The art advanced by WILLIAMS in his declaration wherein he stated a POSA Would need “ at least 2 – 5 years of academic or industry experience in Mobile. (patent owner response)

Although he uses the Word “Context – Aware “ in Three places in his curriculum Vitae , his actual work did not involve contextual awareness applications or Technologies in any meaningful way .

In addition Mr. WILLIAMS has not demonstrated a special knowledge with Respect to the level of a POSA in order for his testimony to be acceptable As a patent expert unable or un willing to recognize these important technical Distinctions between presence detection and contextual awareness.

Mr .WILLIAMS incorrectly concludes that they are equal.

A POSA wanting to determine fine- granularity of many activities based on Large amounts of input data , would not look to the combination for a variety Of valid reasons.

POSA =" A person of ordinary skill in the Art "

Williams : Expert witness for Google in IPR