Case Nos. IPR2015-01470, -01471, -01472, -01473, -01474 and -01475 5 International Conference on March 29 - April 2, 2009 (“Luo”) (Ex. GOOG 1017). 5. I have also considered the viewpoint of a person of ordinary skill in the art prior to September 28, 2010. I am familiar with the technology at issue as of the September 28, 2010, the effective filing date of the parent ’522 patent. I am also familiar with the level of ordinary skill in the art with respect to the technology at issue as of the September 28, 2010. III. My Background and Qualifications 6. In formulating my opinions, I have relied upon my training, knowledge, and experience in the relevant art. A copy of my current curriculum vitae is provided as Ex. 2016 and provides a comprehensive description of my academic and employment history over the last thirty-plus years. 7. I attended Michigan State University from 1977 to 1981 as a Merit Scholar and an Alumni Distinguished Scholar, and received a bachelor’s degree in Chemistry. I later attended Carnegie Mellon University from 1988 to 1995, during which time I received both a master’s degree (1992) and a Ph.D. (1996) in Computer Science. My dissertation was entitled “Safe and Efficient Persistent Heaps” and focused on high performance automatic storage management for advanced database systems. 8. Before earning my Ph.D., I worked for over four years in industry at e.Digital Corporation Exhibit 2015 - Page 7 Case Nos. IPR2015-01470, -01471, -01472, -01473, -01474 and -01475 6 Silicon Solutions, Inc. and Digital Equipment Corporation, developing computer aided design (CAD) software for the semiconductor and computer sectors. For example, I designed and implemented systems for VLSI mask generation and VLSI design rule checking. I also built the first graphical drawing editor for the X window system, Artemis, which included a sophisticated graphical user interface. 9. I have worked as a professor at three universities since 1995: the University of Pennsylvania, the University of Arizona, and The University of Texas at Austin. I was the recipient of a National Science Foundation CAREER award for “CAREER: Advancing Experimental Computer Science in Storage Management and Education” while I was an Assistant Professor at the University of Pennsylvania. During this time, I also was part of the DARPA-funded SwitchWare project, which was one of the pioneering groups in the area of Active Networking (“AN”). My group developed PLAN, the first domain-specific programming language for programmable packets, as well as PLANet, the first purely active inter-network. 10. I joined the faculty of The University of Texas at Austin (“UT”), in the Department of Electrical and Computer Engineering in 1999. In 2005, I was appointed Associate Professor with tenure. At UT, I continued to develop AN technology and in 2002, my Ph.D. student, Michael Hicks, won the ACM SIGPLAN dissertation award for our joint work on software updating. e.Digital Corporation Exhibit 2015 - Page 8 Case Nos. IPR2015-01470, -01471, -01472, -01473, -01474 and -01475 7 11. Along with my Ph.D. student, Seong-kyu Song, I focused my AN work on mobile and wireless networking. As a result, my research shifted away from AN to mobile and wireless networking in general, especially interactions between the network, the radios, and the physical world. My most recent research involves the development of Hydra, which is a working prototype of an advanced software-implemented WiFi network funded primarily by NSF. 12. My CV contains an extensive listing of my teaching experience, but a summary is useful. At all three universities my teaching responsibilities spanned undergraduate, graduate, and Ph.D. level instruction. Most recently, at the undergraduate level, I generally teach our second programming class (Intro to Java), Operating Systems, and Networking. At the graduate level I have generally taught networking or computer architecture. At the PhD level, in addition to individual instruction, I have recently regularly taught and advanced seminar most recently labeled “Wireless and Mobile Networking.” This class is a seminar in which the students read papers and then do group projects with reports and presentations on topics of interest. One of my colleagues, Christine Julien, works in part in the area of context awareness. Her students regularly took this class and did projects in this area. 13. In the spring of 2013, I left my full time position at UT and I now work as a consultant and expert witness. e.Digital Corporation Exhibit 2015 - Page 9
Case Nos. IPR2015-01470, -01471, -01472, -01473, -01474 and -01475 8 IV. Legal Principles A. Claim Construction 14. I understand that claims are construed from the perspective of a person of ordinary skill in the art at the time of the claimed invention (“POSA”). I further understand that, during inter partes review, claims must be given their broadest reasonable interpretation (“BRI”) in light of the specification of the subject patent, which means that the words of the claims should be given their broadest possible meaning consistent with the specification of the subject patent. I also understand that the BRI used here may be different from the interpretation that a POSA may give to the claims in another context—e.g., in litigation—and that the broadest reasonable interpretation may be informed by the construction advanced by a patentee in litigation. B. Obviousness 15. I understand that an obviousness analysis involves comparing a claim to the prior art to determine whether the claimed invention would have been obvious to a POSA in view of the prior art and in light of the general knowledge in the art at the time of the invention. I also understand that when a POSA would have reached the claimed invention through routine experimentation, the invention may be deemed obvious. 16. I also understand that combining or modifying the teachings of the e.Digital Corporation Exhibit 2015 - Page 10
