`Petitioner
`v.
`Wi-Fi One, LLC,
`Patent Owner
`
`IPR2013-00601
`
`Trial Hearing: December 8, 2014
`Patent Owner’s Demonstrative Exhibits
`
`Wi‐Fi One Exhibit 2024
`Broadcom v. Wi‐Fi One
`Wi‐Fi One, LLC
`IPR2013 – 00601
`Exhibit 2024‐1
`
`
`
`The Petitions Are Barred Under 315(b)
`
`“(b) Patent Owner's Action.—An inter partes review
`may not be instituted if the petition requesting the
`proceeding is filed more than 1 year after the date
`on which the petitioner, real party in interest, or
`privy of the petitioner is served with a complaint
`alleging infringement of the patent.”
`
`Paper No. 40 at 5‐6
`
`Wi‐Fi One, LLC
`Exhibit 2024‐2
`
`
`
`The Petitions Are Barred Under 315(b)
`
`Ex. 2016 at 1
`
`Wi‐Fi One, LLC
`Exhibit 2024‐3
`
`
`
`The Petitions Are Barred Under 315(b)
`
`Ex. 2017 at 2‐4
`
`Wi‐Fi One, LLC
`Exhibit 2024‐4
`
`
`
`’215 Patent: Instituted Grounds
`
`Board instituted an inter partes review of
`claims 1, 2, 4, 6, 8, 15, 22, 25, 26, 29, 32, 34,
`45, 46, 49, 52, and 54 of the ’215 patent
`based solely on Seo
`
`Paper No. 29 at 22
`
`Wi‐Fi One, LLC
`Exhibit 2024‐5
`
`
`
`’215 Patent
`
`Exhibit 1001
`
`Wi‐Fi One, LLC
`Exhibit 2024‐6
`
`
`
`’215 Patent Claim 1
`
`Exhibit 1001
`
`Wi‐Fi One, LLC
`Exhibit 2024‐7
`
`
`
`Problem: Efficient Encoding of Messages
`
`Exhibit 1001
`
`Wi‐Fi One, LLC
`Exhibit 2024‐8
`
`
`
`Prior Art: S-PDU
`
`Exhibit 2020 at 8‐9
`
`Wi‐Fi One, LLC
`Exhibit 2024‐9
`
`
`
`Prior Art: Problems with ARQ
`
`Exhibit 1001 at 3:46‐50
`
`Wi‐Fi One, LLC
`Exhibit 2024‐10
`
`
`
`‘215 Patent: Encoding Method
`
`Exhibit 2020 at 12
`
`Wi‐Fi One, LLC
`Exhibit 2024‐11
`
`
`
`‘215 Patent: Encoding Method
`
`Exhibit 2020 at 13
`
`Wi‐Fi One, LLC
`Exhibit 2024‐12
`
`
`
`’215 Patent: Claim 1
`
`Exhibit 1001
`
`Wi‐Fi One, LLC
`Exhibit 2024‐13
`
`
`
`’215 Patent: Claim Construction
`
`Term
`
`Responsive to the
`receiving step,
`constructing a
`message field for a
`second data unit, said
`message field
`including a type
`identifier field
`
`Wi‐Fi One’s
`Proposal
`Responsive to the
`receiving step,
`generating a message
`field including a field
`that identifies a
`message type of the
`feedback response
`message from a
`number of different
`message types
`
`Broadcom’s
`Proposal
`Responsive to the
`receiving step,
`generating a message
`field including a field
`that identifies the
`message type of the
`feedback response
`message from a
`number of different
`message types
`
`Board’s
`Construction
`A field of a message
`that identifies the
`type of the message
`
`Wi‐Fi One, LLC
`Exhibit 2024‐14
`
`
`
`Seo Patent
`
`Exhibit 1002
`
`Wi‐Fi One, LLC
`Exhibit 2024‐15
`
`
`
`Seo: Background
`
`Exhibit 2020 at 19
`
`Wi‐Fi One, LLC
`Exhibit 2024‐16
`
`
`
`Seo: Figure 2
`
`Header
`
`Payload
`
`Exhibit 2020 at 20 (“header (in red)…payload (in blue)”)
`
`Wi‐Fi One, LLC
`Exhibit 2024‐17
`
`
`
`Seo: Figure 4
`
`Header
`
`Message
`
`Exhibit 2020 at 22 (“header (shown in red) …
`fixed length message field (shown in blue)”)
`
`Wi‐Fi One, LLC
`Exhibit 2024‐18
`
`
`
`Seo: “Padding Bits … Required to Fill”
`
`Exhibit 1002 at 6:1‐6
`
`Wi‐Fi One, LLC
`Exhibit 2024‐19
`
`
`
`Seo: Not Anticipatory
`
`Ex. 2020 at 24
`
`Wi‐Fi One, LLC
`Exhibit 2024‐20
`
`
`
`Claim 15: Seo Not Anticipatory
`
`Ex. 1001
`
`Wi‐Fi One, LLC
`Exhibit 2024‐21
`
`
`
`’215 Patent: Printed Matter Doctrine
`
`Wi‐Fi One, LLC
`Exhibit 2024‐22
`
`
`
`’215 Patent: Printed Matter Doctrine
`
`“Here there is a new and unobvious functional
`relationship
`between
`a measuring
`receptacle,
`volumetric indicia thereon indicating a certain ratio to
`actual volume, and a legend indicating the ratio, and
`in our judgment the appealed claims properly define
`this relationship.”
`
`Paper No. 40 at 27 (citing In re Miller, 418 F.2d 1392, 1396 (CCPA 1969)).
`
`Wi‐Fi One, LLC
`Exhibit 2024‐23
`
`
`
`’215 Patent: Printed Matter Doctrine
`
`“If there is a functional relationship between the printed
`matter and its substrate, the printed matter may serve to
`distinguish the invention from the prior art.”
`
`Paper No. 40 at 29 (AstraZeneca LP v. Apotex, Inc., 633 F.3d 1042, 1064 (Fed. Cir. 2010).
`
`Wi‐Fi One, LLC
`Exhibit 2024‐24
`
`
`
`’215 Patent: Printed Matter Doctrine
`
`The data structures “contain both information used by
`application programs and information regarding their
`physical
`interrelationships within a memory” and
`therefore “define[d] functional characteristics of the
`memory.”
`
`Paper No. 40 at 31 (citing In re Edward S. Lowry, 32 F.3d 1579, 1583 (Fed. Cir. 1994).
`
`Wi‐Fi One, LLC
`Exhibit 2024‐25
`
`
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