`SUBJECT TO PROTECTIVE ORDER
`
`CONTAINS NOKIA/ZTE/ SAMSUNG/QUALCOMM/INTERDIGITAL
`CONFIDENTIAL SOURCE CODE – OUTSIDE ATTORNEYS’ EYES ONLY –
`SUBJECT TO PROTECTIVE ORDER
`
`THE UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, D.C.
`Before the Honorable Theodore R. Essex
`Administrative Law Judge
`
`In the Matter of
`
`CERTAIN WIRELESS DEVICES WITH
`3G AND/OR 4G CAPABILITIES AND
`COMPONENTS THEREOF
`
`Investigation No. 337-TA-868
`
`REBUTTAL WITNESS STATEMENT OF DR. PAUL MIN
`
` Ex. 2003-0001
`
`RX-4590C
`
`InterDigital Tech. Corp.
`Exhibit 2003
`ZTE Corp. v. InterDigital Tech. Corp.
`IPR2014-00275
`
`
`
`
`CONTAINS CONFIDENTIAL BUSINESS INFORMATION
`SUBJECT TO PROTECTIVE ORDER
`
`specification. Based on the intrinsic evidence and the plain meaning of “radio resources,” a
`
`person of ordinary skill in the art would have understood that “radio” refers specifically
`
`physical resources.
`
`Q996) What is the difference between Respondents’ and InterDigital’s construcitons?
`A) The only difference is that Respondents construction requires “physical” resources.
`
`Q997) What is the basis for your opinion that radio resource must be a physical resource?
`A) As I testified in my opening statement, the purported invention requires transmission
`
`of uplink and downlink channel assignment information via a physical channel, which the
`
`151 Patent and specification describe as occupying a radio resource. The radio resources
`
`must be physical, not logical, resources for the claims to cover the purported invention.
`
`Q998) Does Dr. Brogioli agree that a “radio resource” must be a physical resource?
`A) No.
`
`Q999) Does InterDigital agree with Dr. Brogioli’s position that radio resources do not have to
`be physical resources?
`A) No, they do not.
`
`Q1000)
`A)
`
`How do you know that InterDigital disagrees?
`
`I reviewed the claim construction briefing related to the 151 Patent from Delaware. In
`
`that briefing, InterDigital agreed with Respondents’ construction.
`
`I am handing you a document marked RX-3373C (Delaware CC Brief). Do you
`Q1001)
`recognize this document?
`A) Yes. This is joint claim construction brief from the Delaware litigation.
`
`Q1002)
`A)
`
`What part of RX-3373C (Delaware CC Brief) did you reference earlier?
`
`If you look at page 54, it states with respect to the term “radio resources”: “There
`
`appears to be no genuine dispute among the parties with regard to the construction of this
`
`- 304 -
`
` Ex. 2003-0002
`
`
`
`CONTAINS CONFIDENTIAL BUSINESS INFORMATION
`
`SUBJECT TO PROTECTIVE ORDER
`
`Q1067)
`
`In Question and Answer 262 ofExhibit CX-1014C (Brogioli Stmt.), Dr. Brogioli
`
`also testifies that “step ‘4 ’ in paragraph [003]] includes language explicitly showing a
`
`sequence where such is required, i. e., step ‘4’ uses the language ‘based on the
`
`determination ofstep (3), ”’ but that there is no sequence language included regarding
`
`steps “2 ” and "3. ” Does this alter your opinion?
`
`A) No. Dr. Brogioli is conflating two separate concepts. As I described, the numbering
`
`of these steps sets up a specific sequence: step 1 then step 2 then step 3 then step 4. In
`
`addition, the passage cited by Dr. Brogioli also sets up a dependency between two of those
`
`steps: step 4 not only follows step 3 in sequence, but is also “based on the determination
`
`of” step 3. One of skill in the art would understand that a consecutively numbered set of
`
`steps indicates a specific order, especially where one of the steps is explicitly described as
`
`being dependent on the outcome of a previous step, which necessarily requires that the
`
`steps occur in the indicated sequence.
`
`CONCLUSION
`
`Q1068)
`
`Dr. Min, does this witness statement contain your answers to my questions?
`
`A) Yes. This statement contains my answers to your questions.
`
`Dr. Paul Min
`
`-332-
`
` Ex. 2003-0003
`EX. 2003-0003
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
