ZTE (USA) Inc., HTC Corporation, HTC America,
`Samsung Electronics Co., LTD., and Samsung
`Electronics America, Inc.
`Petitioner
`v.
`Evolved Wireless LLC, Patent Owner
`U.S. Patent No. 7,881,236
`IPR2016-00757 (IPR2016-01335—consolidated)
`Oral Argument – August 8, 2017
`Evolved Wireless’s Hearing Demonstratives
`
`Evolved Exhibit No. 2010
`ZTE/HTC v. Evolved Wireless, LLC
`IPR2016-00757
`
`
`Samsung Electronics Co., LTD., and Samsung
`Electronics America, Inc.
`Petitioner
`v.
`Evolved Wireless LLC, Patent Owner
`U.S. Patent No. 7,881,236
`IPR2016-00757 (IPR2016-01335—consolidated)
`Oral Argument – August 8, 2017
`Evolved Wireless’s Hearing Demonstratives
`
`Evolved Exhibit No. 2010
`ZTE/HTC v. Evolved Wireless, LLC
`IPR2016-00757
`
`
`
`Introduction to the ‘236 Patent
`
`IPR2016-00757, Patent Owner Response (paper 22) at 3.
`
`2
`
`Evolved Exhibit No. 2010
`Page 2
`
`
`
`Introduction to the '236 Patent
`Claim 1
`
`IPR2016-00757, Patent Owner Response (paper 22) at 6.
`
`3
`
`Evolved Exhibit No. 2010
`Page 3
`
`
`
`Introduction to the '236 Patent
`Claim 7
`
`IPR2016-00757, Patent Owner Response (paper 22) at 8.
`
`4
`
`Evolved Exhibit No. 2010
`Page 4
`
`
`
`Introduction to the '236 Patent
`Claim 1
`
`IPR2016-00757, Patent Owner Response (paper 22) at 6.
`
`5
`
`Evolved Exhibit No. 2010
`Page 5
`
`
`
`Condition X
`Claim 1
`
`IPR2016-00757, Patent Owner Response (paper 22) at 7.
`
`6
`
`Evolved Exhibit No. 2010
`Page 6
`
`
`
`Condition X
`Claim 1
`
`These two limitations are of the form “If X, then do one thing,
`but if not X, do the other thing.”
`
`IPR2016-00757, Patent Owner Response (paper 22) at 7.
`
`7
`
`Evolved Exhibit No. 2010
`Page 7
`
`
`
`Arguments Independent of Claim Construction
`
`Petitioners’ argument that the 321 reference teaches
`limitation 1(c) is wrong, even using Petitioners’
`unreasonable claim construction
`
`Even if Petitioners had correctly rewritten the claim 1(f)
`limitation, Petitioners’ proof still fails
`IPR2016-00757, Patent Owner Response (paper 22) at i.
`
`“Petitioner need not show the prior art satisfies the first
`‘transmitting’ feature to establish invalidity.”
`
`IPR2016-00757, Petitioner’s Reply (paper 28) at 2.
`
`IPR2016-00757, Patent Owner Response (paper 22) at i; IPR2016-00757, Petitioner’s Reply (paper 28) at 2.
`
`8
`
`Evolved Exhibit No. 2010
`Page 8
`
`
`
`The first “determining” limitation
`
`Petitioners’ argument that the 321 reference teaches
`limitation 1(c) is wrong, even using Petitioners’
`unreasonable claim construction
`
`IPR2016-00757, Patent Owner Response (paper 22) at 6, 33.
`
`9
`
`Evolved Exhibit No. 2010
`Page 9
`
`
`
`The first “determining” limitation
`
`According to claim limitation 1(c), the “when” must be “when
`receiving the UL Grant signal on the specific message.”
`Petitioners’ argument relies on the following (false) conclusion
`about when the determining takes place: “the HARQ entity would
`perform this determination during the same TTI in which the UE
`received the uplink grant.” Id. at 25 (emphasis added). That
`(false) conclusion comes straight from the Min Declaration. Ex.
`1016 at ¶ 61.
`
`IPR2016-00757, Patent Owner Response (paper 22) at 34.
`
`10
`
`Evolved Exhibit No. 2010
`Page 10
`
`
`
`The first “determining” limitation
`
`IPR2016-00757, Patent Owner Response (paper 22) at 34.
`
`11
`
`Evolved Exhibit No. 2010
`Page 11
`
`
`
`The first “determining” limitation
`
`Petitioners relied on the argument that “when” in the
`1(c) limitation meant one particular TTI, in other words
`the TTI in which the associated UL Grant was
`received. However, Petitioners’ expert confirmed that
`the 321 does not teach that limitation. As such,
`Petitioners’ argument fails.
`
`IPR2016-00757, Patent Owner Response (paper 22) at 34-35.
`
`12
`
`Evolved Exhibit No. 2010
`Page 12
`
`
`
`Even if Petitioners had correctly rewritten the claim 1(f)
`limitation, Petitioners’ proof still fails
`
`IPR2016-00757, Patent Owner Response (paper 22) at 6.
`
`13
`
`Evolved Exhibit No. 2010
`Page 13
`
`
`
`Even if Petitioners had correctly rewritten the claim 1(f)
`limitation, Petitioners’ proof still fails
`
`IPR2016-00757, Patent Owner Response (paper 22) at 38.
`
`14
`
`Evolved Exhibit No. 2010
`Page 14
`
`
`
`Even if Petitioners had correctly rewritten the claim 1(f)
`limitation, Petitioners’ proof still fails
`
`IPR2016-00757, Patent Owner Response (paper 22) at 39.
`
`15
`
`Evolved Exhibit No. 2010
`Page 15
`
`
`
`Even if Petitioners had correctly rewritten the claim 1(f)
`limitation, Petitioners’ proof still fails
`
`IPR2016-00757, Petitioner’s Reply (paper 28) at 21.
`
`16
`
`Evolved Exhibit No. 2010
`Page 16
`
`
`
`Even if Petitioners had correctly rewritten the claim 1(f)
`limitation, Petitioners’ proof still fails
`
`IPR2016-00757, Petitioner’s Reply (paper 28) at 22.
`
`17
`
`Evolved Exhibit No. 2010
`Page 17
`
`
`
`None of the prior art teaches the “only if” behavior or renders it obvious
`
`Patent Owner fails to rebut three of Petitioner’s assertions:
`
`(1) “the 321 reference taught that the UE ‘shall’ monitor’ for random access responses
`and, after successfully receiving one, ‘process the received UL grant value’”;
`
`(2) “the 321 reference did not say anything about monitoring for a grant on a PDCCH
`during the random access procedure”; and
`
`(3) “[i]t would have been a common-sense design choice for a UE to select the correct
`grant (in the random access response) rather than the incorrect one (in the PDCCH) and
`to transmit message 3 using the random access response grant.”
`
`IPR2016-00757, Petitioner’s Reply (paper 28) at 10-11 (footnotes omitted).
`
`18
`
`Evolved Exhibit No. 2010
`Page 18
`
`
`
`None of the prior art teaches the “only if” behavior or renders it obvious
`
`Patent Owner fails to rebut three of Petitioner’s assertions:
`
`(1) “the 321 reference taught that the UE ‘shall’ monitor’ for random access
`responses and, after successfully receiving one, ‘process the received UL grant
`value’”;
`
`The error Petitioners made was to make a
`general conclusion based only on one
`example of a simple random access
`procedure. Had Petitioners considered the
`case illustrated in Figure 7, they would have
`come to a different conclusion. Overlooking
`the results of sending Msg3 buffer data using
`the wrong UL Grant happened in the prior
`art, and Petitioners have made the same
`mistake in 2017. See Ex. 1001 at 12:13-24;
`Cooklev at ¶ 85.
`
`IPR2016-00757, Patent Owner Response (paper 22) at 44-45.
`
`19
`
`Evolved Exhibit No. 2010
`Page 19
`
`
`
`None of the prior art teaches the “only if” behavior or renders it obvious
`
`Patent Owner fails to rebut three of Petitioner’s assertions:
`
`(2) “the 321 reference did not say anything about monitoring for a grant on a
`PDCCH during the random access procedure”; and
`
`Petitioners continue, “[b]y contrast, the 321 reference did not say anything about monitoring
`for a grant on a PDCCH during the random access procedure.” Id. at 30. That assertion,
`however, is disproven by Line 2 of Petitioners’ Appendix A (“if an uplink grant for this TTI has
`been received on the PDCCH . . . .”), which requires monitoring for UL Grants on a PDCCH.
`
`IPR2016-00757, Patent Owner Response (paper 22) at 42-43
`
`20
`
`Evolved Exhibit No. 2010
`Page 20
`
`
`
`None of the prior art teaches the “only if” behavior or renders it obvious
`
`Patent Owner fails to rebut three of Petitioner’s assertions:
`
`(3) “[i]t would have been a common-sense design choice for a UE to select the
`correct grant (in the random access response) rather than the incorrect one (in the
`PDCCH) and to transmit message 3 using the random access response grant.”
`
`IPR2016-00757, Patent Owner Response (paper 22) at 42.
`
`21
`
`Evolved Exhibit No. 2010
`Page 21
`
`
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