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. IPR2015-01664
`
`SUPPLEMENTAL DECLARATION OF ZYGMUNT J. HAAS, PH.D.
`UNDER 37 C.F.R. § 1.68 ON BEHALF OF PETITIONER
`
`
`
`
`
`ERIC-1020
`Ericsson v. IV, IPR2015-01664
`Page 1 of 23
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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. IPR2015-01664
`
`SUPPLEMENTAL DECLARATION OF ZYGMUNT J. HAAS, PH.D.
`UNDER 37 C.F.R. § 1.68 ON BEHALF OF PETITIONER
`
`
`
`
`
`ERIC-1020
`Ericsson v. IV, IPR2015-01664
`Page 1 of 23
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`TABLE OF CONTENTS
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`Introduction ........................................................................................................................... 1
`I.
`II. Claim Construction ............................................................................................................... 2
`A.
`“variable band” .............................................................................................................. 2
`III. The Prior Art References Disclose the Disputed Claim Elements ................................ 7
`A.
`“Transmit[ting] a broadcast channel in an orthogonal frequency division multiple
`access (OFDMA) core-band” ................................................................................................... 7
`“Transmitting control and data channels using a variable band including a second
`B.
`plurality of subcarrier groups”.............................................................................................. 11
`1.
`Prior art shows a “variable band,” even under Patent Owner’s construction ... 11
`2.
`Prior art discloses both a “first plurality of subcarrier groups” and a “second
`plurality of subcarrier groups”.......................................................................................... 13
`IV. Reasons to Combine Dulin and Yamaura ..................................................................... 16
`A.
`Location of Frame Map ................................................................................................ 16
`B.
`Dulin teaches the use of one base station ...................................................................... 18
`C.
`Dr. Zeger’s arguments regarding “no reasonable expectation of success” are without
`merit 19
`V. Conclusion ........................................................................................................................... 21
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`ERIC-1020
`Page 2 of 23
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`Haas Decl.
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`I.
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`Introduction
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`IPR2015-01664
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`1. 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., IPR2015-
`
`01664. I have provided an updated CV as ERIC-1022.
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`2.
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`In the preparation for this declaration, I have studied:
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`(1) The ’431 Patent, ERIC-1001;
`
`(2) U.S. Publication No. 2002/0055356 (“Dulin”), ERIC-1002;
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`(3) U.S. Patent No. 7,782,750 (“Yamaura”), ERIC-1003;
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`(4) U.S. Patent No. 7,426,175 (“Zhuang”), ERIC-1004;
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`(5) I. Hwang et al., IEEE C802.16d-04/19, “A New Frame Structure for
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`Scalable OFDMA Systems,” pp. 0-12, March 11, 2004 (“Hwang”),
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`ERIC-1005;
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`(6) My previous declaration in this IPR, Declaration of Zygmunt J. Haas,
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`ERIC-1012;
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`(7) Deposition Transcript of Kenneth Zeger, June 15, 2016, (“Zeger Depo.”),
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`ERIC-1018;
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`(8) U.S. Publication No. 2002/0141355 (“Struhsaker”), ERIC-1020; and
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`(9) Declaration of Kenneth Zeger (“Zeger Decl.”), Ex. 2001.
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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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`1
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`ERIC-1020
`Page 3 of 23
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`Haas Decl.
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`II. Claim Construction
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`IPR2015-01664
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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
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`for a term. The discussion of the claim terms below is my opinion regarding each
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`of 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
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`in the art at the priority date of the ‘431 patent..
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`A. “variable band”
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`5.
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`I did not offer a construction of “variable band” in my previous
`
`declaration, ERIC-1012, implicitly taking the position that no construction was
`
`necessary. However, Dr. Zeger has proposed a construction for the term “variable
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`band” as “a frequency band having variable operating channel bandwidth.” I
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`disagree with the construction, because Dr. Zeger adds the terms “operating
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`channel” to “variable band,” thereby unduly limiting the term “variable band.”
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`The term “variable band” does not need construction as the plain and ordinary
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`meaning is sufficient. To the extent the Board is considering adopting a claim
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`2
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`ERIC-1020
`Page 4 of 23
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`Haas Decl.
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`construction for the term “variable band”, it is my opinion that “variable band”
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`IPR2015-01664
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`
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`should be interpreted to mean “variable bandwidth.”
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`6.
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`The term “variable band” is not used in the specification of the ’431
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`patent.
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` However, the terms “variable bandwidth” and “variable channel
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`bandwidth” are used in the specification, particularly in the section entitled
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`“Variable Bandwidth OFDMA.” See Ex.1001, 4:16-62. Moreover, the terms
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`“variable bandwidth” and “variable channel bandwidth” are used in the
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`specification in a very general context to refer to the flexibility of an OFDMA
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`system to vary signal bandwidth by simply varying the number of subchannels, as
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`discussed further below.
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`7.
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`The ’431 patent describes a degree of flexibility in the use of the
`
`operating channel bandwidth (or available bandwidth) in that the available
`
`bandwidth is divided into “subchannels” that “provides high flexibility.” Ex. 1001,
`
`3:11. This flexibility is described further as follows:
`
`“The data subcarriers can be arranged into groups called subchannels
`to support scalability and multiple-access. Each subchannel may be
`set at a different power level. The subcarriers forming one subchannel
`may or may not be adjacent to each other. Each user may use some
`or all of the subchannels.”
`Ex. 1001, 3:34-40 (emphasis added). Thus, the ’431 patent describes a flexible use of
`
`the spectral bandwidth in which a user may use “some or all” of the subchannels. Said
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`3
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`ERIC-1020
`Page 5 of 23
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`Haas Decl.
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`differently, at any particular time, a user is not necessarily required to use all the
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`IPR2015-01664
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`
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`subchannels (i.e., all the operating channel bandwidth or available bandwidth).
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`8.
`
`As an example, referring to Figure 3, a mobile terminal
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`(corresponding to a “user”) at a given time may be assigned subchannel 2, and at
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`another time the mobile terminal may be assigned all the subchannels. There is no
`
`requirement that there exists another mobile terminal at these times, or that a user
`
`always be given the total bandwidth. Figure 3 shows the set of subchannels in the
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`frequency domain with differing heights of the subchannels representing power
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`(“[e]ach subchannel may be set at a different power level). A particular scenario of
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`a user occupying subchannel 2 at time t1, and all the subchannels at a later time t2 is
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`illustrated in annotated Fig. 3 of the ’431 patent below, which illustrates varying
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`the signal bandwidth. At time t2, the occupied bandwidth is equal to the operating
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`channel bandwidth, or the total available bandwidth.
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`4
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`ERIC-1020
`Page 6 of 23
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`Haas Decl.
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`IPR2015-01664
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`’431 patent, Figure 3 (annotated, user 1, time t1)
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`5
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`Haas Decl.
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`IPR2015-01664
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`’431 patent, Figure 3 (annotated, user 1, time t2)
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`
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`9.
`
`This understanding is consistent with other parts of the ’431 patent.
`
`In one example, a mobile station is described as sending a “bandwidth request” to a
`
`base station, which is consistent with a mobile station requesting and thereafter
`
`receiving a varying signal bandwidth. As another example, the ’431 patent states:
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`“In some embodiments, the variable channel bandwidth is realized by adjusting
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`the number of usable subcarriers.” Ex. 1001, 4:25-26 (emphasis added).
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`6
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`ERIC-1020
`Page 8 of 23
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`Haas Decl.
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`IPR2015-01664
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`10. Accordingly, based on the ’431 patent specification, the term
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`“variable band” means a “variable bandwidth,” as opposed to Dr. Zeger’s proposed
`
`construction of “variable operating channel bandwidth.” It is my opinion that the
`
`term does not need construction as the plain and ordinary meaning is sufficient. To
`
`the extent the Board is considering adopting a claim construction, it is my opinion
`
`that “variable band” should be interpreted to mean “variable bandwidth.”
`
`III. The Prior Art References Disclose the Disputed Claim Elements
`
`A. “Transmit[ting] a broadcast channel in an orthogonal frequency
`division multiple access (OFDMA) core-band”
`
`11. According to Dr. Zeger, “Yamaura’s Figure 17, reproduced and
`
`
`
`annotated below, illustrates the point that Yamaura’s base station transmits only
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`part of the control signals in the narrow-band during the broadcast burst.” Ex.
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`2001, ¶ 115. Dr. Zeger incorrectly illustrates Yamaura’s control signals as follows:
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`Furthermore, according to Dr. Zeger:
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`7
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`ERIC-1020
`Page 9 of 23
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`Haas Decl.
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`IPR2015-01664
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`“As illustrated above, based on the disclosure of Yamaura, only a part
`of the control signals are transmitted using the narrow-band carriers
`SC1 and SC2 during the broadcast burst. As set forth in the annotated
`figure above, the remaining part of the control signals are transmitted
`by multiplexing the information on the other subcarriers during the
`broadcast burst period.”
`Ex. 2001, ¶ 116.
`There is no explicit disclosure of Dr. Zeger’s alleged understanding in Yamaura,
`
`and Dr. Zeger is incorrect in inferring that a transmitter sends “part” of control
`
`signals in subcarriers SC1 and SC2 at the same time as another “part” of control
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`signals are transmitted outside subcarrier SC1 and SC2 during the broadcast
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`preamble, BCH, and FCH time slots.
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`12. Contrary to Dr. Zeger’s inference, the other “part” of control signals not
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`in SC1 and SC2 refers to control signals not transmitted at the same time as the
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`broadcast preamble, BCH, and FCH time slots. For example, the ACH time slot also
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`carries control signals: “The broadcast burst consists of … ACH for reply to RCH
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`used for calling from the terminal station.” Yamaura, 21:7-11. Dr. Zeger confirms
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`this understanding:
`
`Q In Yamaura, does the ACH carry control signals?
`[…]
`A Yeah. I think it -- I think that's what it does. … ACH is used to reply
`to RCH for calling from terminal stations, so I think the answer’s yes.
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`Zeger Trans., 96:15-21.
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`8
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`ERIC-1020
`Page 10 of 23
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`Haas Decl.
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`Furthermore, Yamaura teaches the following, regarding transmission and reception
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`IPR2015-01664
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`
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`using a small number of subcarriers.
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`• “All that is necessary is to place specific control signals (such as calling signals for
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`the terminal station) in the data in the two subcarriers SC1 and SC2.” Id., 21:30-32.
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`• “This passing band variable filter 236 is so designed as to vary the passing band
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`according to control by the control unit 202. […] At the time of waiting reception,
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`[variable filter 236] is so set up as to pass the narrow band including only the two
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`subcarriers SC1 and SC2 near the center.” Id., 21:60-67 (emphasis and brackets
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`added).
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`• “The advantage of operating the system constituted as in the second embodiment
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`is that all that is necessary is to receive intermittently specific subcarriers [e.g., SC1
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`and SC2] in the vicinity of the central frequency f0 in the carrier frequency band
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`while the terminal station is in the stand-by state.” Id., 23:49-53 (brackets added).
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`Specific control signals are broadcast on subcarriers SC1 and SC2 during the time
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`periods of the broadcast preamble, BCH and FCH, while other control signals are
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`broadcast on additional subcarriers during at least the ACH time period. These
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`teachings of Yamaura are illustrated below.
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`ERIC-1020
`Page 11 of 23
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`Haas Decl.
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`IPR2015-01664
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`Yamaura, Figure 17 (annotated)
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`
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`13. Thus, during the broadcast preamble, BCH, and FCH time slots, the
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`subcarriers SC1 and SC2 include the claimed “broadcast channel.” As explained in
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`my previous declaration, the combination of Dulin, Yamaura, and Hwang discloses
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`“transmit[ting] a broadcast channel in an orthogonal frequency division multiple
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`access (OFDMA) core-band.” See ERIC-1012, pp. 63-80.
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`10
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`ERIC-1020
`Page 12 of 23
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`Haas Decl.
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`IPR2015-01664
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`B. “Transmitting control and data channels using a variable band including a
`second plurality of subcarrier groups”
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`
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`
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`1. Prior art shows a “variable band,” even under Patent Owner’s
`construction
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`14. As discussed earlier, Dr. Zeger incorrectly alleges that “variable band”
`
`means a “frequency band having a variable operating channel bandwidth.” Also, as
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`explained in my prior declaration, the term “core-band” means “a frequency segment
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`that is not greater than the smallest operating channel bandwidth among all the
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`possible spectral bands that a receiver is designed to operate with,” see ERIC-1012, ¶
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`28, which implies that in the ’431 patent there is more than one variable operating
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`channel bandwidth.
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`15.
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`In my prior declaration (ERIC-1012), I demonstrated that Hwang (in
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`combination with Yamaura) discloses a “core-band” for claim element 8.1, wherein
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`“core-band” is “a frequency segment that is not greater than the smallest operating
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`channel bandwidth among all the possible spectral bands with which the receiver is
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`designed to operate.” See ERIC-1012, pp. 72-73. The following is an excerpt from
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`my prior declaration:
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`11
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`ERIC-1020
`Page 13 of 23
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`Haas Decl.
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`ERIC-1012, p. 52. Hwang thus teaches a variable operating channel bandwidth. I
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`illustrated this in my prior declaration on p. 76 in an annotated figure. The figure is
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`reproduced below, with a new annotation added on the right in purple to highlight
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`Hwang’s variable operating channel bandwidth.
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`12
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`ERIC-1020
`Page 14 of 23
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`Haas Decl.
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`16. Thus, Hwang still teaches “variable band” even under Dr. Zeger’s
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`flawed construction of “variable band,” as “frequency band having a variable
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`operating channel bandwidth.”
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`2. Prior art discloses both a “first plurality of subcarrier groups” and a
`“second plurality of subcarrier groups”
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`17. The language of claim 18 is as follows (claim 8 is substantively similar):
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`
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`“transmitting control and data channels by the cellular base station using a variable
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`band including a second plurality of subcarrier groups, wherein the variable band
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`includes at least the core-band.”
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`13
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`Haas Decl.
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`18. Dr. Zeger essentially seems to argue that in order to satisfy this claim
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`element, the control channels must use the second plurality of subcarrier groups, and
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`the data channels must also use the second plurality of subcarrier groups:
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`“However, the variable band as purportedly disclosed by Dulin only
`provides for a second plurality of subcarrier groups that include data
`channels, not “control and data channels” as claimed. To the extent the
`Petition relies on Yamaura’s control channels transmitted in frequency
`block B2, Yamaura’s control channels correspond to the first plurality of
`subcarrier groups.”
`Ex. 2001, ¶ 123. Thus, according to Dr. Zeger, Petitioner’s showing of control
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`channels in the core-band (which includes a first plurality of subcarrier groups) and
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`data channels in the second plurality of subcarrier groups does not satisfy the claim,
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`because there must also be a control channel in the second plurality of subcarrier
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`groups.
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`19.
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`I disagree with Dr. Zeger based on the plain language of claims 8 and 18.
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`The “control and data channels,” or, as construed, “control channels and data
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`channels,” use a variable band, wherein the variable band includes the core-band and
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`a second plurality of subcarrier groups. This claim element does not specify which of
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`the control channels or data channels is in which part of the variable band. The prior
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`art combination, which I rely on in my analysis, shows data channels using a second
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`plurality of subcarrier groups and control channels using the core-band (which
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`includes a first plurality of subcarrier groups and is part of the variable band). Thus,
`14
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`ERIC-1020
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`Haas Decl.
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`the control channels and data channels together use the variable band, which is all that
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`IPR2015-01664
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`is required by the claim.
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`20. Furthermore, even assuming Dr. Zeger’s incorrect interpretation,
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`Yamaura illustrates a control channel, namely ACH, that uses the entire operating
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`channel bandwidth, which includes a second plurality of subcarrier groups. For
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`example, the ACH time slot also carries control signals: “The broadcast burst consists
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`of […] ACH for reply to RCH used for calling from the terminal station.”
`
`Yamaura, 21:7-11. Dr. Zeger confirms this understanding:
`
`Q In Yamaura, does the ACH carry control signals?
`[…]
`A Yeah. I think it -- I think that's what it does. … ACH is used to reply
`to RCH for calling from terminal stations, so I think the answer’s yes.
`
`Zeger Depo., 96:15-21. Fig. 17 from Yamaura, annotated below, illustrates the
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`ACH:
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`15
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`ERIC-1020
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`Haas Decl.
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`IPR2015-01664
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`Additional subcarriers are used during the broadcast burst in the ACH slot, so that
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`transmission of the ACH uses the full operating channel bandwidth. These additional
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`subcarriers are available to transmit data channels in the later portions of the claim.
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`
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`IV. Reasons to Combine Dulin and Yamaura
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`A. Location of Frame Map
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`21. Dr. Zeger makes a number of allegations about the combination of Dulin
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`and Yamaura. First, Dr. Zeger alleges that Dulin teaches away from Yamaura,
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`because Dulin requires frame map information at the beginning of a frame, see Ex.
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`2001, ¶ 127, whereas Yamaura conveys frame map information in the FCH time slot,
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`which is after the broadcast preamble and BCH time slots, i.e., not at the beginning of
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`Haas Decl.
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` a
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` frame, see id., ¶ 130. Dr. Zeger uses flawed technical reasoning in making this
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`allegation.
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`22. First, Dr. Zeger, recognizes that synchronization is essential for radio
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`operation yet Dulin does not describe how it will accomplish the synchronization.
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`Zeger, 61:20-62:3. Dr. Zeger also recognized that early on in the communication
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`between a base station and a receiver one needs to accomplish synchronization and
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`cell identification to establish communication. Zeger, 45:16-46:11. Thus, once Dulin
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`is placed in the context of an actual system, even Dulin would need to send
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`synchronization (broadcast preamble) and cell identification (BCH) before sending a
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`frame map.
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`23. A frame map should necessarily come before any data transmission. For
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`systems, such as the combined Yamaura and Dulin system, that have preamble
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`information and other control information at the beginning of a frame followed by
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`data transmission, the frame map should come near the beginning of the frame –
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`before the data transmission. It was never my position that a frame map must be the
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`very first thing transmitted in a frame, as Dr. Zeger seems to imply. Again, given the
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`fact that some operations (such as synchronization) are required before data reception
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`commences, placing the frame map as the very first thing in a frame would be
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`unreasonable.
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`17
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`Haas Decl.
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`24. All that is required for the combined Dulin and Yamaura system to work
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`is that a frame map be transmitted before Dulin’s data blocks – mobile stations must
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`necessarily be able to determine which time slots and frequency blocks to use for
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`receiving the data blocks. When Dulin is combined with Yamaura, data is transmitted
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`after the initial control information is transmitted.
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`B. Dulin teaches the use of one base station
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`25. According to Dr. Zeger, Dulin and Yamaura would not be combined
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`because they are “very different,” Ex. 2001, p. 54, as Dulin allegedly relates to “two
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`or more base stations” communicating with a mobile terminal, whereas Yamaura
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`relates to a “single base station” communicating with a mobile terminal, see id., ¶ 136.
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`26. Contrary to Dr. Zeger’s characterization, Dulin teaches a single base
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`transceiver station having a single antenna communicating with a single mobile
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`station/subscriber unit. According to Dulin, there are several modes of transmission,
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`one which “includes transmission between a single base transceiver station and a
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`single subscriber unit.” Id., para. [0073]. See also id. para. [0072] (“If transmission is
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`between only a single base transceiver station and a single subscriber unit, then look
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`ahead scheduling is not required.”). Base transceiver stations are illustrated as having
`
`a single antenna (see Dulin, Fig. 3 and para. [0059]). Thus, Dulin discloses a
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`communication mode in which a base transceiver station having a single antenna
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`communicates with a mobile station/subscriber unit.
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`Haas Decl.
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`C. Dr. Zeger’s arguments regarding “no reasonable expectation of success”
`are without merit
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`27. According to Dr. Zeger, “[a] person of ordinary skill in the art would
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`recognize that some time will elapse between decoding the received map information
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`[in Yamaura’s FCH] and tuning the receiver to the center frequency of the assigned
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`frequency block [to receive Dulin’s data],” and thus the receiver will miss some of the
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`data transmitted to it while retuning the receiver. See Ex. 2001, ¶ 147 (brackets
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`added).
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`28. Dr. Zeger is incorrect. For OFDM transmission, such as in Dulin and in
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`Yamaura, reception of an OFDM signal of varying bandwidth and varying use of
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`frequency blocks can be controlled in a digital signal processor that implements Fast
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`Fourier transforms (FFTs) by selectively zeroing out subbands, so that the elapsed
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`time for tuning the receiver is negligble. Indeed, Dr. Zeger suggests this technique in
`
`his deposition:
`
`Q Okay. What part of the receiver is being tuned?
`
`[…]
`
`A Well, either a local oscillator or, if you’re using FFTs, taking out
`certain sub-bands from it. I mean, it depends how it's implemented.
`
`Zeger Depo., 116:4-13. There is no need to retune a local oscillator (or a frequency
`
`synthesizer) to the center frequency of a frequency block. Rather, one option is for
`
`the center frequency for RF reception to remain the same for all time slots and simple
`
`
`
`19
`
`
`
`ERIC-1020
`Page 21 of 23
`
`
`
`Haas Decl.
`
`selecting of the subband(s) of interest from FFT could be used. Thus, the tuning
`
`IPR2015-01664
`
`
`
`operation would simply consist of selecting the appropriate subcarriers.
`
`29. Furthermore, for a given receiver architecture, the extent there is any
`
`non-negligible time required to switch between narrow band processing of SC1 and
`
`SC2 and reception of data channels, it would not require undue experimentation to
`
`insert a small transition period in the frame between the end of control signals in SC1
`
`and SC2 and the beginning data of channels to allow a receiver to adjust. Dr. Zeger
`
`admits that a POSITA “would recognize that some time would elapse between
`
`decoding the received map information and tuning the receiver to the center frequency
`
`of the assigned frequency block.” Given this recognition, a POSITA would have
`
`recognized that merely inserting a transition period in the frame would allow for the
`
`proper operation of the switching hardware. For example, Struhsaker discusses a
`
`“TDD transition period 350[…] for delay associated with switching hardware
`
`operations from TX to RX or from RX to TX” in a TDD system. See ERIC-1020,
`
`para. [0123]. A similar sort of transition period could be used in a combined
`
`Yamaura/Dulin system if receiver architectures were expected to have non-negligible
`
`switching periods.
`
`
`
`
`
`
`
`20
`
`
`
`ERIC-1020
`Page 22 of 23
`
`
`
`Haas Decl.
`
`IPR2015-01664
`
`V.
`
`Conclusion
`
`30.
`
`This declaration and my opinions herein are made to the best of my
`
`knowledge and understanding, and based on the material available to me, at the
`
`time of signing this declaration.
`
`I declare that all statements made herein on my
`
`own knowledge are true and that all statements made on information and belief are
`
`believed to be true, and further,
`
`that
`
`these statements were made with the
`
`knowledge that willful false statements and the like so made are punishable by fine
`
`or imprisonment, or both, under Section 1001 or Title 18 of the United States
`
`Code.
`
`_July 25, 2016
`Date
`
`/Zygmunt Haas/
`Zygmunt Haas, Ph.D.
`
`21
`
`ERIC-1020
`
`Page 23 of 23
`
`ERIC-1020
`Page 23 of 23
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