Free Claim Construction Opening Brief - District Court of Delaware - Delaware

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HW THE UNITED STATES DISTRICT COURT _
FOR THE MSTRICT OF DELAWARE

A Plaintiff, g
) Civil Action No. G4-1231 (SLR)
1:. )
- )
RADIANSE, INC., )
Defendant. g
DECL;&][[Q§ QE EQNQX 'K`EN§VI’I`Z
I, Henry Tenrrrvitz, hereby deciere under penalty of perjury that the following facts set
forth herein are true and correct, and, if celled as c witness, I could and would testify
competently es sel: forth below:
1. I om the president of the P§air1tiff, Versus Technology, Inc. ("Versus").
2. I have taken various courses from Michigan State University and Nortlzwestem
Michigan College studying mathematics, physicai sciences and software engineering. I continue
to enhance my knowledge base through s process of self teaching and practice.
3. In have 25 years experience in the fields of process engineering, automation
soitwere design and msmxfsemring. I have 10 years experience in the fields of indoor wireless
locating equipment design and manufacture, indoor wireless system design and the deployment
and the use of indoor wireless systems to automate various processes.
4. It is generally understood in the indoor wireless locating industry that wireless
transmitters contain modulators for modulating some or all of the transmission to encode the

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signal so that the transmitter signai may be distinguished from background noise or other
devices.
5. It is generally understood in the indccz wireless locating industry that, in order to
mmsmit an identifying code that is unique to the transmitter as disclosed in claim 1 of U.S.
?atcnt Nc. 5,027,314 ("t.hc ’3 E4 patcnt"), only the following structures are necessary: a timer,
programmable memory (PROM), and an IR cmitzcr.
6. It is generally understood in the indoor wireless locating industry that processors
are components to computers, and ozhcxlcicctrcxlic devices, that can been preprogxanuncd tc
perform commands and trmxsmit/receive data.
7. It is generally understood in the indoor wireless locating inéustry thai term
"p1·occssm·s" may refer to one or more micmprc ccssurs andlor a central processor.
8. It is generally unécrstood in thc indoor wireless iocating industry that processors
can be programmed to peyfomx mncticns, such as raccmding data (ag., received sigzms) or
processing data (ag, determining Eccation).
9. It is generally understood in the indoor wéraiess locating industry ihat processors
can bc pmgzammad ua mmrd, scam and accumulate data.
l0. it is gcncraiiy undcrstc cd in the indoear wixclcss locating industry that signals
scm Exam sensors are clcctricai signals.
H. It is gcucmlly understood in the indoor wirclcss locating industry that the only
structures necessary to scné and rcccivc messages over a computer network in a variable-based
pmtaccl that implements object identifier variables as disclosed in ciaim 1 of UZS. Patent N0,
2

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5,5 72,195, arc the compute: network and contra} processor or computer disclosed in the claim
and tho specification.
Puxsuant to 28 U.S.C. § 1746, I declare under penalty of perjury undo: the iaws of the
United States of America that the foregoing is tmc and correct This Declaration is executed this
3‘° day ofNov¢m`¤c1·, 2005.
Henry Tooarvitz
3