UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`ERICSSON INC. AND TELEFONAKTIEBOLAGET
`LM ERICSSON (“Ericsson”),
`Petitioner
`
`v.
`
`INTELLECTUAL VENTURES II LLC (“IV”),
`Patent Owner
`___________________
`
`Patent 7,787,431
`
`Title: METHODS AND APPARATUS FOR MULTI-CARRIER
`COMMUNICATIONS WITH VARIABLE CHANNEL BANDWIDTH
`_____________________
`
`IPR Case No. IPR2014-01195
`
`SUPPLEMENTAL DECLARATION OF ZYGMUNT J. HAAS, PH.D.
`UNDER 37 C.F.R. § 1.68 ON BEHALF OF PETITIONER
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`1
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`ERIC-1034
`Ericsson v. IV, IPR2014-01195
`Page 1 of 22
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`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`ERICSSON INC. AND TELEFONAKTIEBOLAGET
`LM ERICSSON (“Ericsson”),
`Petitioner
`
`v.
`
`INTELLECTUAL VENTURES II LLC (“IV”),
`Patent Owner
`___________________
`
`Patent 7,787,431
`
`Title: METHODS AND APPARATUS FOR MULTI-CARRIER
`COMMUNICATIONS WITH VARIABLE CHANNEL BANDWIDTH
`_____________________
`
`IPR Case No. IPR2014-01195
`
`SUPPLEMENTAL DECLARATION OF ZYGMUNT J. HAAS, PH.D.
`UNDER 37 C.F.R. § 1.68 ON BEHALF OF PETITIONER
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`1
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`ERIC-1034
`Ericsson v. IV, IPR2014-01195
`Page 1 of 22
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`I, Zygmunt Haas, do hereby declare:
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`1.
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`My background and qualifications are detailed in ¶¶ 5-13 in my
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`previous declaration submitted as exhibit ERIC-1012 in this IPR, i.e., IPR2014-
`
`01195.
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`2.
`
`In the preparation for this declaration, I have studied:
`
`(1) The ’431 Patent, ERIC-1001;
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`(2) U.S. Patent No. 6,904,283 (“Li”), ERIC-1002;
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`(3) U.S. Patent No. 7,782,750 (“Yamaura”), ERIC-1003;
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`(4) H. Newton, Newton’s Telecom Dictionary, 16th Edition, CMP Books
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`(2000), ERIC-1030;
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`(5) H. Holma, et al., WCMDA for UMTS, Radio Access for Third Generation
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`Mobile Communications, Revised Edition, John Wiley and Sons, Ltd.
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`(2001), ERIC-1032;
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`(6) U.S. Patent Pub. No. 2004/0141522 (“Texerman”), ERIC-1033;
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`(7) The excerpts from Ex. 2001, Declaration of Kenneth Zeger, provided by
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`counsel for Ericsson in Appendix A; and
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`(8) The excerpts from ERIC-1012, Declaration of Zygmunt Haas, referenced
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`herein.
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`3.
`
`My understanding of the relevant legal standards remain the same as
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`submitted in my previous declaration, ERIC-1012, ¶¶ 14-17.
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`I. Meaning of Certain Terms of the ’431 Patent
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`4.
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`It is my understanding that in order to properly evaluate the ’431
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`patent, the terms of the claims must be defined. It is my understanding that the
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`claims are to be given their broadest reasonable interpretation in light of the
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`specification. It is my further understanding that claim terms are given their
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`ordinary and accustomed meaning as would be understood by one of ordinary skill
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`in the art, unless the inventor, as a lexicographer, has set forth a special meaning for
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`a term. The discussion of the claim terms below is my opinion regarding each of
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`the referenced terms, as defined in accordance with the broadest reasonable
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`construction standard, and based on the understanding of a person of ordinary skill
`
`in the art.
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`“radio control and operation signaling”
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`5.
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`I did not offer a construction of “radio control and operation
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`signaling” in my previous declaration, ERIC-1012, implicitly taking the position
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`that no construction was necessary. However, I have been informed by counsel for
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`Ericsson that the Patent Owner (PO) has proposed a construction for the term “radio
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`control and operation signaling” in the PO Response as “radio control signals and
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`radio operation signals.”
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`6.
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`The term “radio control and operation signaling” is used only once in
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`the detailed description, which recites: “Radio control and operation signaling is
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`Page 3 of 22
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`realized through the use of a core-band (CB).” ERIC-1001, 4:66-67. The word “is”
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`is highlighted to show that the signaling is a single concept, not two distinct
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`concepts.
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`7.
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`Implicit in my application of “radio control and operation signaling”
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`is that “control and operation” would have been understood by a person of ordinary
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`skill in the art as referring to a single concept. This is consistent with the ’431
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`patent as well as the understanding of a person of ordinary skill in that art.
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`8.
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`Basic grammar teaches that a writer would have adhered to the
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`following table depending on whether “control and operation signaling” conveyed
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`one object or two. See id. As shown in the table, the ’431 patent treats “control and
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`operation signaling” as one object.
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`Two objects
`
`One object
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`Radio control signaling and operation
`signaling are realized …
`
`Radio control and operation signaling is
`realized … [’431 patent, 4:66-67]
`
`
`9.
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`The only disclosure in the ’431 patent related to control signals in the
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`context of an example core-band (which is recited in claim 1 as being “utilized by
`
`the base station as a broadcast channel carrying” the “radio control and operation
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`signaling” under construction) is as follows:
`
` In one embodiment relevant or essential radio control signals such as
`preambles, ranging signals, bandwidth request, and/or bandwidth
`allocation are transmitted within the CB. In addition to the essential
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`ERIC-1034
`Page 4 of 22
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`control channels, a set of data channels and their related dedicated
`control channels are placed within the CB to maintain basic radio
`operation. Such a basic operation, for example, constitutes the primary
`state of operation. When entering into the network, a mobile station
`starts with the primary state and transits to the normal full-bandwidth
`operation to include the sidebands for additional data and radio
`control channels.
`ERIC-1001, 5:8-18. This passage provides examples of “control signals” but
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`otherwise does not clarify what is meant by “radio control and operation
`
`signaling.” A person of ordinary skill in the art would have understood that “radio
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`control and operation signaling” refers to a single concept due to the understanding
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`in the art and the grammatical construction used. Basic grammar teaches that if
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`the writer meant for “control and operation signaling” to refer to two different
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`objects, the writer would have recited “control signaling and operation signaling.”
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`10.
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`By contrast, Dr. Zeger regards “control and operation” as referring to
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`separate concepts. Regarding control signals, Dr. Zeger, explains “that radio
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`control signals include signals used to set up radio operations, such as preambles
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`with address information, synchronization information, ranging signals, bandwidth
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`request information, and bandwidth allocation information.” Ex. 2001, ¶ 54
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`(reproduced in Appendix A, emphasis added). Regarding operation signals, Dr.
`
`Zeger explains that “[i]n addition to the essential control channels, a set of data
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`channels and their related dedicated control channels are placed within the CB to
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`ERIC-1034
`Page 5 of 22
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`maintain basic radio operations. A person of ordinary skill in the art would
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`understand that data channels and their related dedicated control channels are
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`examples of operation signaling.” Ex. 2001, ¶ 56 (reproduced in Appendix A,
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`emphasis added). Thus, the distinction Dr. Zeger seems to draw between “control
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`signals” and “operation signals” is that “control signals” set up radio operation and
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`“operation signals” maintain radio operation.
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`11.
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`There are two problems with the examples given by Dr. Zeger within
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`the context of claim 1. First, the examples contradict the fact that a “broadcast
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`channel” carries the signaling – for claim recites “a broadcast channel carrying
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`radio control and operation signaling.” Second, the examples contradict the
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`ordinary and customary meaning of “signaling.”
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`12. As a first contradiction, a “broadcast channel” cannot carry dedicated
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`channels. A “broadcast channel” is defined as “a wireless term for the logical
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`channel used in certain cellular networks to broadcast signaling and control
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`information to all cellular phones.” ERIC-1030, p. 129. Thus, a broadcast channel
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`is a channel for all users. On the other hand, a dedicated channel is a channel
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`dedicated to a specific user. This is a standard use of the terms “broadcast
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`channel” and “dedicated channel” in this field. For example, in a UMTS system,
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`which is a well-known third generation cellular system, a dedicated channel refers
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`to a channel for a particular user: “Two types of transport channels exist:
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`dedicated channels and common channels. The main difference between them is
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`that a common channel is a resource divided between all or a group of users in a
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`cell, whereas a dedicated channel resource […] is reserved for a single user only.”
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`ERIC-1032, p. 71. Thus, dedicated control channels are not an example of
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`operation signaling because the claim requires a broadcast channel to carry
`
`operation signaling.
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`13. As a second contradiction, the term “signaling” has an ordinary and
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`customary meaning in the field and is not merely the same as “signals.” Thus, Dr.
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`Zeger improperly conflates “signals” and “signaling.” For example, a technical
`
`dictionary describes “signaling” as follows: “in any telephone system – inside an
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`office or across the country – some form of signaling mechanism is required to set
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`up and tear down the calls.” ERIC-1030, p. 801. Thus, “signaling” refers to the
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`process used to set up or tear down calls. In contrast, data channels refer to
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`channels that carry information intended for a user.
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`14.
`
`Thus, the examples of “operation signals” provided by Dr. Zeger – a
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`set of data channels and their related dedicated control channels – are not valid
`
`examples of “operation signaling” in a “broadcast channel”. Accordingly, the most
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`likely construction of “radio control and operation signaling” is that it refers to a
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`single concept – control signaling that affects the operation of a receiver.
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`“sufficient for basic radio operation”
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`ERIC-1034
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`15.
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`I did not previously offer a construction of “sufficient for basic radio
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`operation” in my previous declaration, ERIC-1012, implicitly taking the position
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`that no construction was necessary. However, I have been informed by counsel for
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`Ericsson that the PO has proposed a construction for the term “sufficient for basic
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`radio operation” in the PO Response as “including radio control channels and data
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`channels sufficient for the mobile station to operate at a primary state.”
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`16. When construing the term “sufficient for basic radio operation,” it is
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`worth bearing in mind that the more complete claim language is “a primary
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`preamble sufficient for basic radio operation.” That is, it is the “primary preamble”
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`that is “sufficient for basic radio operation.”
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`17. When construing “sufficient for basic radio operation” it is important
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`to distinguish between what information may be in the core-band versus what
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`information is required in the “primary preamble” for basic radio operation. The
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`only definitive statement in the ’431 patent about what information may be
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`contained in a preamble is that “[t]he DL preamble is used at a base station to
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`broadcast
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`radio network
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`information such as synchronization and cell
`
`identification.” ERIC-1001, 3:54-56. This description is consistent with basic
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`radio operation, because synchronization and cell identification are needed for basic
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`radio operation.
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`18.
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`Beyond this, all that is explained by the ’431 patent is that “[t]he EP
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`Page 8 of 22
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`[primary preamble] alone is sufficient for basic radio operation.” Id., 5:21-22. It is
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`also known that the primary preamble has a series of properties related to
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`autocorrelation, cross-correlation, etc. listed in the specification and claim 1. These
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`properties allows the primary preamble to be identified to provide synchronization,
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`for example.
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`19.
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`There are several problems with the PO’s construction and Dr.
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`Zeger’s reasoning in support of the PO’s construction. First, Dr. Zeger conflates
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`core-band with primary preamble when formulating his construction. For example,
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`Dr. Zeger states that “to maintain basic radio operation, the core-band must include
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`relevant or essential radio control signals and a set of data channels and their
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`dedicated control channels.” Ex. 2001, ¶ 65 (reproduced in Appendix A, emphasis
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`added).
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`20.
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`Second, and closely related to the first issue, the temporal location of
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`a primary preamble – both sides agree that it is near the beginning of a frame – does
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`not comport with the PO’s definition of “sufficient for basic radio operation.”
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`There is no reason why data channels would be near the beginning of a frame to be
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`“sufficient for basic radio operation.” Instead, it makes more sense that the
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`beginning of a frame would allow a mobile station to synchronize and provide base
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`station information. The specification (and common sense) do not support having a
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`plurality of control channels and a plurality of data channels at the beginning of a
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`ERIC-1034
`Page 9 of 22
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`frame.
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`21.
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`In summary, the properties of a primary preamble listed in claim 1
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`(e.g., auto-correlation, cross-correlation, etc.) allow the primary preamble to be
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`identified by a receiver. The primary preamble can thus be an effective mechanism
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`for synchronization purposes. See ERIC-1001, 3:51-56. The primary preamble can
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`also be used to convey base station cell identification. See id. These are examples
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`of information used to establish radio operation. Beyond these aspects, the ’431
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`patent does not provide specifics on other types of information that could be
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`contained in a preamble. Thus, under the broadest reasonable interpretation in view
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`of the ’431 patent specification, one of ordinary skill in the art would understand
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`that “sufficient for basic radio operation” means containing information to establish
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`radio operation.
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`II. Certain Claim Elements Addressed by the PO
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`Core-band, including a plurality of subcarrier groups, substantially centered at
`an operating center frequency of the different communication schemes
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`22.
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`I was told by Ericsson counsel that the PO argues that Li in view of
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`Yamaura does not disclose different communication schemes substantially centered
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`at an operating center frequency.
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`23. As already explained in my previous declaration, Li’s base station
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`first allocates basic clusters (resulting in a first scheme), and Li’s base station
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`subsequently allocates more clusters, referred to as auxiliary clusters, to increase
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`the communication bandwidth (resulting in a second scheme). See ERIC-1002,
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`6:41-48; see also ERIC-1012, ¶ 35 and p. 81.
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`24. Yamaura discloses a narrowband control channel centered within a
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`single operating channel bandwidth. For example, Yamaura discloses that in
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`conventional OFDM systems a “terminal station has to receive and decode the band
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`signal (corresponding to 20 MHz) every 2 ms regardless of presence or absence of
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`data being transmitted and received.” ERIC-1003, 5:44-47. In order to address this
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`issue, Yamaura discloses a system in which “part of control signals addressed to a
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`terminal station from a base station is transmitted by means of a carrier whose
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`band is narrower than that for said multi-carrier signals […]” Id., 6:5-8. The
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`narrowband control channel resides within a “core band” (different operating
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`channel bandwidths are discussed in the claim charts in claim element 1.8 with
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`respect to Beta). The combination of Li and Yamaura, as would have been
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`understood by a person of ordinary skill in the art, is illustrated in annotated Fig. 17
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`of Yamaura below.
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`Yamaura, Fig. 17 (annotated)
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`25.
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`In view of the teaching of Yamaura that control information is
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`transmitted by a central frequency band, a person of ordinary skill in the art would
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`have centered Yamaura’s control signals within Li’s initially allocated basic
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`clusters. In order to maintain the benefits of Yamaura’s narrowband control
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`signals, Li’s auxiliary clusters would have been placed so that the narrowband
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`control signals remain at the center.
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`Radio control and operation signaling
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`26.
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`For the sake of argument, suppose that “radio control and operation
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`signaling” is construed according to the PO’s proposed construction as “radio
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`control signals and radio operation signals,” which, according to Dr. Zeger, “control
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`signals” refers to setting up radio operations and “operation signals” refers to
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`maintaining radio operations. See supra, ¶ 9. In what follows, I explain that even
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`assuming this construction (independent of whether I do or do not agree with it), the
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`prior art still discloses this construction.
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`27. Yamaura discloses control signaling – e.g., signals in the BCH.
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`Yamaura also discloses operation signaling – e.g., signals in the FCH. Although
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`not specified in Yamaura, the acronyms BCH and FCH are known to stand for
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`“broadcast channel” and “frame channel,” respectively. See, e.g., Texerman, ¶ 23
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`(ERIC-1033). The terms BCH and FCH are used here as synonymous with
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`“signals” in the context of Yamaura because Yamaura’s channels carry signals.
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`28.
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`The BCH and FCH are within a “broadcast channel,” as required by
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`claim 1. For example, referring to Fig. 17, Yamaura recites:
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`[t]he broadcast burst consists of BCH for the multiple addressing of
`broadcast preamble and base station information, FCH to inform each
`terminal station of the traffic channel allocation in the same frame,
`and ACH for reply to RCH used for calling from the terminal station.
`In the case of this embodiment, the two subcarriers SC1 and SC2
`shown in FIG. 16 are used for transmission of specific control signals
`in the sections of broadcast preamble, BCH, and FCH in the broadcast
`burst.
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`ERIC-1003, 21:7-15 (emphasis added). The BCH and FCH are communicated in a
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`“broadcast channel,” because the BCH and FCH are intended for all terminals.
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`Again, assuming the PO construction (independent of whether I do or do not agree
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`with it), a signal transmitted in Yamaura’s BCH is a control signal, because it
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`ERIC-1034
`Page 13 of 22
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`provides base station information, and a signal transmitted in Yamaura’s FCH is
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`both a control signal and an operation signal, according to the PO’s definition,
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`because the FCH contains information to first establish and then maintain a traffic
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`channel.
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`29.
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`Furthermore, the control and operation signals in Yamaura’s narrow
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`band (e.g.,
`
`including only
`
`two subcarriers SC1 and SC2) are used for
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`synchronization, which is needed both to set up communications and to maintain
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`communications. Below is paragraph 50 excerpted from my first declaration
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`(ERIC-1012), which explains how Yamaura provides for synchronization.
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`50. Another advantage is that Yamaura’s narrowband control
`signals indicate a frame boundary. “The advantage of transmitting
`narrow-band signals from the base station is that the terminal station
`can recognize the break of MAC frame of the carrier for information
`communication in the base station even though it receives only the
`narrow-band signals. As the result, it can recognize the break of MAC
`frame immediately and perform necessary processing when it starts
`reception in the carrier for information communication in response to
`information obtained by receiving the narrow-band signals or when it
`becomes apparent that transmission should be started in the carrier for
`information communication.” Id., 10:47-57. Furthermore, “[t]he fact
`that the base station transmits, in synchronism with the frame position
`for information transmission, part of the control signals addressed to
`the terminal station which is transmitted by means of the specific
`carrier permits the terminal station to capture the framing timing
`14
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`ERIC-1034
`Page 14 of 22
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`simply by receiving the specific subcarrier.” Id., 30:5-11. Thus,
`Yamaura’s control signals are also used
`for
`frame
`timing
`(synchronization).
`ERIC-1012, ¶ 50. The term “control signals” in the excerpted paragraph is being
`
`used in the sense of the PO’s interpretation of “control signals and operation
`
`signals.” Yamaura’s synchronization is both a “control signal” and an “operation
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`signal” in the sense used by the PO.
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`30. Accordingly, Yamaura discloses “radio control and operation
`
`signaling,” even according to the PO’s construction of the term (independent of
`
`whether I do or do not agree with the PO’s proposed construction).
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`Intentionally Left Blank
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`ERIC-1034
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`IV. CONCLUSION
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`31.
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`This declaration and my opinions herein are made to the best of my
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`knowledge and understanding, and based on the material available to me, at the
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`time of signing this declaration. I declare that all statements made herein on my
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`own knowledge are true and that all statements made on information and belief are
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`believed to be true, and further, that these statements were made with the
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`knowledge that willful false statements and the like so made are punishable by fine
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`or imprisonment, or both, under Section 1001 or Title 18 of the United States Code.
`
`Zygmunt Haas, Ph.D.
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`ERIC-1034
`Page 16 of 22
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`Appendix A
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`17
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`ERIC-1034
`Page 17 of 22
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`1.
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`“Eadin I:I.'lIl1'1'I‘.lL-'i.]]I‘] flpemtinn Signaling”
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`5].
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`Claim 1 of I11: ‘43l patent recites :1 cure-band “11I:i]1'::cd hjr the base
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`stati-::u1 as a hr-nadcast chamlel canjring rad.-in ccmtrul and uperafi-an signaling-“
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`13
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`18
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`18
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`ERIC-1034
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`Page 18 of 22
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`ERIC-1034
`Page 18 of 22
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`Eeger Declaration
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`Inter Porter Review ofU_S Patent No. T,?E?,43l
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`52- A person ofordinarjr slcill in the art would understand “radio control
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`and operation
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`to mean “radio control signals and radio operation
`
`signals."
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`53.
`
`This is consistent with the disclosure ofthe ‘#131 patent. For example,
`
`in describing radio operation via the core—band, the ‘43l patent specification notes
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`that “specific signaling and control methods are
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`to facilitate the user
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`terminals to operate in a variable bandwidth ('lu"B} environment. Exhibit lfltll at
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`4:6-1—fifi_ “Radio control amt operation signaling is realized through the use of a
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`core—b-and.”l"d'_ at4:fifi—d?_.e5rpersonofordinarj,rskiflind1eartwould1mderstand
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`that radio control signaling is separate front radio operation signaling.
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`54. Apersonofurdinar3rslrillintheartwould1n1derstandthat,indre
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`contest of wireless
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`radio control signals inchide signals used to
`
`set up radio operations
`
`such as preambles with
`
`address
`
`information,
`
`synchronization infonnation, ranging signals, and bandwidth request and allocation
`
`information. This is consistent with the disclosure of the ‘-131 patent, which
`
`describes an embodiment where “relevant or essential radio control signals such as
`
`preambles, ranging signals, bandwidth requefl, andfor bandwidth allocation are
`
`transmitted within the CE." Is‘. at 5:E—l[l_
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`55-
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`flncera:hooperatiunsaresetup,radioconnnlsigna]sma}rno1unger
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`be essential- Rather, operation signals, such as on data channels, are transmitted to
`
`
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`139
`19
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`ERIC-1034
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`Page 19 of 22
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`ERIC-1034
`Page 19 of 22
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`Eeger Declaraiinn
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`Inter Psrfes Review nfU_S Patent Nu. ?',?3?,43l
`
`pertnitiheaelualcunlmunicatinn nfdatahetweenihehasestatinnaiadflieternninal
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`staiic-11 In adcliiicnn, dedicated cc-ntrcrl channels fur data channels nlajr pnrcnride
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`infcrrnlaiinn specific tn particular cell phnne tuwers such as ten allcnw calls already
`
`inprcncesstncctntinne astheuseIn1mresa1n1mxlanxltncunl1nlpm:.reI1e1rels_
`
`56.
`
`This untlerstanliing is cnensiflent wifla the ‘431 patent, which slates
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`that, "(flu sdditisn In the esseniial cunlml channels, a set of data channels and
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`tlieirrelateddedicated cunlml channels areplacedmiflzninthe CB tnmaintain basic
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`radio cIpeIa1icr11s_" Eshihit lflfll at 5:1fl—l3 [emphasis added_} A perscrn crf |.'I1’l§l.tlEIfl1'jF
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`slcilliniheanwenldlmtlerstandthatdata channelsandflieirrelateddedicatetl
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`cnentml channels are EIEIEIPIES c-f nperaiicln signaling.
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`ERIC-1034
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`Page 20 of 22
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`ERIC-1034
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`3.
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`“I"r'in1ar3.' Preamble Sufficient For Basic Radio Dperalion”
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`63.
`
`Claim 1 requires that the information hearing signal have a “primary
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`preanrhle sufficient for hasic radio
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`64.
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`The claim liniitation “suflicient for basic radio operation” suggests
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`thattheprmiarppremnblealomennrstinchrdemfinnmfionsuflidenttoaflowflie
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`radiotooperate_Inthecontextofthe‘43l patent,apersonofordina:ryslcillinthe
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`art would understand a “priniarjr preamble suflicient for basic radio operation" to
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`mean a “prin1ar'_r,r preamble including radio control channels and data channels
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`sirfficient for the mobile station to operate at a priniarjr state.”
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`65.
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`This is consistent with the disclosures ofthe ‘=t3l patent. As discussed
`
`above with respect to the claim term “radio control and operation
`
`the
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`‘-131 patent eicplains that “[i]n one embodiment, relevant or essential radio control
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`signals such as preambles, ranging signals, bandwidth request, andfoer bandwidth
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`allocation are transmitted within the CB- In addition to the essential control
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`channels, a set of data channels and their related dedicated craitrnl channels are
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`ERIC-1034
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`Page 21 of 22
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`ERIC-1034
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`Eeger Declaiatinn
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`Inter Pnrtes Review efU_S Patent Nu. T,T"ET",=l3l
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`placed within the CB to maintain hasic rad.-in nperatienf’ Earhihit 1{J{Itl at 5:3-13-
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`Thns, tn maintain hasic iadin npetatiuui, l.l1E: ceIe—hand tnnst inchide relevant er
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`essential Iadin cnntml signals and a set ef data channels and their dedicated central
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`channels.
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`56.
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`The ‘43l patent further explains that “[s]uch hasic Iadie npetatiust, for
`
`example, censtitntes flie pIin1ar_r.r state nf . ‘When entering int-:1 the
`
`netwerhanmhilestafinnflarlswithflieprnhaiyflateandtansitsmthennnhal
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`:['hll—handwidth epeiatien tn inchide the sidehands fer additional data and radio
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`cnntrnl channels-” Id. at 5:13-13- The inclnsi-an ed‘ “nddflinnnt data and iadin
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`cnntrnl channels" in the sidehands dnting nnn:nal fiJll—handwidth nperatinn stmnglyr
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`suggests that hath data and radio cnntrnl channels are 3lI‘E.".'1I.'lj|' included in the
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`pI1n1ar_r,r' state nf operations," i_e_, hrasic Iad1n' nperati-an-
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`Page 22 of 22
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`ERIC-1034
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