Elan Microelectronics Corporation v. Apple, Inc.

Filing 213

Declaration of Robert Dezmelyk in Support of 212 MOTION for Partial Summary Judgment of Infringement of U.S. Patent 5,875,352 [Public Version] MOTION for Partial Summary Judgment of Infringement of U.S. Patent 5,875,352 [Public Version] filed byElan Microelectronics Corporation. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Related document(s) 212 ) (DeBruine, Sean) (Filed on 5/24/2011)

EXHIBIT A

LCS/Telegraphics
Curriculum Vitae
Robert Dezmelyk
President
Personal:
Born 1956 in Philadelphia, Pennsylvania
Married with two children
Education:
BA Massachusetts Institute of Technology 1979
Special program in computer based control systems
Recent Continuing Education:
MCLE 2002 Conference on Intellectual Property - June 14, 2002
Employment History:
President and CEO of LCS/Telegraphics (“LCS”) since its formation in 1980. Consulting
and product development, with ongoing, direct involvement in hardware, firmware and
software engineering. Responsible for overall corporate management and strategy.
Formerly responsible for major account sales relationships as well as technical leadership
of the LCS engineering staff.
LCS presently develops and licenses designs and firmware for USB interfaces used in
input devices, instruments and medical devices. The company also provides specialized
hardware design and software and firmware development services and consulting for
companies incorporating USB interfaces into their products.
Historically, LCS was a leading supplier of input device software and engineering
services to input device manufacturers around the world. During its 30 years of operation
LCS has supplied technology to essentially all of the manufacturers of input devices, as
well as many of the world’s largest computer companies. Representative prior customers
or OEM licensees of LCS’ technology include Logitech, Microsoft, Alps, Mitsumi,
Synaptics, GTCOCalcomp, Wacom, Primax, Compaq, IBM, NEC, Sony, Sharp and
many others.
Prior to founding LCS - independent consulting, and software, hardware and firmware
development.

Expertise:
Personal computer input device architecture, standards and device drivers, including the
history and evolution of the technology. LCS has one of the world’s largest collections of
input devices and input device prior art.
Input device market opportunities, product design, and future technology evolution.
IBM Compatible PC operating systems architecture from MS-DOS through Windows
XP, including device driver and code installation architecture, systems programming, and
software development.
The history and evolution of PC applications software technology including user
interface designs, early GUI implementations, graphics editing programs, and the
interaction of the programs with input subsystems. LCS maintains an extensive collection
of early PC applications software.
Microprocessor based hardware and firmware design, particularly of input devices and
USB devices.
The industry standards process including negotiating compromises among multiple
competitive parties and reaching the consensus necessary for acceptance of a standard.
Reverse engineering of applications programming interfaces and software components,
including issues related to copyright infringement and legitimate functional reverse
engineering.
Detection and analysis of software for copyright infringement and strategies for the
prevention of intellectual property piracy by manufacturing partners.
The evaluation of user interfaces in terms of visual similarity, functional abstraction, and
usability.
Techniques for developing, maintaining and testing complex software code bases to
ensure high reliability even in the presence of frequent releases and multiple code
variants.
Human factors related to voting systems.
Industry Standards Activities:
Founder and Chairman, Committee For Advanced Pointing Standards, the group which
created the Wintab™ standard Applications Programming Interface for digitizing tablets
and other advanced pointing devices. 1991 to 2000.
Chairman, Universal Serial Bus Human Interface Device Working Group, the group
which created the USB HID standard. 1996 to Nov. 1998
Chairman Access.bus Software Working Group, part of the Access.bus industry
standards group which developed a predecessor to Universal Serial Bus. 1993 to 1995
Participant, Active PS/2 Multiplexing Specification project. 1998

Published Specifications:
Wintab™ Interface Specification 1.1, Revised May 9. 1996 (My employee R. Poyner
served as the named author of the specification. I had final editorial authority over the
publication) The specification is available at
http://www.csl.sony.co.jp/projects/ar/restricted/wintabl.html.
Universal Serial Bus HID 1.0 Specification, January 30, 1996 (My employee S.
Schumacher served as the named editor, I had final editorial authority over the
publication, subject to the votes of the committee I chaired) The latest version of the
specification is available at http://www.usb.org/developers/devclass_docs/HID1_11.pdf.
Access.bus Specification, sections on locator devices, software interfaces. September
1995. Available at http://www.mcc-us.com/abspec30.htm.
Active PS/2 Multiplexing Standard, October 6, 1998. (Edited by Dave Gillespie at
Synaptics, I was a contributor to the specification.) The specification is available at
http://www.synaptics.com/decaf/utilities/ps2-mux.PDF
Other Industry Groups
Member, IEEE
Former Member of the American Society of Photogrammetry, American Committee for
Interoperable Systems (ACIS), and the Audio Engineering Society.
Other Activities:
United States Election Assistance Commission Standards Board 2009 to the present
New Hampshire State Disabilities Access and Voting Systems Task Force 2005
Moderator, Town of Newton, New Hampshire 2002 to the present
Assistant Moderator, Town of Newton, New Hampshire 1999 to 2002
Chairman, Newton School Study Committee, Town of Newton, New Hampshire 1995
Expert Consultancy:
Undisclosed Client, for the plaintiff
Forensic analysis of object code established that defendant had copied plaintiff’s
proprietary machine control software. Case settled as a result.
Undisclosed Client
Review of claim construction and prior art for several patents.
Undisclosed Client
Review of claim construction and prior art for several patents. Non-infringement
strategy.

Undisclosed Client, for the defendant
Review and analysis of software that plaintiff contended infringed his copyrights. Case
settled.
Undisclosed Client, for the defendant
Review of prior art for several patents related to game controller technology.
Undisclosed Client
Review of a patent portfolio related to input device and remote controller technology.
Undisclosed Client
Review of patents related to portable computer technology.
Undisclosed Client, for the defendant
Review of prior art from LCS’ archives which anticipated a patent related to input
devices. Case settled.
Undisclosed Client, for the defendant
Technical consulting and review of prior art related to input device interfaces.
Undisclosed Client
Review of patents related to serial bus interface technology
Undisclosed Client
Technical consulting regarding a touch sensing device

Testimony:
Schumer v. Lab. Computer Sys., Inc., No. C99-0474L (W.D. Wash. Oct. 16, 2001)
Patent dispute regarding input device technology.
Computer Access Technology Corporation v. Catalyst Enterprises, Inc. (Dec. 2000
Northern District of California)
Trade dress/Trademark infringement dispute regarding a user interface.
Trading Technologies International, Inc. v. eSpeed, Inc. et al, No. 04 C 5312 (September
2007) Patent dispute regarding a user interface
Smart Technologies Inc v. Polyvision Corporation, No. 1:04-cv-713 (November 2007)
Patent dispute regarding input device technology.
Anascape Ltd. v. Microsoft and Nintendo of America, Inc. No.: 9:06-CV-00158-RC
(Eastern District of Texas, May 2008)
Patent dispute regarding input device technology

Primax Electronics Ltd. v. KYE Systems America Corp. No. CV 09-02821 RGK (FFMx)
(Central District of California, May 2010)
Patent dispute regarding input device technology
Elan Microelectronics Corp. v. Apple, Inc. No. 09-cv-01531 RS
(Northern District of California)
Patent dispute regarding input device technology