.
`
`2
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`Case PGR2020-00012
`Patent 10,294,717
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`The wire is outside the
`
`bracket. There is a clear
`
`gap between the wire
`
`and the bracket.
`
`Drill bits cannot drill a
`
`sweeping turn like this.
`
`12.
`
`Petitioner alleges the wires 130 pass inside the bracket, make a sweeping turn,
`
`and then enter the frame 120. Petition at 46.
`
`13.
`
`This cannot be true, and a POSITA with actual experience designing or
`
`installing window shade assemblies would immediately recognize the wires run
`
`outside the bracket. First, given my experience in the industry designing,
`
`manufacturing, and installing shade assemblies, the wires do not, and cannot, pass
`
`through the bracket as Petitioner alleges. The bracket does not have enough depth
`
`(from left to right above) for there to be such a passage. The passage would need to
`
`3
`
`
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`Case PGR2020-00012
`Patent 10,294,717
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`be larger than the wire (which the figure does not show), and there is no room to
`
`Q^VYY _aPU N ]N__NTR V[ ‘UR O^NPXR‘ \S 7\Y_\[i_ Figure 1. I have drilled many such
`
`passages and worked with others to do the same. It simply cannot be done. The
`
`bracket would break or crack if you tried to drill such a passage.
`
`14. And second, it is not possible to drill a passage with the sweeping turn the
`
`wire and the passage allegedly makes in the illustration above. There is no such drill
`
`or drill bit that would allow someone to drill a path as Petitioner alleges. So even if
`
`V‘ cN_ ]\__VOYR ‘\ Q^VYY _\ZR _\^‘ \S ]N__NTR V[ ‘UR O^NPXR‘ \S 7\Y_\[i_ :VTa^R + %V‘
`
`V_[i‘&’ ‘UR^R V_ [\ cNe TVbR[ RbR[ Pa^^R[‘ ‘RPU[\Y\Te’ YR‘ NY\[R ‘RPU[\Y\Te N‘ ‘UR
`
`‘VZR \S ‘UR i1+1 ]N‘R[‘’ ‘\ Q^VYY N ]N__NTR ‘UN‘ ZNXR_ _aPU a sweeping turn.
`
`DR‘V‘V\[R^i_ NYYRTRQ ]N__NTR PN[[\‘ RdV_‘ N_ V‘ c\aYQ OR VZ]\__VOYR ‘\ Q^VYY _aPU N
`
`passage.
`
`15.
`
`Third, there is no basis from a design perspective that would run one wire
`
`through the bracket and one wire outside the bracket as allegedly shown V[ 7\Y_\[i_
`
`Figure 1. There would be no benefit to run less than all the wires through the bracket
`
`because wire would still be exposed, defeating the whole purpose of running any
`
`wire through the bracket in the first place. So a designer would not go through the
`
`engineering effort and expense involved to drill a passage for less than all the wire.
`
`Someone designing a shade system would either run both wires or none of the wires
`
`through the bracket. Because the wire on the right is clearly not passing through the
`
`4
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`Case PGR2020-00012
`Patent 10,294,717
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`bracket, there is no reason to assume the first wire is. Instead, both wires are outside
`
`the bracket.
`
`16. Not only is it technically impossible for both wires to extend through a
`
`]N__NTR V[ ‘UR O^NPXR‘ \S 7\Y_\[i_ :VTa^R +’ Oa‘ ‘UN‘ c\aYQ OR V[P\[_V_‘R[‘ cV‘U ‘UR
`
`drawing in general and the way the industry was operating before I invented my
`
`exposed shade systeZ) 5_ V_ _U\c[ V[ 7\Y_\[i_ :VTa^R +’ ‘UR _P^Rc N‘‘NPUV[T ‘UR
`
`bracket to the wall or other surface is exposed. In addition to the wiring, this is
`
`another indication that this bracket was not mean to be exposed. Instead, it would be
`
`hidden behind N gPRVYV[T ]\PXR‘’h gbNYN[PR’h \^ gSN_PVN)h For example, the following
`
`V_ S^\Z N @a‘^\[ ZN[aNY N[Q V_ P\[_V_‘R[‘ cV‘U ‘UR QV_PY\_a^R V[ 7\Y_\[i_ :VTa^R +)
`
`EX. 2003 at 10.
`
`5
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`
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`Case PGR2020-00012
`Patent 10,294,717
`
`As you can see, the wires do not run through the bracket. And the screws are exposed
`
`just like Colson, which is an indication the bracket was intended to be hidden behind
`
`another structure.
`
`17.
`
`:V[NYYe’ ‘UR^R V_ [\‘UV[T NO\a‘ 7\Y_\[i_ :VTa^R + ‘\ _aTTR_‘ ‘UR cV^R ]N__R_
`
`through the bracket. The wire is not shaded, cross-hatched, or otherwise changed to
`
`V[QVPN‘R ‘UN‘ V‘ V_ UVQQR[ cV‘UV[ ‘UR O^NPXR‘) GUV_ V_ V[ _‘N^X P\[‘^N_‘ ‘\ ‘UR i1+1 ]N‘R[‘
`
`as shown below and technical drawings generally.
`
`18.
`
`=[ ‘UR R[Q’ DR‘V‘V\[R^ V_ \[Ye NOYR ‘\ ZNXR V‘_ N^TaZR[‘ ORPNa_R 7\Y_\[i_
`
`Figure 1 is a two-dimensional drawing that obscures depth. If shown in three-
`
`QVZR[_V\[_’ 7\Y_\[i_ :VTa^R + c\aYQ Y\\X YVXR ‘UR @a‘^\[ VZNTR NO\bR) =‘ PR^‘NV[Ye
`
`c\aYQ [\‘ Y\\X YVXR ‘UR VZNTR S^\Z ‘UR i1+1 ]N‘R[‘ _U\c[ ORY\c’ cUR^R ‘UR^R V_ N
`
`clearly marked passage for the wire to pass through. EX 1001, Fig. 21.
`
`19.
`
`:\^ N‘ YRN_‘ ‘UR_R ^RN_\[_’ ‘UR cV^R_ V[ 7\Y_\[i_ :VTa^R + Za_‘ ]N__ \a‘_VQR ‘UR
`
`O^NPXR‘ N[Q DR‘V‘V\[R^i_ g]N__NTRh PN[[\‘ RdV_‘ N_ ]N^‘ \S 7\Y_\[i_ :VTa^R +)
`
`6
`
`
`
`I declare that the above is true and correct to the best of my knowledge. I make this
`
`Case PGR2020-00012
`Patent 10,294,717
`
`declaration under the penalty of perjury.
`
`Executed on May __, 2020.
` 6
`
`_________________________________________
`James Geiger
`
`7
`
`
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