UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC., MICROSOFT COROPORATION, MICROSOFT MOBILE
`
`OY, and
`
`MICROSOFT MOBILE INC. (F/K/A/ NOKIA INC.),
`
`Petitioner
`
`v.
`
`EVOLVED WIRELESS LLC,
`
`Patent Owner.
`
`_____________________________
`
`Case IPR2016-01228
`
`Case IPR2016-01229
`
`Patent 7,881,236 B2
`
`_____________________
`
`Declaration of Todor Cooklev Ph.D.
`
`
`
`
`
`
`
`
`____________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC., MICROSOFT COROPORATION, MICROSOFT MOBILE
`
`OY, and
`
`MICROSOFT MOBILE INC. (F/K/A/ NOKIA INC.),
`
`Petitioner
`
`v.
`
`EVOLVED WIRELESS LLC,
`
`Patent Owner.
`
`_____________________________
`
`Case IPR2016-01228
`
`Case IPR2016-01229
`
`Patent 7,881,236 B2
`
`_____________________
`
`Declaration of Todor Cooklev Ph.D.
`
`
`
`
`
`
`
`
`
`
`
`CONTENTS
`I.
`Introduction ...................................................................................................... 3
`II. Qualifications ................................................................................................... 4
`III. Scope and Summary of opinions ..................................................................... 6
`IV. Legal standards ................................................................................................ 6
`A. Anticipation ........................................................................................... 7
`B. Obviousness ........................................................................................... 8
`Level of Ordinary Skill in the Art ................................................................. 12
`V.
`VI. Overview of the technology .......................................................................... 13
`A. Acquiring Radio Resources—UL Grants ............................................ 17
`B. HARQ .................................................................................................. 19
`C.
`Contention-based Random Access Procedures ................................... 22
`D.
`The four phases of the Random Access Procedure ............................. 24
`1.
`Phase 1 – Random Access preamble ........................................ 24
`2.
`Phase 2 – Random Access Response (RAR) ............................ 25
`3.
`Phase 3 – msg3 .......................................................................... 25
`4.
`Phase 4—Contention Resolution, msg4 ................................... 26
`VII. Overview of the ‘236 patent .......................................................................... 28
`VIII. A PHOSITA would understand the “if” language in claims 1 and 7 to
`mean “only if” or “only when” ...................................................................... 33
`IX. Validity .......................................................................................................... 40
`
`
` 2
`
`Exhibit 2011-002
`
`
`
`
`
`I.
`
`INTRODUCTION
`1. My name is Todor Cooklev. I have been retained by Evolved
`
`Wireless LLC (“Evolved Wireless” or “Evolved”).
`
`2.
`
`I have been asked to prepare this Declaration in connection with
`
`Case Nos. IPR2016-01228 and IPR2016-01229 for inter partes review of U.S.
`
`Patent No. 7,881,236 (“the ‘236 patent’) and the Declaration of Dr. Jonathan
`
`Wells (“the Wells Declaration”). I understand that Dr. Jonathan Wells has been
`
`retained by Microsoft Corporation, Microsoft Mobile Oy, Microsoft Mobile,
`
`Inc., and Apple, Inc. (collectively “Petitioners”) to determine if the ‘236
`
`patent’s claims are invalid. See Wells Declaration ¶ 1. I have been asked to
`
`consider the opinions of Dr. Wells, and provide my opinions regarding the
`
`validity of the ’236 patent’s claims.
`
`3.
`
`I base my Declaration on information currently available to me.
`
`I reserve the right to continue my investigation. I further reserve the right to
`
`expand, modify, and/or supplement this Declaration and my opinions as
`
`additional information becomes available to me.
`
`4.
`
`In this Declaration, I cite to various documents and testimony.
`
`These citations are meant to be exemplary, and not exhaustive. Citations to
`
`documents or testimony are not intended to signify that my conclusions or
`
` 3
`
`Exhibit 2011-003
`
`
`
`
`
`opinions are limited to the cited sources, or supported by the cited sources
`
`only.
`
`II. QUALIFICATIONS
`5. My qualifications are stated more fully in my Curriculum Vitae,
`
`a copy of which is attached hereto as Appendix 1.
`
`6.
`
`I have a Ph.D. in electrical engineering from Tokyo Institute of
`
`Technology in 1995. Currently I work as the Founding Director of the
`
`Wireless Technology Center at Indiana University-Purdue University Fort
`
`Wayne and hold an endowed faculty position as Harris Chair of Wireless
`
`Communication and Applied Research.
`
`7.
`
`I have received research funding from the National Science
`
`Foundation (NSF), the U.S. Air Force Research Laboratory, the Defense
`
`Advanced Research Projects Agency (DARPA), and several major
`
`companies such as Raytheon, Harris (formerly ITT), France Telecom, and
`
`other smaller technology companies.
`
`8.
`
`I am a named inventor on thirty (30) patents issued in the United
`
`States relating
`
`to
`
`the design of
`
`integrated circuits for wireless
`
`communications systems. I have also authored and co-authored more than
`
` 4
`
`Exhibit 2011-004
`
`
`
`
`
`100 peer-reviewed articles. (A list of my publications and patents appears in
`
`my Curriculum Vitae attached as Appendix 1.)
`
`9.
`
`I received a 1994 Asia-Pacific Conference on Circuits and
`
`Systems Best Paper Award and a 2012 IEEE Standards Association award
`
`for “outstanding contributions to IEEE 802.11aa.”
`
`10. I have experience working on the design of integrated circuits
`
`(“ICs”) for wireless communication systems implementing algorithms of the
`
`types that are at issue in this investigation.
`
`11. I have been actively involved in professional organizations, in
`
`particular relevant to standards for wireless communications systems. I have
`
`served the IEEE Standards Association in several capacities, including as
`
`the first Chair of the IEEE Standards Education Committee during 2006-
`
`2007.
`
`12. I have served on standards committees, such as IEEE 802 and
`
`3GPP, and have directly contributed to the development of several standards
`
`for communications systems. I have chaired a number of standards
`
`committee meetings and served in other leadership roles. In particular, I
`
`have attended meetings of 3GPP, and have prepared documents submitted
`
`to 3GPP.
`
` 5
`
`Exhibit 2011-005
`
`
`
`
`
`13. I have served as an expert in connection with several patent
`
`litigation cases involving various communications technologies. A list of
`
`the litigations in which I have served as an expert appears in my Curriculum
`
`Vitae attached as Appendix 1.
`
`III.
`
`SCOPE AND SUMMARY OF OPINIONS
`14. As explained below, in my opinion the ’236 patent’s claims are
`
`valid. Accordingly, I disagree with Dr. Wells’s opinions and conclusions to
`
`the contrary.
`
`15. In reaching my opinions, I reviewed: 1) the materials identified
`
`in this Declaration, 2) Dr. Wells’s Declaration, including the materials
`
`considered therein. I have also relied on my personal knowledge and
`
`experience in the 3GPP’s standards development process and procedures,
`
`and the ’236 patent’s relevant field of invention.
`
`IV. LEGAL STANDARDS
`16. I am not an attorney and I will offer no opinions on the law. I
`
`am, however, informed by Evolved’s counsel of the legal standards
`
`regarding validity. I have applied these legal standards to the facts,
`
`circumstances, and materials considered, along with my experience, in
`
`arriving at my stated conclusions in this declaration.
`
` 6
`
`Exhibit 2011-006
`
`
`
`
`
`A.
`
`Anticipation
`17. I understand that a prior art reference anticipates a patent claim
`
`only if the reference discloses all elements of the claim arranged as in the
`
`claim. I understand this means that every limitation of a claim must be
`
`disclosed expressly or inherently in a single prior art reference for the
`
`reference to anticipate the claim.
`
`18. I understand that a reference inherently discloses an element if
`
`that element is necessarily present in the disclosure of the reference and
`
`would be so recognized by persons of ordinary skill. I further understand
`
`that the possibility that an element may result from a certain set of
`
`circumstances – that is, an element might be present – is not sufficient to
`
`establish inherency.
`
`19. I further understand that in order for a prior art reference to be
`
`anticipating it must be enabling to one of ordinary skill in the art. That
`
`means that the reference must enable one of ordinary skill in the art to
`
`practice an embodiment of the prior art invention without undue
`
`experimentation.
`
`20. I have been informed that, although anticipation cannot be
`
`established through a combination of references, additional references may
`
` 7
`
`Exhibit 2011-007
`
`
`
`
`
`be used to interpret the allegedly anticipating reference by, for example,
`
`indicating what the allegedly anticipating reference would have meant to
`
`one of ordinary skill in the art. For the claim to be anticipated, however,
`
`these other references must make clear that the missing descriptive matter in
`
`the patent claim is necessarily or implicitly present in the allegedly
`
`anticipating reference, and that it would be so recognized by one of ordinary
`
`skill in the art.
`
`B.
`
`Obviousness
`21. I have been informed that a patent claim is invalid as obvious if,
`
`at the time the invention was made, it would have been obvious to one of
`
`ordinary skill in the art in light of the teachings of the relevant prior art. I
`
`have been informed that the analysis of obviousness involves determining
`
`the scope and content of the prior art, the differences between the prior art
`
`and the claimed invention, the level of ordinary skill in the art at the time of
`
`the invention, and whether the differences are such that the claimed
`
`invention as a whole would have been obvious to one of ordinary skill in the
`
`art at the time the invention was made.
`
`22. I understand that multiple references can be combined with one
`
`another, or with the knowledge of a person of ordinary skill in the art, to
`
` 8
`
`Exhibit 2011-008
`
`
`
`
`
`render a claim obvious. However, obviousness is not established simply
`
`because all of the elements of a patent claim can be found in the prior art. I
`
`understand that it is impermissible to use hindsight reconstruction or the
`
`invention itself as a roadmap to pick and choose among disclosures in the
`
`prior art to reconstruct the claimed invention.
`
`23. I have been informed that, in seeking to determine whether an
`
`invention that is a combination of known elements would have been obvious
`
`to a person of ordinary skill in the art at the time of the invention, one must
`
`consider the references in their entirety to ascertain whether the disclosures
`
`in those references would have rendered the combination obvious to skilled
`
`artisans.
`
`24. In addition, it is my understanding that it will often be necessary
`
`to look to interrelated teachings of multiple references, the effects of
`
`demands known to the design community or present in the marketplace, and
`
`the background knowledge possessed by a person of ordinary skill in the art
`
`in order to determine whether there was an apparent reason to combine the
`
`known elements in the fashion claimed by the patent at issue.
`
`25. I understand that any need or problem known in the field of
`
`endeavor at the time of invention and addressed by the patent can provide a
`
` 9
`
`Exhibit 2011-009
`
`
`
`
`
`reason for combining the elements in the manner claimed. I understand that
`
`when a work is available in one field of endeavor, design incentives and
`
`other market forces can prompt variations of it, either in the same field or a
`
`different one. I understand that the combination of familiar elements
`
`according to known methods may be obvious when it does no more than
`
`yield predictable results. I also understand that a claim is not invalid as
`
`obvious if it is more than the predictable use of prior art elements according
`
`to their established functions.
`
`26. I understand that if a technique has been used to improve one
`
`device, and a person of ordinary skill in the art could recognize that it would
`
`improve similar devices in the same way, application of the technique to
`
`similar devices is likely to be obvious unless its actual application in that
`
`context is beyond his or her skill. I understand that if design needs or market
`
`pressures urge solution to a problem, and there are a finite number of
`
`identified, predictable solutions, then a person of ordinary skill has good
`
`reason to pursue the known options (i.e., obvious to try). I understand that
`
`under these circumstances, the combination of elements of prior art may be
`
`considered a matter of common sense and may demonstrate obviousness.
`
` 10
`
`Exhibit 2011-010
`
`
`
`
`
`27. In addition, I understand that the following rationales are also
`
`acceptable justifications to conclude that a claim would have been obvious:
`
`the claimed invention is a simple substitution of one known element for
`
`another to obtain predictable results; the combinations were within the skill
`
`and understanding of a person of ordinary skill in the art; there is some
`
`teaching, motivation, or suggestion in the prior art references themselves
`
`that would have led one of ordinary skill to modify the prior art reference or
`
`to combine prior art references to arrive at the claimed invention; the
`
`applicant admitted the feature existed in the prior art.
`
`28. I understand that if the prior art teaches away from combining
`
`known elements in the manner claimed by the invention at issue, discovering
`
`a successful way to combine them is less likely to be obvious. I also
`
`understand that similar subject matter may not be sufficient motivation for
`
`a person of skill in the art to combine references if the references have
`
`conflicting elements.
`
`29. I understand that a motivation to conduct further testing or
`
`research that may lead to the claimed invention does not necessarily render
`
`a claim obvious. I further understand that an invention is not necessarily
`
`rendered obvious simply because it was obvious to try a certain combination.
`
` 11
`
`Exhibit 2011-011
`
`
`
`
`
`30. I understand that an improper standard for obviousness is that a
`
`non-obvious invention must produce a "synergistic" result, i.e., the claimed
`
`invention must produce a result that is greater than the sum of its parts.
`
`Another improper standard for obviousness is focusing on each of the
`
`individual features of the invention and not on the invention as a whole.
`
`V.
`
`LEVEL OF ORDINARY SKILL IN THE ART
`31. Dr. Wells opines that a person having ordinary skill in the art
`
`(PHOSITA) of the subject matter of the ‘236 patent would have had a
`
`master’s degree in electrical engineering or bachelor’s degree with at least 2
`
`years of experience and also have had experience with the wireless Standard
`
`Setting Organizations such as ETSI, IEEE, and 3GPP, and would have been
`
`familiar with relevant standards and draft standards directed to wireless
`
`communications. See Wells Declaration at ¶ 39. I do not disagree with Dr.
`
`Wells’s proposed level of ordinary skill in the art. I am familiar with the
`
`knowledge and capabilities of one or ordinary skill in this area based on my
`
`experience working with industry, with undergraduate and graduate
`
`students, with colleagues from academia, and with engineers practicing in
`
`the industry.
`
`
`
` 12
`
`Exhibit 2011-012
`
`
`
`
`
`
`VI. OVERVIEW OF THE TECHNOLOGY
`
`Overview of the LTE Prior Art System
`
`32. The ’236 patent is titled, “Data Transmission Method and User
`
`Equipment for the Same” and generally describes a method “for efficiently
`
`transmitting data stored in a message 3 (Msg3) buffer and a user equipment”
`
`in a mobile communication system such as the Evolved Universal Mobile
`
`Telecommunication System (“E-UMTS”), which is a Long Term Evolution
`
`(“LTE”) system developed and standardized in the 3rd Generation
`
`Partnership Project (“3GPP”). Ex. 1001, Abstract, (54), 1:17–32. In
`
`particular, the ’236 patent describes a random access procedure for a user
`
`equipment (UE) and a base station in such a telecommunication system. Id.
`
`at 3:42–59. Figure 1 of the ’236 patent is reproduced below.
`
`
`
`
`
` 13
`
`Exhibit 2011-013
`
`
`
`
`
`
`
`
`
`Fig. 1, Ex. 1001
`
`
`
`33. Figure 1 is a schematic view of an E-UMTS system with core
`
`network 102 and Evolved UMTS Terrestrial Radio Network (E-UTRAN)
`
`101 including User Equipment (UE) 103, base stations eNode B 104a-n, and
`
`access gateway 105. Ex. 1001, 1:33–37. In lay language, a UE is a “mobile
`
`telephone”, “cell phone”, or another mobile computing device such as tablet
`
`that is capable of using a cellular wireless network. In its “Discussion of the
`
`Related Art,” the ’236 patent describes a random access procedure for a UE
`
` 14
`
`Exhibit 2011-014
`
`
`
`
`
`to gain access to an LTE system, where the UE stores data to be transmitted
`
`in a message 3 (Msg3) buffer and transmits the data “in correspondence
`
`with” receipt from the base station of an uplink (UL) grant signal that
`
`contains information about radio resources. Id. at 3:42–44, 4:18–26.
`
`According to the ’236 patent, the then-current LTE system standard
`
`provided that data stored in the Msg3 buffer of the UE would be transmitted
`
`to the base station “regardless of the reception mode of the UL Grant signal”
`
`and that “if the data stored in the Msg3 buffer is transmitted in
`
`correspondence with the reception of all UL Grant signals, problems may
`
`occur.” Id. at 4:26–32 (emphasis added). The ’236 patent purports to solve
`
`such problems. Id. at 4:33–34. Figure 9 of the ’236 patent is reproduced
`
` 15
`
`
`
`below.
`
`Exhibit 2011-015
`
`
`
`Fig. 9, Ex. 1001
`
`34. eNodeBs use various Radio Network Temporary Identifiers
`
`(RNTI) to identify UEs. The C-RNTI provides a unique UE identification at
`
`the cell level. The eNode B uses C-RNTI to provide a UE with uplink grants,
`
` 16
`
`
`
`
`
`
`
`Exhibit 2011-016
`
`
`
`
`
`for example. The eNode B also uses the C-RNTI to differentiate uplink
`
`transmissions from the different UEs.
`
`A.
`
`Acquiring Radio Resources—UL Grants
`35. The ‘236 patent is directed to helping a UE acquire radio
`
`resources with which to communicate with the eNode B. Initially, for
`
`example just after a UE is powered up, a UE does not have any allocated
`
`radio resources with which to transmit, i.e. it must be “scheduled” in order
`
`to transmit. More specifically, these radio resources include the time
`
`intervals and frequencies at which the UE may transmit to the eNode B. The
`
`scheduler in the base station distributes the radio resources among the UEs
`
`in the cell. The scheduler takes into account the received UEs Scheduling
`
`Requests and Buffer Status Reports, as well as the estimated channel
`
`conditions.
`
`36. There are two ways in the prior art that the UE properly receives
`
`radio resource allocation from the base station. Both involve receiving
`
`Uplink Grants (UL Grant).
`
`37. If the UE has a C-RNTI then it can send a scheduling request
`
`(SR) to the base station and receive UL grants through a channel called
`
`“PDCCH” (the Physical Downlink Control Channel).
`
` 17
`
`Exhibit 2011-017
`
`
`
`
`
`38. Another way for the UE to receive an UL is to complete the
`
`random access procedure.
`
`39. A UE may request uplink resources by sending a Buffer Status
`
`Report (BSR). BSRs refer to the data that is buffered in the logical channel
`
`queues in the UE MAC, and inform the base station how much data must be
`
`uploaded.
`
`40. In LTE, data is classified into four groups, called radio bearer
`
`groups (RBG). Each RBG has data at the same priority level. The UE reports
`
`BSR per group. BSRs are triggered when (i) there is new data in a previously
`
`empty buffer; (ii) the UE has already sent a BSR and is waiting for a grant,
`
`but then higher-priority data arrives, triggering a new BSR. The higher-
`
`priority data can belong to the same RBG; (iii) BSRs can be sent periodically
`
`when a timer expires; (iv) BSRs can also be sent whenever spare space in a
`
`MAC PDU can accommodate a BSR.
`
`41. It is not strictly required that an SR or BSR report precedes the
`
`grant. When the base station believes that a mobile needs an opportunity to
`
`send data it can provide a grant to the mobile without waiting for an SR.
`
`This has the benefit of speeding up scheduling.
`
` 18
`
`Exhibit 2011-018
`
`
`
`
`
`B.
`
`HARQ
`42. The multiplexing/demultiplexing entity at the transmitter can
`
`multiplex data from several logical channels into one transport channel and
`
`generates MAC PDUs from MAC SDUs. The prioritization entity
`
`determines how much data and from which logical channels should be
`
`included in each MAC PDU.
`
`43. At
`
`the
`
`receiver,
`
`the multiplexing/demultiplexing entity
`
`demultiplexes the data from one transport channel into one or more logical
`
`channels and reassembles the SDUs from the PDUs.
`
`44. A MAC PDU consists of a MAC header, zero or more MAC
`
`Service Data Units (MAC SDU), zero, or more MAC control elements, and
`
`optionally padding. The header and the SDUs are of variable sizes. The C-
`
`RNTI is a 16-bit MAC control element that can be used as an identifier.
`
`45. LTE handles packet errors using two different types of
`
`retransmission protocols, namely ARQ (Automatic Repeat Request) and
`
`HARQ (Hybrid Automatic Repeat Request).
`
`46. The LTE HARQ protocol is a combination of FEC and ARQ.
`
`HARQ is based on ACK/NACKs and features soft combining based on
`
`Incremental Redundancy. When the receiver detects erroneous data, it sends
`
` 19
`
`Exhibit 2011-019
`
`
`
`
`
`a NACK, but doesn't discard the data. The sender will retransmit the same
`
`data again but this time, with different set of coded bits. The receiver will
`
`combine the previously received erroneous data with newly received data.
`
`This will repeat as long as the receiver is not able to decode the entire data.
`
`The advantage of this method is that with each re-transmission, the coding
`
`rate is lowered and the chances of successfully decoding the data improve.
`
`This is advantageous compared to using the same coding rate in every re-
`
`transmission. In this sense HARQ operates at the PHY layer, but requires
`
`control from the MAC layer. In this sense its operation straddles these two
`
`layers.
`
`47. If a packet transmission is not successful after HARQ, it will be
`
`retransmitted according to the ARQ. ARQ handles retransmissions in
`
`acknowledged mode at Layer 2. More specifically, ARQ is performed by
`
`the RLC (Radio Link Control) layer. HARQ can operate without ARQ.
`
`48. There are multiple HARQ processes, each associated with a
`
`separate HARQ buffer. HARQ is Stop-and-Wait (SAW) in the sense that
`
`once a packet is sent, it waits for ACK/NACK. Since there are multiple
`
`HARQ processes, when one process is waiting for ACK/NACK, the other
`
`processes continue. Up to eight HARQ Stop-and-Wait processes can be used
`
` 20
`
`Exhibit 2011-020
`
`
`
`
`
`in parallel to speed-up transmission. This means that one process should wait
`
`8 ms before transmitting or retransmitting again.
`
`49. In asynchronous HARQ retransmissions can take place at any
`
`time relative
`
`to
`
`the
`
`initial
`
`transmission. In synchronous HARQ
`
`retransmissions occur at fixed times relative to the first transmission and the
`
`process number can be inferred.
`
`50. HARQ can be Adaptive and Non-Adaptive HARQ. If adaptive,
`
`then each retransmission uses different modulation and coding scheme in
`
`response to changing channel conditions.
`
`51. The operation of HARQ in the downlink and uplink is different.
`
`In LTE asynchronous adaptive HARQ is used for the downlink, and
`
`synchronous adaptive or non-adaptive HARQ in the uplink.
`
`52. The UE monitors the PDCCH at each TTI, and checks the
`
`downlink scheduling information that is received. If there is any scheduling
`
`information pertaining to the UE, data is received through the PDSCH.
`
`53. To indicate whether the transmitted data is an initial transmission
`
`or a retransmission there is a NDI (New Data Indicator). The NDI field is a
`
`one bit field that is toggled (0→1→0→1 . . .) whenever new data is
`
` 21
`
`Exhibit 2011-021
`
`
`
`
`
`transmitted, while retransmissions are indicated by the NDI field being the
`
`same as that of a previous transmission.
`
`54. In the uplink direction HARQ is synchronous. Retransmissions
`
`do not require grants transmitted on PDCCH. This reduces any waste of
`
`radio resources that would be needed if scheduling information is
`
`transmitted using the PDCCH, and eliminates problems where the UE
`
`cannot perform a retransmission because the PDCCH was not properly
`
`received.
`
`55. Retransmissions can be performed up to a maximum number. A
`
`maximum number of retransmissions is provided in order to minimize the
`
`delay that would occur if retransmission attempts were unlimited.
`
`56. The Physical HARQ Indicator Channel (PHICH) carries
`
`ACK/NACKs used in response to uplink transmissions. When a PDCCH for
`
`the UE’s C-RNTI is correctly received, the UE follows what the PDCCH
`
`asks the UE to do, i.e. perform a transmission or adaptive retransmission,
`
`regardless whether PHICH carries ACK or NACK.
`
`C.
`
`Contention-based Random Access Procedures
`57. In the LTE system, the random access (RA) procedures can be
`
`contention-based or contention-free. This division depends upon whether
`
` 22
`
`Exhibit 2011-022
`
`
`
`the random access preamble used during the random access procedure is
`
`selected by the UE itself or selected by the base station.
`
`58. The contention-based RA procedure is a four-phase procedure,
`
`both in the prior art and in the ‘236 patent invention, as illustrated below in
`
`Fig. 5 from the ‘236 patent (in this figure, “eNB” means “eNode B”, or base
`
`station):
`
`Fig. 5, Ex. 1001
`
` 23
`
`
`
`
`
`
`
`
`
`Exhibit 2011-023
`
`
`
`
`
`D.
`
`The four phases of the Random Access Procedure
`59. Next, I describe the four phases of the RA procedure, as
`
`understood in the prior art.
`
`Phase 1 – Random Access preamble
`1.
`60. In phase 1, the UE transmits a random access preamble (Msg1).
`
`The preamble transmission carries no data bits. The identity of the UE that
`
`sent
`
`the preamble
`
`is called RA-RNTI
`
`(Random access
`
`radio
`
`network temporary identity). The RA-RNTI is implicitly specified by
`
`the time-frequency resource used to send the preamble. Problematically,
`
`multiple UEs may transmit a RA preamble using the same time-frequency
`
`resource, meaning that they will have the same RA-RNTI.
`
`61. Contention is avoided if UEs that have the same RA-RNTI
`
`choose different preamble sequences.
`
`62. It is possible, however, that there is contention, i.e. two or more
`
`UEs with the same RA-RNTI choose identical preamble sequences. This
`
`may or may not mean unsuccessful preamble transmission by any of the
`
`colliding UEs. The devices will not know that a collision occurred until the
`
`fourth phase of the RA procedure (when a Contention Resolution (CR)
`
`message is transmitted. I discuss this below.)
`
` 24
`
`Exhibit 2011-024
`
`
`
`
`
`
`
`63. Preamble transmission may fail due to several reasons. Even in
`
`the absence of contention, preamble transmission may fail due to, for
`
`example, the power with which the preamble is transmitted being low.
`
`Phase 2 – Random Access Response (RAR)
`2.
`64. The RAR (i.e. RACH MSG 2, or “message 2”) is transmitted via
`
`a PDSCH (Physical Downlink Shared Channel). Note that this channel is
`
`different from the PDCCH channel on which UL grants are transmitted to
`
`UEs that have C-RNTIs. (It is true, though, that control information is also
`
`transferred to the UE through the PDCCH as part of the phase. This PDCCH
`
`information includes information that the UE that needs to receive the
`
`PDSCH.)
`
`65. The content of message 2 is: (1) Random access preamble
`
`identifier; (2) Timing adjustment information; (3) UL grant for the
`
`transmission of msg3; and (4) Temporary C-RNTI.
`
`Phase 3 – msg3
`3.
`66. The UE transmits what is called msg3 (or “message 3”) to the
`
`network using the UL grant. In the transmission the UE applies the Time
`
` 25
`
`Exhibit 2011-025
`
`
`
`
`
`Alignment Command, and applies the temporary C-RNTI received in the
`
`RAR.
`
`67. The primary function of msg3 is to uniquely identify the UE. The
`
`reason an identifier is needed is that the temporary C-RNTI may have been
`
`assigned to more than one UEs in the RAR, due to multiple requests coming
`
`at same time. In addition to the identifier, Msg3 can include a BSR.
`
`68. The transmission of msg3 uses HARQ. The base station will send
`
`ACK or NACK using PHICH and msg3 may be retransmitted. These
`
`retransmissions are repeated until the maximum number of transmissions of
`
`msg3 is reached or until an ACK is received.
`
`69. When msg3 is transmitted, the UE starts a Contention Resolution
`
`timer. Furthermore, every time msg3 is retransmitted the Contention
`
`Resolution Timer will be re-started.
`
`Phase 4—Contention Resolution, msg4
`4.
`70. In this phase, the base station will send an UL Grant to the UE.
`
`The UL Grant will be in the PDCCH, not in the random access response.
`
`The main purpose of msg4 (or “message 4”) is contention resolution. In the
`
`fourth phase, the eNode B echoes the identity provided by the UE in Phase
`
`3. Only the UE that finds a match between the identity received in the fourth
`
` 26
`
`Exhibit 2011-026
`
`
`
`
`
`step and the identity transmitted as part of the third step can declare the
`
`random access procedure successful, if msg4 is received before expiration
`
`of the contention resolution timer. After step 4, the successful UE can
`
`proceed with, for example, a SR and the transmission of new data.
`
`71. UEs that do not find a match between the identity received in
`
`Phase 4 and the identity transmitted as part of Phase 3 consider themselves
`
`to have failed the random access procedure and need to restart the random
`
`access procedure with Phase 1.
`
`72. If the Random Access is not successful, a UE usually has to wait
`
`certain amount of time before starting another random access attempt, which
`
`significantly increases the latency. For example, assuming the backoff
`
`window size is 50, the average backoff time would be 25ms before starting
`
`the next random access. Therefore, if the random access procedure is not
`
`successful, the latency may become too high.
`
`73. The random access process may fail because of multiple reasons.
`
`Like all wireless transmissions, any one of the messages may fail due to
`
`inadequate coverage or high interference level.
`
`74. Another problem with the basic random access procedure is that,
`
`in a case of many simultaneous random access attempts made by different
`
` 27
`
`Exhibit 2011-027
`
`
`
`
`
`UEs, the collision probability will increase. In this condition, the base station
`
`is unable to uniquely identify the various UEs.
`
`75. In general, neither the network nor any of the UEs can detect a
`
`collision during message 1. This state of confusion will remain for a certain
`
`period of time. The UEs participating in a collision may detect the collision
`
`only after their contention resolution timer expires without receiving
`
`message 4 successfully.
`
`76. In the prior art, including all prior art references identified by
`
`Petitioner, independently scheduled transmissions can interfere with the
`
`random access procedure prior to the successful completion of the fourth
`
`step. The prior art relied upon by Petitioner, however, did not recognize
`
`these problems. I discuss this below with respect to the Kitazoe reference.
`
`VII. OVERVIEW OF THE ‘236 PATENT
`77. The application that was granted as ‘236 patent was filed on Aug.
`
`10, 2009 and claims priority to U.S. Provisional Application No 61/087,988
`
`filed on Aug. 11, 2008.
`
`78. The ‘236 patent relates to the contention-based random access
`
`procedure. For example, the ‘236 recognizes that UEs need to send BSRs,
`
` 28
`
`Exhibit 2011-028
`
`
`
`
`
`
`
`and that if there are not sufficient radio resources for the sending these BSRs
`
`then the random access procedure can be used:
`
`[H]ereinafter, as described above, the request for the transmission of
`the BSR is represented by triggering of the BSR transmission (S6100).
`If the BSR transmission is triggered, the UE should transmit the BSR
`to the eNode B. However, if the radio resources for transmitting the
`BSR are not present, the UE may trigger a random access procedure
`and attempt to request radio resources (S6200).
`
`’236 patent at 11:41-47.
`
`79. The ‘236 patent also relates to the scheduling procedure, where
`
`a
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