U.S. Patent No. 5,659,891
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`In re Patent of:
`U.S. Patent No.:
`Issue Date:
`Appl. Serial No.:
`Filing Date:
`Title:
`
`Hays et al.
`5,659,891
`Aug. 19, 1997
`08/480,718
`Jun. 7, 1995
`MULTICARRIER TECHNIQUES IN BANDLIMITED CHANNELS
`
`DECLARATION OF DR. APOSTOLOS K. KAKAES
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`1.
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`My name is Apostolos K. Kakaes of Vienna, Virginia. I understand that I am
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`submitting a declaration offering technical opinions in connection with the above-referenced
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`Inter Partes Review proceeding pending in the United States Patent and Trademark Office for
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`U.S. Patent No. 5,659,891 (the “’891 patent”), and prior art references relating to its subject
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`matter. My current curriculum vitae is attached and some highlights follow.
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`2.
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`I have over thirty (30) years of experience in electrical engineering and computer
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`science and in fixed and mobile communications networks. I attended the University of Colorado
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`from 1974 to 1980, during which, I earned a Bachelor of Science (B.S.) and a Master of Science
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`(M.S.) in applied mathematics with a minor in electrical engineering. I attended the Polytechnic
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`Institute of New York between 1982 and 1988, during which, I earned a Doctor of Philosophy
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`(Ph.D.) in electrical engineering, with a thesis titled “Topological Properties and Design of
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`Multihop Packet Radio Networks.” While pursuing the Ph.D. degree, I held a joint appointment
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`as Special Research Fellow and Adjunct Instructor at the Polytechnic Institute of New York
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`between 1985 and 1986.
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`3.
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`Between 1982 and 1987, I worked at AT&T Bell Laboratories in Holmdel, New
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`Jersey. While at AT&T Bell Laboratories, I worked on modeling, analysis, design, and
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`performance evaluation of voice and data networks. I developed algorithms for DNHR
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`(Dynamic, Non-Hierarchical Routing) used in the telephone network. I also worked on analysis
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`U.S. Patent No. 5,659,891
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`of advanced data services and formulation of long term plans for development of enhanced data
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`services and network design tools to support such services.
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`4.
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`I was an Assistant Professor of Electrical Engineering and Computer Science at
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`The George Washington University (GWU), Washington, D.C., between 1987 and 1994. During
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`my association with GWU, I taught graduate courses in the area of communication engineering,
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`including communication theory, coding theory, voice and data networking, and mobile
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`communications. I also received several research awards/grants, including the prestigious NSF
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`Research Initiation Award.
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`5.
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`In 1988, I founded Cosmos Communications Consulting Corporation (“Cosmos”),
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`which is a private communications engineering consulting firm specializing in mobile
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`communications, and I have been the President of the company since the founding. Since 1994,
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`I have worked full-time at Cosmos. At Cosmos, among various activities, I have consulted on
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`high level technology-related issues and trends to corporate entities, governmental agencies, and
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`international organizations, such as the United Nations. I have provided technical consultancy to
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`engineering firms, operators, and equipment vendors on issues related to existing or evolving
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`technologies for mobile communications, and to the investment community on issues related to
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`both fixed and wireless communications technologies. I have served as consultant on both civil
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`and criminal legal cases, including several patent infringement cases both at the ITC and in
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`district court. I also participated as a technical consultant in the analysis of large patent
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`portfolios for the purposes of due diligence, sales, and merger and acquisition activities for some
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`of the largest companies in the mobile communications space. These projects spanned a
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`multidimensional spectrum of technologies in both fixed and mobile communications as they
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`have evolved over the past thirty (30) years.
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`6.
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`During my work at Cosmos, I have provided expert advice and conducted
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`extensive training for practicing engineers in the field in diverse networking technology areas,
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`including Wireless Local Area Networks (LAN), Metropolitan Area Networks (MAN), and
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`Personal Area Networks (PAN) technologies, paging networks, ad hoc networks, including IEEE
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`802.11 (Wi-Fi), IEEE 802.16 (WiMAX), HIPERLAN, Bluetooth, Near Field Communications,
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`IrDA (Infrared Data Association). My experience includes detailed in depth analysis of cellular
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`networks operating with any of the available access technologies as standardized in various
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`standards, broadly known as AMPS, GSM, GPRS, EDGE (EGPRS); North American TDMA
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`and IS-136, iDEN, IS-95, UMTS, HSPA, and LTE. I have experience in the design and
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`implementation of voice and data networking (circuit switching as well as all the evolving all IP-
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`based technologies), traffic engineering, RF design, Quality of Service (QoS) and resource
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`allocation, MAC protocols, as well as in the design of core networks, both user plane and control
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`plane.
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`7.
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`Over the course of my career, I have authored and co-authored some thirty (30)
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`publications on various aspects of fixed and mobile communications, as noted in my curriculum
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`vita. I am a member of the Institute of Electrical and Electronics Engineers (IEEE) and actively
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`involved in the Communications Society and the Information Theory Society of IEEE. Between
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`1991 and 1992, I served as the Secretary of IEEE Communications Society National Capital
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`Area Chapter. Between 1992 and 1993, I was the Vice-Chair of IEEE Communications Society
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`National Capital Area Chapter. I was the Vice-Chair of the Communication Theory Technical
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`Committee of the Communications Society of the IEEE for the 1993-1996 term, and Treasurer of
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`the Communication Theory Technical Committee of the Communications Society of the IEEE
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`for the 1996-1999 term.
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`8.
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`I have served as a reviewer for the IEEE, book editors, other technical
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`publications, and various National Science Foundation (NSF) Panels. I have organized technical
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`sessions in technical conferences, including the IEEE International Conference on
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`Communications (ICC) and IEEE Global Communications Conference (Globecom). I served as
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`the Technical Program Chair for the Communication Theory Mini-Conference in 1992.
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`9.
`
`I am familiar with the content of U.S. Patent No. 5,659,891 (the “’891 patent”).
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`In addition, I have considered the various documents referenced in my declaration as well as
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`additional background materials. For example, I have considered: (1) Dr. Rade Petrovic et al.,
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`Permutation Modulation for Advanced Radio Paging, IEEE Proceedings of Southeastcon ‘93 (7
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`Apr 1993) (“Petrovic”); (2) WIPO Publication No. 1989/008355 to Raith et al. (“Raith”); and (3)
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`C. Alakija and S. P. Stapleton, A Mobile Base Station Phased Array Antenna, 1992 IEEE
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`International Conference on Selected Topics in Wireless Communications at 118 (Jun. 1992)
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`(“Alakija”). I have also reviewed the prosecution history of the ’891 patent and the claim
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`construction orders from Mobile Telecommunications Technologies, LLC v. T-Mobile USA, Inc.,
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`et al., Case No. 2:13-cv-00886-JRG-RSP (E.D. Tex.); Mobile Telecommunications
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`Technologies, LLC v. Sprint Nextel Corp., et al., Case No. 2:12-cv-00832-JRG-RSP (E.D. Tex.);
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`Mobile Telecommunications Technologies, LLC v. Leap Wireless International, Inc., et al., Case
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`No. 2:13-cv-00885-JRG-RSP (E.D. Tex.); and Mobile Telecommunications Technologies, LLC
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`v. Clearwire Corp., et al., Case No. 2:12-cv-00308-JRG-RSP (E.D. Tex.). I have also reviewed
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`the January 22, 2015 Decision on Institution of Inter Partes Review of the Patent Trial and
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`Appeal Board in Case IPR2014-01035.
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`10.
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`Counsel has informed me that I should consider these materials through the lens
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`of one of ordinary skill in the art related to the ’891 patent at the time of the invention, and I have
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`done so during my review of these materials. I believe one of ordinary skill as of June 7, 1995
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`(the priority date of the ’891 patent) would have at least a B.S. degree in electrical engineering,
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`computer science, computer engineering, or equivalent education. This person would also need
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`to have at least two years of experience in the design and configuration of wireless paging
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`systems, or other two-way wireless communications systems and be familiar with the operation
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`and functionality of multicarrier transmissions. I base this on my own personal experience,
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`extensive training that I provided for those in the industry as well as my knowledge of colleagues
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`and other professionals at the time. With this in mind, for purposes of this analysis, references
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`that I make to the views of a person of ordinary skill are intended to relate the views of that
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`person as of June 7, 1995 or earlier, whether stated with respect to the present or past tense.
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`11.
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`Counsel has advised me that, during Inter Partes Review, claims of an expired
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`patent (like the ’891 patent) are generally given their ordinary and customary meaning as
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`understood by a person of ordinary skill in the art in question at the effective filing date of the
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`patent. Counsel has also informed me that this may yield interpretations that are different from
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`the interpretations applied during a District Court proceeding, such as the pending MTel
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`litigation.
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`12.
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`I have no financial interest in either party or in the outcome of this proceeding. I
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`am being compensated for my work as an expert on an hourly basis. My compensation is not
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`dependent on the outcome of these proceedings or the content of my opinions.
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`13. My findings, as explained below, are based on my study, experience, and
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`background in the fields discussed above, informed by my education in applied mathematics and
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`electrical engineering, and my experience in the design and analysis of fixed and mobile
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`communications systems.
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`Page 5 of 23
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`14.
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`This declaration is organized as follows:
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`I.
`
`II.
`
`Brief Overview of the ’891 Patent (page 6)
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`Petrovic and Combinations Based on Petrovic (page 7)
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`III.
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`Conclusion (page 18)
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`Brief Overview of the ’891 Patent
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`The ’891 patent is generally directed to “multicarrier techniques in bandlimited
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`I.
`
`15.
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`channels.” Ex. SAM1001, Title. The ’891 patent includes 5 claims, of which claims 1, 3, and 5
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`are independent.
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`16.
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`The ’891 patent describes “a method for operating more than one carrier in a
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`single mask-defined, bandlimited channel assigned to mobile paging use.” Ex. SAM1001, 1:6-8.
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`Features of the claims are readily discernible from FIGS. 3A and 3B, which the ’891 patent
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`describes as follows:
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`Referring to FIG. 3A. two submasks defining two subchannels. 30a and 30b, are
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`asymmetrically located within a single mask-defined, bandlimited channel 31, resulting
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`in some subchannel overlap. FIG. 3B depicts two carriers, 32a and 32b, operating
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`respectively over two asymmetrically-located subchannels, resulting in some carrier
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`overlap. In accordance with this asymmetry, the frequency difference between the center
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`frequency of each carrier and the nearest band edge of the mask is greater than half the
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`frequency difference between the center frequencies of the two carriers.
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`Ex. SAM1001, 4:25-35. An annotated version of FIG. 3B is provided below to illustrate one
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`implementation of the claim language.
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`17.
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`The ’891 patent acknowledges the prior existence of “traditional multicarrier
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`design[s]” in which “carriers are symmetrically located within the channel such that they are
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`evenly spaced relative to each other and to the band edges of the primary mask defining the
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`primary channel.” Ex. SAM1001, 2:1-12. Thus, the alleged invention of the ’891 patent is the
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`spacing of the carriers within the channel. See Ex. SAM1001, 2:15-17, 2:26-36. As will be
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`described in the following sections, however, the claimed positioning of carriers within a channel
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`was well known in the art well before June 7, 1995.
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`II.
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`Petrovic and Combinations Based on Petrovic
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`A.
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`Petrovic
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`18.
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`Petrovic describes the authors’ “efforts to increase both bit rate and spectral
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`efficiency in simulcast paging networks.” Ex. SAM1013, p. 1, Introduction. To accomplish this
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`Page 7 of 23
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`U.S. Patent No. 5,659,891
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`goal, Petrovic outlines a “multicarrier permutation modulation technique” that “can be used in
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`simulcast networks with high power transmitters.” Ex. SAM1013, p. 1, Abstract. This type of
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`modulation is often classified as Multicarrier Modulation (MCM). Ex. SAM1013, p. 1, Proposed
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`Modulation Technique. The MCM technique described by Petrovic involves encoding data
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`across eight subcarrier frequencies within a band-limited channel. See Ex. SAM1013, p. 1,
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`Proposed Modulation Technique. “The signal spectrum at transmitter output is presented in Fig.
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`1, and 2.” Ex. SAM1013, p. 2, Experiments.
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`19.
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`The proposed multicarrier permutation modulation technique includes “moving
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`the current emission mask boundaries away from the center frequency by +/- 12.5 kHz. This
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`would give a 35 kHz pass band in the middle of the channel and 7.5 kHz guard bands on each
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`side for the skirts of the spectrum.” Ex. SAM1013, p. 1, Proposed Modulation Technique. To
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`illustrate the mask boundaries of the band-limited channel, Petrovic guides the reader to “[s]ee
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`dashed lines in Figs. 1 and 2,” which “represent[] the proposed emission mask.” Ex. SAM1013,
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`p. 1, Proposed Modulation Technique; p. 2, Experiments. The following Annotation 1 of FIG. 1
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`highlights the guard bands with relation to the mask boundaries.
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`These 7.5 kHz guard bands are each only a portion of the frequency difference
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`20.
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`between the center frequency of the outer most of the carriers and the band edge of the mask
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`defining the channel. Thus, the frequency difference between the center frequency of the outer
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`most of the carriers and the band edge of the mask defining the channel is at least 7.5 kHz.
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`21.
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`Petrovic further describes that, “[i]n order to fully utilize the allocated spectrum,
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`and provide fast fall-off of the spectrum in the guard band we propose eight subcarriers spaced 5
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`kHz apart, so that there is exactly 35 kHz spacing between end subcarriers.” See Ex. SAM1013,
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`p. 1. The following Annotation 2 of FIG. 1 highlights the spacing between the center frequency
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`of the subcarriers described by Petrovic.
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`Taking these teachings together, Petrovic describes a guard band of 7.5 kHz (as
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`22.
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`shown in Annotation 1) and a spacing between the center frequency of adjacent carriers of 5 kHz
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`(as shown in Annotation 2). In other words, the frequency difference between the center
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`frequency of the outer most of the carriers and the band edge of the mask defining said channel
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`(which is greater than 7.5 kHz) is more than half the frequency difference between the center
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`frequencies of each adjacent carrier (which is 5 kHz), as required by claim 1. Thus, Petrovic
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`describes the feature that led to the allowance of the ’891 patent.
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`23.
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`In Petrovic’s modulation scheme, adjacent subcarriers partially overlap each
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`other. The following Annotation 3 of FIG. 1 shows the hypothetical position of the eight
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`subcarriers within the bandlimited channel, with carriers/subchannels 1, 2, 4 and 8 being ‘ON’
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`and carrier/subchannels 3, 5, 6, and 7 being ‘OFF’.
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`24. Where the value of the transmitted signal between carrier/subchannel 1 and
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`carrier/subchannel 2 (highlighted in blue below) does not return to practical zero (highlighted as
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`a red broken line that extends the lowest point of the mask), the carrier/subchannel 1 overlaps
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`adjacent carrier/subchannel 2. This is illustrated in the following Annotation 4 of an excerpt of
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`FIG. 1, which is shown side-by-side with a similarly annotated FIG. 5A of the ’891 patent to
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`illustrate the similar type of overlap.
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`
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`25.
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`Petrovic describes using a transmitter with four subtransmitters to transmit the
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`eight subcarriers. Ex. SAM1013, p. 2, Experiments. In particular, “[e]ach transmitter has four
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`subtransmitters capable of 4-FSK over a subset of the 8 frequencies. Outputs of the
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`subtransmitters are combined and sent to a common antenna.” Id. Thus, each of the eight
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`subcarriers are transmitted from the same location (i.e., the common antenna). It would have
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`been understood by one of ordinary skill that a plurality of Petrovic’s mobile receiving units
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`independently receive one of the plurality of transmitted subcarriers. For example, Petrovic
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`describes that “[a] receiver . . . consists of an RF section which down converts the signal to a
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`Page 11 of 23
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`frequency band below 100 kHz, an A/D converter, a DSP processor which performs signal
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`detection through DFT analysis, and a PC to control the operation and present results. SeeEx.
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`SAM1013, p. 2, Experiments.
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`26.
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`Petrovic describes that “[e]ach transmitter has four subtransmitters capable of 4-
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`FSK over a subset of the 8 frequencies. Outputs of the subtransmitters are combined and sent to
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`a common antenna.” Ex. SAM1013, p. 2, Experiments. Each subtransmitter generates and
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`modulates a signal to be transmitted. Ex. SAM1013, p. 3, Proposed Modulation Technique. A
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`block diagram of the four “subtransmitters” described by Petrovic would be structured in a
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`similar manner to the systems shown in either of Figures 1 and 2 of the ’891 patent, except with
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`four data sources and modulators instead of two. Indeed, as in Figures 1 and 2 of the ’891
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`patent, Petrovic describes that “[o]utputs of the subtransmitters are combined and sent to a
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`common antenna [i.e., transmission source].” Ex. SAM1013, p. 2, Experiments.
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`B.
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`Combination of Petrovic, Raith, and Alakija
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`27.
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`I have been asked to consider a scenario in which the “co-locating” limitation of
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`claim 5 requires co-locating a plurality of structurally separate transmitters. In such a scenario,
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`Petrovic discloses a plurality of transmitters, but does not explicitly disclose co-location. Rather,
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`under such a construction Petrovic discloses two transmitters located seven miles apart. See Ex.
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`SAM1013, p. 2, Experiments. However, based on Petrovic in view of Raith and Alakija it would
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`be obvious to co-locate the plurality of transmitters disclosed in Petrovic such that the plurality
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`of carriers can be emanated from the same transmission source.
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`28.
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`In particular, Petrovic describes an experiment in which “[t]wo transmitters [each
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`including four subtransmitters capable of 4-FSK over a subset of the 8 described frequencies]
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`were installed seven miles apart and synchronized to provide a simulcast overlap area with
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`Page 12 of 23
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`approximately 35 dBpV/r signal strength.” Ex. SAM1013, p. 2, Experiments. Thus, Petrovic
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`describes a plurality of geographically spaced transmitters, but describes them as being located
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`seven miles apart. However, co-location of transmitters was well known in the art and the
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`number and location of transmitters in the paging system described by Petrovic would simply be
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`a matter of design choice that would have been obvious to one of ordinary skill in the art. In
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`fact, the ’891 specification describes at least two potential benefits of co-located
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`transmitters:“[b]ecause transmitter co-location does not give rise to the near-far problem to
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`which the FCC mask requirements are directed, carrier spacings far closer than would ordinarily
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`be allowed (e.g., 5 to 10 kHz) are achievable. Moreover, the carriers need not be symmetrically
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`or evenly spaced within the mask defining the channel.” Ex. SAM1001 at 4:12-23. In other
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`words, co-locating transmitters can have subcarriers (1) more closely divided (e.g., less than 5
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`kHz) and (2) non-evenly spaced. Petrovic, however, discloses subcarriers that are evenly spaced
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`at 5 kHz. Ex. SAM1013, p. 2, Proposed Modulation Technique. Therefore, a person having
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`ordinary skill in the art at the time would have been motivated to co-locate transmitters so that
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`the subcarriers described in Petrovic be more closely and/or asymmetrically placed without
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`causing undue interference.
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`29.
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`For example, Figure 1 of Raith describes “the division of an area into cells and the
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`assignation of base station transmitters to the cells in a mobile telephone system.” Ex.
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`SAM1014, 6:1-3. For adjacent cells, Raith describes that it is common to co-locate groups of
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`three base transmitters to service contiguous cells. See Ex. SAM1014, 6:11-13. Thus, as
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`highlighted in the following annotation of Figure 1, “the base station transmitter BS1 for the cell
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`C1 is co-located with the base station transmitter BS3 for the cell C3 and the base station
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`transmitter BS5 for the cell C5.” Ex. SAM1014, 6:13-15 (emphasis added).
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`Page 13 of 23
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`The systems of Petrovic and Raith are similar. Raith describes a cellular digital
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`30.
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`mobile radio system with plural base station transmitters and a method of transmitting
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`information in such a system. Ex. SAM1014, Title. Specifically, Raith describes:
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`[A]t least two base station transmitters (Bma, Bmb, Bna, Bnb) at a given
`transmitting distance from each other are assigned to each of certain cells (Cm,
`Cn) within a restricted geographical area. The base station transmitters which are
`assigned to the same cell transmit digitally modulated radio signals within the
`same frequency range at least partially simultaneously to the mobile stations of
`the cell. The radio signals from different base station transmitters associated with
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`Page 14 of 23
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`the same cell are digitally modulated with the same message information to the
`mobile stations in the cell.
`Ex. SAM1014, Abstract. In other words, each individual cell described by Raith is similar to the
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`experiment described by Petrovic, with two transmitters located a certain distance apart to
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`simultaneously transmit the same message information to a mobile station. Raith simply
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`describes a more complex network of cells and associated transmitters, which are used for two-
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`way telephone communication, as opposed to one-way pager communication.
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`31.
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`Considering Petrovic and Raith in combination, one of ordinary skill in the art
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`would have been motivated to expand the experimental paging system configuration described in
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`Petrovic to include multiples adjacent paging cells/regions similar in structure illustrated in
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`Figure 1 of Raith. In this modified configuration, multiple transmitters configured and operated
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`as described by Petrovic would be co-located to service contiguous cells, as described by Raith.
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`The following annotation of a portion of FIG. 1 of Raith illustrates the proposed combination.
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`Page 15 of 23
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`32.
`
`One of ordinary skill in the art would have been motivated to expand the
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`experiment described by Petrovic in order to provide messaging services to a larger geographic
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`area and a larger number of mobile devices (e.g., pagers).
`
`33.
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`To the extent it is found that Petrovic in view of Raith does not explicitly describe
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`emanating a plurality of carriers from the same transmission source, it would have been obvious
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`to one of ordinary skill in the art to connect the plurality of co-located transmitters taught by
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`Petrovic in view of Raith to a single antenna structure, such as the one described by Alakija, such
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`that the plurality of carriers output by the co-located transmitters could be emanated from the
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`same transmission source.
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`34.
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`In particular, Alakija describes a “mobile communications base station antenna,
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`which utilizes a cylindrical array design.” Ex. SAM1015, Abstract. “Using a switching matrix,
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`different subsets of antenna elements, in the array, can be excited, thus producing a narrow
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`steerable beam.” Id. In one configuration of the cylindrical antenna, Alakija describes that,
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`“[b]y combining a number of feed networks into a single antenna system, an antenna with
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`multiple independently steerable beams is achieved.” Ex. SAM1015, pp. 1-2 (emphasis
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`added). One of ordinary skill would have understood that each of the three co-located
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`transmitters described by Petrovic in view of Raith could provide the “number of feed networks”
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`contemplated by Alakija as inputs to the cylindrical antenna. The following annotated version of
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`FIG. 6 of Alakija illustrates this configuration:
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`Page 16 of 23
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`35. Moreover, Alakija describes that the characteristics of the cylindrical antenna can
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`be altered to cater to variable sector sizes. See Ex. SAM1015, p. 2. Examples of these different
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`patterns that can be obtained by varying phase distribution of the cylindrical antenna are shown
`
`in FIG. 9. See Ex. SAM1015, pp. 2-3. One of ordinary skill in the art would have understood
`
`that one of the illustrated patterns would readily service the mobile cell structure described by
`
`Raith. In the following diagram, three of the independently steerable beams taught by FIG. 9 of
`
`Alakija (i.e., the red pattern that is shown in FIG. 9 and the two blue patterns that one of ordinary
`
`skill in the art would have understood could be independently steered as part of the configuration
`
`shown in FIG. 6) have been overlayed on FIG. 1 of Raith to illustrate this point.
`
`Page 17 of 23
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`Petitioners, Ex. 1003, Page 17
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`

`
`Il.S. Patent No. 5.659.891
`
`lc2
`
`x;q--,,
`
`B54
`c4
`
`Figuro 9: Simulatcd cylin&ical anay parcrns
`wirh dirlqcDt phasc disribu&ms,
`
`36. One ofordinary skill in the art would have been motivated to utilize a single
`
`cylindrical antenna structure to emit the output signals ofthe three co-located transmitters de-
`
`scribed by Petrovic in view of Raith instead of three separate antennas, because a single antenna
`
`structure "[c]an be used to realize advantages such as . . . hardware savings. low manufacturing
`
`costs, [and] low installation costs," as recognized by Alakija. Ex SAM10l5, p. 3.
`III. Conclusion
`37 .
`
`I hereby declare that all statements made herein of my own knowledge are true
`
`and that all statements made on information and beliefare believed to be true; and further that
`
`these statements were made with the knowledge that willful false statements and the like so
`
`made are punishable by fine or imprisonment. or both. under Section l00l of Title l8 of the
`
`United States Code.
`
`Date:
`
`Signature:
`
`los K. Kakaes, Ph.D.
`
`Page 18 of 23
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`Petitioners, Ex. 1003, Page 18
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`

`
`
`
`APOSTOLOS K. KAKAES
`Cosmos Communications Consulting Corporation, President
`908 Park St. SE, Suite 201
`Vienna, Virginia 22180
`703-310-6076 (Office); 703-981-0999 (Mobile);
`e-mail: akakaes@gmail.com
`
`AREAS OF EXPERTISE
`
`All aspects of fixed and mobile communications. Over the years, my emphasis has been both in
`breadth and in depth, originally in fixed communications networks and then in mobile
`communications. Specific areas of in-depth expertise include:
` LTE/LTE-Advanced and evolution issues of 3G to 4G and beyond
` UMTS, including FDD, TDD, HSDPA/HSUPA, HSPA+, both air interface (UTRA) and
`core networking issues
` cdma2000 family from IS-95, through its evolution to 1x, 3x, 1xEV-DO (HDR), 1xED-
`DV (all aspects of the evolution to “3G” and beyond)
` Wireless Local Area Networks (LAN), Metropolitan Area Networks (MAN), and
`Personal Area Networks (PAN) technologies, Paging networks, Ad hoc networks,
`including IEEE 802.11 (WiFi), IEEE 802.16 (WiMAX), HIPERLAN, Bluetooth, Near
`Field Communications, IrDA (Infrared Data Association) operating with any of the
`available access technologies
` GSM, GPRS, EDGE (EGPRS) and related evolutionary issues
` North American TDMA and IS-136
` TETRA
`iDENTM
`
` Core Network technologies, IS-41, SS7, ATM, MAP, etc.
` Voice over IP (VoIP)
` Design and implementation of voice and data networking (circuit switching as well as all
`the evolving all IP-based technologies)
` Traffic engineering and network design; both air interface aspects (including resource
`allocation, QoS, MAC protocol, etc.) and design of core network, both user plane and
`control plane
`
`EMPLOYMENT HISTORY
`
`9/88 – Present
`Cosmos Communications Consulting Corporation. Founder and president of private
`communications engineering consulting firm specializing in mobile communications. Initially
`part time; full time since 1994.
` Developed and presented courses, seminars, and lectures on fixed and mobile
`communications to both corporate and government entities, such as the FCC and the US
`Marshal’s Office.
` Consulted on high level technology-related issues and trends, pros and cons of each, etc.
`to corporate entities, governmental agencies, and international organizations, such as the
`UN.
`
`Page 19 of 23
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`Petitioners, Ex. 1003, Page 19
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`

`
`
`
` Consulted at the detailed technical level to engineering firms, operators, and equipment
`vendors on technical issues related to existing or evolving technologies for mobile
`communications.
` Served as technology consultant to the investment community both fixed and wireless
`communications technologies.
` Served as consultant and expert witness on both civil and criminal legal cases, including
`a class action lawsuit brought in California, a murder case in Illinois, and several patent
`infringement cases both at the ITC and in district court.
` Participated as a technical consultant in the analysis of large patent portfolios for the
`purposes of due diligence, sales, and/or M/A activities for some of the largest companies
`in the mobile communications space.
`
`These projects spanned a multidimensional spectrum of
` Technologies: both fixed and mobile communications as they have evolved over the past
`30+ years;
` Audiences: non-technical support personnel, highly specialized engineers, Wall Street
`analysts, hedge fund managers, litigation teams, as well as decision making executives at
`the CEO/CFO/CTO level;
` Geographic and cultural backgrounds that span all continents and over 40 countries.
`
`9/87 - 5/94
`The George Washington University, Washington, D.C. Department of Electrical Engineering and
`Computer Science.
` Taught mostly graduate courses in the area of communication engineering, including
`communication theory, coding theory, voice and data networking, and mobile
`communications.
` Proposed, developed and taught new graduate courses in the area of mobile
`communications.
` Received several research awards/grants, including the prestigious NSF Research
`Initiation Award.
` Participated in several committees, including the departmental Graduate Curriculum
`Committee as well as various University-wide committees.
`
`7/85 - 12/86
`Polytechnic Institute of New York, Brooklyn, New York. Joint appointment as Special Research
`Fellow and Adjunct Instructor (while pursuing the Ph.D. degree)
`
`1/82 - 7/87
`AT&T Bell Laboratories, Holmdel, New Jersey. Worked on modeling, analysis, design, and
`performance evaluation of voice and data networks. Developed algorithms for DNHR
`(Dynamic, Non-Hierarchical Routing) used in the telephone network. Analysis of advanced data
`services and formulation of long term plans for development of enhanced data services and
`network design tools to support such services.
`
`7/76 - 12/81
`University of Colorado, Boulder, Colorado and Michigan State University, East Lansing,
`Michigan. Undergraduate and then graduate teaching assistant.
`
`Page 20 of 23
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`Petitioners, Ex. 1003, Page 20
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`

`
`
`
`EDUCATION
`
`09/82 - 01/88
`Polytechnic Institute