Case IPR2015-01567
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`Petition for Inter Partes Review of Patent 5,687,196
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`CELLCO PARTNERSHIP D/B/A VERIZON WIRELESS,
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`T-MOBILE US., INC. and T-MOBILE USA, INC.
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`SPRINT SPECTRUM, L.P. and SPRINT CORPORATION, and
`AT&T MOBILITY LLC
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`Petitioners
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`V.
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`ORLANDO COMMUNICATIONS LLC,
`Patent Owner
`
`Case IPR2015-01567
`
`Patent No. 5,687,196
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`DECLARATION OF DR. MARTIN WALKER IN SUPPORT OF PETITION
`
`FOR INTER PARTES REVIEW OF U.S. PATENT NO. 5,687,196
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`Mail Stop: Patent Board
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
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`P.O. Box 1450
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`Alexandria, VA 22313-1450
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`961620.04
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`PETITIONERS 1013-0001
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`Petition for Inter Partes Review of Patent 5,687,196
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CELLCO PARTNERSHIP D/B/A VERIZON WIRELESS,
`
`T-MOBILE US., INC. and T-MOBILE USA, INC.
`
`SPRINT SPECTRUM, L.P. and SPRINT CORPORATION, and
`AT&T MOBILITY LLC
`
`Petitioners
`
`V.
`
`ORLANDO COMMUNICATIONS LLC,
`Patent Owner
`
`Case IPR2015-01567
`
`Patent No. 5,687,196
`
`DECLARATION OF DR. MARTIN WALKER IN SUPPORT OF PETITION
`
`FOR INTER PARTES REVIEW OF U.S. PATENT NO. 5,687,196
`
`Mail Stop: Patent Board
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
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`P.O. Box 1450
`
`Alexandria, VA 22313-1450
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`961620.04
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`PETITIONERS 1013-0001
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`Case lPR20l5-01567
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`Petition for Inter Partes Review of Patent 5,687,196
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`DECLARATION OF DR. MARTIN WALKER
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`I, MARTIN WALKER, declare the following:
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`I.
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`INTRODUCTION
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`1.
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`I have been retained by Petitioners to provide my expert opinions
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`regarding U.S. Patent No. 5,687,196 (“the ’ 196 Patent”). More specifically, I have
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`been asked to give my opinion about the meanings of certain terms of the ’ 196
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`Patent claims, and to compare the ‘ 196 Patent claims to prior art patents and
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`publications. I submit this declaration in support of Petitioner’s petition for inter
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`partes review of the ’ 196 Patent.
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`2.
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`I am being compensated for my work in this matter at my standard
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`hourly rate of $500 for consulting services. My compensation in no way depends
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`on the outcome of this proceeding.
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`II.
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`PROFESSIONAL BACKGROUND
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`3.
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`My qualifications are stated more fully in my curriculum vitae, a copy
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`of which is attached hereto as Exhibit A.
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`4.
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`I received a Bachelor’s of Science in electrical engineering
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`(“B.S.E.E.”) from the Massachusetts Institute of Technology in 1973, a Master’s of
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`Science in electrical engineering (“M.S.E.E.”) from Stanford University in 1976,
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`and a Ph.D. in electrical engineering from Stanford University in 1979.
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`5.
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`I have 35 years of experience in design of integrated circuits,
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`including analog, digital and RF/microwave circuits of the type described in the
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`’ 196 Patent. In particular, I have designed built and tested hardware components
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`and software components such as those for communication systems described in
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`Figure 4 of the ’ 196 Patent.
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`I also have thirty years of experience in the field of
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`Electronic Design Automation (“EDA”) software systems. Such systems are used
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`in the design and testing of signal processing circuits such as those described in the
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`’ 196 Patent.
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`6.
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`From 1983 to 1989, I was the founder and Chief Technical Officer at
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`Analog Design Tools, Inc.
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`I was primarily responsible for writing the original
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`business plan, raising the venture capital necessary to launch the company, and
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`recruiting the staff Later, I was responsible for all technical aspects of product
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`definition and development. My efforts were instrumental in growing Analog
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`Design Tools, Inc., from a start-up company to a leader in the field of analog
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`design automation.
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`7.
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`From 1990 to 1994, I was a founder and Executive Vice President of
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`Symmetry Design System, which specialized in product design and consulting for
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`the electronic design marketplace. In this role, I was instrumental in development
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`of Symmetry’s products.
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`8.
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`In 1995, I founded a company called Frequency Technology (later
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`Sequence Design) that develops EDA software for the design of advance system-
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`on-a-chip integrated circuits. Sequence’s products have become the de facto
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`industry standard for parasitic extraction, circuit optimization and RTL power
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`analysis. As Chief Executive Office, director, and Chief Scientist at Sequence, I
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`was involved in overseeing the development of the company’s products and
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`technologies.
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`I also took an active role in recruiting the technical and business
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`staff
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`9.
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`During my consulting career, I have had the opportunity to review
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`numerous hardware/software signal processing systems. In particular, I have
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`researched and analyzed location determination features and algorithms used in
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`cellular networks for systems that are similar to those described by the ’ 196 Patent.
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`10.
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`I am named as an inventor on three patents in the field of electronic
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`design automation.
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`I have also published over fifty articles relating to EDA
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`software, including technical papers in peer-reviewed journals and an invited
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`article in International Electronic and Electrical Engineers (IEEE) Spectrum, and I
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`have presented papers in various conference proceedings.
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`III. MATERIALS CONSIDERED
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`1 1.
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`In preparing this Declaration, I considered the following materials:
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`(a)
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`The ’l96 Patent (EX. 1001) and its file history;
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`(b)
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`U.S. Patent No. 5,381,444 (“Tajima”) (Ex. 1002),
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`(e)
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`U.S. Patent No. 5,742,635 (“Sanderford”) (EX. 1003).
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`Petition for Inter Partes Review of Patent 5,687,196
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`(c)
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`U.S. Patent No. 5,414,729 (“Fenton”) (Ex. 1004);
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`(d)
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`U.S. Patent No. 2,582,971 (“Dunmore) (Ex. 1005);
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`(f)
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`Any other materials specifically referenced in this declaration
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`or the Petitioners’ petition for inter partes review of the ‘196
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`Patent.
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`IV. RELEVANT LEGAL STANDARDS
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`12.
`
`I have been asked to provide my opinion as to whether claims 12-14
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`and 16 of the ’ 196 Patent are anticipated by prior art and/or would have been
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`obvious to a person of ordinary skill in the art at the time of the alleged invention,
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`in view of the prior art.
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`13.
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`I am an engineer by training and profession. The opinions I am
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`expressing in this report involve the application of my engineering knowledge and
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`experience to the evaluation of certain prior art with respect to the ’ 196 Patent. 1
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`am not a patent attorney. Therefore, I have requested the attorneys who represent
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`Petitioners to provide me with guidance as to the applicable patent law in this
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`matter. The paragraphs below express my understanding of howl must apply
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`current principles related to patentability.
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`14.
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`It is my understanding that in determining whether a patent claim of
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`an expired patent is anticipated or obvious in view of the prior art, the Patent
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`Office must construe the claims by giving them “generally given their ordinary and
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`Petition for Inter Partes Review of Patent 5,687,196
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`customary meaning” as understood by one of ordinary skill in the art at the time of
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`the invention, in light of the specification. For the purposes of this review, I have
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`construed each claim term in accordance with its plain and ordinary meaning
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`consistent with the use of the term in the specification and in the prosecution
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`history.
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`15.
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`It is my understanding that a claim is anticipated under 35 U.S.C.
`
`§ 102 if each and every element and limitation of the claim is found either
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`expressly or inherently in a single prior art reference.
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`16.
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`It is my understanding that a claim is unpatentable under 35 U.S.C.
`
`§ 103 if the claimed subject matter as a whole would have been obvious to a
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`person of ordinary skill in the art at the time of the alleged invention.
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`1 also
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`understand that an obviousness analysis takes into account the scope and content of
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`the prior art, the differences between the claimed subject matter and the prior art,
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`the level of ordinary skill in the art at the time of the invention, and objective
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`evidence of nonobviousness.
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`17 .
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`In determining the scope and content of the prior art, it is my
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`understanding that a reference is considered appropriate prior art if it falls within
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`the field of the inventor’s endeavor. In addition, a reference is prior art if it is
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`reasonably pertinent to the particular problem with which the inventor was
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`involved. A reference is reasonably pertinent if it logically would have
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`commended itself to an inventor’s attention in considering his problem. If a
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`reference relates to the same problem as the claimed invention, that supports use of
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`the reference as prior art in an obviousness analysis.
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`18.
`
`To assess the differences between prior art and the claimed subject
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`matter, it is my understanding that 35 U.S.C. § 103 requires the claimed invention
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`be considered as a whole. This “as a whole” assessment requires showing that one
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`of ordinary skill in the art at the time of invention, confronted by the same
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`problems as the inventor and with no knowledge of the claimed invention, would
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`have selected the elements from the prior art and combined them in the claimed
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`manner.
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`19.
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`It is my further understanding that the Supreme Court has recognized
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`several rationales for combining references or modifying a reference to show
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`obviousness of claimed subject matter. Some of these rationales include:
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`combining prior art elements according to known methods to yield predictable
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`results; simple substitution of one known element for another to obtain predictable
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`results; a predictable use of prior art elements according to their established
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`functions; applying a known technique to a known device (method or product)
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`ready for improvement to yield predictable results; choosing from a finite number
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`of identified, predictable solutions, with a reasonable expectation of success, when
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`there is a design need or market pressure to solve a problem; and some teaching,
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`suggestion, or motivation in the prior art that would have led one of ordinary skill
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`to modify the prior art reference or to combine prior art reference teachings to
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`arrive at the claimed invention.
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`V.
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`PERSON OF ORDINARY SKILL IN THE ART
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`20.
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`It is my understanding that when interpreting the claims of the ’ 196
`
`Patent I must do so based on the perspective of one of ordinary skill in the art at
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`the relevant priority date. My understanding is that the earliest claimed priority
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`date of the ’ 196 Patent is September 30, 1994.
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`21.
`
`Generally, the challenged claims of the ’ 196 Patent relate to a method
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`for detennining the range (or distance) between a reference point and a remote
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`transmitter. For example, the Abstract of the ’ 196 Patent states:
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`A system and method for tracking a remote RF transmitter with
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`reduced susceptibility to the effects of multipath in which the distance
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`and direction of an arriving RF chirp signal are determined with
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`respect to the earliest arriving portion of the signal which is presumed
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`to be the direct path signal. The received chirp signals, including the
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`direct and multipath signals, from a remote transmitter are correlated
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`into plural path signals, and the direction and distance to the
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`transmitter is determined from the earliest arriving path signal.
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`22.
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`In my opinion, a person of ordinary skill in the art would have a
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`minimum of a Bachelor’s degree in Electrical Engineering, Computer Engineering
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`or a closely related field, or at least three years of professional experience in the
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`design or development and analysis of wireless communication systems.
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`23.
`
`I have formed my opinion regarding the level of ordinary skill in the
`
`art for the ’ 196 Patent by reviewing the patent and its file history, and based on my
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`knowledge of the level of skill of individuals in the field. Other factors relevant to
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`my opinion regarding the level of ordinary skill in the art include (i) the nature of
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`problems that the patents-in-suit were intended to solve, and (ii) the education level
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`of active workers in this field.
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`24.
`
`Based on this description, I possess at least the ordinary skill in the art
`
`around the earliest claimed priority date of the ’ 196 Patent. By the earliest claimed
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`priority date of the ’ 196 Patent, I held a Ph.D. in Electrical Engineering, and had
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`been developing wireless communication circuits for more than 20 years By that
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`time, I had also been working on various communication technologies for more
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`than 20 years.
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`25.
`
`I am familiar with the knowledge, experience, and creativity of such a
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`person of ordinary skill in the art of the ’ 196 Patent during the relevant time period.
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`In arriving at my opinions and conclusions in this declaration, I have considered
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`the issues from the perspective of this hypothetical person of ordinary skill in the
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`art at the time of the alleged invention
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`VI.
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`TECHNOLOGY BACKGROUND
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`A. Correlation
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`26.
`
`Correlation is a mathematical operation that uses two signals to form a
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`third signal. The third signal is known as the “cross-correlation” of the two input
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`signals. If an input signal is correlated with itself, the resulting signal is called the
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`“autocorrelation.”
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`27.
`
`In an example shown below, a radar transmits a short pulse of energy
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`that is reflected by an object being examined, e. g., an aircraft.
`
`
`
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`28. A received wavefonn is a shifted version of the transmitted waveform
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`and includes random noise. Correlation enables detection of a known waveform in
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`the received noisy signal.
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`29.
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`Referring to the next example below, correlation involves a received
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`signal, sr[n], a cross-correlation signal, scc[n] and a target signal, st[n]. The target
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`signal, st[n], is the desired wavefonn. Samples from the received signal, sr[n], are
`
`multiplied by corresponding points in the target signal, st[n]. The sum of these
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`products is placed into the proper sample in the cross-correlation signal, scc[n].
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`The amplitude of each sample in the cross-correlation signal, scc[n], is an indication
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`of how much the received signal, sr[n], resembles the target signal, st[n], at that
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`sample location. As a result, a peak will occur in the cross-correlation signal,
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`scc[n], for every target signal, st[n], that is present in the received signal, sr[n]. This
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`means the value of the cross-correlation is maximized when the target signal, st[n],
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`is aligned with the same features in the received signal, sr[n].
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`30.
`
`In the example figure above, the indicated samples from the received
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`signal, sr[n], are multiplied by corresponding points in the target signal, st[n], and
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`the products are added. The samples calculated in scc[n] above indicate where st[n]
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`is fully immersed in sr[n].
`
`31.
`
`The output of a correlation is the energy of the reference signal
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`correlated with the received signal. Thus, a correlation function varies according
`
`to the energy or power of the received signal(s).
`
`B. Ranging using spread spectrum signals
`
`32. A spread-spectrum signal refers to the process of increasing the
`
`bandwidth of an otherwise narrow band signal. See Ex. 1016, Dixon, Spread
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`Spectrum Systems (2d Ed, Published 1984) at 1, 7.
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`33.
`
`Spread spectrum signals have long been used in navigation and,
`
`specifically, ranging applications. Robert Dixon’s 1984 textbook Spread Spectrum
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`Systems states that “the best known applications of spread spectrum methods lie in
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`the navigation area. Direct-sequence ranging has been applied in space exploration
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`programs since the early 1960s at least.” Id. at 291. Dixon explained the basic
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`technique as follows:
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`Any RF signal is subject to a fixed rate of propagation (approximately
`
`6 usec/mi). The signal reaching a receiver at any given instant left the
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`transmitter that sent it some time before. Because signaling
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`waveforms or modulations are also functions of time, the difference in
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`a signaling waveform as seen at a receiver, from that present at the
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`transmitter can be related directly to distance between them and used
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`to measure that distance.
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`Id. at 291.
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`34.
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`Spread spectrum signals are particularly useful for ranging because
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`the code sequence units (chips) provide readily countable units. See id. at 292. In
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`a simple spread spectrum ranging system, a pseudonoise-modulated signal is
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`transmitted. It arrives at the receiver with a time delay corresponding to the
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`propagation distance. The receiver correlates the received signal with a reference
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`signal modulated by the same pseudonoise code. A range measurement is made by
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`counting the chips or fractions of chips by which the two signals are offset or, in
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`other words, how many chips or fractions of chips the reference signal needs to
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`move before the received and reference signals are synchronized. See id. at 293-
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`95.
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`VII. DESCRIPTION OF THE ’196 PATENT
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`35.
`
`The ’ 196 Patent is entitled “Range and bearing tracking system with
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`multipath rejection.” As the abstract explains, the alleged invention generally
`
`describes a system for detennining the distance and direction to the source of an
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`RF signal with reduced susceptibility to the effects of multipath. Thus the system
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`involves three aspects: (a) in the presence of multipath effects, (b) determining
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`distance, and (c) determining direction. However, I note that the challenged claims
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`only address (a) multipath environment and (b) determining distance, but not (c)
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`determining direction.
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`36.
`
`As the ’ 196 Patent acknowledges, using radio waves to determine
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`distance to remote targets was well known in the art. Indeed, the British used such
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`a system (dubbed “CH” or “Chain Home”) to great effect during the Second World
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`War. Below is an image from the display for such a system, called an A-scope.
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`
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`RAF Air Defense Radar Museum catalogue no. NEDAD.20l3.047.058A. The X-
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`axis shows distance from the transmitter, which is directly related to the time of
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`arrival of a signal, while the y-axis indicates the intensity or energy of the signal.
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`The image appears to display returns from three targets: one at roughly 18 miles,
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`one at roughly 25 miles, and one at roughly 31 miles. These signals represent
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`round trips to three different targets, with each signal representing a direct path to
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`the target.
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`37.
`
`The ’ 196 patent also describes a well known problem with such prior
`
`art systems: the systems “experience some difficulty in multipath and other noisy
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`enviromnents.” The ’ 196 Patent illustrates this issue in Figure l of the patent:
`
`25
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`4
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`Composite:/1
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`I
`
`FIG.
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`
`
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`38.
`
`The ’ 196 Patent describes this multipath enviromnent as “blocking
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`and/or reflecting elements 14, such as buildings, towers, mountains may exist in
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`the proximity of and in the direct path between the RF signal source 10 and the
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`base station 12. The blocking and/or reflecting elements cause RF signals
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`impinging upon such elements to be blocked, absorbed, reflected, and often a
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`combination of all three. Generally, such elements cause RF signals to be
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`diminished in strength and to change direction.” 1:60-67.
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`39. When a signal is emitted that signal may be reflected off of these
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`elements “such that instead of a single signal arriving at the base station 12,
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`multiple versions of the same or slightly altered signal arrive at the base station 12.
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`The different versions of the signals arrive at different times because they have
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`travelled different paths of different distances than either the direct version or other
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`indirect versions.” 2:3-8.
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`40.
`
`The ’ 196 patent describes a solution to this problem by identifying the
`
`first arriving signal to determine distance because “the signal travelling directly
`
`from the transmitter to the base station will always be the first signal to arrive
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`(assuming that the signal is not wholly blocked)” 3:63-65. The ’ 196 Patent notes
`
`that “first arriving signal is the signal which has travelled the shortest distance and
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`is most likely the signal corresponding to the direct path to the transmitter.” 3 :66-
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`4:2.
`
`41.
`
`The ’ 196 patent distinguishes the times of arrival of the direct and
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`reflected path signals using a “conventional correlation receiver in which the
`
`power level of the arriving signal is correlated in time and the signal arriving first
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`in lime [sic] is used to determine the total propagation time.” Id. at 4: 14-17.
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`Figure 2 of the ’ 196 patent depicts the output of the correlation process: “the
`
`correlated power level of the signal received plotted against time starting from the
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`time of transmission of the signal.” Id. at 3:41-47. It is similar to the A-Scope
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`shown above.
`
`a,
`D”
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`14
`12
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`F716. 2
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`TIME
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`42. With reference to Figure 2, the first arriving signal is denoted as peak
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`20.
`
`VIII. CLAIM CONSTRUCTION
`
`A. How the challenged claims are to be Construed Under 37 C.F.R. §
`42.104 (b) (3)
`
`43.
`
`I understand that, for purposes of this Petition, the claims are to be
`
`generally given their ordinary and customary meaning as understood by one of
`
`ordinary skill in the art at the time of the invention because the ’ 196 patent expired
`
`on November 11, 2014.
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`44.
`
`I have been asked to address the terms below, and the remaining claim
`
`terms of the ’ 196 patent that are not addressed herein are not believed to require
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`additional clarification for purposes of this proceeding.
`
`1.
`
`“time of arriva ”
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`45. Although the specification of the ’ 196 patent does not directly use the
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`phrase “time of arrival,” the timing of the arrival of the plural path signals is
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`described in relation to the time the transmitted signal was sent. The specification
`
`of the ’ 196 patent describes that, in a multipath environment, “multiple versions of
`
`the same or slightly altered signal arrive at the base station 12. The different
`
`versions of the signals arrive at different times because they have travelled
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`different paths of different distances.” See ’ 196 Patent at 2: 4-8. Figure 2 of the
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`’ 196 patent, reproduced below, illustrates the correlation output depicting those
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`different paths plotted over time.
`
`22
`
`20
`
`DE
`15
`10
`59% 8
`fig‘-' 3
`O
`.
`01:3
`2
`"’
`0
`
`1 2 3 4 5 6 7 B 9101112131415161718
`
`FIG. 2
`
`"ME
`
`46.
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`The specification describes Figure 2 as a depiction of “the correlated
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`power level of the signal plotted against time starting from the time of transmission
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`of the signal.” See ’ 196 Patent at 3:28-29; 3:4l-43. Further, the peaks 20 and 22
`
`shown in Figure 2 “correspond[ ] to the arrival of a signal which has taken a
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`different route.” See ’ 196 Patent at 3:43-47. In other words, each peak in the
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`correlation output of the ’ 196 specification represents the arrival of a received
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`signal plotted relative to the time the transmitted signal was transmitted.
`
`47.
`
`The language of claim 12 makes clear that “time of arriva ” is “when
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`a signal is received in relation to the time when it was transmitted.” After
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`correlating the received multipath signal into plural path signals, the time of arrival
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`of each of those path signals is determined. See ’ 196 Patent at Claim 12. Figure 2
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`shows that the time of arrival is determined relative to a start time of zero. For the
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`reasons explained in the next paragraph, the start time would have been when the
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`signal was originally transmitted.
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`48.
`
`The ’ 196 specification describes a “conventional correlation receiver.”
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`See ’ 196 Patent at 4: 13-17 (“In a preferred embodiment, the base stations receiver
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`is a conventional correlation receiver in which the power level of the arriving
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`signal is correlated in time and the signal arriving first in [time] is used to
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`determine the total propagation time and angle of arrival”). One of ordinary skill
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`in the art at the time would have understood that this “conventional correlation
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`receiver” would have determined the time of arrival of the signal by determining
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`the delay between when the signal was transmitted and when it was received
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`because such a receiver was known at the time of the alleged invention. One of
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`skill in the art would also recognize that delay or propagation time as a “time of
`
`flight.” For example, Dixon describes such a receiver in a basic pseudonoise or
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`spread-spectrum ranging system. See Ex. 1014, Dixon, A Spread Spectrum
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`Ranging Technique for Aerospace Vehicles (published 1968, reprinted in Dixon,
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`Spread Spectrum Techniques (published 1976)), at 278. (“The receiver ‘decodes’
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`a received signal by matching an internally generated sequence to the incoming
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`signal. For ranging, the important point is that the receiver matches its internal
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`sequence to the signal that it sees, and this signal is delayed by an amount of time
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`equal to the propagation timefrom transmitter to receiver”). In other words, a
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`range is detennined from a delay time and the delay time is calculated by counting
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`the number of bits that a reference signal must be delayed in order for the received
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`and local codes to match. Id; see also Section VI.B, above.
`
`49.
`
`For the foregoing reasons, one of ordinary skill in the art at the time of
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`the alleged invention would have understood “time of arrival” to mean “when a
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`signal is received in relation to the time when it was transmitted.”
`
`IX.
`
`’196 PATENT INVALIDITY
`
`A. U.S. Patent 5,381,444 to Tajima (“Tajima”)
`
`50.
`
`Tajima describes “A radio environment measuring system for
`
`measuring a propagation state of radio waves.” (Ex. 1001,, Abstract) As shown in
`
`the image below, the system described in Tajima consists of two pieces of
`
`apparatus: the Fixed Radio Apparatus and the Mobile Radio Apparatus.
`
`Fig. 3
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`TRANSMSSIONI
`RECEPTION
`‘LIMIT
`
`MEASLJFHNG
`
`UNIT
`
`|
`
`Rf-WSMISSIDN
`
`TRANSMSSION I’
`RECEPTDN
`UNIT
`
`RETURNING
`
`MOBJLE RAEHO
`Awmams
`
`Bla§.E’c"r‘l‘%'§
`l§%%§:'2l'%‘3fi'
`FIXED
`APPARI§f5lPE‘iO
`
`51.
`
`The Abstract explains that the fixed apparatus sends a signal to the
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`mobile apparatus, then receives the return signal from the mobile apparatus. The
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`fixed apparatus also comprises a measuring unit for measuring the propagation
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`distance of the radio waves between the fixed apparatus and the mobile apparatus.
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`52. However, as Tajima explains, “in an urban district in which there are
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`many high buildings, since such high buildings constitute reflective bodies against
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`the radio waves, it is very difficult for the mobile radio apparatus to distinguish
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`whether received radio wave is direct or reflected radio wave. Accordingly, it is
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`very difficult to precisely measure the propagation distance/time of the radio
`
`wave.” 4:24-29. Figure l of Tajima illustrates this problem.
`
`Fig.
`
`I
`
`12
`
`I
`
`("N
`x ’ ‘
`
`,»—’
`BUILDING
`
`REFL ECTEO
`'5.
`‘~\,,_RADro wave
`
`“N.
`
`MOBILE
`FIXED
`
`RAEII)
`RADIO
`
`APPARATUS
`APPARATUS.
`
`
`
`
`
`
`53.
`
`Tajima explains that one path (the direct path) results from direct
`
`propagation from the mobile apparatus to the fixed apparatus, another path results
`
`from the reflection of the signal by the wall of the building. The reception of
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`multiple signals produces the combination as shown in Figure 2.
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`F1?. 2
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`
`
` CORRELATIVEDBTPUT
`
`REFLECTED
`WW5 I
`
`
`
`REFLECTED
`WAVE 2
`
`»‘fa‘€:%’i’_z""“
`RAW
`APPARATUS
`
`R‘
`R”
`S§0Fé.2g!£\g1C;:dAVEISTANCE mus;
`
`R”
`
`54.
`
`Tajima seeks to resolve the returned signal into these components
`
`(direct wave, reflected wave 1, and reflected wave 2). These waves are
`
`distinguished based on correlation. The maximum point of each wave’s
`
`correlation function is considered the time of arrival of each wave. See 9: 16-17
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`(“[T]his distance R0 denotes the maximum point of the correlation output of the
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`direct radio wave”). The propagation distance and reception level are measured
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`based on the maximum point of the correlation function. See id; see also 5:46-50.
`
`55.
`
`In order to determine the maximum point on the correlation function
`
`for each wave, Tajima teaches that the transmitted radio signal is first modulated
`
`by a pseudo noise (PN) signal or by a barker code. This modulation results in a
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`spread spectrum signal being transmitted. The return signal is next demodulated.
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`Then the demodulated signal is correlated with the reference signal to determine
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`the correlation as a function of time.
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`56.
`
`Tajima sometimes refers to “auto-correlation.” See, e. g., 5:46-50.
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`One of ordinary skill in the art would understand that auto-correlation is a
`
`correlation using a reference signal that is the same as the transmitted signal
`
`(though it may be shifted in time). See Ex. 1017, The New IEEE Standard
`
`Dictionary of Electrical and Electronics Terms, 274 (5th Ed. l993)(“The term
`
`correlation detection may also apply to detection involving autocorrelation, in
`
`which case the locally generated function is merely a delayed form of the received
`
`signal”).
`
`57.
`
`Figure 9 of Tajima illustrates this correlation process. For the
`
`purposes of this example, assume that the modulation rate is 1 symbol per
`
`microsecond. At time 0, the transmitter begins transmitting the barker code as
`
`follows:
`
`Time
`
`transmitted
`
`0
`
`signal
`+1
`
`0.1 usec -1
`
`0.2 usec +1
`
`0.3 usec -1
`
`0.4 usec +1
`
`58. Note that the mid point of the transmitted signal occurs at 0.2 usec.
`
`Next, the receiver begins to receive the demodulated signal at (for example) after
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`1.0 microseconds.
`
`time
`
`received
`
`signal
`1.0 usec +1
`
`1.1 usec -1
`
`1.2 usec --1
`
`1.3 usec --1
`
`1.4 usec --1
`
`59.
`
`Similarly the midpoint of the received signal occurs at 1.2 usec. Thus
`
`for example at 1.0 usec, the receiver has just received the first symbol, +1. At 1.1
`
`usec, the receiver then receives the -1, so in total the receiver has received +1, then
`
`-1. This process continues as shown in Figure 9 of Tajima:
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`5 BITS BARKER CODE
`+1~l~¥+1-‘i-+1
`
`SHIFT REGISTER
`
`E5
`
`
`
`60.
`
`Focusing on the output graph show above, I have created an annotated
`
`version of this Figure in accordance with the parameters 1 described above (1
`
`symbol/.1 usec, and 1.0 usec delay).
`
`I have also expanded and provided more
`
`detail of the figure to improve clarity.
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`61.
`
`Each received bit is shifted into the shift register, one bit at a time.
`
`The input to the summing operator in each position is the received signal in that
`
`position multiplied by the value of the barker code at that position. For example, at
`
`time 0.9 usec, the second bit of the shift register is +1, while the first bit is -1. All
`
`other bits are 0. Accordingly, the output of the sum operator is l + (-1) = 0.
`
`62.
`
`As Tajima states, “it is possible to obtain a time indicating the
`
`maximum correlation based on the change of the number of shift operation or the
`
`number of shift clock so that it is possible to obtain the propagation time, i.e., the
`
`propagation distance of the radio wave.” Id. at 11:8-13. The pseudo noise
`
`generator “is started in the transmission timing so that the reception code in the
`
`register 50 and an output of the pseudo noise generator 80 are input to
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