UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`WAVES AUDIO, LTD
`Petitioner
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`v.
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`ANDREA ELECTRONICS CORPORATION
`Patent Owner
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`Case: IPR2016-00474
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`Patent 6,049,607
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`AMENDED PETITION FOR INTER PARTES REVIEW OF
`U.S. PATENT NO. 6,049,607
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`

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`
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`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
`
`Joseph Marsh, et al.
`6,049,607
`April 11, 2000
`09/157,035
`September 18, 1998
`Interference Canceling Method and Apparatus
`
`In re Patent of:
`U.S. Patent No.:
`Issue Date:
`Serial No.:
`Filing Date:
`Title:
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`
`Submitted via Electronic Filing
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`AMENDED PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NUMBER 6,049,607 UNDER 35 U.S.C. §§ 311-319
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`Waves Audio Ltd. (“Waves” or “Petitioner”) hereby requests Inter Partes
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`Review of Claims 1-4, 8, 25-28 and 32 in United States Patent Number 6,049,607
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`(“the ’607 Patent,” Exhibit 1001) owned by Andrea Electronics Corporation, LLC
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`(“Andrea” or “Patentee”). A detailed statement supporting the petition follows.
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`The present Amended Petition is being filed to address the defects noted in the
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`Notice of Filing Date Accorded to Petition mailed January 22, 2016. The requisite
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`fee accompanied Petitioner’s initial Petition. If any additional fee is necessary the
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`Director is authorized to charge Deposit Account No. 50-5159. This document has
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`been served on the Patent Owner as reflected in the accompanying Certificate of
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`Service.
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`ii
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`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
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`TABLE OF CONTENTS
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`V.
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`MANDATORY NOTICES ............................................................................ 1
`I.
`PAYMENT OF FEES .................................................................................... 3
`II.
`STANDING ................................................................................................... 3
`III.
`IV. REQUEST TO HOLD CLAIMS 1-4, 8, 25-18 and 32 OF THE ’607
`PATENT UNPATENTABLE ........................................................................ 3
`The Alleged Invention Of The ’607 Patent ........................................ 4
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`Summary Of The Prosecution History Of The ’607 Patent ............... 4
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`CLAIM CONSTRUCTION ........................................................................... 5
`Broadest Reasonable Construction ..................................................... 5
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`“interference signal” (claims 1-2 and 25-26) ...................................... 6
`“adaptive filter” (claims 1, 3, 4, 8, 25, 27, 28 and 32) ....................... 6
`“target signal” (claims 1, 2, 25, 26 and 27) ........................................ 6
`“reference signal” (claims 2, 4, 5, 12, 26, 28, 29 and 37) .................. 6
`“main signal” (claims 5, 8, 12, 29, 32 and 36) ................................... 7
`“transform function” (claims 9, 33) .................................................... 7
`“main input for inputting said target signal / inputting said target
`signal” (claims 1) ................................................................................ 7
`“band limited…signals” (claims 1, 3, 25 and 27) .............................. 7
`“reference input for inputting said interference signal” (claims 1, 2,
`4, 26 and 28) ....................................................................................... 7
`“cancelling” (claims 1 and 25) ........................................................... 8
`“beam splitting/beam splitter” (claims 1 and 25) ............................... 8
`“beam selector” (claims 8 and 32) ...................................................... 8
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`

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`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
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`VI. PRIOR ART TO THE ’345 PATENT FORMING THE BASIS FOR THIS
`PETITION ...................................................................................................... 8
` Prior Art Documents ............................................................................. 8
`Summary Of Unpatentability Arguments ........................................... 10
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`VII. GROUNDS FOR UNPATENTABILITY OF EACH CLAIM ................... 12
` Ground 1: Claims 1-4 and 25-28 Are Unpatentable Under 35 U.S.C. §
`102(b) As Being Anticipated By Chu 307. .......................................... 12
` Ground 2: Claims 1-4 and 25-28 Are Unpatentable Under 35 U.S.C. §
`102(a) As Being Anticipated By Nakagawa ........................................ 20
` Ground 3: Claims 1, 2, 8, 25, 26 and 32 are Unpatentable Under 35
`U.S.C. § 103(a) as Being Obvious over Chu 307 in view of Chu 1995.
` .......................................................................................................... 28
`D. Ground 4: Claims 1-3, 8, 25-27 and 32 Are Unpatentable Under 35
`U.S.C. § 103(a) As Being Obvious over Chu 1993 in view of Chu
`1995. .................................................................................................... 38
` Ground 5: Claims 8 and 32 Are Unpatentable Under 35 U.S.C. §
`103(a) As Being Obvious over Chu 307 or Nakagawa or Dreiseitel in
`view of Griffiths. ................................................................................. 49
` Ground 6: Claims 8 and 32 are Unpatentable Under 35 U.S.C. §
`103(a) As Being Obvious Over Chu ‘307 or Nakagawa in view of
`Provencher. .......................................................................................... 51
` Ground 7: Claims 8 and 32 are Unpatentable Under 35 U.S.C. §
`103(a) As Being Obvious Over Chu 307 or Nakagawa in view of
`Huang. ................................................................................................. 53
`VIII. CONCLUSION ............................................................................................ 54
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`iv
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`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
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`PETITIONER’S EXHIBIT LIST
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`Description
`U.S. Patent No. 6,049,607, “Interference Canceling Method And
`Apparatus,” to Joseph Marash and Baruch Berdugo, issued on Apr. 11,
`2000 (“the ’607 Patent”)
`
`Exhibit #
`1001
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`Prosecution History of U.S. Patent Application No. 09/157,035 which
`issued as U.S. Patent No. 6,049,607
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`1002
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`Table 1 – List Of Each Challenged Claim Element Annotated
`With Its Claim Number and A Reference Letter
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`Petitioner’s List of Related Litigation Matters, And Patents at Issue
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`Petitioner’s List of IPR Petitions and Challenged Patent Claims of the
`Andrea Patents
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`U.S. Patent No. 5,305,307 (“Chu 307”)
`
`U.S. Patent No. 5,774,561 (“Nakagawa”)
`
`Pia Dreiseitel, Eberhard Hänsler, and Henning Puder, “Acoustic Echo
`and Noise Control – A Long Lasting Challenge,” Signal Processing
`Conference (EUSIPCO), Sept. 8-11, 1998, (“Dreiseitel”)
`
`Chu, “Desktop MIC Array for Teleconferencing.” I.E.E.E., 1995,
`(“Chu 1995”)
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`Peter L. Chu, “Weaver SSB Subband Acoustic Echo Canceller,” 1993
`IEEE Workshop on Applications of Signal Processing to Audio and
`Acoustics, pp. 8-11 (“Chu 1993”)
`
`1003
`
`1004
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`1005
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`1006
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`1007
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`1008
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`1009
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`1010
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`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
`
`Griffiths and Jim, “An Alternative Approach to Linearly Constrained
`Adaptive Beamforming,” IEEE Transactions on Antennas and
`Propagation, vol. 30, No. 1, Jan 1982, (“Griffiths”)
`
`1011
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`U.S. Patent No. 4,032,922 (“Provencher”)
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`U.S. Patent No. 6,173,059 (“Huang”)
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`Declaration of Bertand Hochwald (“Hochwald Decl.”)
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`1012
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`1013
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`1014
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`vi
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` Pursuant to 35 U.S.C. § 311, Petitioner hereby respectfully requests inter
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`partes review of claims 1-4, 8, 25-28 and 32 of Ex. 1001, U.S. Patent No. 6,049,607
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`(“the ’607 Patent”) which issued on March 26, 2002. The challenged claims are
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`unpatentable under 35 U.S.C. §§ 102 and 103 over the prior art publications
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`identified and applied in this Petition.
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`I.
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`MANDATORY NOTICES
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`Pursuant to 37 C.F.R. §42.8, Petitioner provides the following mandatory
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`disclosures:
`
`A.
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`Real Parties-In-Interest. Petitioner, Waves Audio, Ltd., Azrielli Center
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`3, Tel-Aviv 67023, ISRAEL, is a real party in interest for the instant petition.
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`B.
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`Related Matters. Pursuant to 37 C.F.R. § 42.8(b)(2), Petitioner submits
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`that the ’607 Patent is the subject of a series of related patent infringement lawsuits
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`brought by Andrea Electronics Corporation (“Andrea”) in the U.S. District Court
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`for the Eastern District of New York (EDNY Actions) and an action in the U.S.
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`International Trade Commission (USITC Action, Investigation No. 337-TA-949).
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`More detail as to the EDNY Actions and the USITC Action are to be found in
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`Exhibit 1004.
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`A Markman Order was entered in the USITC Action on January 7, 2016 and
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`is attached as part of Exhibit 1004.
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`Petitioner further states that the above cited actions also initially involved
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`

`
`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
`
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`Andrea’s U.S. Patent Nos. 5,825,898, 6,049,607, 6,377,637, and 6,483,923 although
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`the ’898 and ’923 patents are no longer part of the USITC Action and a Motion to
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`Terminate as to the ’637 patent is pending before the Commission.
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`Concurrently, Petitioner is filing one other inter partes review petition,
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`challenging certain claim elements of U.S. Patent No. 6,363,345, which are: (1)
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`subject to additional prior art references; and (2) may affect, or be affected by,
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`decision(s) in the proceedings of the Andrea patents. For further references,
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`Petitioner includes as Exhibit 1004 (list of related litigation matters); and Exhibit
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`1005 (list of concurrently filed IPR petitions and challenged patent claims).
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`B.
`Lead and Back-up Counsel and Service Information – 37 C.F.R.
`§42.8(b) (3) & (4).
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`J. Scott Denko (Reg. No. 37,606) is lead counsel. Patrick Stellitano (Reg.
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`No. 42,169) is associate counsel on this matter. The Petitioner may be served in
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`this matter as follows:
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`Post and Hand
`Delivery
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`Email
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`Telephone No.
`Facsimile No.
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`
`
`J. Scott Denko
`Patrick Stellitano
`Denko Lauff, L.L.P.
`denko@dcllegal.com
`Stellitano@dcllegal.com
`512-906-2074
`512-906-2075
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`
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`

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`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
`
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`PAYMENT OF FEES
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`II.
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`Pursuant to 37 C.F.R. §42.103(a) and 42.15(a), the required filing fees for
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`this petition are submitted and charged to Deposit Account 50-5159. Should any
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`further fees be required by the present Petition, the Patent Trial and Appeal Board
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`(“the Board”) is hereby authorized to charge the above referenced Deposit Account.
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`III.
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`STANDING
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`Pursuant to 37 C.F.R. § 42.104(a), Petitioner certifies that the patent sought
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`for review, U.S. Patent No. 6,049,607, is available for inter partes review and that
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`Petitioner is not barred or estopped from requesting an inter partes review
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`challenging the patent claims on the grounds identified herein.
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`IV. REQUEST TO HOLD CLAIMS 1-4, 8, 25-18 and 32 OF THE ’607
`PATENT UNPATENTABLE
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`Pursuant to 37 C.F.R. § 42.104(b), Petitioner requests that the Board hold
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`claims 1-4, 8, 25-28 and 32 of the ’607 Patent unpatentable. Such relief is justified
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`as the alleged invention of the ’607 Patent was described by others prior to the
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`effective filing date of the ’607 Patent. Attached hereto as Exhibit 1003, is a Table
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`that provides the ’607 patent claim elements challenged, each limitation annotated
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`with its claim number and a reference letter.
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`The specific statutory grounds under 35 U.S.C. §102 and/or §103 upon which
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`each challenge to each claim is based and the patents or printed publications relied
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`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
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`upon for each ground are set forth below.
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` The Alleged Invention Of The ’607 Patent
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`The ’607 Patent describes an apparatus and method for echo-cancelling in a
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`full duplex communication system like a teleconference. A teleconference typically
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`involves sounds present at a “near-end” location, such as those of a near- end
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`loudspeaker, that are received by a microphone or by microphones. These sounds
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`are transmitted to a “far-end” system and subsequently broadcast by a far-end
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`loudspeaker. At the far-end system, sounds emanating from the far-end
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`loudspeaker are also received by the far-end microphone and transmitted to the
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`near-end system where they are broadcast by the near-end loudspeaker. As a result,
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`a disturbing echo will be heard in the system. Without an echo cancellation
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`mechanism in the system, a person speaking into the microphone will hear himself
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`as a result of his or her voice being transmitted over the far-end loudspeaker, into
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`the far-end microphone and back out of the near-end loudspeaker.
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`The ’607 Patent specifically describes cancelling echoes in the system by (1)
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`splitting (through splitter 114) the near-end signal from microphone array 102 and
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`far-end signal (through splitter 128) and (2) adaptively filtering the interference
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`signal from the target signal through adaptive filters 116x. See Ex. 1001, Fig. 1.
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` Summary Of The Prosecution History Of The ’607 Patent
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`The application that led to the ’607 Patent was filed on September 18, 1998
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`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
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`and issued with no rejections. Ex. 1001 and 1002 at p. 54-59. On December 3,
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`1999, the Examiner allowed all claims and stated in his reasons for allowance that
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`the prior art of record taken alone and in combination does not disclose the “beam
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`splitter” limitation recited in claim 1 (i.e., “a beam splitter for beam-splitting said
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`target signal . . . whereby for each band-limited target signal there is a
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`corresponding band-limited interference signal.”). Id, page 55-56. The Examiner
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`also indicated that he had called Applicants’ representative that same day,
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`December 3, to discuss some “minor informalities” in claims 1, 13 and 25. Id. at p.
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`57. The Applicants agreed to an Examiner’s amendment changing “equals” to
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`“equal” in these claims. Id at page 57. Additionally, PCT/US99/21186 was filed
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`on September 14, 1999 which is published and claims the benefit of U.S. Patent
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`Application 09/157,035.
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`V.
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`CLAIM CONSTRUCTION
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` Broadest Reasonable Construction
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`Unless otherwise addressed herein, for the purposes of inter partes review
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`only, the terms of ’607 patent’s claims are to be given their broadest reasonable
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`interpretation, as understood by one of ordinary skill in the art, in view of the ’345
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`patent’s specification. See 37 C.F.R. § 42.100(b).
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`Further, while the Petitioner believes that several claims may be invalid
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`under 35 USC § 112, Petitioner is still providing prior art to challenge the
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`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
`
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`patentability of the requested claims to the extent the Board can determine that the
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`claims are valid under the “broadest reasonable interpretation” standard. The
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`Petitioner’s prior art submission, however, is not an admission on its part that all
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`claims are valid under 35 USC § 112. Accordingly, the Petitioner reserves the right
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`to challenge the validity of the claims of the ’345 patent under 35 USC § 112 in
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`Federal District Court or in an action before the International Trade Commission.
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` “interference signal” (claims 1-2 and 25-26)
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`In harmonization with the Markman Order in the USITC Action, Petitioner
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`submits that the term “interference signal” means the signal from a far end that is
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`picked up as an echo by the main input.
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`“adaptive filter” (claims 1, 3, 4, 8, 25, 27, 28 and 32)
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`Petitioner submits that the term “adaptive filter” means a filter in which the
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`coefficients of the filter change based on at least one band limited reference signal
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`and at least one band limited target signal. Col. 2, lines 16-33, Col. 3, lines 60-64.
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`
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`“target signal” (claims 1, 2, 25, 26 and 27)
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`Petitioner submits that the term “target signal” means the desired signal plus
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`interference. Col. 1, lines 32-48. Col. 3, line 65-col. 4, line 6.
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`
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`“reference signal” (claims 2, 4, 5, 12, 26, 28, 29 and 37)
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`Petitioner submits that the term “reference signal” means the signal conveyed
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`from a far end of a teleconference. Col. 3, line 65-col. 4, line 6.
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`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
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`“main signal” (claims 5, 8, 12, 29, 32 and 36)
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`Petitioner submits that the term “main signal” means the target signal. Col.
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`3, lines 52-55.
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`“transform function” (claims 9, 33)
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`Petitioner submits that the term “transform function” means a model of a
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`transformation that the far end signal undergoes when broadcast and then received
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`at the main input. Col. 7, lines 36-42.
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` “main input for inputting said target signal / inputting said target
`signal” (claims 1)
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`Petitioner submits that the terms “main input” and “inputting said target
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`signal” mean an input from more than one sensor, from which at least one beam is
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`formed / inputting signal from more than one sensor, from which at least one beam
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`is formed. Col. 3, lines 52-55.
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`
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`“band limited…signals” (claims 1, 3, 25 and 27)
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`Petitioner submits that the term “band limited” signal means signals limited
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`to a band of frequencies that are a subset of frequencies of the original target and
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`interference signals. Abstract. Col. 7, lines 6-12.
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`“reference input for inputting said interference signal” (claims 1, 2, 4,
`26 and 28)
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`Petitioner submits that the term “reference input” means an input for the
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`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
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`signal from the far end, separate from the main input. Col. 3 lines 53-55 and col. 3,
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`line 65-col. 4, line 2.
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`“cancelling” (claims 1 and 25)
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`Petitioner submits that the term “cancelling” means subtracting. Col. 7, lines
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`34-37.
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`“beam splitting/beam splitter” (claims 1 and 25)
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`Petitioner submits that the term “beam splitter” means hardware or software
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`that splits a time domain signal into a plurality of band limited signals. Col. 7, lines
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`5-10.
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` “beam selector” (claims 8 and 32)
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`Petitioner submits that the term “beam selector” means hardware or software
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`that selects a beam for adaptive filtering, where a beam is a signal from a particular
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`direction. Col. 4, lines 16-26.
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`VI.
`PRIOR ART TO THE ’345 PATENT FORMING THE BASIS FOR
`THIS PETITION
`
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`Prior Art Documents
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`U.S. Patent No. 5,305,307 (“Chu 307”) (Ex. 1006) was published on April
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`19, 1994. As a result, Chu 307 is available as prior art against all claims of the ‘607
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`patent under 35 U.S.C. § 102(b).
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`U.S. Patent No. 5,774,561 (“Nakagawa”) (Ex. 1007) was published on June
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`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
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`30, 1998. As a result, Nakagawa is available as prior art against all claims of the
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`‘607 patent under 35 U.S.C. § 102(a).
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`Peter L. Chu, “Desktop MIC Array for Teleconferencing.” Proceedings of
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`the 1995 International Conference on Acoustic, Speech and Signal Processing, vol.
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`5, 1995, pages 2999-3002, (“Chu 1995”), (Ex. 1009) was published in the United
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`States in 1995. As a result, Chu 1995 is available as prior art against all claims of
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`the ‘607 patent under 35 U.S.C. § 102(b).
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`Peter L. Chu, “Weaver SSB Subband Acoustic Echo Canceller,” 1993 IEEE
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`Workshop on Applications of Signal Processing to Audio and Acoustics, pp. 8-11
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`(“Chu 1993”) (Ex. 1010) was published in the United States in 1993. As a result,
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`Chu 1993 is available as prior art against all claims of the ‘607 patent under 35
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`U.S.C. § 102(b).
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`Griffiths and Jim, “An Alternative Approach to Linearly Constrained
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`Adaptive Beamforming,” IEEE Transactions on Antennas and Propagation, vol.
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`30, No. 1, Jan 1982, (“Griffiths”), (Ex. 1011) was published in the United States in
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`1982. As a result, Griffiths is available as a prior art against all claims of the ‘607
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`patent under 35 U.S.C. §102(b).
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`U.S. Patent No. 4,032,922 (“Provencher”) (Ex. 1012) was published in 1977.
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`As a result, Provencher is available as a prior art against all claims of the ‘607 patent
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`under 35 U.S.C. §102(b).
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`

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`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
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`U.S. Patent No. 6,173,059 (“Huang”) (Ex. 1013) was filed on April 24, 1998.
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`
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`As a result, Provencher is available as a prior art against all claims of the ‘607 patent
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`under 35 U.S.C. §102(e).
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`None of the references relied upon in this Petition were considered during
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`prosecution of the application of the ’607 Patent.
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`
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`Summary Of Unpatentability Arguments
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`The alleged novel features of the ’607 patent were well known at the time of
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`the alleged invention and it would have been obvious to any person of ordinary skill
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`in the art that they could be used separately, or combined into a single system to
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`obtain the advantages of these various features.
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`For example, Chu 307 (Ex. 1006), describes an echo cancelling device for
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`reducing feedback between a loudspeaker and microphone in a full duplex
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`communication system such as a telephone conferencing system.” Chu 307 (Ex.
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`1006), Abstract.
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`In Chu 307 (Ex. 1006), a microphone converts speech and other acoustic
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`signals in a room into an electronic microphone signal. The signal from the
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`microphone is split into distinct frequency bands and the interference signal from
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`the far end is also split into the same frequency bands as the microphone signal to
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`produce band-limited signals. For each band, a band limited interference signal is
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`submitted to an adaptive filter that models the response of the channel between the
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`10
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`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
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`near end loudspeaker and the near end microphone. The output of each filter is used
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`as the estimated echo signal to be subtracted from the microphone signal. Chu 307
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`(Ex. 1006), Col. 4, lines 42-47. See also, Chu 307, col. 7, lines 7-11.
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`Nakagawa (Ex. 1007) discloses a subband acoustic echo canceller that
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`divides the received (target) signal and an echo (interference) signal and separately
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`splits each signal into a plurality of corresponding subbands. The subband acoustic
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`echo canceller has plurality of subband echo path estimation parts for estimating
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`the transfer functions of the subband echo paths from the subband errors signals
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`and subband received signals by an adaptive algorithm so that the subband error
`
`signals are reduced to zero. Nakagawa (Ex. 1007), col. 2, lines 32-39, and col. 4,
`
`lines 27-32.
`
`Chu 1995 (Ex. 1009) describes a beam selection method coupled with echo
`
`cancellation. Chu 1995, section 2 and 4. Chu (Ex. 1010) 1993 discloses sub band
`
`echo cancellation without an intervening whitening filter between the main input
`
`and the sub-band beam splitter. Chu 1993, section 2.1, Figure 1. Griffiths (Ex.
`
`1011) describes beam steering for an array of sensors. Griffiths (1011), page 27,
`
`col. 2. Provencher (Ex. 1012) describes an adaptive that can maximize a desired
`
`signal from a given direction. Provencher (Ex. 1012), col. 1, lines 21-24. Huang
`
`(Ex. 1013), discloses an adaptive array that can maximize the desired signal in a
`
`given direction by a beam-selection process. Huang (Ex. 1013), Abstract and Claim
`
`
`11
`
`

`
`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
`
`
`
`1.
`
`In short, the ’607 Patent claims no inventive matter and discloses no novel
`
`signal processing technology or techniques to echos in a full duplex acoustic
`
`system. Instead, the ’607 Patent merely aggregates matter that was already well-
`
`known to those of skill in the art at the time of the alleged invention. To the extent
`
`that any element can be argued as “novel,” it is a predictable and obvious
`
`application of known techniques disclosed in the closely-related field of signal
`
`processing and noise suppression for precisely the same purposes disclosed in that
`
`art, namely to reduce interference in a digital audio signal. In light of the disclosures
`
`detailed below, the claims of the ‘607 patent are unpatentable because they are
`
`anticipated or rendered obvious by at least eight prior art references.
`
`VII. GROUNDS FOR UNPATENTABILITY OF EACH CLAIM
`
` Ground 1: Claims 1-4 and 25-28 Are Unpatentable Under 35 U.S.C. §
`102(b) As Being Anticipated By Chu 307.
`
`Claims 1-4 and 25-28 are anticipated by Chu 307 (Ex. 1006). Chu 307
`
`describes an echo cancelling device for reducing feedback between a loudspeaker
`
`and microphone in a full duplex communication system such as a telephone
`
`conferencing system.” Chu 307 (Ex. 1006), Abstract. In Chu 307 (Ex. 1006), a
`
`microphone converts speech and other acoustic signals in a room into an analog
`
`electronic microphone signal. The speech and other acoustic signals received by
`
`
`12
`
`

`
`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
`
`
`the microphone forms the target signal. The signal from the microphone, m(z), is
`
`digitized, filtered and split into distinct frequency bands to produce band-limited
`
`signals mn(i). Chu 307 (Ex. 1006), Col. 4, lines 23-26. The whitened signal mw(z)
`
`applied to the twenty nine distinct frequency bands is the target signal beam-split
`
`into the plurality of band limited target signals. The whitened signal sw(z)
`
`separated into twenty nine bandpass loudspeaker signals are the band-limited
`
`“interference” (reference) signals. The interference signal s(z) from the far end is
`
`also digitized, filtered and split into the same frequency bands as the microphone
`
`signal to produce band-limited signals sn(i). Each signal sn(i) is submitted to an
`
`adaptive filter that models the response of the channel between the near end
`
`loudspeaker and the near end microphone. The least-means-squared filter is an
`
`adaptive filter that filters each band limited reference signal from each band limited
`
`target signal. The array of LMS filters in Chu ‘307 is an array of adaptive filters
`
`forming said adaptive filter. The LMS filters of Chu model the channel between
`
`the loudspeaker and the microphone. The output of each filter is used as the
`
`estimated echo signal to be subtracted from mn(i) to produce the a signal for which
`
`the interference is suppressed. Chu 307 (Ex. 1006), Col. 4, lines 42-47. See also,
`
`col. 7, lines 7-11. In light of the above, the table below demonstrates how each
`
`limitation of Claims 1-4 and 25-28 of the ‘607 patent (Ex. 1001) is anticipated by
`
`Chu 307 (Ex. 1006).
`
`
`13
`
`

`
`Claims 1-4 and 25-28 of the 607
`Patent
`1) An interference canceling
`apparatus for canceling, from a
`target signal generated from a
`target source, an
`interference
`signal
`generated
`by
`an
`interference
`source,
`said
`apparatus comprising:
`
`1a) a main input for inputting said
`target signal;
`
`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
`
`Prior Art: Chu 307 (Ex. 1006)
`
`
`
`Chu 307: “An echo cancelling device for
`reducing acoustic feedback between a
`loudspeaker and microphone in a full duplex
`communication system such as a telephone
`conferencing system.” (Ex. 1006) Abstract.
`
`See also, Hochwald Decl. (Ex. 1014), ¶ 83.
`
`Chu 307: “a microphone 10 converts speech
`and other acoustic signals in a room into an
`analog electronic microphone signal. The
`electronic signal is applied to input signal
`conditioner 12 which filters the signal with
`a 7 KHz low pass filter and digitizes the
`filtered signal at a 16 KHz sampling rate.”
`“The resultant digitized microphone signal
`m(z) (where z is an integer representing the
`time at which the sample m(z) was taken
`measured in terms of a number of samples at
`the 16 khz sampling rate) is applied to echo
`cancellation system 15 which processes the
`microphone signal to remove any echo
`components, and
`transmits
`the echo
`corrected signal to the far end of the
`communication system” (Ex. 1006) Col. 3,
`lines 58-63.
`
`See also, Hochwald Decl. (Ex. 1014), ¶ 84.
`
`
`14
`
`

`
`Claims 1-4 and 25-28 of the 607
`Patent
`1b) a reference input for inputting
`said interference signal;
`
`1c) a beam splitter for beam-
`splitting said target signal into a
`plurality of band-limited target
`signals and beam-splitting said
`interference signal
`into band-
`limited
`interference
`signals,
`wherein
`the
`amount
`and
`frequency of band-limited target
`signals equal the amount and
`frequency
`of
`band-limited
`interference signals, whereby;
`
`for
`filter
`adaptive
`an
`1d)
`adaptively filtering, each band-
`limited interference signal from
`each corresponding band-limited
`target signal.
`
`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
`
`Prior Art: Chu 307 (Ex. 1006)
`
`
`
`Chu 307: “A digitized electronic speaker
`signal s(z), representing the voice of persons
`at the far end of the communication system,
`is received at the near end of the system.”
`(Ex. 1006) Col. 5, lines 7-9.
`
`See also, Hochwald Decl., ¶ 85.
`
`Chu 307: “The resultant whitened signal
`mw(z) generated by filter 14 is then applied
`to a splitter 16 which separate mw(z) into
`twenty-nine distinct frequency bands.” (Ex.
`1006) Col. 4, lines 23-26.
`
`“s(z) is passed through a whitening filter 28
`which is similar to or identical to whitening
`filter 14. The whitened loudspeaker signal
`sw(z) is then separated by signal splitter 30
`into its spectral components, represented by
`a ,set of twenty-nine bandpass loudspeaker
`signals sb(i)…” (Ex. 1006) Col. 4, lines 35-
`41. The twenty nine bands are the same for
`the target signal and the interference signal,
`(Ex. 1006) Col. 6, lines 45, 46.
`
`See also, Hochwald Decl. (Ex. 1014), ¶ 86-
`88.
`Chu 307: “each bandpass loudspeaker signal
`sn(i) is then passed through a corresponding
`least-means-squared filter (within the bank
`of echo cancellers 18) which models the
`response
`of
`the
`channel
`between
`loudspeaker 32 and microphone 10 in the
`frequency band n. The output of each filter
`is used as the estimated echo signal to be
`
`
`15
`
`

`
`Amended Petition For Inter Partes Review of U.S. Patent No. 6,049,607
`Afforded Filing Date: January 16, 2016
`
`Prior Art: Chu 307 (Ex. 1006)
`
`Claims 1-4 and 25-28 of the 607
`Patent
`
`
`
`2. The apparatus according to
`claim 1, wherein said target signal
`represents speech generated at a
`near end of a teleconference, said
`reference signal represents said
`target signal broadcast from a far
`end of said teleconference and
`said interference signal represents
`an echo generated by
`said
`broadcast of said reference signal
`of said far end.
`
`3. The apparatus according to
`claim 2, wherein said adaptive
`filter is an adaptive filter array
`with each adaptive filter in said
`array
`filtering
`a
`different
`frequency band.
`
`subtracted from mn(i).” (Ex. 1006) Col. 4,
`lines 42-47. See also, col. 7, lines 7-11.
`
`See also, Hochwald Decl. (Ex. 1014), ¶ 90.
`
`Chu 307: “An echo cancelling device for
`reducing acoustic feedback between a
`loudspeaker and microphone in a full duplex
`communication system such as a telephone
`conferencing system.” Abstract.
`“A plurality of adaptive echo estimators
`estimate the echo in each frequency band
`defined by the above signal splitters. More
`specifically, each estimator generates an
`echo estimation signal representing an
`approximation of the acoustic feedback of a
`corresponding bandlimited
`loudspeaker
`signal into the microphone.” (Ex. 1006)
`Abstract.
`
`See also, Hochwald Decl. (Ex. 1014), ¶ 92.
`
`Chu 307: “To cancel echo, a subtractor
`removes each echo estimation signal from
`the bandlimited microphone signal of