Ericsson Inc. and Telefonaktiebolaget LM
`Ericsson, Petitioner
`
`v.
`
`Intellectual Ventures II LLC, Patent Owner
`
`IPR2014-01195
`U.S. Patent No. 7,787,431
`
`Exhibit 2006
`
`Before Jameson Lee, Justin Busch and J. John Lee,
`Administrative Patent Judges
`
`
`Ericsson, Petitioner
`
`v.
`
`Intellectual Ventures II LLC, Patent Owner
`
`IPR2014-01195
`U.S. Patent No. 7,787,431
`
`Exhibit 2006
`
`Before Jameson Lee, Justin Busch and J. John Lee,
`Administrative Patent Judges
`
`
`
`Grounds for Institution
`
` Ground #1: Claims 1 and 2 for
`obviousness over the combination of Li,
`Yamaura, Zhuang, and Beta/UTRA
`
` Ground #2: Claims 1 and 2 for
`obviousness over the combination of Li,
`Yamaura, Mody, Nobilet, Popovic, and
`Beta/UTRA
`
`IPR2014-01195
`
`Exhibit 2006
`
`2
`
`(Institution Decision at 18)
`
`
`
`Independent Claim 1 of the ‘431 Patent
`
`In a variable bandwidth wireless communication system communicating under multiple different communication
`schemes that each have a different bandwidth, a process performed by a base station of generating an
`information bearing signal for wireless transmission, the process comprising:
`utilizing by the base station a number of subcarriers to construct a variable bandwidth wireless channel;
`utilizing by the base station groups of subcarriers, wherein each group includes a plurality of subcarriers;
`maintaining a fixed spacing between adjacent subcarriers;
`adding or subtracting, by the base station, groups of subcarriers to scale the variable bandwidth wireless
`channel and achieve an operating channel bandwidth; and
`wherein a core-band, including a plurality of subcarrier groups, substantially centered at an operating center
`frequency of the different communication schemes, is utilized by the base station as a broadcast channel
`carrying radio control and operation signalling, where the core-band is substantially not wider than a smallest
`possible operating channel bandwidth of the system; and
`wherein the information bearing signal has a primary preamble sufficient for basic radio operation and
`wherein: the primary preamble is a direct sequence in the time domain with a frequency content confined
`within the core-band, or is an orthogonal frequency-divisional multiplexing (OFDM) symbol corresponding to a
`particular frequency pattern within the core-band; and
`wherein properties of the primary preamble comprise:
`an autocorrelation having a large correlation peak with respect to sidelobes;
`a cross-correlation with other primary preambles having a small cross-correlation coefficient with respect to
`power of other primary preambles; and
`a small peak-to-average ratio; and
`wherein a large number of primary preamble sequences exhibit the properties.
`IPR2014-01195
`Exhibit 2006
`
`Ex. 1001, ‘431 patent
`
`3
`
`
`
`Dependent Claim 2 of the ‘431 Patent
`
`The process of claim 1, wherein the information bearing signal is:
`an orthogonal frequency division multiple access (OFDMA) signal; and is
`utilized in a downlink with a duplexing technique that is either Time Division Duplexing (TDD) or Frequency
`Division Duplexing (FDD).
`
`IPR2014-01195
`
`Exhibit 2006
`
`Ex. 1001, ‘431 patent
`
`4
`
`
`
`Ground #1: Petitioner’s Prior Art Combination for Claim 1
`
`1.0
`
`1.1
`
`1.2
`
`1.3
`
`In a variable bandwidth wireless communication system communicating
`under multiple different communication schemes that each have a
`different bandwidth,
`
`a process performed by a base station of generating an information
`bearing signal for wireless transmission, the process comprising:
`
`utilizing by the base station a number of subcarriers to construct a variable
`bandwidth wireless channel;
`
`utilizing by the base station groups of subcarriers, wherein each group
`includes a plurality of subcarriers;
`
`1.4 maintaining a fixed spacing between adjacent subcarriers;
`
`1.5
`
`adding or subtracting, by the base station, groups of subcarriers to scale
`the variable bandwidth wireless channel and achieve an operating channel
`bandwidth; and
`
`IPR2014-01195
`
`Exhibit 2006
`
`5
`
`Patent Owner Response at pp. 22-23
`
`
`
`Ground #1: Petitioner’s Prior Art Combination for Claim 1
`(cont.)
`
`1.6
`
`including a plurality of subcarrier groups,
`wherein a core-band,
`substantially centered at an operating center frequency of the
`different communication schemes, is utilized by the base station as a
`broadcast channel carrying radio control and operation signalling,
`
`1.7 where the core-band is substantially not wider than a smallest possible
`operating channel bandwidth of the system; and
`
`1.8 wherein the information bearing signal has a primary preamble
`sufficient for basic radio operation and
`
`1.9
`
`wherein: the primary preamble is a direct sequence in the time domain
`with a frequency content confined within the core-band, or is an
`orthogonal
`frequency-divisional multiplexing
`(OFDM)
`symbol
`corresponding to a particular frequency pattern within the core-band;
`and
`
`IPR2014-01195
`
`Exhibit 2006
`
`6
`
`Patent Owner Response at p. 23
`
`
`
`Ground #1: Petitioner’s Prior Art Combination for Claim 1
`(cont.)
`
`1.10
`
`1.11
`
`wherein properties of the primary preamble comprise:
`an autocorrelation having a large correlation peak with respect to
`sidelobes;
`
`a cross-correlation with other primary preambles having a small cross-
`correlation coefficient with respect
`to power of other primary
`preambles; and
`
`1.12
`
`a small peak-to-average ratio; and
`
`1.13
`
`wherein a large number of primary preamble sequences exhibit the
`properties.
`
`IPR2014-01195
`
`Exhibit 2006
`
`7
`
`Patent Owner Response at pp. 23-24
`
`
`
`Ground #1: Petitioner’s Prior Art Combination for Claim 1
`
`IPR2014-01195
`
`Exhibit 2006
`
`8
`
`Patent Owner Response at p. 22
`
`
`
`Ground #1: Li, Yamaura, Zhuang & Beta
`Overview
`
` The Prior Art Combinations Do Not Disclose All of the
`Claim Elements of Independent Claim 1
`– “substantially centered at an operating center frequency of the
`different communications schemes”
`– “substantially not wider than a smallest possible operating
`channel bandwidth of the system”
`– “utilized by the base station as a broadcast channel carrying
`radio control and operation signaling”
`– “a primary preamble sufficient for basic radio operation”
` No Reason To Combine All Four References
`– No motivation to combine Li and Yamaura
`– Zhuang renders Li inoperable
`
`Patent Owner Response at pp. 24-25, 37, 48
`
`IPR2014-01195
`
`Exhibit 2006
`
`9
`
`
`
`Missing Claim Elements
`
` “substantially centered at an operating center
`frequency of the different communications
`schemes”
` “substantially not wider than a smallest possible
`operating channel bandwidth of the system”
` “utilized by the base station as a broadcast
`channel carrying radio control and operation
`signaling”
` “a primary preamble sufficient for basic radio
`operation”
`
`IPR2014-01195
`
`Exhibit 2006
`
`10
`
`Patent Owner Response at pp. 24-25
`
`
`
`Claim Element 1.6: “substantially centered at an operating center frequency
`of the different communications schemes”
`
`IPR2014-01195
`
`Exhibit 2006
`
`11
`
`Patent Owner Response at pp. 22-23
`
`
`
`Dr. Zeger: the “different communication schemes” of claim 1
`“have substantially the same operating center frequency”
`
`Ex. 2001, Zeger Declaration at ¶111
`
`IPR2014-01195
`
`Exhibit 2006
`
`12
`
`
`
`‘431 Patent, Figure 6
`
`IPR2014-01195
`
`Exhibit 2006
`
`13
`
`Ex. 1001, ‘431 patent, Fig. 6
`
`
`
`“Yamaura Only Discloses
`One Communication Scheme”
`
`Ex. 2001, Zeger Declaration at ¶114
`
`IPR2014-01195
`
`Exhibit 2006
`
`14
`
`
`
`Yamaura: “One Transmission Channel”
`
`Ex. 1003, Yamaura patent, 20:54-60
`
`IPR2014-01195
`
`Exhibit 2006
`
`15
`
`
`
`Li: “A cluster can contain consecutive or disjoint subcarriers”
`
`IPR2014-01195
`
`Exhibit 2006
`
`16
`
`Ex. 1002, Li patent, 5:18-23
`
`
`
`Li: “not substantially centered at an
`operating center frequency”
`
`Ex. 1002, Li patent, Figures 1A and 6
`
`IPR2014-01195
`
`Exhibit 2006
`
`17
`
`Ex. 2001, Zeger Declaration at ¶113
`
`
`
`Petitioner’s Reply: “Yamaura, Fig. 17 (annotated)”
`
`IPR2014-01195
`
`Exhibit 2006
`
`18
`
`Ex. 1034, Haas’ Supplemental Declaration, at ¶¶ 24-25
`
`
`
`Claim Element 1.7: “substantially not wider than a smallest possible
`operating channel bandwidth of the system”
`
`IPR2014-01195
`
`Exhibit 2006
`
`19
`
`Patent Owner Response at pp. 22-23
`
`
`
`Claim Construction: “Core-Band”
`
`Patent Owner’s
`Proposed Construction
`“a frequency segment that is
`not greater than the smallest
`operating channel bandwidth
`among all the possible
`spectral bands with which
`the receiver is designed to
`operate”
`
`Petitioner’s
`Proposed Construction
`“a frequency segment that
`is not greater than the
`smallest operating channel
`bandwidth among all the
`possible spectral bands that
`a receiver is designed to
`operate with”
`
`PTAB’s
`Preliminary Construction
`“a frequency segment that
`is not greater than the
`smallest operating channel
`bandwidth among all the
`possible spectral bands
`with which the receiver is
`designed to operate”
`
`No meaningful dispute over the construction of “core-band.”
`
`IPR2014-01195
`
`Exhibit 2006
`
`20
`
`Patent Owner Response, p. 11
`
`
`
`Claim Construction: “Substantially Not Wider”
`
`Patent Owner’s
`Proposed Construction
`“significantly narrower”
`
`Petitioner’s
`Proposed Construction
`No construction necessary. Or “narrower
`than or equal to in width within a degree of
`accuracy that accounts for process and
`operational tolerances”
`
`IPR2014-01195
`
`Exhibit 2006
`
`21
`
`Patent Owner Response at p. 18
`
`
`
`Claim Construction: “Substantially Not Wider”
`
`Ex. 2001, Zeger Declaration at ¶58
`
`IPR2014-01195
`
`Exhibit 2006
`
`22
`
`
`
`Claim Construction: “Substantially Not Wider”
`
`Ex. 2001, Zeger Declaration at ¶59
`
`IPR2014-01195
`
`Exhibit 2006
`
`23
`
`
`
`Claim Construction: “Substantially Not Wider”
`
`Ex. 1001, ‘431 patent at 4:37-45
`
`IPR2014-01195
`
`Exhibit 2006
`
`24
`
`
`
`Claim Construction: “Substantially Not Wider”
`
`IPR2014-01195
`
`Exhibit 2006
`
`25
`
`Ex. 1001, ‘431 patent, Fig. 6
`
`
`
`Claim Construction: “Substantially Not Wider”
`
`Ex. 1001, ‘431 patent, 4:63-5:7
`
`IPR2014-01195
`
`Exhibit 2006
`
`26
`
`
`
`Petitioner’s Expert, Dr. Haas, agrees that
`“substantially” means “significantly”
`
`IPR2014-01195
`
`Exhibit 2006
`
`27
`
`Ex. 2004, Haas Deposition at 121:3-122:4
`
`
`
`Claim Construction: “Substantially Not Wider”
`
`Ex. 1001, ‘431 patent at 4:63-5:7
`
`IPR2014-01195
`
`Exhibit 2006
`
`28
`
`
`
`File History of the ‘431 Patent
`
`Ex. 1010, File History of the ‘431 patent, p. 160
`
`IPR2014-01195
`
`Exhibit 2006
`
`29
`
`
`
`Dr. Zeger: “100 kHz is not ‘substantially not wider’ than 100 kHz”
`
`Ex. 2001, Zeger Declaration at ¶121-122
`
`IPR2014-01195
`
`Exhibit 2006
`
`30
`
`
`
`Claim Element 1.6: “utilized by the base station as a broadcast
`channel carrying radio control and operation signaling”
`
`IPR2014-01195
`
`Exhibit 2006
`
`31
`
`Patent Owner Response at p. 23
`
`
`
`Claim Construction: “Radio Control And Operation Signaling”
`
`Patent Owner’s
`Proposed Construction
`“radio control signals and radio operation
`signals”
`
`Petitioner’s
`Proposed Construction
`“control signaling that affects the operation
`of a receiver”
`
`IPR2014-01195
`
`Exhibit 2006
`
`32
`
`Patent Owner Response at p. 16; Petitioner’s Reply at p. 8
`
`
`
`Claim Construction: “Radio Control and Operation Signaling”
`
`Ex. 2001, Zeger Declaration at ¶52
`
`IPR2014-01195
`
`Exhibit 2006
`
`33
`
`
`
`Claim Construction: “Radio Control and Operation Signaling”
`
`Ex. 1001, ‘431 patent at 4:63-5:7
`
`IPR2014-01195
`
`Exhibit 2006
`
`34
`
`
`
`Claim Construction: “Radio Control and Operation Signaling”
`
`Ex. 1001, ‘431 patent, 5:8-18
`
`IPR2014-01195
`
`Exhibit 2006
`
`35
`
`
`
`Claim Construction: “Radio Control and Operation Signaling”
`
`IPR2014-01195
`
`Exhibit 2006
`
`36
`
`Ex. 2001, Zeger Declaration at ¶54
`
`
`
`Claim Construction: “Radio Control and Operation Signaling”
`
`Ex. 2001, Zeger Declaration at ¶55
`
`IPR2014-01195
`
`Exhibit 2006
`
`37
`
`
`
`Claim Construction: “Radio Control and Operation Signaling”
`
`IPR2014-01195
`
`Exhibit 2006
`
`38
`
`Ex. 2001, Zeger Declaration at ¶56
`
`
`
`Yamaura Discloses Calling Signals
`
`Ex. 1003, Yamaura patent, 24:6-14
`
`IPR2014-01195
`
`Exhibit 2006
`
`39
`
`
`
`Yamaura Discloses Control Signaling
`
`Ex. 1012, Haas Declaration at pp. 87, 89
`
`IPR2014-01195
`
`Exhibit 2006
`
`40
`
`
`
`Yamaura Patent, Figure 17 (annotated by Petitioner)
`
`Ex. 1012, Haas Declaration at p. 59
`
`IPR2014-01195
`
`Exhibit 2006
`
`41
`
`
`
`Claim Element 1.6: “utilized by the base station as a broadcast
`channel carrying radio control and operation signaling”
`
`Ex. 2001, Zeger Declaration at ¶128
`
`IPR2014-01195
`
`Exhibit 2006
`
`42
`
`
`
`Claim Element 1.6: “utilized by the base station as a broadcast
`channel carrying radio control and operation signaling”
`
`Ex. 2001, Zeger Declaration at ¶129
`
`IPR2014-01195
`
`Exhibit 2006
`
`43
`
`
`
`Claim Element 1.8: “a primary preamble sufficient for
`basic radio operation”
`
`IPR2014-01195
`
`Exhibit 2006
`
`44
`
`Patent Owner Response at p. 23
`
`
`
`Claim Construction: “Sufficient for Basic Radio Operation”
`
`Patent Owner’s
`Proposed Construction
`“including radio control channels and data
`channels sufficient for the mobile station to
`operate at a primary state”
`
`Petitioner’s
`Proposed Construction
`“[a primary preamble] containing
`information to establish radio operation”
`
`IPR2014-01195
`
`Exhibit 2006
`
`45
`
`Patent Owner Response at p. 20; Petitioner’s Reply at p. 11
`
`
`
`Claim Construction: “Sufficient for Basic Radio Operation”
`
`Ex. 2001, Zeger Declaration at ¶64
`
`IPR2014-01195
`
`Exhibit 2006
`
`46
`
`
`
`Claim Construction: “Sufficient for Basic Radio Operation”
`
`Ex. 1001, ‘431 patent at 5:8-18
`
`IPR2014-01195
`
`Exhibit 2006
`
`47
`
`
`
`Claim Construction: “Sufficient for Basic Radio Operation”
`
`Ex. 1001, ‘431 patent at 5:8-18
`
`IPR2014-01195
`
`Exhibit 2006
`
`48
`
`
`
`Claim Construction: “Sufficient for Basic Radio Operation”
`
`IPR2014-01195
`
`Exhibit 2006
`
`49
`
`Ex. 1001, ‘431 patent, 5:19-36
`
`
`
`Claim Construction: “Primary Preamble”
`
`Patent Owner’s Current
`Proposed Construction
`“a signal transmitted by the
`base station near the
`beginning of each frame and
`occupying only the core-
`band”
`
`Petitioner’s Proposed
`Construction
`“a signal transmitted near the
`beginning of a transmission,
`such as a frame of time slot,
`and occupying only the core-
`band”
`
`Board’s Preliminary
`Construction
`“a direct sequence in the time
`domain with its frequency
`response confined within the
`CB or an OFDM symbol
`corresponding to a particular
`pattern in the frequency
`domain within the CB, at or
`near the beginning of the
`transmission, which alone is
`sufficient for basic radio
`operation.”
`
`IPR2014-01195
`
`Exhibit 2006
`
`50
`
`Patent Owner Response at p. 11
`
`
`
`Claim Construction: “Primary Preamble”
`
`IPR2014-01195
`
`Exhibit 2006
`
`51
`
`Ex. 1001, ‘431 patent, Fig. 8
`
`
`
`No Motivation To Combine Li, Yamaura, Zhuang, and Beta
`
`IPR2014-01195
`
`Exhibit 2006
`
`52
`
`Patent Owner Response at p. 50
`
`
`
`No Motivation To Combine Li and Yamaura
`
`IPR2014-01195
`
`Exhibit 2006
`
`53
`
`Ex. 2001, Zeger Declaration at ¶138
`
`
`
`No Motivation To Combine Li and Yamaura
`
`IPR2014-01195
`
`Exhibit 2006
`
`54
`
`Ex. 2001, Zeger Declaration at ¶135
`
`
`
`Li Abstract
`
`Ex. 1002, Li patent, Abstract
`
`IPR2014-01195
`
`Exhibit 2006
`
`55
`
`
`
`Li Discloses Control Signals
`
`IPR2014-01195
`
`Exhibit 2006
`
`56
`
`Ex. 1002, Li patent, 3:54-64
`
`
`
`Li: Base Station Notifies Subscriber About Cluster
`Allocation Through Downlink Control Channel
`
`IPR2014-01195
`
`Exhibit 2006
`
`57
`
`Ex. 1002, Li patent, 6:30-36
`
`
`
`No Motivation To Combine Li and Yamaura
`
`IPR2014-01195
`
`Exhibit 2006
`
`58
`
`Ex. 2001, Zeger Declaration at ¶139
`
`
`
`Li’s Pilot Signals
`
`IPR2014-01195
`
`Exhibit 2006
`
`59
`
`Ex. 1002, Li patent, 12:44-56
`
`
`
`Zhuang’s Chirp Sequences
`
`Ex. 1012, Haas Declaration at p. 67
`
`IPR2014-01195
`
`Exhibit 2006
`
`60
`
`
`
`No Motivation to Combine Li and Zhuang
`
`IPR2014-01195
`
`Exhibit 2006
`
`61
`
`Ex. 2001, Zeger Declaration at ¶154
`
`
`
`No Motivation to Combine Li and Zhuang
`
`IPR2014-01195
`
`Exhibit 2006
`
`62
`
`Ex. 2001, Zeger Declaration at ¶155
`
`
`
`Zhuang Destroys Li’s Functionality
`
`IPR2014-01195
`
`Exhibit 2006
`
`63
`
`Ex. 2001, Zeger Declaration at ¶156
`
`
`
`Zhuang Renders Li Inoperable
`
`Ex. 2001, Zeger Declaration at ¶157
`
`IPR2014-01195
`
`Exhibit 2006
`
`64
`
`
`
`Ground #1: Li, Yamaura, Zhuang & Beta
`Conclusion: Petitioner Failed to Establish Unpatentability
`
` The Prior Art Combinations Do Not Disclose All of the
`Claim Elements of Independent Claim 1
` “substantially centered at an operating center frequency of the
`different communications schemes”
` “substantially not wider than a smallest possible operating
`channel bandwidth of the system”
` “utilized by the base station as a broadcast channel carrying
`radio control and operation signaling”
` “a primary preamble sufficient for basic radio operation”
` No Reason To Combine All Four References
` No motivation to combine Li and Yamaura
` Zhuang renders Li inoperable
`
`Patent Owner Response at pp. 24-25, 37, 48
`
`IPR2014-01195
`
`Exhibit 2006
`
`65
`
`
`
`Ground #2: Petitioner’s Prior Art Combination for Claim 2
`
`1.0
`
`In a variable bandwidth wireless communication system communicating under
`multiple different communication schemes that each have a different
`bandwidth,
`
`1.1 a process performed by a base station of generating an information bearing
`signal for wireless transmission, the process comprising:
`
`1.2 utilizing by the base station a number of subcarriers to construct a variable
`bandwidth wireless channel;
`
`1.3 utilizing by the base station groups of subcarriers, wherein each group includes
`a plurality of subcarriers;
`
`1.4 maintaining a fixed spacing between adjacent subcarriers;
`
`1.5
`
`adding or subtracting, by the base station, groups of subcarriers to scale the
`variable bandwidth wireless channel and achieve an operating channel
`bandwidth; and
`
`IPR2014-01195
`
`Exhibit 2006
`
`66
`
`Patent Owner Response at p. 52
`
`
`
`Ground #2: Petitioner’s Prior Art Combination for Claim 2
`(cont.)
`
`1.6
`
`wherein a core-band, including a plurality of subcarrier groups, substantially
`centered at an operating center frequency of the different communication
`schemes, is utilized by the base station as a broadcast channel carrying radio
`control and operation signalling,
`
`1.7 where the core-band is substantially not wider than a smallest possible
`operating channel bandwidth of the system; and
`
`1.8 wherein the information bearing signal has a primary preamble sufficient for
`basic radio operation and
`
`1.9
`
`wherein: the primary preamble is a direct sequence in the time domain with a
`frequency content confined within the core-band, or is an orthogonal
`frequency-divisional multiplexing (OFDM) symbol corresponding to a
`particular frequency pattern within the core-band; and
`
`IPR2014-01195
`
`Exhibit 2006
`
`67
`
`Patent Owner Response at p. 52
`
`
`
`Ground #2: Petitioner’s Prior Art Combination for Claim 2
`(cont.)
`
`1.10
`
`wherein properties of the primary preamble comprise:
`an autocorrelation having a large correlation peak with respect to sidelobes;
`
`1.11 a cross-correlation with other primary preambles having a small cross-
`correlation coefficient with respect to power of other primary preambles; and
`
`1.12 a small peak-to-average ratio; and
`
`1.13 wherein a large number of primary preamble sequences exhibit the properties.
`
`IPR2014-01195
`
`Exhibit 2006
`
`68
`
`Patent Owner Response at p. 53
`
`
`
`Ground #2: Petitioner’s Prior Art Combination for Claim 2
`
`IPR2014-01195
`
`Exhibit 2006
`
`69
`
`Patent Owner Response at p. 51
`
`
`
`Ground #2: Li, Yamaura, Mody, Nobilet, Popovich & Beta
`Overview
`
` The Prior Art Combinations Do Not Disclose All of the
`Claim Elements of Independent Claim 1
`– “substantially centered at an operating center frequency of the
`different communications schemes”
`– “substantially not wider than a smallest possible operating
`channel bandwidth of the system”
`– “utilized by the base station as a broadcast channel carrying
`radio control and operation signaling”
`– “a primary preamble sufficient for basic radio operation”
` No Reason To Combine All Six References
`– No motivation to combine Li and Yamaura
`– Mody, Nobilet, and Popovic render Li inoperable
`Patent Owner Response at pp. 53-55
`
`IPR2014-01195
`
`Exhibit 2006
`
`70
`
`
`
`Same Missing Claim Elements as Described Above
`
`Petitioner’s arguments about Challenge #4 are generally flawed
`for the same reason as those pertaining to Challenge #2 (except with
`respect to disclosure of properties of a preamble). Thus, for the same
`reasons articulated above in Section V.A.1, the Challenge #4 combination
`of prior art references fails to address at least three claim elements:
`
`(1) “a core-band… substantially centered at an operating
`center frequency of the different communication
`schemes” and “utilized by the base station as a broadcast
`channel carrying radio control and operation signaling”;
`“the core-band is substantially not wider than a smallest possible
`operating channel bandwidth of the system”; and
`“wherein the information bearing signal has a primary preamble
`sufficient for basic radio operation.”
`
`(3)
`
`(2)
`
`IPR2014-01195
`
`Exhibit 2006
`
`71
`
`Patent Owner Response at pp. 53-54
`
`
`
`No Motivation To Combine Li, Yamaura, Mody, Nobilet,
`Popovic, and Beta
`
`IPR2014-01195
`
`Exhibit 2006
`
`72
`
`Patent Owner Response at p. 59
`
`
`
`Ground #2: Li, Yamaura, Mody, Nobilet, Popovic & Beta
`Conclusion: Petitioner Failed to Establish Unpatentability
`
` The Prior Art Combinations Do Not Disclose All of the
`Claim Elements of Independent Claim 1
` “substantially centered at an operating center frequency of the
`different communications schemes”
` “substantially not wider than a smallest possible operating
`channel bandwidth of the system”
` “utilized by the base station as a broadcast channel carrying
`radio control and operation signaling”
` “a primary preamble sufficient for basic radio operation”
` No Reason To Combine All Six References
` No motivation to combine Li and Yamaura
` Mody, Nobilet, and Popovic render Li inoperable
`Patent Owner Response at pp. 53-55
`
`IPR2014-01195
`
`Exhibit 2006
`
`73
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