`
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________________
`
`
`
`
`
`T-Mobile US, Inc., T-Mobile USA, Inc., TeleCommunication Systems, Inc.,
`Ericsson Inc., and Telefonaktiebolaget LM Ericsson
`Petitioners,
`
`v.
`
`TracBeam, LLC,
`Patent Owner.
`
`__________________
`
`
`
`U.S. Patent No. 7,525,484
`
`Title: GATEWAY AND HYBRID SOLUTIONS FOR WIRELESS LOCATION
`
`__________________
`
`
`
`DECLARATION OF DR. WILLIAM R. MICHALSON
`
`
`T-Mobile / TCS / Ericsson EXHIBIT 1006
`T-Mobile / TCS / Ericsson v. TracBeam
`
`
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`
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`TABLE OF CONTENTS
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`Page
`
`I.
`
`INTRODUCTION ........................................................................................... 1
`A.
`Compensation and Prior Testimony ...................................................... 2
`B.
`Background and Qualifications ............................................................. 2
`C. Materials Considered ............................................................................. 8
`LEGAL STANDARDS .................................................................................10
`II.
`III. THE ‘484 PATENT .......................................................................................12
`A. Overview .............................................................................................12
`B.
`Location Center of the Hybrid Location System ................................16
`1.
`Signal processing subsystem.....................................................18
`2.
`Location Hypothesizing Models (FOMs) .................................19
`3.
`Hypotheses Evaluator ...............................................................20
`4.
`Output Gateway ........................................................................21
`IV. PROSECUTION HISTORY OF THE ‘484 PATENT ..................................21
`V.
`LEVEL OF ORDINARY SKILL IN THE ART ...........................................22
`VI. CLAIM CONSTRUCTION ..........................................................................22
`“mobile station” ...................................................................................23
`A.
`“location information” ........................................................................23
`B.
`“obtained via/from transmissions” ......................................................25
`C.
`VII. STATE OF THE ART / TECHNOLOGY OVERVIEW ..............................26
`A.
`Early applications of wireless location technologies ..........................26
`B.
`Hybrid wireless location approaches ..................................................28
`C.
`Fundamental location technologies .....................................................29
`1.
`Coverage Area ...........................................................................30
`2.
`Trilateration (time of arrival and signal strength) .....................31
`3.
`Time Difference of Arrival (TDOA) ........................................33
`4.
`Satellite-Based Location Technologies ....................................35
`VIII. PRIOR ART ...................................................................................................38
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`DECLARATION OF WILLIAM MICHALSON, PH.D.
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`
`T-Mobile / TCS / Ericsson EXHIBIT 1006
`T-Mobile / TCS / Ericsson v. TracBeam
`
`i
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`D.
`
`Loomis .................................................................................................38
`A.
`B. Wortham ..............................................................................................39
`IX. LOOMIS-WORTHAM COMBINATION ......................................................40
`A. Overview .............................................................................................40
`B.
`Two-Way Wireless Communication and Location Functionality ......42
`C.
`Satellite / Non-Terrestrial GPS Technique .........................................46
`1.
`Satellite (non-terrestrial) technique ..........................................46
`2.
`Satellite signal time delay measurements .................................47
`3.
`Satellite location information ....................................................49
`Terrestrial Radio Technique ................................................................49
`1.
`Terrestrial communication stations at fixed locations ..............49
`2.
`Terrestrial location technique ...................................................50
`3. Wireless signal measurements ..................................................51
`4.
`Signal time delay measurements ...............................................52
`Resulting Location Determination ......................................................54
`1.
`Determining resulting location information .............................55
`2.
`Likelihood indication ................................................................57
`Output of the Resulting Location Information ....................................58
`F.
`G. Other features ......................................................................................59
`1.
`Plurality of Mobile Stations ......................................................59
`2.
`A Plurality of Requests for Information ...................................61
`3.
`Independent Position Information ............................................62
`Teachings from Loomis ..................................................62
`(i)
`(ii) Teachings from the Loomis-Wortham combination .......65
`(iii) Testimony of named inventor Dennis Dupray ...............72
`H. Global Reasons to Modify and/or Combine........................................74
`
`E.
`
`
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`DECLARATION OF WILLIAM MICHALSON, PH.D.
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`T-Mobile / TCS / Ericsson EXHIBIT 1006
`T-Mobile / TCS / Ericsson v. TracBeam
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`ii
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`
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`I, William R. Michalson, Ph.D., declare as follows:
`
`I.
`
`INTRODUCTION
`1. My name is William Michalson, Ph.D. I am over the age of eighteen
`
`(18) and otherwise competent to make this declaration.
`
`2.
`
`I have been retained as an expert witness on behalf of T-Mobile US,
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`Inc. and T-Mobile USA, Inc. (“T-Mobile”), TeleCommunication Systems, Inc.
`
`(“TCS”), and Ericsson Inc. and Telefonaktiebolaget LM Ericsson (“Ericsson”) to
`
`provide my opinions regarding the validity of Claim 25 of U.S. Patent No.
`
`7,525,484 (the “’484 Patent”). I am providing this declaration in connection with
`
`the inter partes review petition for the ‘484 Patent that is being filed by the parties
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`identified above.
`
`3.
`
`I previously provided a declaration in connection with other inter
`
`partes review petitions for the ‘484 Patent. I understand that the Board instituted
`
`review on all challenged claims of the ‘484 Patent except for Claim 25. This
`
`declaration provides opinions regarding the validity of Claim 25.
`
`4.
`
`I have also provided separate declarations in connection with other
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`inter partes review petitions for three patents that are related to the ‘484 Patent:
`
`U.S. Patent Nos. 7,764,231 (the “’231 Patent”), 8,032,153 (the “’153 Patent”), and
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`7,298,327 (the “’327 Patent”).
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`DECLARATION OF WILLIAM MICHALSON, PH.D.
`
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`T-Mobile / TCS / Ericsson EXHIBIT 1006
`T-Mobile / TCS / Ericsson v. TracBeam
`
`1
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`
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`A. Compensation and Prior Testimony
`5.
`I am being compensated for my time in connection with this matter at
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`my standard legal consulting rate of $500 per hour. I am also being reimbursed for
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`reasonable and customary expenses associated with my work and testimony in this
`
`investigation. My compensation is not contingent on the outcome of this matter or
`
`the specifics of my testimony.
`
`6.
`
`I previously provided an expert declaration and expert testimony
`
`regarding invalidity of the ‘484 Patent (and the related ’231 Patent) in connection
`
`with TracBeam’s lawsuit against Google: TracBeam, LLC. v. Google, Inc., No.
`
`6:13-cv-00093 (E.D. Tex.).
`
`7.
`
`In addition, I have also provided expert consulting services (including
`
`expert declarations and/or testimony) for various other patent disputes in both
`
`district court proceedings and inter partes review proceedings. My consulting
`
`engagements are identified in my curriculum vitae (Ex. 1005).
`
`B.
`8.
`
`Background and Qualifications
`
`I received my Ph.D. in Electrical Engineering from Worcester
`
`Polytechnic Institute in 1989, my Master of Science in Electrical Engineering from
`
`Worcester Polytechnic Institute in 1985, and my Bachelor of Science in Electrical
`
`Engineering from Syracuse University in 1981.
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`DECLARATION OF WILLIAM MICHALSON, PH.D.
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`T-Mobile / TCS / Ericsson EXHIBIT 1006
`T-Mobile / TCS / Ericsson v. TracBeam
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`2
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`9.
`
`I was employed as an engineer at Raytheon Company from 1981 until
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`1991. During this period, I worked on a variety of projects which involved both
`
`hardware and software design and debugging. These projects involved developing
`
`computer systems and software for a variety of applications including: air traffic
`
`display systems, signal and data processing systems, and communications systems.
`
`During this time period, I was involved in hardware and software development that
`
`included experience working with satellite, airborne, and ground-based systems for
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`navigation and communications. From 1985 until 1988, I received a fellowship
`
`from Raytheon to pursue my Ph.D. degree and worked part-time during this period.
`
`I returned to Raytheon full-time from 1988 until 1991. I have been a full-time
`
`faculty member at the Worcester Polytechnic Institute in Massachusetts since
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`1991. My emphasis at Worcester Polytechnic Institute is on teaching and
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`conducting research on navigation, communications, and computer system design.
`
`10.
`
`I hold eight patents in the fields of audio signal processing, indoor
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`geolocation devices, and handheld GPS (Global Positioning System) mapping
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`devices. I have authored or co-authored over 100 original articles in the fields of
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`communications networks, precision location systems, and GPS, including more
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`than 15 journal papers and 90 conference papers. I have also authored one book
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`chapter relating to optical interconnect networks for massively parallel computers.
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`DECLARATION OF WILLIAM MICHALSON, PH.D.
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`T-Mobile / TCS / Ericsson EXHIBIT 1006
`T-Mobile / TCS / Ericsson v. TracBeam
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`3
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` became a Senior Member of the Institute of Electrical and Electronics Engineers
`
` I
`
`(IEEE) in 2003.
`
`11.
`
`I have worked in the field of computer architecture and computer
`
`systems since I began employment at Raytheon in 1981. In addition, I teach
`
`classes relating to computer architecture and design, and I also teach classes
`
`relating to embedded system designs, advanced system architectures, and real-time
`
`system designs, which relate to the design of computer systems, including real-
`
`time operating systems and programming. I have worked extensively in software
`
`programming, including during my employment at Raytheon and in a variety of
`
`projects relating to navigation and communications systems at Worcester
`
`Polytechnic Institute.
`
`12. GPS and GPS-related technologies have dominated the bulk of my
`
`research since 1992, and at Worcester Polytechnic Institute, I direct the Center for
`
`Advanced Integrated Radio Navigation. I have been involved in numerous
`
`academic, consulting, and
`
`litigation-related projects
`
`involving navigation
`
`technologies. Examples of academic projects include (1) a container tracking
`
`system in 2003 which explored the application of tracking and communications
`
`technologies to track shipping containers, (2) an automotive based system in 2000
`
`which combined GPS and map data in an automotive environment, (3) a remote
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`hazard detection system in 1996 that combined GPS and radio communications to
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`DECLARATION OF WILLIAM MICHALSON, PH.D.
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`T-Mobile / TCS / Ericsson EXHIBIT 1006
`T-Mobile / TCS / Ericsson v. TracBeam
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`remotely identify hazards to the engineer operating a freight train, and (4) a
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`differential GPS system in 1995 that combined GPS and radio technologies to
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`allow determining the precise path of vehicles operating off-road during forest
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`operations. As a consultant, I have worked with the combination of GPS and radio
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`communications in the context of space shuttle docking operations, transfer of
`
`traffic information to GPS devices in a vehicle, combinations of GPS and cellular
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`communications for the tracking of individuals, and map-based handheld tracking
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`devices.
`
`13.
`
`I have extensive experience with the development and maintenance of
`
`the hardware and software associated with server computers, including server
`
`computers attached to the Internet. This experience includes the installation and
`
`maintenance of web servers and file servers, as well as the design, development,
`
`test, and maintenance of web based applications. These applications typically
`
`employ C/C++, Java, JavaScript, PHP, HTML, MySQL, and other applications,
`
`languages and/or utilities as might be appropriate for a given application.
`
`14.
`
`I have extensive experience with the design, implementation, and
`
`testing of computer hardware and software systems for a variety of military and
`
`non-military applications. This experience specifically includes the design,
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`implementation, and testing of hardware and software systems used in navigation
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`systems and geographical information systems (GIS) as well as experience in the
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`DECLARATION OF WILLIAM MICHALSON, PH.D.
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`T-Mobile / TCS / Ericsson EXHIBIT 1006
`T-Mobile / TCS / Ericsson v. TracBeam
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`5
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`
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`
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`design, implementation, and testing of hardware and software systems in the
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`context of a client-server computer architecture in which at least one client
`
`computer exchanges navigation and/or geographical information with at least one
`
`server computer through a wired and/or wireless network.
`
`15. Since 1992, I have not only been involved with the development of
`
`GIS related software for evaluating various aspects of GPS performance, but I have
`
`also used a number of commercial GPS and GIS products. GPS products I am
`
`familiar with include products produced by GEC Plessey, Motorola, Rockwell,
`
`Trimble, Novatel, Magellan, Garmin, and others. GIS products I am familiar with
`
`include products such as ArcView/ArcGIS, GeoRover, and Navtech, as well as
`
`various data sets made available by government agencies (for example, USGS
`
`topographical maps, Digital Elevation Models, marine and aviation charts, and the
`
`like). I am also familiar with numerous GIS and mapping products that existed in
`
`the market since the late 1980s, including systems and software developed by Etak,
`
`Microsoft, DeLorme, AutoMap, and others. In the conduct of my research and
`
`other work, I have routinely used database systems such as Microsoft Access,
`
`Borland Paradox, Oracle, SQL and others.
`
`16.
`
` I teach undergraduate and graduate classes relating to computer
`
`systems and engineering design. I have taught computer architecture classes
`
`(undergraduate and graduate), in which I cover memory hierarchies, caching, and
`
`DECLARATION OF WILLIAM MICHALSON, PH.D.
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`T-Mobile / TCS / Ericsson EXHIBIT 1006
`T-Mobile / TCS / Ericsson v. TracBeam
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`6
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`
`
`
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`communications/networking. I also teach classes relating to embedded system
`
`designs, advanced system architectures, real-time system design, communication
`
`systems, navigation and robotics. Some of my classes address network protocols
`
`at the hardware level (i.e., the low-level hardware interfaces necessary for
`
`performing computer communications), while other classes address networking at
`
`the architectural level and cover layered protocol models, such as the OSI
`
`reference model developed by the International Standards Organization (ISO). In
`
`addition to the classes listed in my curriculum vitae (Ex. 1005), I have also taught
`
`a number of guest lectures in the areas of satellite navigation, systems engineering,
`
`and engineering design. In addition, I teach classes in the Fundamentals of Robot
`
`Systems and courses in navigation, both of which cover radiolocation, inertial
`
`navigation, and other means of navigating as well as using position information for
`
`purposes of guidance, mapping, navigation and path planning.
`
`17. Other projects that I worked on and supervised involved public safety
`
`radio systems, aircraft laser communications, and railroad communications
`
`between locomotives and railway switches. Many of the projects that I worked on
`
`and supervised involved the use of existing communications protocols such as File
`
`Transfer Protocol (FTP), Transmission Control Protocol (TCP), and Internet
`
`Protocol (IP), while other projects required the design of new communications
`
`protocols for data exchange between computers.
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`DECLARATION OF WILLIAM MICHALSON, PH.D.
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`T-Mobile / TCS / Ericsson EXHIBIT 1006
`T-Mobile / TCS / Ericsson v. TracBeam
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`7
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`
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`18.
`
`In my research, I have done extensive work in communications and
`
`networking system design, and have worked with all of the digital, analog and
`
`software components needed to build communications and navigation systems.
`
`My work with communications and networking protocols began in the mid-1980s
`
`with TCP/IP over packet radio. I have used these and other communications and
`
`networking protocols extensively in conducting my research. In addition, my work
`
`on GPS and navigation
`
`systems
`
`involved
`
`implementing
`
`low-latency
`
`communications to support differential techniques that allow a GPS receiver to
`
`provide more accurate positioning information.
`
`19.
`
`In writing this declaration, I have considered my own knowledge and
`
`experience, including my work experience in the fields of electrical engineering,
`
`computer engineering, networking, wireless location technologies, wireless
`
`communication technologies, and navigation and GIS systems; my experience in
`
`teaching those subjects; and my experience in working with others involved in
`
`those fields.
`
`20. A copy of my curriculum vitae, which further describes my
`
`qualifications, has been provided as Ex. 1005.
`
`C. Materials Considered
`21.
`In formulating my opinion, I have considered the following materials:
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`DECLARATION OF WILLIAM MICHALSON, PH.D.
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`T-Mobile / TCS / Ericsson EXHIBIT 1006
`T-Mobile / TCS / Ericsson v. TracBeam
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`8
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`
`
`
`
`Number
`
`1001
`
`1002
`
`1003
`
`1004
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`1012
`
`1013
`
`1014
`
`1015
`
`1016
`
`1017
`
`1018
`
`1024
`
`Description
`
`U.S. Patent No. 7,764,231
`
`U.S. Patent No. 7,525,484
`
`U.S. Patent No. 8,032,153
`
`U.S. Patent No. 7,298,327
`
`U.S. Patent No. 5,724,660 to Kauser
`
`U.S. Patent No. 5,936,572 to Loomis
`
`U.S. Patent No. 6,748,226 to Wortham
`
`International PCT Application No. PCT/US93/12179
`Schuchman
`
`to
`
`U.S. Patent No. 5,327,144 to Stilp
`
`FAA Advisory Circular 20-101C, Airworthiness Approval of
`Omega/VLF Navigation Systems For Use in the U.S. National
`Airspace System (NAS) and Alaska (Sep. 12, 1988)
`
`FAA Advisory Circular 20-130A, Airworthiness Approval of
`Navigation or Flight Management Systems Integrating Multiple
`Navigation Sensors (Jun. 14, 1995)
`
`FCC Notice of Proposed Rulemaking for Locating Wireless 911
`Callers (Released Oct. 19, 1994)
`
`TR45 Joint Experts Meeting (JEM) for Emergency Services (Aug.
`18, 1994)
`
`C.J. Driscoll & Associates, Survey of Location Technologies to
`Support Mobile 9-1-1, July 1994
`
`Claim Construction Order (MetroPCS and TCS lawsuits)
`
`Supplemental Claim Construction Order
`
`T-Mobile US, Inc. et al v. TracBeam, LLC, Case IPR2015-01681,
`
`DECLARATION OF WILLIAM MICHALSON, PH.D.
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`T-Mobile / TCS / Ericsson EXHIBIT 1006
`T-Mobile / TCS / Ericsson v. TracBeam
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`9
`
`
`
`
`
`Paper 12
`
`1025
`
`1026
`
`1027
`
`T-Mobile US, Inc et al v. TracBeam, LLC, Case IPR2015-01708,
`Paper 10
`
`T-Mobile US, Inc et al v. TracBeam, LLC, Case IPR2015-01711,
`Paper 9
`
`Excerpts of Fed. R. Civ. P. 30(b)(6) Deposition of Dr. Dennis
`Dupray, February 17, 2016.
`
`
`II. LEGAL STANDARDS
`22. This section provides my understanding of the applicable legal
`
`principles regarding the standards for patentability, which I have used in forming
`
`my opinions regarding the invalidity of the ‘484 Patent.
`
`23.
`
`I understand that the petitioners have the burden to prove that the
`
`claims challenged in its inter partes review petitions are not patentable by a
`
`preponderance of the evidence. I understand “preponderance of evidence” to be
`
`just enough evidence to make it more likely than not that their position is correct.
`
`24.
`
`I understand that patentability of each claim challenged in the
`
`petitions is assessed based on documents that predate the ‘484 Patent, such as other
`
`patents and printed publications, which are referred to as “prior art.”
`
`25.
`
`It is my understanding that a claim is not patentable if it is directed to
`
`subject matter that is not new or if the subject matter recited in the claim would be
`
`obvious to a person of ordinary skill in the art in the field of the invention at the
`
`time of the invention. I understand that an obviousness analysis involves a
`
`DECLARATION OF WILLIAM MICHALSON, PH.D.
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`T-Mobile / TCS / Ericsson EXHIBIT 1006
`T-Mobile / TCS / Ericsson v. TracBeam
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`10
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`
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`consideration of (1) the scope and content of the prior art; (2) the differences
`
`between the claimed invention and the prior art; (3) the level of ordinary skill in
`
`the pertinent field; and (4) secondary considerations of non-obviousness. I
`
`understand that secondary considerations of non-obviousness include failure of
`
`others, copying, unexpectedly superior results, perception in the industry,
`
`commercial success, and long-felt but unmet need. It is also my understanding that
`
`obviousness can be established by combining or modifying the teachings of the
`
`prior art to produce the claimed invention where there is some teaching,
`
`suggestion, or motivation to do so. Additionally, it is my understanding that
`
`obviousness can be established when the claimed invention is considered to be
`
`predictable based on the prior art.
`
`26.
`
`I understand that obviousness is determined based on the point of
`
`view of a person of ordinary skill in the art. I also understand that the person of
`
`ordinary skill in the art has ordinary creativity.
`
`27.
`
`I understand that, in an inter partes review proceeding, the claims
`
`must be given their broadest reasonable interpretation in view of the specification.
`
`After interpreting the claims in this manner, the claims can then be compared to the
`
`prior art.
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`DECLARATION OF WILLIAM MICHALSON, PH.D.
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`T-Mobile / TCS / Ericsson EXHIBIT 1006
`T-Mobile / TCS / Ericsson v. TracBeam
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`11
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`
`
`III. THE ‘484 PATENT
`A. Overview
`28. As the first sentence under the “Summary Discussion” section states:
`
`“The present invention relates to a wireless mobile station location system, and in
`
`particular, various subsystems related thereto such as a wireless location gateway,
`
`and the combining or hybriding of a plurality of wireless location techniques.”1
`
`29. The ‘484 Patent lists various objectives the inventors were trying to
`
`achieve, including:
`
`1. To provide a system and method for wireless telecommunication
`systems to accurately locate people and/or objects in a cost effective
`manner;
`
`2. To provide such location capabilities using the measurements from
`wireless signals communicated between mobile stations and a network
`of base stations; and
`3. To provide a low cost location system and method, adaptable to
`wireless telephony systems, for using simultaneously a plurality of
`location techniques for increasing location accuracy and consistency.2
`30. To achieve these objectives, the ‘484 Patent discloses the use of a
`
`combination of prior art wireless location technologies that locate mobile stations
`
`using measurements from wireless signals communicated between the mobile
`
`station and the base stations.3 The use of multiple location technologies (each of
`
`
`1 Ex. 1002 (‘484 Patent) at 10:33-37.
`2 Ex. 1002 (‘484 Patent) at 7:65-9:27.
`3 Ex. 1002 (‘484 Patent) at 12:1-10, 12:62-13:30.
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`DECLARATION OF WILLIAM MICHALSON, PH.D.
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`T-Mobile / TCS / Ericsson EXHIBIT 1006
`T-Mobile / TCS / Ericsson v. TracBeam
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`12
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`
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`which by itself is known in the art) and then selecting or combining the results of
`
`the different technologies is the advertised inventive aspect of the ‘484 Patent:
`
`[A] fundamental aspect of the present invention is to use a plurality
`MS location techniques for generating location estimates and to
`analyze the generated estimates (likely after being adjusted) to detect
`patterns of convergence or clustering amongst the estimates.4
`
`31.
`
`In particular, the limitations of the various prior art location
`
`technologies were recognized by the inventors and are discussed in the background
`
`section of the ‘484 Patent:
`
`Systems have been proposed that rely upon signal strength and
`trilateralization techniques to permit location [determinations]….
`Furthermore, the systems are generally only effective in line-of-sight
`conditions, such as rural-settings. Radio wave surface reflections,
`refractions and ground clutter cause significant distortion,
`in
`determining the location of a signal source in most geographical areas
`that are more than sparsely populated.
`
`GPS is impractical in many applications. The signal power levels
`from the satellites are low and the GPS receiver requires a clear, line-
`of-sight path to at least three satellites above a horizon of about 60
`degrees for effective operation. Accordingly, inclement weather
`conditions, such as clouds, terrain features, such as hills and trees, and
`buildings restrict the ability of the GPS receiver to determine its
`
`
`4 Ex. 1002 (‘484 Patent) at 66:45-49 (emphasis added).
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`DECLARATION OF WILLIAM MICHALSON, PH.D.
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`position.5
`
`32. The inventors sought to overcome the limitations of any single
`
`location technology using a hybrid location solution:
`
`The present invention relates to a wireless mobile station location
`system, and in particular, various subsystems related thereto such as a
`wireless location gateway, and the combining or hybriding of a
`plurality of wireless location techniques.
`
`Yet another objective is to provide a low cost location system and
`method, adaptable
`to wireless
`telephone systems,
`for using
`simultaneously a plurality of location techniques for synergistically
`increasing MS [mobile station] location accuracy and consistency.6
`
`33. Figure 4 illustrates a high level diagram of the hybrid location
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`solution described by the ‘484 Patent, which includes a plurality of mobile devices
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`(referred to as “mobile stations” by the patent); a plurality of base stations and
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`mobile base stations; a mobile switching center; and a public switched telephone
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`network, or PSTN.
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`5 Ex. 1002 (‘484 Patent) at 1:43-54 and 2:2-9.
`6 Ex. 1002 (‘484 Patent) at 10:33-37 and 9:1-5 (emphasis added).
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`34. Each mobile station is connected to the wireless network through one
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`
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`of the base stations, and the base stations are connected to the public switched
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`telephone network through the mobile switching center. The base stations may
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`either be typical stationary base stations or may be mobile base stations. Mobile
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`base stations are vehicles equipped with base station equipment to provide the
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`functionality of a stationary base station but with the ability to change locations.
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`35. Figure 4 also features a location center and location applications. The
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`location applications use the location of mobile stations to provide services.
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`Examples of services disclosed in the ‘484 Patent include 911 emergency response
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`services, taxi services, vehicle navigation services, and stolen vehicle tracking
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`services.7 In order to provide these services, the location applications submit
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`location requests to the location center. The location center then activates various
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`different location technologies to obtain multiple location estimates for the target
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`mobile station. After obtaining location estimates from the various technologies,
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`the location center provides a “most likely” location estimate of the target mobile
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`station by selecting or combining the various location estimates from each location
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`technology.
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`B.
`Location Center of the Hybrid Location System
`36. This section provides an explanation of the “location center” used in
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`the hybrid location system of the ‘484 Patent.
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`37. Figure 5 illustrates a more detailed diagram of the location center,
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`which includes, among other components: a signal processing subsystem; location
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`hypothesizing models, which the patent also refers to as “First Order Models,” or
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`FOMs; a hypothesis evaluator; and an output gateway.
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`7 Ex. 1002 (‘484 Patent) at 8:52-55.
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`38. The location center determines the location of mobile stations using
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`
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`wireless signal measurements of the mobile stations.8
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`39. At a high level, the location center:
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`(cid:120)
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`(cid:120)
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`(cid:120)
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`receives a request for the location of a mobile station from a location
`application
`collects and processes wireless signal measurements associated with
`the mobile station
`obtains multiple location estimates of the mobile station using a
`plurality of different location technologies (e.g., Time of Arrival,
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`8 Ex. 1002 (‘484 Patent) at 25:8-10.
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`(cid:120)
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`(cid:120)
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`(cid:120)
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`Time Difference of Arrival, GPS9)
`generates a “most likely” estimate by selecting or combining the
`various location estimates from the different location techniques
`formats the “most likely” location estimate based on the needs of the
`requesting location application
`routes the formatted location estimate to the requesting location
`application
`1.
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`Signal processing subsystem
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`40. When a request for the location of a mobile station is received by the
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`location center, the location center collects measurements of the wireless signals
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`transmitted between the mobile station and one or more base stations within range
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`of the mobile station. For example, in Figure 5, mobile station 140 is within range
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`of various base stations. The jagged arrows between the mobile station and the
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`base stations represent wireless signals. These wireless signals are measured and
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`provided to the location center. For example, the base stations may measure the
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`wireless signals and route the measurements to the location center through the
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`Mobile Switching Center. These wireless signal measurements are then provided
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`to the signal processing subsystem of the location center, which analyzes the
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`measurements in order to identify various characteristics of the wireless signals.
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`9 As explained in Section III.B.2, the original patent application for the ’484 Patent
`only disclosed using GPS to locate the mobile base stations (e.g., cell towers
`attached to a vehicle), but it did not disclose GPS as one of the location
`technologies used in its hybrid location system to locate the mobile stations
`(e.g., cell phones). The use of GPS to locate the mobile stations was
`subsequently added during prosecution.
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`Examples of wireless signal characteristics
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`include:
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`(i) signal
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`timing
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`measurements, such as those used in time of arrival and time difference of arrival
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`techniques; (ii) signal strength measurements; and (iii) signal angle of arrival
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`measurements.10
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`2.
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`Location Hypothesizing Models (FOMs)
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`41. Next, the location center simultaneously activates multiple location
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`hypothesizing models using the wireless signal characteristics from the signal
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`processing subsystem as input. The location hypothesizing models are also
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`referred to in the