Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 UNITED STATES PATENT AND TRADEMARK OFFICE
`
` 2 BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` 3
`
` ZTE (USA) INC., HTC )
` 4 CORPORATION, HTC AMERICA, )
` SAMSUNG ELECTRONICS CO., )
` 5 LTD., and SAMSUNG ) Case IPR2016-00757
` ELECTRONICS AMERICA, INC., ) Patent 7,881,236 B2
` 6 )
` Petitioners, )
` 7 )
` vs. )
` 8 )
` EVOLVED WIRELESS LLC, )
` 9 )
` Patent Owner. )
`
` 10
`
` 11
`
` 12 The deposition of PAUL S. MIN, Ph.D., called
`
` 13 by the Patent Owner for examination, taken pursuant to
`
` 14 the rules of the United States Patent and Trademark
`
` 15 Office, taken before Jennifer L. Bernier, Certified
`
` 16 Shorthand Reporter, Registered Professional Reporter,
`
` 17 Certified Realtime Reporter, and Notary Public, at
`
` 18 McDermott, Will & Emery, 227 West Monroe Street,
`
` 19 Chicago, Illinois, commencing at 9:04 a.m., on
`
` 20 March 16, 2017.
`
` 21
`
` 22
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` 23
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` 24
`
`Depo International, Inc.
`(763) 591-0535 or (800) 591-9722 | info@depointernational.com
`
`Page 1
`
`Exhibit 2004-001
`
`
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 UNITED STATES PATENT AND TRADEMARK OFFICE
`
` 2 BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` 3
`
` ZTE (USA) INC., HTC )
` 4 CORPORATION, HTC AMERICA, )
` SAMSUNG ELECTRONICS CO., )
` 5 LTD., and SAMSUNG ) Case IPR2016-00757
` ELECTRONICS AMERICA, INC., ) Patent 7,881,236 B2
` 6 )
` Petitioners, )
` 7 )
` vs. )
` 8 )
` EVOLVED WIRELESS LLC, )
` 9 )
` Patent Owner. )
`
` 10
`
` 11
`
` 12 The deposition of PAUL S. MIN, Ph.D., called
`
` 13 by the Patent Owner for examination, taken pursuant to
`
` 14 the rules of the United States Patent and Trademark
`
` 15 Office, taken before Jennifer L. Bernier, Certified
`
` 16 Shorthand Reporter, Registered Professional Reporter,
`
` 17 Certified Realtime Reporter, and Notary Public, at
`
` 18 McDermott, Will & Emery, 227 West Monroe Street,
`
` 19 Chicago, Illinois, commencing at 9:04 a.m., on
`
` 20 March 16, 2017.
`
` 21
`
` 22
`
` 23
`
` 24
`
`Depo International, Inc.
`(763) 591-0535 or (800) 591-9722 | info@depointernational.com
`
`Page 1
`
`Exhibit 2004-001
`
`
`
`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 APPEARANCES:
`
` 2 McDERMOTT, WILL & EMERY
` HERSH MEHTA, ESQUIRE
` 3 MICHAEL HEMES, ESQUIRE
` 227 West Monroe Street
` 4 Chicago, Illinois 60606
` Phone: (312) 372-2000
` 5 E-Mail: hmehta@mwe.com
` mhemes@mwe.com
`
` 6
`
` 7
`
` On behalf of the Petitioners;
`
` ROBINS KAPLAN, LLP
` 8 MILES A. FINN, Ph.D., ESQUIRE
` 601 Lexington Avenue
` 9 Suite 3400
` New York, New York 10022
` 10 Phone: (212) 980-7439
` E-Mail: Mfinn@robinskaplan.com
`
` 11
`
` 12
`
` On behalf of the Patent Owner.
`
` 13 ALSO PRESENT VIA TELEPHONE:
`
` 14 CHARLES McMAHON, ESQUIRE
` CHARLIE STIERNBERG, ESQUIRE
` 15 NAM KIM, ESQUIRE
`
` * * * * * *
`
` 16
`
` 17
`
` 18
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` 19
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` 20
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` 21
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`Depo International, Inc.
`(763) 591-0535 or (800) 591-9722 | info@depointernational.com
`
`Page 2
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`Exhibit 2004-002
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`
`
`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 TRANSCRIPT INDEX
`
` 2
`
` 3 EXAMINATION OF PAUL S. MIN, Ph.D. PAGE
`
` 4 By Mr. Finn.............................. 4
`
` 5 By Mr. Mehta.............................165
`
` 6
`
` 7
`
` 8 INDEX OF EXHIBITS
`
` 9 (Retained by Court Reporter.)
`
` 10 NUMBER DESCRIPTION MARKED
`
` 11 Exhibit 1 Notice......................... 4
`
` 12 Exhibit 2 ZTE/HTC Exhibit 1003-0001...... 7
`
` 13 Exhibit 3 Dahlman reference.............. 10
`
` 14 Exhibit 4 '236 Patent.................... 26
`
` 15 Exhibit 5 ZTE/HTC Exhibit 1045-0001...... 38
`
` 16 Exhibit 6 Min Declaration................ 71
`
` 17 Exhibit 7 Excerpted Teachings............ 73
`
` 18 Exhibit 8 Transmission Form.............. 105
`
` 19 Exhibit 10 ZTE/HTC Exhibit 1002-0001...... 120
`
` 20 Exhibit 9 3GPP TS 36.321................. 151
`
` 21 Exhibit 11 63 Report...................... 152
`
` 22
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` 23
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` 24
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`Depo International, Inc.
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`Page 3
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`Exhibit 2004-003
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`
`
`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 (Witness sworn.)
`
` 2 WHEREUPON:
`
` 3 PAUL S. MIN, Ph.D.,
`
` 4 called as a witness herein, having been first duly
`
` 5 sworn, was examined and testified as follows:
`
` 6 DIRECT EXAMINATION BY COUNSEL FOR PATENT OWNER
`
` 7 BY MR. FINN:
`
` 8 Q. Good morning, Dr. Min. My name is Miles Finn.
`
` 9 I represent the patent owner in this matter, Evolved
`
` 10 Wireless.
`
` 11 You've stated your name for the record,
`
` 12 Paul Min.
`
` 13 A. Yes. My name is Paul Min.
`
` 14 Q. Now, I'm going to hand you a few exhibits,
`
` 15 through the court reporter, and we'll be discussing
`
` 16 those.
`
` 17 First of all, I'll hand over Exhibit 1, if I
`
` 18 may.
`
` 19 (Min Exhibit 1, Notice, was marked
`
` 20 for purposes of identification.)
`
` 21 Q. Now, Dr. Min, I'm not sure if you've seen this
`
` 22 document. It's a notice, a second notice of deposition.
`
` 23 Have you seen this?
`
` 24 A. Yes.
`
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`Page 4
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`Exhibit 2004-004
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`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 Q. And that's why you're here to testify today;
`
` 2 is that right?
`
` 3 A. Yes.
`
` 4 Q. Now, have you ever been deposed before, sir?
`
` 5 A. Yes, I have. Yes.
`
` 6 Q. And in patent matters?
`
` 7 A. Yes.
`
` 8 Q. Okay. Now, as you can see, there is a court
`
` 9 reporter here, and she'll be typing down what we say.
`
` 10 So it's important that you don't start to answer a
`
` 11 question until I'm finishing it. And, likewise, I'm
`
` 12 going to try to not talk until you're finished answering
`
` 13 your question, you've finished your answer. Does that
`
` 14 make sense?
`
` 15 A. Yes.
`
` 16 Q. Okay. It's a hard skill to learn.
`
` 17 A. I'll do my best.
`
` 18 Q. Thank you. And it's also important that we
`
` 19 get a verbal record. So it's important that you answer
`
` 20 with words, rather than nodding your head or shaking
`
` 21 your head. Do you understand that?
`
` 22 A. Yes.
`
` 23 Q. Okay. Now, your counsel may object to some of
`
` 24 the questions that I ask. And unless he instructs you
`
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`Page 5
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`Exhibit 2004-005
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`
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`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 not to answer, you're still required to answer my
`
` 2 question. Do you understand that?
`
` 3 A. Yes.
`
` 4 Q. Okay. Now, if I ask a question that you don't
`
` 5 understand, please ask me to explain it. Because if you
`
` 6 don't ask me to explain a question, I'm going to assume
`
` 7 that you understand it. Is that okay?
`
` 8 A. Yes.
`
` 9 Q. Okay. Thank you.
`
` 10 Now, we'll take breaks occasionally through
`
` 11 the deposition. We'll try to do those about once an
`
` 12 hour, if that's comfortable for you. The only thing
`
` 13 that I would ask is, if a question is pending, we won't
`
` 14 take a break until you've answered that pending
`
` 15 question. Do you understand that?
`
` 16 A. Yes.
`
` 17 Q. Okay. Thank you.
`
` 18 Okay. Now, let's start talking about uplink
`
` 19 grants, if we may, or UL Grants.
`
` 20 Okay. Now, with respect to the time -- let me
`
` 21 back up. You know the 321 reference that we've
`
` 22 discussed in this matter, Exhibit 1003; do you remember
`
` 23 that?
`
` 24 A. I do remember the 321 reference. I just don't
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`Page 6
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`Exhibit 2004-006
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`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 remember the number exactly.
`
` 2 Q. Okay. Sure. Just to make sure we're talking
`
` 3 about the same thing, I'll hand the reporter this to be
`
` 4 marked as Exhibit 2.
`
` 5 (Min Exhibit 2, ZTE/HTC Exhibit
`
` 6 1003-0001, was marked for purposes
`
` 7 of identification.)
`
` 8 Q. Okay. Dr. Min, do you recognize what's been
`
` 9 marked as Min Exhibit 2?
`
` 10 A. Yes.
`
` 11 Q. In this matter, it's been called Exhibit 1003;
`
` 12 is that correct?
`
` 13 A. Yes. Now, I can see the exhibit number at the
`
` 14 bottom, so that is clear.
`
` 15 Q. Good. Thank you.
`
` 16 So, now, let's put yourself, please, and
`
` 17 answer the following questions in the time scale of the
`
` 18 date of this document.
`
` 19 A. Okay.
`
` 20 Q. Does that make sense?
`
` 21 A. Okay.
`
` 22 Q. Okay. Now, at the date of this document, what
`
` 23 is an uplink grant?
`
` 24 A. And uplink grant, as the document that I have
`
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`Page 7
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`Exhibit 2004-007
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`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 here -- the 321 reference -- describes, is, basically, a
`
` 2 base station, eNodeB, so, in this case, LTE base station
`
` 3 permission through UE --
`
` 4 THE REPORTER: I'm sorry. Permission to?
`
` 5 A. -- UE, user equipment, to basically transmit
`
` 6 in a direction towards the base station. And that is
`
` 7 uplink, and grant is given in terms of a resource
`
` 8 allocation.
`
` 9 Q. Okay. Now, you said that was permission to
`
` 10 transmit in the direction of the base station. What
`
` 11 does that mean?
`
` 12 A. So UE is the one who is getting the
`
` 13 permission.
`
` 14 Q. Mm-hmm.
`
` 15 A. And the base station is what is expecting that
`
` 16 transmission to be received by. So that's what I meant,
`
` 17 UE transmitting data, control of whatever the bits needs
`
` 18 to be transmitted going from UE to the base station
`
` 19 direction.
`
` 20 Q. Okay. Does the UE have directionality in its
`
` 21 transmission?
`
` 22 MR. MEHTA: Objection. Form.
`
` 23 A. I am not sure of the question.
`
` 24 Q. Does the UE transmit anything other than an
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`Page 8
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`Exhibit 2004-008
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`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 omnidirectional transmission?
`
` 2 A. In an omnidirectional, is that what you said?
`
` 3 Q. Yes.
`
` 4 A. UE -- well, yes. And I'm trying to remember
`
` 5 exactly the time frame. There are -- maybe not at this
`
` 6 particular moment in time, in August -- or, I'm sorry,
`
` 7 2008, the month of May. There is a mercury antenna
`
` 8 configuration where you can do a beam forming, so that
`
` 9 will give certain directionality.
`
` 10 But that's really not what we are referring to
`
` 11 here. Here it's really UE transmitting through the base
`
` 12 station.
`
` 13 Q. Okay. Thank you.
`
` 14 Now, you said that the uplink grant gives
`
` 15 resource allocations; is that correct?
`
` 16 A. Over some time, yes. That's correct.
`
` 17 Q. Now, what are resource allocations?
`
` 18 A. Now, just to be clear, once again, are we
`
` 19 talking in the context of this document right here,
`
` 20 or --
`
` 21 Q. We're talking in the context of the time of
`
` 22 this document with respect to LTE systems, yes.
`
` 23 MR. MEHTA: Objection to form.
`
` 24 A. Okay. So resource in the LTE, as a whole,
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`Page 9
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`Exhibit 2004-009
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`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 comprises, basically, time and frequency. That's the
`
` 2 general framework of LTE. Having said that, there are
`
` 3 certain channels that also utilize the code allocation.
`
` 4 Okay. So the code could be a resource as well. So
`
` 5 it's, generally speaking, in the framework of orthogonal
`
` 6 frequency --
`
` 7 THE REPORTER: I'm sorry, sir.
`
` 8 A. -- orthogonal frequency-division multiple
`
` 9 access, OFDMA, that frequency and time are two major
`
` 10 resources. But, in many cases, there are code
`
` 11 allocations as well.
`
` 12 Q. Now, the court reporter will hand you what
`
` 13 we've marked as Min Exhibit 4 -- 3, excuse me, Min
`
` 14 Exhibit 3.
`
` 15 (Min Exhibit 3, Dahlman reference,
`
` 16 was marked for purposes of
`
` 17 identification.)
`
` 18 MR. MEHTA: Is this, Miles, an exhibit that
`
` 19 the patent owner has previously filed with the
`
` 20 PTAB?
`
` 21 MR. FINN: This is a portion of an exhibit, Exhibit
`
` 22 2001, that the patent owner filed, yes.
`
` 23 MR. MEHTA: And what is the number of the exhibit
`
` 24 that was filed previously?
`
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`Page 10
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`Exhibit 2004-010
`
`
`
`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 MR. FINN: As it states at the bottom, it's 2001.
`
` 2 Q. Now, Dr. Min, do you recognize any part of
`
` 3 this exhibit?
`
` 4 A. Any part of this particular exhibit --
`
` 5 Q. Yes, sir.
`
` 6 A. -- or the entirety of this textbook?
`
` 7 Q. Let's just look at the front page of this
`
` 8 exhibit. Do you recognize that?
`
` 9 A. Yeah.
`
` 10 Q. What is this?
`
` 11 A. This is a well-known textbook/reference book
`
` 12 written by Erik Dahlman and three other authors listed,
`
` 13 which we typically refer to as the Dahlman reference.
`
` 14 Q. So the Dahlman reference, at least this
`
` 15 excerpt from the Dahlman reference that's been marked as
`
` 16 Min Exhibit 3 --
`
` 17 A. Okay.
`
` 18 Q. -- that's what we're talking about now.
`
` 19 So would you please turn, sir, to the last
`
` 20 page of this exhibit -- of this excerpt of this exhibit,
`
` 21 which, at the foot, it says, Exhibit 2001-081; do you
`
` 22 see that?
`
` 23 A. Yes.
`
` 24 Q. Okay. Now, what I want to do is talk a little
`
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`Page 11
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`Exhibit 2004-011
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`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 bit about time and frequency allocations, okay?
`
` 2 A. Okay.
`
` 3 Q. Now, do you see Figure 14.1, up on the top of
`
` 4 this page; in fact, 14.1(b)?
`
` 5 A. Yes.
`
` 6 Q. Okay. Now, this figure, as I understand it,
`
` 7 is written in terms of downlink?
`
` 8 MR. MEHTA: Objection to form.
`
` 9 Q. Do you understand that?
`
` 10 MR. MEHTA: Objection to form.
`
` 11 A. Written in terms of a downlink, you said?
`
` 12 Q. A downlink, yes.
`
` 13 A. So the caption of this figure is a downlink
`
` 14 channel-dependent scheduling in time and frequency
`
` 15 domains.
`
` 16 Q. Okay.
`
` 17 A. So if that's what you're referring to as a
`
` 18 downlink, I think you're correct.
`
` 19 Q. Okay. Now, does this figure also represent,
`
` 20 for uplink, the time and frequency resources that could
`
` 21 be allocated?
`
` 22 MR. MEHTA: Objection to form.
`
` 23 A. I'm not sure if I understand your question
`
` 24 correctly. This figure is captioned as a downlink. So
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`Page 12
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`Exhibit 2004-012
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`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 when you say applied to uplink, I don't understand what
`
` 2 you mean.
`
` 3 Q. Well, if the caption were not there, would
`
` 4 this be a representation of time resources allocated to
`
` 5 a UE?
`
` 6 A. Time resources? So UE, the way that the
`
` 7 OFDMA, the LTE standard, allocates resources to UE on
`
` 8 the uplink version -- so that's what we are talking
`
` 9 about right now -- is, for a given time, frequencies
`
` 10 allocated in terms of a resource block. So the time is
`
` 11 not something that is explicitly allocated because the
`
` 12 frequency is given on a per time and subframe basis. So
`
` 13 the time is sort of like implicitly indicated by the
`
` 14 time that allocation is made.
`
` 15 Q. So let me just understand what you just said.
`
` 16 I think you said the time is implicitly allocated by the
`
` 17 time the allocation is made?
`
` 18 A. That's right.
`
` 19 Q. Okay. Now, does that mean to say the time for
`
` 20 transmission is implicitly allocated based on the time
`
` 21 the allocation was made?
`
` 22 A. So --
`
` 23 MR. MEHTA: Objection to form.
`
` 24 A. When you say transmission, so we are still
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`Page 13
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`Exhibit 2004-013
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`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 talking about the uplink direction?
`
` 2 Q. Yes, sir.
`
` 3 A. So when allocation has made a certain time by
`
` 4 the base station to the UE in terms of an uplink grant.
`
` 5 And based on that timing, when the actual uplink grant
`
` 6 was made, that timing indicates when UE will have that
`
` 7 uplink allocation, so that, in that regard, the timing
`
` 8 is also implicitly indicated to the UE for uplink
`
` 9 transmission.
`
` 10 Q. Now, time for uplink grants is measured in
`
` 11 transmission time intervals; is that correct?
`
` 12 A. Measured is probably not the right word that I
`
` 13 should use. That is unit over allocation.
`
` 14 Q. Okay.
`
` 15 A. So time is still -- the clock is ticking,
`
` 16 that's time. But whatever that time is, the TTI, the
`
` 17 transmission time interval, is the frame, the time
`
` 18 frame, during which this allocation is made, and you are
`
` 19 given/assigned an allocation in terms of the TTI units.
`
` 20 Q. Okay. Now, I'd like to carefully understand
`
` 21 the difference between the time and allocation that's
`
` 22 made --
`
` 23 A. Mm-hmm.
`
` 24 Q. -- and the time that the UE transmits to the
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`Page 14
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`Exhibit 2004-014
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`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 base station.
`
` 2 A. Mm-hmm.
`
` 3 Q. Okay. First of all, just to make sure we're
`
` 4 talking the same language --
`
` 5 A. Okay.
`
` 6 Q. -- when an allocation is made, that means when
`
` 7 an uplink grant is transmitted by the base station and
`
` 8 received by the UE; is that correct?
`
` 9 MR. MEHTA: Objection to form.
`
` 10 A. We are talking about that TTI?
`
` 11 Q. Yes.
`
` 12 A. So every control -- I shouldn't say every.
`
` 13 But control over allocation, in terms of research, is
`
` 14 done in terms of TTI.
`
` 15 Q. Okay.
`
` 16 A. So given TTI allocation information, the UL
`
` 17 Grant is given from the base station to UE.
`
` 18 Q. Okay.
`
` 19 A. And that information is contained in the TTI,
`
` 20 time interval point or time period.
`
` 21 Q. Okay. So if we look at this figure, Figure
`
` 22 14.1(b), in Min Exhibit 3 that we talked about just a
`
` 23 few minutes ago --
`
` 24 A. Yes.
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`Page 15
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`Exhibit 2004-015
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`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 Q. -- could we say that one of those darker
`
` 2 colored rectangles indicates one particular TTI and one
`
` 3 frequency range?
`
` 4 MR. MEHTA: Objection to form.
`
` 5 A. You said one frequency range?
`
` 6 Q. Well, yeah, I did say that. Don't answer my
`
` 7 previous question. Let's make sure we understand that.
`
` 8 I used the term frequency range. Would you
`
` 9 use a different term to describe a frequency band or
`
` 10 spectrum allocator to a UE?
`
` 11 MR. MEHTA: Objection to form.
`
` 12 A. So since we are talking in the context of LTE,
`
` 13 so we have what is a frequency range that defines what
`
` 14 we call the resource block.
`
` 15 Q. Okay.
`
` 16 A. So there are 12 subcarriers, 15 kilohertz
`
` 17 each.
`
` 18 Q. Mm-hmm.
`
` 19 A. So that's the unit that you are actually
`
` 20 making the allocation. So you don't really divide that,
`
` 21 you know, the 12 subcarriers, consecutive in any
`
` 22 fraction. So we are going to make -- the base station
`
` 23 will be making allocation in terms of the 12
`
` 24 subcarriers, their time.
`
`Depo International, Inc.
`(763) 591-0535 or (800) 591-9722 | info@depointernational.com
`
`Page 16
`
`Exhibit 2004-016
`
`
`
`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 Q. Okay. Now, 12 times 15 is 180 kilohertz,
`
` 2 right?
`
` 3 A. That's correct, yes.
`
` 4 Q. Now, looking at this Figure 14.1(b), do the --
`
` 5 I don't know what to call them. The figure is kind of
`
` 6 at the back, the vertical with rounded points. Does
`
` 7 each one of those represent 180 kilohertz?
`
` 8 MR. MEHTA: Objection to form.
`
` 9 Q. Band?
`
` 10 MR. MEHTA: Objection to form.
`
` 11 A. You mean one of the, like, penciled-looking
`
` 12 things, the Crayon-looking things?
`
` 13 Q. Yes, sir.
`
` 14 A. I don't think so. I think, if you look at --
`
` 15 it's not clear from here. I'm sorry. It says on the
`
` 16 right tiles. So if you look at the flat tile on the
`
` 17 floor --
`
` 18 (Telephone interruption.)
`
` 19 A. -- it shows one of those rectangular tiles is
`
` 20 one millisecond in time and 180 kilohertz in frequency.
`
` 21 So I don't know how many of those, the penciled- or
`
` 22 Crayon-looking things that's standing up, actually shows
`
` 23 there; but I think, perhaps, what we are looking at is
`
` 24 the shape of tile and what that tile, the width and the
`
`Depo International, Inc.
`(763) 591-0535 or (800) 591-9722 | info@depointernational.com
`
`Page 17
`
`Exhibit 2004-017
`
`
`
`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 height, correspond to.
`
` 2 Q. Okay. And that's fair enough. I think there
`
` 3 was six, so that would make 30 kilohertz.
`
` 4 A. Yeah.
`
` 5 Q. I'm not sure if this reference tied to LTE
`
` 6 anyway. So let's go back to that.
`
` 7 A. Okay.
`
` 8 Q. If we're looking at one of these things you
`
` 9 called a tile, that's a millisecond in duration and 180
`
` 10 kilohertz in --
`
` 11 A. Frequency band or frequency bandwidth, any one
`
` 12 of those.
`
` 13 Q. Thank you, sir. Frequency band or bandwidth.
`
` 14 A. Okay.
`
` 15 Q. One of these one millisecond,
`
` 16 180-kilohertz-bandwidth tiles, that would represent one
`
` 17 block that the UE has been allocated to use by the base
`
` 18 station?
`
` 19 MR. MEHTA: Objection to form.
`
` 20 Q. Isn't that correct?
`
` 21 MR. MEHTA: Objection to form.
`
` 22 A. Not in this particular diagram, but that's
`
` 23 something that could be allocated as to a UE. But in
`
` 24 this diagram, I don't have any, once again, since you
`
`Depo International, Inc.
`(763) 591-0535 or (800) 591-9722 | info@depointernational.com
`
`Page 18
`
`Exhibit 2004-018
`
`
`
`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 said this might not be an LTE diagram, but that could be
`
` 2 allocated that way.
`
` 3 Q. Okay. This could be an allocation in the LTE
`
` 4 system?
`
` 5 A. It could.
`
` 6 MR. MEHTA: Objection to form.
`
` 7 A. Yes, it could be.
`
` 8 Q. Thank you. Okay.
`
` 9 So, now, let's just think about one of these
`
` 10 tiles, and let's think about a tile that is -- I guess I
`
` 11 would like to point out one of them in particular to
`
` 12 you.
`
` 13 If we're -- if we're kind of considering a
`
` 14 frequency access, we would count over one, two, three
`
` 15 tiles, and the time. We count backwards in time two
`
` 16 units. Do you see the tile there I'm referring to?
`
` 17 I'll just show you this one on my picture. This one
`
` 18 here. (Indicating.)
`
` 19 A. Okay.
`
` 20 Q. Okay. So let's just call that a reference
`
` 21 tile, if that's okay. Is that okay for you?
`
` 22 A. Okay.
`
` 23 Q. And, Counsel, were you able to see what I was
`
` 24 talking about?
`
`Depo International, Inc.
`(763) 591-0535 or (800) 591-9722 | info@depointernational.com
`
`Page 19
`
`Exhibit 2004-019
`
`
`
`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 MR. MEHTA: That one? (Indicating.)
`
` 2 MR. FINN: Yes. That's good.
`
` 3 A. I'll mark it here as well.
`
` 4 Q. Sure.
`
` 5 A. Okay. (Indicating.)
`
` 6 Q. Now, that's a TTI in which the UE has
`
` 7 permission to transmit, correct?
`
` 8 MR. MEHTA: Objection to form.
`
` 9 A. You mean hypothetically, right?
`
` 10 Q. Yes.
`
` 11 A. It doesn't say anything here, but you are
`
` 12 saying that's what it is.
`
` 13 Q. Can we agree that this was a diagrammatic
`
` 14 representation of an LTE system that, for that reference
`
` 15 tile, an uplink grant has been given?
`
` 16 MR. MEHTA: Objection. Form.
`
` 17 A. Okay. Hypothetically?
`
` 18 Q. Sure.
`
` 19 A. All right.
`
` 20 Q. Now, previous to this, an uplink grant will be
`
` 21 received; is that right?
`
` 22 MR. MEHTA: Objection.
`
` 23 A. I'm sorry?
`
` 24 Q. Previous to this reference tile, prior in
`
`Depo International, Inc.
`(763) 591-0535 or (800) 591-9722 | info@depointernational.com
`
`Page 20
`
`Exhibit 2004-020
`
`
`
`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 time, the UE will have received an uplink grant?
`
` 2 MR. MEHTA: Objection to form.
`
` 3 Q. Is that correct?
`
` 4 MR. MEHTA: Objection to form.
`
` 5 A. Prior to? I mean, when the grant is given,
`
` 6 you will know. So I don't know if -- so your reference
`
` 7 to prior to, I'm not really sure. So a base station
`
` 8 will give an uplink grant and a TTI, and then you will
`
` 9 know, for that TTI, that an uplink grant has been made.
`
` 10 Q. Okay. So let me ask this question.
`
` 11 A. Okay.
`
` 12 Q. For this particular reference tile --
`
` 13 A. Okay.
`
` 14 Q. -- let's assume that the UE transmits into the
`
` 15 reference tile.
`
` 16 A. Okay.
`
` 17 Q. Was the uplink grant --
`
` 18 A. Yes.
`
` 19 Q. -- would the uplink grant have been received
`
` 20 during that TTI?
`
` 21 MR. MEHTA: Objection to form.
`
` 22 A. During the TTI? There is -- I mean, it really
`
` 23 depends on the different scenarios. There are different
`
` 24 ways to make the grant. There are, like, a grant such
`
`Depo International, Inc.
`(763) 591-0535 or (800) 591-9722 | info@depointernational.com
`
`Page 21
`
`Exhibit 2004-021
`
`
`
`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 as the one that, you know, you receive it, and then you
`
` 2 will have something in the order of four subframe TTIs
`
` 3 later that you actually get to transmit.
`
` 4 And then there are different types of grants
`
` 5 that are semi-static, so it can actually have, like, a
`
` 6 voice course. A grant that's given and stays on you
`
` 7 don't really need to receive a repetitive grant on a
`
` 8 continuing basis.
`
` 9 (Telephone interruption.)
`
` 10 A. So it depends on how -- what kind of
`
` 11 particular scheme.
`
` 12 Q. Okay. That's fair enough.
`
` 13 MR. FINN: Counsel, I wonder if we could turn the
`
` 14 phone down some. I don't mean a lot, just so it's a
`
` 15 little bit less disruptive when people come in and out.
`
` 16 Q. Okay. So you just gave me a lot of
`
` 17 information. We'll have to just break this down bit by
`
` 18 bit.
`
` 19 A. Okay.
`
` 20 Q. Let's talk about the random access procedure.
`
` 21 A. Okay.
`
` 22 Q. Could you just say, in general, what a random
`
` 23 access procedure is?
`
` 24 A. So a random access procedure is a procedure
`
`Depo International, Inc.
`(763) 591-0535 or (800) 591-9722 | info@depointernational.com
`
`Page 22
`
`Exhibit 2004-022
`
`
`
`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 performed by user equipment, and the reason for doing so
`
` 2 is because UE does not have an allocated resource. That
`
` 3 is given by the base station. So the UE does not have
`
` 4 any resource to transmit its data, or control, or
`
` 5 something.
`
` 6 So what UE has to do is basically send
`
` 7 something on a sort of like available to all UE channel,
`
` 8 which is called a random access channel, so that the
`
` 9 base station will know that the UE needs something, some
`
` 10 resource, to transmit the data in a subsequent time.
`
` 11 Q. Someone -- is the following an apt description
`
` 12 of this? Someone once described to me a random access
`
` 13 procedure is a little bit like a child in the classroom
`
` 14 wanting permission to leave the room and perhaps raising
`
` 15 her hand.
`
` 16 MR. MEHTA: Objection. Form.
`
` 17 A. I mean, there are similarities, but that's an
`
` 18 oversimplification. Basically, the child does not have
`
` 19 permission to say things yet. In that regard, this
`
` 20 analogy that you describe is, you know, somewhat
`
` 21 analogous.
`
` 22 Q. Okay. So one scenario you talked about for a
`
` 23 random access procedure is when the UE does not have
`
` 24 permission to transmit; is that right?
`
`Depo International, Inc.
`(763) 591-0535 or (800) 591-9722 | info@depointernational.com
`
`Page 23
`
`Exhibit 2004-023
`
`
`
`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 A. The UE does not have allocation, right. So,
`
` 2 you know, UE can transmit on random access without
`
` 3 permission.
`
` 4 Q. Okay.
`
` 5 A. But the UE does not have an allocated
`
` 6 resource.
`
` 7 Q. Good. Good. Now, you also described -- I
`
` 8 think you used the phrase a semi-persistent
`
` 9 grant?
`
` 10 MR. MEHTA: Objection to form.
`
` 11 A. Yeah, something semi-persistent or somewhat
`
` 12 persistent, yes.
`
` 13 Q. Now, I think you said, also -- please correct
`
` 14 me if I've got this wrong -- that a semi-persistent
`
` 15 grant might be given to a voice call?
`
` 16 MR. MEHTA: Objection to form.
`
` 17 A. That it was the intended use so that since
`
` 18 voice has repetitive, periodic, predictable patterns of
`
` 19 transmission, to minimize the controlling information
`
` 20 going up and down. For the case of voice calls, you
`
` 21 know, something that is given as a standing; something
`
` 22 that lasts more than one TTI.
`
` 23 Q. Understood. Okay. Now, let's refer back to
`
` 24 this figure and this reference tile that we're looking
`
`Depo International, Inc.
`(763) 591-0535 or (800) 591-9722 | info@depointernational.com
`
`Page 24
`
`Exhibit 2004-024
`
`
`
`Paul S. Min, Ph.D. - 3/16/2017
`ZTE (USA) Inc., et al. vs. Evolved Wireless, LLC
`
` 1 at.
`
` 2 A. Okay.
`
` 3 Q. Now, let's assume that this reference -- that
`
`
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