WI-LAN Inc. v. Alcatel-Lucent USA Inc. et al

Filing 185

RESPONSE in Opposition re 174 MOTION for Partial Summary Judgment that Patent Claims Are Indefinite filed by WI-LAN Inc.. (Attachments: # 1 Exhibit A - Declaration of Jonathan Wells, # 2 Exhibit 1 - ISO Declaration of Jonathan Wells - Jonathan Wells CV, # 3 Exhibit B - Wi-Lan's proposed constructions for "means" terms, # 4 Text of Proposed Order)(Weaver, David)

EXHIBIT 1

Jonathan Wells, Ph.D., M.B.A.
Pleasanton, CA 94566, USA
Phone: [phone]
Email: [e-mail]
Web: www.ajisconsulting.com

Wireless Technology Expertise
Cellular Networks (2G, 3G, 4G, GSM,
GPRS, EDGE, UMTS, WCDMA, HSPA,
HSDPA, HPSA+, LTE and LTE-Advanced)
Cellular Infrastructure Equipment (Base
Stations, Backhaul and Handsets)
Radio Frequency (RF), Microwave and
MM-Wave Devices, Systems and Networks

RF Design, including RF Assemblies,
Subassemblies and Components
Wireless Standards, Rules and
Regulations (3GPP, 3GPP2, FCC,
ETSI, CEPT)
Intellectual Property, Patent
Infringement and Litigation Support

Professional Summary
Dr. Wells has over 20 years of wireless technology experience gained from working in three
continents. He is currently an independent consultant providing expertise on cellular technologies,
wireless devices, network infrastructure and wireless rules and regulations to a client base of
attorneys, intellectual property organizations, investment and research institutions, public listed and
private companies. Dr. Wells has 40 academic and commercial publications and presentations, and is
lead inventor on three patents. He is Senior Member of the IEEE and is author of “Multi-Gigabit
Microwave and Millimeter-Wave Wireless Communications,” Artech House, 2010.

Employment History
2007 to present AJIS LLC, Pleasanton, CA Independent Consultant
Managing Partner of AJIS LLC, an independent consulting firm specializing in wireless
technology and emerging wireless fields. His consulting experience includes:
Expert witness and expert consulting support of 3G and 4G wireless patent litigation.
Multiple projects analyzing 3GPP WCDMA and LTE patents and infringing equipment.
Cellular backhaul and wireless technology consulting for investment and research
institutions.
Wireless product development and marketing strategies for NYSE and NASDAQ-listed
public companies, private entities and startups.
Specialized technical workshops on various wireless technologies; including cellular
networks, mm-wave radios, security sensors and short range radios.
Specialized global regulatory tasks and product approvals for consortium of US and
international wireless companies.

March 2012

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Resume: Dr. Jonathan Wells

2005 to 2007

[phone]

GigaBeam Corporation, Herdon, VA
Director Product Management and Global Regulatory Affairs

Responsible for overall product strategy for industry-transforming 1.25 Gbps (1,250 Mbps)
wireless products. Setup global regulatory framework for 71-76 / 81-86 GHz bands.
Participated in FCC, CEPT, ETSI and other technical body meetings. Initiated market
development in over 40 countries including Europe, Canada, Caribbean, Latin America, Middle
East and Asia.
2000 to 2004

Stratex Networks (now Aviat Networks), San Jose, CA
Director Product Development

Responsible for global product development of Outdoor Unit (ODU) portfolio of high-end
digital microwave radios primarily for cellular backhaul applications.
Led RF/microwave development team of 35, with $5M annual budget.
Technical leadership of flagship Eclipse product providing 6-622 Mbps data at 5-40 GHz.
Product shipped over 150,000 units. Managed full product lifecycle. Innovative design
drove 7 patents and yielded several technology and low cost manufacturing breakthroughs.
Technical management of overseas manufacturing subcontractors.
1998 to 2000

Adaptive Broadband (now GE Digital Energy), Rochester, NY
1999-00: Director Wideband Products, 1998-9: Engineering Group Leader

Full responsibility for the Terrestrial Infrastructure Group.
P&L responsibility for $4M wireless division.
Increased revenue 200% over 4 quarters through new products and product repositioning.
Responsible for the development of the LEDR II family of digital radios.
1994 to 1998

MAS Technology (now Aviat Networks), Wellington, New Zealand
1995-98: RF Group Manager, 1994-95: Senior RF Design Engineer
Responsible for RF hardware development for advanced 330 MHz to 7 GHz telecommunication
equipment for worldwide export.
Led development of three families of innovative wireless products.
Responsible for company’s European regulatory approvals.
Personally designed wide range of RF devices.
1993 to 1994

Matra Marconi Space, Portsmouth, UK Senior Design Engineer

Developed X-band GaAs MMIC mixer and L-band upconverter / amplifier and low noise VCO.
1990 to 1992

University of Bath, Bath, United Kingdom Post Doctoral Research Officer

Fabricated novel quantum amplifiers in clean room environment. Demonstrated negative
resistance for oscillator applications.
Developed numerical models to predict mm-wave performance. Built and verified
performance in 94 and 183 GHz systems. Extended theoretical simulations to 600 GHz.

January 2012

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Resume: Dr. Jonathan Wells

[phone]

Education
Year
2004
1998

College/University
Stanford Executive Institute,
Stanford University, CA, USA
Massey University, New Zealand

1991
1987

University of Bath, United Kingdom
University of Bath, United Kingdom

Degree
Graduated from 10-day, full-time executive
management course
M.B.A. (Graduated top 10% of class with
Distinction)
Ph.D., Microwave Physics
B.Sc., Physics with Physical Electronics
(Graduated 3rd in class with 1st Class Honors)

Expert Witness Experience
Several cases in process, where complaint has not yet been served. Filed cases include:
Sept 2011 to
present

[Specifics withheld. Case still in progress]
Case: Patent infringement case relating to one 3G WCDMA patent
Role: Testifying expert for defendant

Mar 2011 to
present

[Specifics withheld. Case still in progress]
Case: Patent infringement case relating to four 3G HSPA patents
Role: Testifying expert for plaintiff

Oct 2010 to
Jan 2011

People of the State of California v. Wandrey, CR920809
Case: Criminal murder case involving location via cell phone
Role: Retained by defendant to provide technical evaluation

Sept 2010 to
Oct 2010

People of the State of California v. Tran, CC826024
Case: Criminal murder case involving location via cell phone
Role: Retained by defendant to provide technical evaluation

May 2010 to
Apr 2011

People of the State of California v. Rivas & Carrillo, SS090603A/B,
SS110071A/B
Case: Criminal murder case involving location via cell phone
Role: Testifying expert for defendant. Testified in court. Provided expert
report

June 2009 to
June 2010

American Traffic Solutions v. Redflex Traffic Systems, CV 08-2051-PHX-FJM
Case: Unfair competition related to FCC authorization of speed radars
Role: Testifying expert for plaintiff. Provided expert report, supplement to
expert report and declaration

January 2012

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[phone]

Professional Affiliations and Achievements
2009 – present

Co-chair, Intellectual Property Special Interest Group (IP SIG), IEEE
Consultants’ Network of Silicon Valley (CNSV)

2008 – present

Member, IEEE Consultants’ Network of Silicon Valley (CNSV)

2008 – present

Manger and Moderator, LinkedIn MM-Wave Special Interest Group

1995 – present

Senior Member, Institute of Electrical and Electronic Engineers (IEEE).
(Member since 1995; Senior Member since 1999)

1995 – present

Member, IEEE Microwave Theory and Techniques Society (MTT-S)

2011 – 2012

Technical Reviewer, Wireless and Cellular Communication Systems,
International Microwave Symposium (IMS2011 and IMS2012)

2010

Guest speaker, Carnegie Mellon University (CMU) course 96-833:
Fundamental Consulting Skills

2009

Reviewer for US Government’s Broadband Technology Opportunity Program
(BTOP) and Broadband Initiatives Program (BIP), part of American Recovery
and Reinvestment Act of 2009

2009

Selected Expert Advice columnist for Microwave Journal

2009

Session chair, International Microwave Symposium (IMS2009)

2008

Co-chair and organizer, IWPC workshop on Millimeter-Wave Security Sensors

2008

Co-chair, IWPC workshop on Extending the Life of GSM & EDGE Networks

2008

Co-chair, IWPC workshop on Wireless IP/Ethernet Backhaul for Next
Generation Mobile Networks

2005 – 2006

Member, European Conference of Postal and Telecommunications
Administrations Spectrum Engineering Group 19 (CEPT SE19)

2005 – 2006

Member, European Telecommunications Standards Institute Transmission and
Multiplex Group 4 (ETSI TM4)

2002 – 2006

Member and deputy chair, Wireless Communications Association (WCA) 40+
GHz Spectrum Development Committee

2001 – 2004

Member, Cal Poly Electrical Engineering Industrial Advisory Committee

1993 – 2002

Member, Institution of Electronic Engineers (MIEE)

1987 – 1995

Member, Institute of Physics (MInstP)

1995

Registered as Chartered Engineer (CEng)

1990

Registered as Chartered Physicist (CPhy)

January 2012

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Publications and Presentations
Books and Published Research Reports
J.A. Wells, “Backhaul for Small Cells,” Mobile Experts, Oct. 2011
J.A. Wells, “Multi-Gigabit Microwave and Millimeter-Wave Wireless Communications,” Artech
House, Boston, Sept. 2010 (ISBN 1608070824)
J.A. Wells, “Venture Capital: Does It Exist In New Zealand?” MBA Thesis, Massey University, 1998
J.A. Wells, “The Design and Optimisation of a Millimetre-Wave Balanced Mixer,” PhD Thesis,
University of Bath, 1991
Publications
J.A. Wells, “The Seven Rules for Hiring a Wireless Technology Expert,” New Matter; Official
Publication of the Intellectual Property Section of the State Bar of California, Vol. 35, No. 4, pp.
5-6, Dec. 2010
J.A. Wells, “MM-Waves in the Living Room: The Future of Wireless High Definition
Multimedia Connectivity,” Microwave Journal, Vol. 52, No.8, pp. 72-84, Aug. 2009
J.A. Wells, “The Gigabit Millimeter-Wave Superhighway,” Microwave Journal Online, Expert
Advice Blog, Aug. 2009 (Invited Column)
J.A. Wells, “Faster Than Fiber: The Future of Multi-Gb/s Wireless”, IEEE Microwave
Magazine, Vol. 10, No.3, pp. 104-112, May 2009 (Invited Paper)
J.A. Wells, “Multigigabit Wireless Technology at 70, 80 and 90 GHz,” RF Design, pp. 50-58, May
2006
J.A. Wells, “Gigabit per Second Wireless Backhaul at 70 and 80 GHz for WiMAX Networks,” Focus
on Technology supplement in Wireless Design and Development, pp. S6-S8, May 2006
J.A. Wells, “New Multi-Gigabit Wireless Systems Satisfy High Security Rapid Response
Applications,” Military Embedded Systems, Vol. 2, No. 1, pp. 22-26, Spring 2006
J.A. Wells, “Multi-Gigabit Connectivity at 70, 80 and 90 GHz,” Microwave Journal, pp. 128-135, July
2005
J.A. Wells, “Millimeter Wave Point-To-Point Radios,” Applied Microwave and Wireless, pp. 81-82,
Aug. 2002 (Guest Editorial)
J.A. Wells and N.J. Cronin, “Theoretical Analysis of Air Bridging and Back Etching Techniques on
the Shunt Capacitance of Planar Subharmonic Mixer Diodes,” IEE Proceedings - Part H, Vol. 140,
No. 6, pp. 474-80, Dec. 1993
J.A. Wells and N.J. Cronin, “Frequency Dependant Simulation of Planar Millimeter-Wave Mixer
Diodes,” 17th International Conference on Infra-Red and Millimeter Waves Digest, USA, pp. 214-5,
Dec. 1992
J.A. Wells and N.J. Cronin, “Determination and Reduction of the Capacitance Associated with the
Bonding Pads of Planar Millimeter-Wave Mixer Diodes,” IEEE Microwave and Guided Wave Letters,
Vol. 2, No. 7, pp. 297-9, July 1992

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J.A. Wells and N.J. Cronin, “Planar Schottky-Diode Devices for Millimetre-Wave Balanced Mixer
Applications,” 21st European Microwave Conference Digest, Germany, pp. 370-5, Sept. 1991
N.J. Cronin, R. James and J.A. Wells, “Subharmonic Mixers for Short Millimetre Wavelengths,” 16th
International Conference on Infra-Red and Millimeter Waves Digest, Switzerland, p. 143, Aug. 1991
J.A. Wells, N.J. Cronin and P.H. Reece, “A Rugged 94GHz Crossbar Balanced Mixer,” IEE
Proceedings - Part H, Vol. 137, No. 4, pp. 235-7, Aug. 1990
J.A. Wells, N.J. Cronin and P.H. Reece, “A Rugged 94GHz Millimetre-Wave Balanced Mixer,” 1st
International Conference on Millimeter Waves and Far-Infrared Technology Digest, China, pp. 254-6,
June 1989
Presentations
J.A. Wells, “Building a Successful Consulting Practice,” Carnegie Mellon University (CMU)
course 96-833: Fundamental Consulting Skills, USA, May 2011
J.A. Wells, “Faster Than Fiber: Enabling Multi-Gigabit Wireless Communication Links,” IEEE
International Microwave Symposium IMS 2009, USA, June 2009
J.A. Wells, “The Future of Cellular Infrastructure,” IEEE CNSV, USA, Mar. 2009
J.A. Wells, “Wireless Backhaul Trends: The Future Role of Wireless, Fiber Optics and Copper
Wire,” IEEE-SCV Communications Society, USA, Oct. 2008
J.A. Wells, “Millimeter-Wave Sensor Systems Benchmarking for Security Applications,” IWPC
Workshop on MM-Wave Sensors for Layered Security of Critical Infrastructure, USA, April
2008
J.A. Wells, “Marketing for Translators and Interpreters,” Northern California Translators
Association Workshop, USA, Mar. 2007
J.A. Wells, “WiFiber: New Spectrum Links for Wireless Gigabit Transmission,” ACM/IEEE
conference on Supercomputing SC06, USA, Nov. 2006
J.A. Wells, “WiFiber Wireless Fiber: Ultra High Data Rate Radios,” Wireless Fibre Amsterdam, The
Netherlands, Sept. 2006 (Keynote Speaker)
J. Krzywicki and J.A. Wells, “Gbps+ Wireless Local Loop: Transforming Last Mile Economics,”
USTA Webinar, Aug. 2006
J. Krzywicki and J.A. Wells, “WiFiber: New Spectrum Links for Wireless Gigabit Local
Broadband,” Internet 2 Spring Meeting, USA, April 2006
J.A. Wells, “Multi-Gigabit Wireless Backhaul at 70 and 80 GHz for WiMAX Networks,” PTC’06,
USA, Jan. 2006
J.A. Wells, “Future Trends in MM-Wave Radios for Wireless Backhaul Applications,” IWPC
Workshop on Millimeter Wave Backhaul and 60 GHz Unlicensed Band Radios, USA, June 2002
J.A. Wells, “Millimeter Wave Point-To-Point Radios for Carrier Class Access and Transport
Applications,” 8th WCA Technical Symposium Proceedings, USA, Feb. 2002
J.A. Wells, “Commercial Opportunities at 94 GHz,” IEEE MTT-S International Microwave
Symposium, USA, May 2001 (Invited Panelist)

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J.A. Wells, “Research and Development at MAS Technology,” New Zealand Communications
Research Workshop 1997, New Zealand, May 1997 (Invited Paper)
J.A. Wells, “Overcoming RF Technical Difficulties in Moving from QPSK to 16 QAM Modulation,”
New Zealand Communications Research Workshop 1997, New Zealand, May 1997
J.A. Wells, “Modern Microwave Technology,” VHF Convention 1995, New Zealand, April 1995
J.A. Wells, “100W 2GHz Linear FET Amplifier Design,” VHF Convention 1995, New Zealand, April
1995
J.A. Wells, “Low Phase Noise Oscillator Design for Wide band Radio Applications,” 4th New Zealand
Communications Workshop, New Zealand, Sept. 1994
J.A. Wells, “Numerical Modeling of Millimeter-Wave Schottky Diodes,” 2nd UK-Japan N+N
Meeting on Terahertz Technology, Japan, July 1992

Patents
Lead inventor on three patents:
US Patent 7,623,829: Transceiver power detection and control architecture
US Patent 7,236,745: Transceiver power detection architecture
European Patent WO2004080035: Transceiver power detection architecture

January 2012

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