UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
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`CISCO SYSTEMS, INC.,
`Petitioner
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`v.
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`TQ DELTA, LLC,
`Patent Owner
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`_____________________
`
`Case IPR2016-01009
`Patent 8,238,412 B2
`_____________________
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`PETITIONER’S RESPONSE TO PATENT OWNER’S MOTION FOR
`OBSERVATION ON CROSS-EXAMINATION TESTIMONY
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`
`CISCO SYSTEMS, INC.,
`Petitioner
`
`v.
`
`TQ DELTA, LLC,
`Patent Owner
`
`_____________________
`
`Case IPR2016-01009
`Patent 8,238,412 B2
`_____________________
`
`
`PETITIONER’S RESPONSE TO PATENT OWNER’S MOTION FOR
`OBSERVATION ON CROSS-EXAMINATION TESTIMONY
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`Petitioner’s Response to Patent Owner’s Motion for Observation
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`IPR2016-01009
`This response is submitted in view of the Scheduling Order (Paper 9); the
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`Notice of Parties’ Stipulation Regarding Scheduling Order, submitted June 28,
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`2017 (Paper 21); and the Trial Practice Guide, 77 Fed. Reg. 48756, 48767–68
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`(Aug. 14, 2012). This paper responds to Patent Owner’s Motion for Observation on
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`Cross-examination (Paper 29) filed on July 5, 2017, in the present inter partes
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`review. Patent Owner presented nineteen (19) observations on the June 26, 2017,
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`deposition testimony of Dr. Kiaei (Ex. 2011). Although Petitioner responds to
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`each of Patent Owner’s observations below, the Board should deny Patent Owner’s
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`motion because the observations contain at least one of the following deficiencies:
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`(1) they fail to identify the relevant issue; (2) they are not relevant to any issue; (3)
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`they include attorney argument, and; (4) they mischaracterize Dr. Kiaei’s
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`testimony.
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`Response to Observation 1:
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`Patent Owner’s observation omits relevant testimony pertaining to the term
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`“subchannel” in the ‘956 patent (which shares a common specification with the
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`‘412 patent at issue). Specifically, Dr. Kiaei testified that based on the ‘956
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`patent’s disclosure at “Column 1, lines 47 to 49” (which corresponds to the ‘412
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`patent at 1:44-45), “only subchannels that are discrete, nonoverlapping, and have
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`limited bandwidth are carriers.” Ex. 2011, 173:24-174:17. This testimony is
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`consistent with Dr. Kiaei’s declaration testimony that in the context of the ‘412
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`2
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`Petitioner’s Response to Patent Owner’s Motion for Observation
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`IPR2016-01009
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`patent, “a ‘subchannel’ would be understood to be ‘a portion of a frequency
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`spectrum used for communication.’” Ex. 1100, ¶11. Furthermore, as to the
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`relevance of this testimony to Milbrandt, Dr. Kiaei explained that Milbrandt’s
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`“sub-frequency” teaches the claimed “subchannel,” “even under TQ Delta’s
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`narrow construction.” Ex. 1100, ¶¶15-24.
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`Response to Observation 2:
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`Patent Owner’s observation includes attorney argument, which
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`mischaracterizes that Dr. Kiaei “testified that subbands and carriers are not the
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`same” and that “Dr. Kiaei contradicts himself.” To the contrary, nowhere does Dr.
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`Kiaei “testif[y] that subbands and carriers are not the same.” Dr. Kiaei merely
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`quoted Exhibit 1101 at 69, which states that “there are 256 subbands” and no
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`distinction was made between ADSL carriers and subbands. Ex. 2011, 21:6-11.
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`(“Q. So you said here, and I quote, ‘We're not talking about carriers right now.
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`We're talking about 256 subbands.’ So you make a distinction between carriers and
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`subbands? A. No, that's not -- specifically, I was just reading what they [Exhibit
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`1101 at 69] said.”)
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`Response to Observation 3:
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`Patent Owner’s observation omits relevant testimony pertaining to the term
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`“subchannel.” Specifically, Dr. Kiaei testified that based on the ‘956 patent’s
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`disclosure at “Column 1, lines 47 to 49,” subchannels are not always carriers and
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`IPR2016-01009
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`that “only subchannels that are discrete, nonoverlapping, and have limited
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`bandwidth are carriers.” Ex. 2011, 173:24-174:17. Dr. Kiaei’s deposition
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`testimony is consistent with his declaration testimony since in the context of the
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`‘412 patent, “a ‘subchannel’ would be understood to be ‘a portion of a frequency
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`spectrum used for communication.’” Ex. 1100, ¶11. Furthermore, as to the
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`relevance of this testimony to Milbrandt, Dr. Kiaei explained that Milbrandt’s
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`“sub-frequency” teaches the claimed “subchannel,” “even under TQ Delta’s
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`narrow construction.” Ex. 1100, ¶¶15-24.
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`Response to Observation 4:
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`Patent Owner’s observation mischaracterizes the cited testimony.
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`Specifically, and contrary to Patent Owner’s observation, the question was not “if a
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`subchannel is associated with a frequency” but rather “is that the frequency
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`associated with that subchannel?” Ex. 2011, 84:16-17. Regardless, Dr. Kiaei’s
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`cited deposition testimony is consistent with his declaration in Ex. 1009, ¶67 and
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`¶69; Ex. 1100, ¶6 Moreover, Patent Owner’s experts, Dr. Chrissan and Dr. Short,
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`similarly testified that, in the ADSL context, the terms at issue were used
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`interchangeably. Ex. 1103, ¶36; Ex. 1110, 53:20-54:1.
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`Response to Observation 5:
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`Patent Owner’s observation is consistent and actually reaffirms Dr. Kiaei’s
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`declaration testimony, as evidenced by testimony omitted by Patent Owner. Ex.
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`4
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`Petitioner’s Response to Patent Owner’s Motion for Observation
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`2011, 33:12-22 (“A. … Elahi actually reaffirms other terminologies that uses as
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`well for the same thing. As you read on page 108, it says that ‘ADSL uses discrete
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`multitone encoding methods which use QAM to divide the bandwidth of the
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`channel into multiple subchannels and each channel which is now the subchannel.’
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`So it's interchanging channel and subchannels transmitting information using QAM
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`modulation.”) Regardless, the testimony cited by Patent Owner is not relevant
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`since Dr. Kiaei’s combination relies on Milbrandt—not Elahi.
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`Response to Observation 6:
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`Patent Owner’s cited deposition testimony pertains to a specific example in
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`the ANSI T1.413 (related to the maximum value of PSD) that is not relevant to Dr.
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`Kiaei’s declaration, which relied on other portions of the ANSI T1.413 standard.
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`Further, Patent Owner mischaracterizes the cited testimony in presenting attorney
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`argument that allegedly Dr. Kiaei testified that the communicated PSD “could be a
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`single value for the entire upstream or downstream channel”—in fact, he testified
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`that it is for a “portion” of the upstream or downstream. Ex. 2011, 106:7-8.
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`Moreover, Patent Owner omits clear testimony that PSD is not a single value for
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`the entire upstream or downstream channel. Ex. 2011, 113:21-114:4 (“Q. Do you
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`agree that that 3-bit value is for the entire upstream or downstream channel? ...
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`THE WITNESS: All it's saying here is talking about C-REVERB1 reporting the
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`bits representing the power spectral density of that. It doesn't talk about the entire
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`upstream or downstream issues in here.”); see also, id., 117:9-25 (“PSD is not a
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`single value for the entire spectrum. What PSD in here is that -- is a level of power
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`for each one of the subchannels that are going downstream being sent on C-
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`REVERB1. So ATU-C is telling ATU-R the level of power PSD per each one of
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`the subchannels...you cannot have a single number for the entire bandwidth.”)
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`Response to Observation 7:
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`Patent Owner’s cited deposition testimony pertains to a specific example in
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`the ANSI T1.413 (related to the maximum value of PSD) that is not relevant to Dr.
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`Kiaei’s declaration, which relied on other portions of the ANSI T1.413 standard.
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`Further, Patent Owner omits clear testimony from Dr. Kiaei that PSD is not a
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`single value for the entire upstream or downstream channel. Ex. 2011, 117:9-25
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`(“PSD is not a single value for the entire spectrum. What PSD in here is that -- is a
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`level of power for each one of the subchannels that are going downstream being
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`sent on C-REVERB1...you cannot have a single number for the entire bandwidth.”)
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`Also, Dr. Kiaei’s credibility and the accuracy of his statement that “a POSITA
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`would have measured PSD per subfrequency in Milbrandt’s ADSL system based
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`on Reverb to also comply with ANSI T1.413” is supported by Alcatel’s FCC filing
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`of figures illustrating PSD based on Reverb per subchannel that complies with
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`ANSI T1.413 power requirements. Ex. 1100, ¶39 (citing Ex.1109, 3 FIG. 5.6.).
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`Response to Observation 8:
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`Dr. Kiaei’s deposition testimony is consistent with his declaration since
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`initialization functions, such as measuring SNR, can occur during Showtime. Ex.
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`2011, 51:2-8 (“Q. So initialization continues during Showtime? THE WITNESS:
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`Some of the procedures for looking at SNL [sic] degradation, for example, looking
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`at the other issues that may come up in the transmission and communication
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`between ATU-C and ATU-R…there is still some training- and initialization-type
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`processes going on, yes.”); see also, Ex. 2011, 49:15-50:15. Furthermore, as to the
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`relevance of this testimony to Milbrandt, Dr. Kiaei explained that “Milbrandt
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`measures noise information… after initialization.” Ex. 1100, ¶48.
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`Response to Observation 9:
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`Patent Owner’s observation includes attorney argument, which
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`mischaracterizes that “Dr. Kiaei testified that he did not have an opinion on the
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`topic” of “whether Milbrandt’s modem determined test and diagnostic information
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`… ‘during Showtime.’” The testimony indicates otherwise. Ex. 2011, 62:24-63:4
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`(“Q. So it is your understanding as an expert in DSL that a modem can determine
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`attenuation while it is transmitting and receiving data? A. I -- there are
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`possibilities, yeah. I don't -- yes, there are possible ways to do that.”) Only when
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`asked “How would you do it?” did Dr. Kiaei answer that it was “outside of the
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`scope of this” and did not provide an opinion. Ex. 2011, 63:5-17. Furthermore,
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`the cited testimony in Patent Owner’s observation is a general statement unrelated
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`to the specific teachings in Milbrandt that Petitioner relied upon.
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`Response to Observation 10:
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`Patent Owner’s observation includes attorney argument, which
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`mischaracterizes the cited testimony. Dr. Kiaei never said that a person with a
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`background in mathematics and statistics “would qualify as a person of ordinary
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`skill in the art.” When the question was posed, and after providing qualifiers, Dr.
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`Kiaei stated that such a person would understand some of the concepts. Ex. 2011,
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`15:20-24 (“I don't have Mr. Abe's -- Mr. Abe's resume in front of me, but in
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`general, a person with a background in mathematics and statistics would, and
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`having a background in other areas related to that would understand some of the
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`concepts that are discussed here”). To the point, Dr. Kiaei testified that he was not
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`changing his definition of a POSITA. Ex. 2011, 15:12-17. (“Q. So are you
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`changing your definition of a 13 POSITA then? A. No, I'm not.” “Q. So you're
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`supplementing your definition of a POSITA then? A. No, I'm not, Counsel.”)
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`Response to Observation 11:
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`Patent Owner’s observation includes attorney argument which
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`mischaracterizes the cited testimony. Dr. Kiaei never “agreed that the ‘956 patent
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`specification…does not equate channel and subchannel.” To the contrary, Dr.
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`Kiaei testified that “[a] POSITA will also understand that terminology used here
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`Petitioner’s Response to Patent Owner’s Motion for Observation
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`for a broadband communication channel, which is the DSL upstream or
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`downstream channels, could also be said as an upstream subchannel and
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`downstream subchannel.” Ex. 2011, 86:16-24. This is also consistent with Dr.
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`Chrissan’s testimony that he “personally in appropriate contexts equate[s], channel,
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`subchannel, carrier, and subcarrier. I believe that other people in appropriate
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`contexts would equate any of those four terms as well.” Ex-1110, 53:20-54:1.
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`Further, Dr. Kiaei testified that based on the ‘956 patent’s disclosure at “Column 1,
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`lines 47 to 49” (which corresponds to the ‘412 patent at 1:44-45), subchannels are
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`not always carriers and that “only subchannels that are discrete, nonoverlapping,
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`and have limited bandwidth are carriers.” Ex. 2011, 173:24-174:17. Furthermore,
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`as to the relevance of this testimony to Milbrandt, Dr. Kiaei explained that
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`Milbrandt’s “sub-frequency” teaches the claimed “subchannel,” “even under TQ
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`Delta’s narrow construction.” Ex. 1100, ¶¶15-24.
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`Response to Observation 12:
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`Patent Owner’s cited deposition testimony is consistent with Dr. Kiaei’s
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`declaration testimony that “the terms ‘tone,’ ‘carrier,’ ‘subcarrier,’ ‘channel,’
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`‘band,’ ‘sub-band’…‘subfrequency,’ in the ADSL context, would also be
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`understood to be equivalent and interchangeable with the term ‘subchannel.’” Ex.
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`1100, ¶6. This is also consistent with Dr. Chrissan’s testimony that he “personally
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`in appropriate contexts equate[s], channel, subchannel, carrier, and subcarrier. I
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`believe that other people in appropriate contexts would equate any of those four
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`terms as well.” Ex-1110, 53:20-54:1. Moreover, the fact that these terms are
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`admittedly equivalent and interchangeable, in the ADSL context, confirms Dr.
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`Kiaei’s position that Patent Owner’s construction for “subchannel” is “confusing
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`and circular.” Ex. 1100 at ¶ 10.
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`Response to Observation 13:
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`The cited testimony in Patent Owner’s observation is consistent with Dr.
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`Kiaei’s declaration. Specifically, Dr. Kiaei testified that “[a] POSITA will also
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`understand that terminology used here for a broadband communication channel,
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`which is the DSL upstream or downstream channels, could also be said as an
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`upstream subchannel and downstream subchannel.” Ex. 2011, 86:16-24. Dr. Kiaei
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`additionally testified that based on the ‘956 patent’s disclosure “Column 1, lines 47
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`to 49” (which corresponds to the ‘412 patent at 1:44-45), subchannels are not
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`always carriers and that “only subchannels that are discrete, nonoverlapping, and
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`have limited bandwidth are carriers.” Ex. 2011, 173:24-174:17. Only when asked
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`specifically with respect to “subchannels in DSL” context, did Dr. Kiaei testify that
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`the subchannels do not overlap. Ex. 2011, 180:11-13. As such, Dr. Kiaei’s
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`deposition testimony is consistent with the testimony in his declaration that “the
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`terms ‘tone,’ ‘carrier,’ ‘subcarrier,’ ‘channel,’ ‘band,’ ‘sub-band’…‘subfrequency,’
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`in the ADSL context, would also be understood to be equivalent and
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`interchangeable with the term ‘subchannel.’” Ex. 1100, ¶6; see also Ex. 1001,
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`1:42-49.
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`Response to Observation 14:
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`The testimony in Patent Owner’s observation is consistent with Dr. Kiaei’s
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`declaration that the “V.90 protocol uses the voice frequency spectrum, which is in
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`fact a ‘sub-frequency’ of the overall frequency spectrum” and that “[a] POSITA
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`would have understood that since the V.90 protocol is an alternative to the ADSL
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`protocol, Milbrandt’s teaching or use of the term ‘sub-frequency’ in the context of
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`V.90 protocol is not inconsistent with the use of that term in the context of the
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`ADSL protocol.” Ex. 1100, ¶25.
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`Response to Observation 15:
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`Patent Owner’s observation omits Dr. Kiaei’s testimony that Chang taught
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`multiple ways to measure background noise.
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`Q. But it is your position that to measure background
`noise you have to transmit a signal and measure the
`reflection back. Isn't that what you said?
`A. You mischaracterized what I said, Counsel. I said
`there are different methodologies -- three different
`methods in this patent [Chang] I discussed that talks
`about these different methods. These different teachings
`can be used in general to -- for measuring the background
`noise.
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`Ex. 2011, 153:16-25. Also, Patent Owner’s citation omits relevant portions of Dr.
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`Kiaei’s testimony that supports Petitioner’s position (see Petition, Paper 2, 19;
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`Reply, Paper 17, 14-15) that a POSITA would have known how to apply Chang’s
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`general teachings of measuring idle channel noise to Milbrandt’s ADSL system,
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`without physical incorporation of elements. Ex. 2011, 16-:6-22 (“Actually, TQ
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`Delta's expert, Dr. Chrissan, also agrees with the specification of the patent at
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`issue, did not disclose how to determine idle channel noise, and that was well
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`known how to measure idle channel noise without a truck roll.”); see also Ex.
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`2011, 157:10-22 (“I personally performed background noise measurements at
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`different modes of the system when I was in Motorola and ADSL. I was aware of
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`many other vendors that performed the same thing, both during the DSL standards
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`as well as the interactions we had with different customers. It's based on my
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`experience of being in the field for the past 35 years and knowing that these
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`general teachings could apply to different methods. I would be able to hand this
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`patent to one of my students and say go and come up with the methodologies based
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`on his method of measuring background noise.”)
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`Response to Observation 16:
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`Patent Owner’s citation to Dr. Kiaei’s testimony (Ex. 2011, 154:1-157:4) is
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`consistent with Petitioner’s position (see Petition, Paper 2, 19; Reply, Paper 17, 14-
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`15) that a POSITA would have known how to apply Chang’s general teachings of
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`measuring idle channel noise to Milbrandt’s ADSL system, without physical
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`incorporation of elements. Patent Owner also omits other relevant portions of Dr.
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`Kiaei’s testimony stating that both experts agree that it was well known how to
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`measure idle channel noise. Ex. 2011, 160:6-22 (“Actually, TQ Delta's expert, Dr.
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`Chrissan, also agrees with the specification of the patent at issue, did not disclose
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`how to determine idle channel noise, and that was well known how to measure idle
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`channel noise without a truck roll.”).
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`Response to Observation 17:
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`Contrary to Patent Owner’s observation, “the factual basis” for Dr. Kiaei’s
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`position that a POSITA would have known “how to apply Chang’s general
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`teaching of measuring idle channel noise to Milbrandt ADSL without a physical
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`incorporation of Chang’s elements,” is demonstrated by his deposition testimony.
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`Ex. 2011, 157:10-22 (“I personally performed background noise measurements at
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`different modes of the system when I was in Motorola and ADSL. I was aware of
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`many other vendors that performed the same thing.”) Further, Patent Owner’s
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`contention that Dr. Kiaei “would not discuss the nature of his work at Motorola”
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`mischaracterizes the testimony. Ex. 2011, 159:8-18 (“A. We had a working DSL.
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`We had a -- which many customers used it. I was in charge of the system
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`engineering for the DSL and I have personally experience in there.”) Patent
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`Owner’s citation is also incomplete since it omits other relevant portions of Dr.
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`Kiaei’s testimony, which demonstrate that it was well known how to measure idle
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`channel noise. Ex. 2011, 160:6-22 (“Actually, TQ Delta's expert, Dr. Chrissan, also
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`agrees with the specification of the patent at issue, did not disclose how to
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`determine idle channel noise, and that was well known how to measure idle
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`channel noise without a truck roll.”)
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`Response to Observation 18:
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`Patent Owner’s observation pertaining to “idle packets” disclosed in Ex.
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`1014 (ANSI T1.413 standard) is not relevant to Petitioner’s combination which
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`addressed the “idle channel noise” claim limitation with the combination of
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`Milbrandt and Chang—not ANSI T1.413. See, Petition, Paper 2, 15-16 and 29.
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`Also, Patent Owner did not afford Dr. Kiaei an opportunity to review the relevant
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`portion of the ANSI T1.413, to answer the question. Ex. 2011, 131:15-22, 133:13-
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`18 (“Q. Are you familiar with this generally? A. Yes. Q. Okay. A. In general, yes,
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`but I haven't looked at it recently.” “Can you measure idle channel noise while
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`these superframes are being transmitted? MR. EMERSON: Object to the scope.
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`THE WITNESS: I'd have to look at the details of the superframes and how it's
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`being sent and if there is -- what are the details there.”) Further, the fact that “idle
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`packets” are sent supports Petitioner’s position (Reply, Paper 17, 16-17) that there
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`are idle periods during which idle channel noise can be measured, as confirmed by
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`Dr. Kiaei’s deposition testimony. Ex. 2011, 133:21-134:15 (“Q. You have your
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`opinion here that Milbrandt's ADSL modem will experience idle periods during the
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`day when no information is being transmitted. And when no information is being
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`transmitted, your position is that idle chatter noise can be measured; is that correct?
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`A. Yes. And actually, we did that when I was in Motorola. Q. And can you
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`perform -- when you were at Motorola when you performed idle channel
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`measurement, were these superframes being transmitted?... THE WITNESS:…
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`That was 15 years ago, 17 years ago, but we were able to measure background
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`noise when the modem was in idle. What happened in idle protocol to deal with
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`these issues I'm not prepared to answer, meaning the superframes and so on.”)
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`Response to Observation 19:
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`Patent Owner’s observation regarding whether Dr. Kiaei could remember
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`the provided reasons for measuring SNR at the subscriber modem, which he
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`provided in his first declaration, is not relevant to the issue of “Dr. Kiaei’s
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`credibility and qualifications as an expert in DSL communications,” since
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`depositions are not a memory test. Ex. 2011, 164:24-165:2 (“So I don't remember
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`whether I discussed it there or not, but I don't have that declaration in front of me
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`so I can't say that.”) Nevertheless, and contrary to Patent Owner’s observation, Dr.
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`Kiaei did in fact provide motivation for measuring SNR at the subscriber modem
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`in his first declaration. See e.g., IPR2016-01009, Ex. 1009, ¶85, and pp. 91-93.
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`July 17, 2017
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`Petitioner’s Response to Patent Owner’s Motion for Observation
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`IPR2016-01009
`Respectfully submitted,
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`/David L. McCombs/
`David L. McCombs
`Counsel for Petitioner
`Registration No. 32,271
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`CERTIFICATE OF SERVICE
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`The undersigned certifies, in accordance with 37 C.F.R. § 42.205, that
`service was made on the Patent Owner as detailed below.
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`Date of service
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`July 17, 2017
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`Persons served
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`Manner of service
`Email: pmcandrews@mcandrews-ip.com;
`twimbiscus@mcandrews-ip.com; smcbride@mcandrews-ip.com;
`cscharff@mcandrews-ip.com; rchiplunkar@mcandrew-ip.com;
`TQD-CISCO@mcandrews-ip.com
`
`Documents served
`
`Petitioner’s Response to Patent Owner’s Motion
`for Observation on Cross-examination Testimony
`
`Peter J. McAndrews
`Thomas J. Wimbiscus
`Scott P. McBride
`Christopher M. Scharff
`Rajendra A. Chiplunkar (admitted PHV)
`MCANDREWS, HELD & MALLOY, LTD
`500 West Madison Street, 34th Floor
`Chicago, IL 60661
`
`
`
`/David L. McCombs/
`David L. McCombs
`Counsel for Petitioner
`Registration No. 32,271
`
`17
`
`
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