`
`
`Seung Hee Han, et al.
`In re Patent of:
`7,746,916 Attorney Docket No.: 00035-0006IP1
`U.S. Patent No.:
`June 29, 2010
`
`Issue Date:
`Appl. Serial No.: 11/563,909
`
`Filing Date:
`November 28, 2006
`
`Title:
`Method and Apparatus for Generating and Transmitting
`Code Sequence in a Wireless Communication System
`
`
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`
`
`
`
`1
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`DECLARATION OF JONATHAN WELLS, PH.D.
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`ZTE/SAMSUNG/HTC 1003-0001
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`I.
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`II.
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`Table of Contents
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`Introduction ...................................................................................................... 9
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`Qualifications ................................................................................................... 9
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`III. Materials Considered ..................................................................................... 12
`
`IV. Applicable Legal Standards ........................................................................... 14
`
` My Understanding of Anticipation ..................................................... 14
`
` My Understanding of Obviousness ..................................................... 14
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` My Understanding of Claim Construction .......................................... 19
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`V.
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`Level of Ordinary Skill in the Art ................................................................. 19
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`VI. Overview of the Technology ......................................................................... 20
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`
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`Random Access Overview .................................................................. 20
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`1.
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`Introduction ............................................................................... 20
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`2. When is Random Access Used? ............................................... 24
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`3.
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`4.
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`Types of Random Access Procedures ....................................... 24
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`The Random Access Preamble ................................................. 25
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`
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`Preamble Code Sequences .................................................................. 27
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`1.
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`2.
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`Hadamard Code Sequences ....................................................... 29
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`CAZAC Sequences ................................................................... 30
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`Zadoff–Chu Sequences ................................................... 31
`a)
`GCL Sequences .............................................................. 32
`b)
`3. Manipulation of Code Sequences ............................................. 32
`
`VII. Brief Overview of the ’916 Patent ................................................................. 35
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`2
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`ZTE/SAMSUNG/HTC 1003-0002
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`VIII. Claim Construction ........................................................................................ 40
`
` Acquiring/generating a code sequence having a second length by a
`cyclic extension of a code sequence having a first length (Claims 1
`and 6) ................................................................................................... 41
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`“cyclic prefix” (Claims 2 and 7) ......................................................... 42
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`"cyclic postfix" (Claims 2, 3 and 7) .................................................... 45
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`"reference signal sequence" (Claims 5 and 10) ................................... 47
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`“a code sequence generator” (claim 6) ................................................ 47
`
`IX. Application of Zhuang327 to the Challenged Claims of the ’916 Patent ..... 49
`
` Overview of Zhuang327 ...................................................................... 49
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`1.
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`2.
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`3.
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`4.
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`5.
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`6.
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`Generating Access Sequence 120 based on GCL Sequence 110
` ................................................................................................... 51
`
`Generating Access Signal 130 based on Access Sequence 120
` ................................................................................................... 52
`
`Generating Circularly-Shifted Access Signal 140 by circularly
`shifting Access Signal 130 ........................................................ 52
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`Generating Access Waveform 150 based on Access Signal 140
` ................................................................................................... 52
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`Transmitting Access Waveform 150 ........................................ 53
`
`Summary ................................................................................... 53
`
`
`
`
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`A method/apparatus for transmitting a code sequence [from a
`transmitting party to a receiving party] in a wireless communication
`system (claims 1 and 6) ....................................................................... 54
`
`Acquiring/generating a code sequence having a second length by a
`cyclic extension of a code sequence having a first length (Claims 1
`and 6) ................................................................................................... 54
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`3
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`ZTE/SAMSUNG/HTC 1003-0003
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`Performing a circular shift to the code sequence having the second
`length (claims 1 and 6) ........................................................................ 63
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`Transmitting the circular shifted code sequence having the second
`length to the receiving party (claims 1 and 6) ..................................... 63
`
` Wherein the first length is a largest prime number smaller than the
`second length (claims 1 and 6) ............................................................ 64
`
` Wherein the cyclic extension of the code sequence having the first
`length is performed such that a part of the code sequence having the
`first length, having a length corresponding to a difference between the
`first length and the second length, is added to either a start or an end
`of the code sequence having the first length (claims 1 and 6) ............ 64
`
` Wherein the circular shift is performed to the code sequence having
`the second length such that either a rear portion of the code sequence
`having the second length moves to a start of the code sequence having
`the second length, or a front portion of the code sequence having the
`second length moves to an end of the code sequence having the
`second length (claims 1 and 6) ............................................................ 65
`
`
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`
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`The part of the code sequence having the first length comprises at
`least a cyclic prefix or a cyclic postfix (claims 2 and 7) ..................... 69
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`The cyclic extension is performed such that a cyclic postfix of the
`code sequence having the first length, having the length corresponding
`to the difference between the first length and the second length, is
`added to the end of the code sequence having the first length (claims 3
`and 8) ................................................................................................... 69
`
`The code sequence having the second length is transmitted as a
`reference signal sequence (claims 5 and 10) ....................................... 70
`
`A code sequence generator for generating a code sequence having a
`second length by cyclic extension of a code sequence having a first
`length, and performing a circular shift to the code sequence having the
`second length (claim 6) ....................................................................... 71
`
` A transmitting unit for transmitting the circular shifted code sequence
`having the second length (claim 6) ..................................................... 85
`4
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`ZTE/SAMSUNG/HTC 1003-0004
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`X. Application of Zhuang327 and Popovic to the Challenged Claims of the ’916
`Patent ............................................................................................................. 86
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`
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`Zadoff-Chu (ZC) sequence (claims 4 and 9) ....................................... 86
`
`XI. Application of Zhuang327 and Hou to the Challenged Claims of the ’916
`Patent ............................................................................................................. 92
`
` A method/apparatus for transmitting a code sequence [from a
`transmitting party to a receiving party] in a wireless communication
`system (claims 1 and 6) ....................................................................... 97
`
`
`
`
`
`
`
`Acquiring/generating a code sequence having a second length by a
`cyclic extension of a code sequence having a first length (claims 1 and
`6) .......................................................................................................... 98
`
`Performing a circular shift to the code sequence having the second
`length (claims 1 and 6) ......................................................................101
`
`Transmitting the circular shifted code sequence having the second
`length to the receiving party (claims 1 and 6) ...................................108
`
` Wherein the first length is a largest prime number smaller than the
`second length (claims 1 and 6) ..........................................................109
`
` Wherein the cyclic extension of the code sequence having the first
`length is performed such that a part of the code sequence having the
`first length, having a length corresponding to a difference between the
`first length and the second length, is added to either a start or an end
`of the code sequence having the first length (claims 1 and 6) ..........109
`
` Wherein the circular shift is performed to the code sequence having
`the second length such that either a rear portion of the code sequence
`having the second length moves to a start of the code sequence having
`the second length, or a front portion of the code sequence having the
`second length moves to an end of the code sequence having the
`second length (claims 1 and 6) ..........................................................110
`
` A code sequence generator for generating a code sequence having a
`second length by cyclic extension of a code sequence having a first
`
`
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`5
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`ZTE/SAMSUNG/HTC 1003-0005
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`length, and performing a circular shift to the code sequence having the
`second length (claim 6) .....................................................................111
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`
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`
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`A transmitting unit for transmitting the circular shifted code sequence
`having the second length (claim 6) ...................................................116
`
`Application of Zhuang327 and Hou to dependent claims 2-5 and 7-10
` ...........................................................................................................117
`
`XII. Application of Zhuang327, Hou and Popovic to the Challenged Claims of
`the ’916 Patent .............................................................................................117
`
`XIII. Application of Zhuang175 to the Challenged Claims of the ’916 Patent ...118
`
` Overview of Zhuang175 ....................................................................118
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`
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`
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`A method/apparatus for transmitting a code sequence [from a
`transmitting party to a receiving party] in a wireless communication
`system (claims 1 and 6) .....................................................................124
`
`Acquiring/generating a code sequence having a second length by a
`cyclic extension of a code sequence having a first length (Claims 1
`and 6) .................................................................................................126
`
`Performing a circular shift to the code sequence having the second
`length (claims 1 and 6) ......................................................................127
`
`Transmitting the circular shifted code sequence having the second
`length to the receiving party (claims 1 and 6) ...................................129
`
` Wherein the first length is a largest prime number smaller than the
`second length (claims 1 and 6) ..........................................................130
`
` Wherein the cyclic extension of the code sequence having the first
`length is performed such that a part of the code sequence having the
`first length, having a length corresponding to a difference between the
`first length and the second length, is added to either a start or an end
`of the code sequence having the first length (claims 1 and 6) ..........130
`
` Wherein the circular shift is performed to the code sequence having
`the second length such that either a rear portion of the code sequence
`
`
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`6
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`ZTE/SAMSUNG/HTC 1003-0006
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`having the second length moves to a start of the code sequence having
`the second length, or a front portion of the code sequence having the
`second length moves to an end of the code sequence having the
`second length (claims 1 and 6) ..........................................................131
`
`The part of the code sequence having the first length comprises at
`least a cyclic prefix or a cyclic postfix (claims 2 and 7) ...................133
`
`The cyclic extension is performed such that a cyclic postfix of the
`code sequence having the first length, having the length corresponding
`to the difference between the first length and the second length, is
`added to the end of the code sequence having the first length (claims 3
`and 8) .................................................................................................134
`
`The code sequence having the second length is transmitted as a
`reference signal sequence (claims 5 and 10) .....................................135
`
`A code sequence generator for generating a code sequence having a
`second length by cyclic extension of a code sequence having a first
`length, and performing a circular shift to the code sequence having the
`second length (claim 6) .....................................................................136
`
`
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` A transmitting unit for transmitting the circular shifted code sequence
`having the second length (claim 6) ...................................................144
`
`XIV. Application of Zhuang175 and Popovic to the Challenged Claims of the ’916
`Patent ...........................................................................................................145
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`
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`Zadoff-Chu (ZC) sequence (claims 4 and 9) .....................................146
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`XV. Application of Zhuang175 and Hou to the Challenged Claims of the ’916
`Patent ...........................................................................................................151
`
`
`
`Performing a circular shift to the code sequence having the second
`length (claims 1 and 6) ......................................................................157
`
` Wherein the circular shift is performed to the code sequence having
`the second length such that either a rear portion of the code sequence
`having the second length moves to a start of the code sequence having
`the second length, or a front portion of the code sequence having the
`
`
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`7
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`ZTE/SAMSUNG/HTC 1003-0007
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`second length moves to an end of the code sequence having the
`second length (claims 1 and 6) ..........................................................162
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`
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`Application of Zhuang175 and Hou to other claim elements of
`independent claims 1 and 6, and dependent claims 2-5 and 7-10 .....165
`
`XVI. Application of Zhuang175, Hou and Popovic to the Challenged Claims of
`the ’916 Patent .............................................................................................165
`
`XVII. Application of Zhuang175 and Fukuta to the Challenged Claims of the ’916
`Patent ...........................................................................................................167
`
` A code sequence generator for generating a code sequence having a
`second length by cyclic extension of a code sequence having a first
`length, and performing a circular shift to the code sequence having the
`second length (claim 6) .....................................................................170
`
` Wherein the circular shift is performed to the code sequence having
`the second length such that either a rear portion of the code sequence
`having the second length moves to a start of the code sequence having
`the second length, or a front portion of the code sequence having the
`second length moves to an end of the code sequence having the
`second length (claims 1 and 6) ..........................................................179
`
`
`
`The code sequence having the second length is transmitted as a
`reference signal sequence (claims 5 and 10) .....................................183
`
`Application of Zhuang175, Fukuta and Popovic to the Challenged
`XVIII.
`Claims of the ’916 Patent ............................................................................183
`
`XIX. Conclusions ..................................................................................................185
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`8
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`ZTE/SAMSUNG/HTC 1003-0008
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`I.
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`
`
`Introduction
`
`I, Dr. Jonathan Wells, declare as follows:
`
`1.
`
`I have been retained on behalf of Petitioner, Apple Inc., Microsoft Cor-
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`poration, Microsoft Mobile Oy, and Microsoft Mobile Inc. (f/k/a Nokia Inc.) to pro-
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`vide expert opinions in connection with this inter partes review. Specifically, I have
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`been asked to provide my opinion relating to an inquiry into the patentability of
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`claims of the U.S. Patent No. 7,746,916 (the “’916 patent”).
`
`II. Qualifications
`2.
`I have over 25 years of academic and industry experience in wireless
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`networks (e.g., 2G, 3G and 4G networks, comprising GSM, EDGE, WCDMA,
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`HSDPA and LTE technologies), cellular infrastructure equipment (base stations,
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`backhaul and handsets), and wireless standards, rules and regulations (e.g., 3GPP,
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`FCC, ETSI and CEPT). Over my career, I have worked with companies to develop
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`and deploy radio frequency (RF) hardware for telecommunication infrastructure
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`equipment for worldwide export, to implement marketing and product development
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`strategies for cellular wireless products, and to participate in Federal Communica-
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`tions Commission (“FCC”), European Conference of Postal and Telecommunica-
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`tions Administrations (“CEPT”), European Telecommunications Standards Institute
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`(“ETSI”) and other technical body meetings.
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`9
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`ZTE/SAMSUNG/HTC 1003-0009
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`3.
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`In 1987, I received my Bachelor of Science degree in Physics with
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`Physical Electronics (with 1st Class Honours) from the University of Bath, Bath,
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`United Kingdom. In 1991, I received the Doctor of Philosophy (Ph.D.) degree in
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`Physics from the University of Bath. In 1998, I received a Master of Business Ad-
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`ministration (with distinction) from Massey University, New Zealand.
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`4.
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`After completing my Ph.D., I began working at the University of Bath
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`as a Postdoctoral Research Officer. I continued to work at the University of Bath
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`until 1992. During this time, I fabricated novel electronic devices, and developed
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`software models to predict their performance in wireless communication systems.
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`5.
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` For more than 20 years I worked in private industry designing, devel-
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`oping and implementing various wireless communication products throughout the
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`world.
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`6.
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`Specifically, from 1993 to 1994, I was a Senior Design Engineer at
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`Matra Marconi Space, where I developed space-qualified electronic components and
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`sub-systems for two satellite systems.
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`7.
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`From 1994 to 1995, I was a Senior RF Design Engineer, and from 1995-
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`1998, I was RF Group Manager, at MAS Technology (now Aviat Networks), where
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`I, among other things, led the development of three families of innovative wireless
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`products, oversaw the company’s European regulatory approvals, and personally de-
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`signed a wide range of RF devices.
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`10
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`ZTE/SAMSUNG/HTC 1003-0010
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`8.
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`From 1998 to 1999, I was an Engineering Group Leader, and from
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`1999-2000 I was the Director of Wideband Products, at Adaptive Broadband (now
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`GE Digital Energy), where I oversaw the Terrestrial Infrastructure Group, and led
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`the development of a family of digital radio products.
`
`9.
`
`From 2000 to 2004, I was the Director of Product Development at Stra-
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`tex Networks (now Aviat Networks), where I was responsible for the global product
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`development of the company’s Outdoor Unit (ODU) portfolio of high-end digital
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`microwave radios, which were primarily directed towards cellular applications.
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`10. From 2005 to 2007, I was the Director of Product Management and
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`Global Regulatory Affairs at GigaBeam Corporation, where I developed the overall
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`product strategy for a novel wideband communication system for future cellular ap-
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`plications. During this time I had responsibility for establishing a global regulatory
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`framework for this new product, which included developing FCC (Federal Commu-
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`nications Commission) and ETSI (European Telecommunications Standards Insti-
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`tute) standards to cover the specification and regulation of the system.
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`11. Since 2007, I have been the Managing Partner of AJIS Consulting––an
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`independent consulting firm specializing in wireless communications and emerging
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`wireless fields. Specifically, I analyze cellular and wireless technologies, as well as
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`conduct technical workshops on various wireless technologies; including cellular
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`networks, mm-wave radios, security sensors and short range radios.
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`11
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`ZTE/SAMSUNG/HTC 1003-0011
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`12.
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`I have given guest lectures on various aspects of technology at UC
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`Berkeley and Carnegie Mellon University. I have authored or co-authored more than
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`40 scientific and industry publications relating to wireless networks, cellular infra-
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`structure equipment, and wireless standards, rules and regulations. I also published
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`a book titled “Multi-Gigabit Microwave and Millimeter-Wave Wireless Communi-
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`cations” in 2010. I have presented numerous tutorials, workshops, and lectures to
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`industry and academic audiences on these topics. I am listed as the lead inventor on
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`multiple patents that relate to these topics as well. I was elected a Senior Member of
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`the Institute of Electrical and Electronic Engineers (IEEE) in 1999.
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`13. My Curriculum Vitae is attached as Exhibit 1004, which contains fur-
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`ther details on my education, experience, publications, and other qualifications to
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`render an expert option. My work on this case is being billed at an hourly rate, with
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`reimbursement for actual expenses. My compensation is not contingent upon the
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`outcome of this inter partes review.
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`III. Materials Considered
`14.
`In forming my opinions expressed in this declaration, I have considered
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`and relied upon my education, background, and experience. I reviewed U.S. Patent
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`No. 7,746,916 (the “’916 patent”, Exhibit 1001) and its patent file history (Exhibit
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`1002).
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`12
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`ZTE/SAMSUNG/HTC 1003-0012
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`15. Additionally, I have reviewed and relied upon the following list of ma-
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`terials in preparation of this declaration:
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`U.S. Patent No. US 8,340,232 to Ding et al. (“Ding,” Exhibit 1006);
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`U.S. Patent No. US 7,599,327 to Zhuang et al. (“Zhuang327,” Exhibit
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`1007);
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`
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`B.M. Popovic, “Generalized chirp-like polyphase sequences with optimum
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`correlation properties”, IEEE Trans. On Information Theory, vol. 38, pp. 1406-
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`1409, July 1992 (“Popovic,” Exhibit 1009);
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`
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`U.S. Patent No. 8,116,195 to Hou et al. (“Hou,” Exhibit 1011);
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`U.S. Patent No. 7,426,175 to Zhuang et al. (“Zhuang175,” Exhibit 1012);
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`U.S. Patent Application Publication No. 2007/0270273 to Fukuta et al.
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`(“Fukuta,” Exhibit 1013);
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`U.S. Patent No. US 7,400,573 to Sundstrom et al. (“Sundstrom,” Exhibit
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`1027);
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`U.S. Patent No. US 7,701,919 to Ah Lee (“Ah Lee,” Exhibit 1029);
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`U.S. Patent No. US 7,693,924 Cho et al. (“Cho,” Exhibit 1030);
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`Motorola, Inc. 2004 Annual Report (Exhibit 1031); and
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` WCDMA for UMTS: Radio Access for Third Generation Communica-
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`tions, Holma and Toskala, 3rd ed, Wiley and Sons, Ltd., 2004 (Exhibit 1032).
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`16.
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`I have also considered all other materials cited herein.
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`13
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`ZTE/SAMSUNG/HTC 1003-0013
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`IV. Applicable Legal Standards
` My Understanding of Anticipation
`A1. I understand that documents and materials that qualify as prior art can
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`be used to invalidate a patent claim as anticipated or as obvious.
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`A2. I understand that, once the claims of a patent have been properly con-
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`strued, the second step in determining anticipation of a patent claim requires a com-
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`parison of the properly construed claim language to the prior art on a limitation-by-
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`limitation basis.
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`A3. I understand that a prior art reference “anticipates” an asserted claim,
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`and thus renders the claim invalid, if all elements of the claim are disclosed in that
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`prior art reference, either explicitly or inherently (i.e., necessarily present).
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`A4. I understand that anticipation in an inter partes review must be shown
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`by a preponderance of the evidence.
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` My Understanding of Obviousness
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`17.
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`I understand that a patent claim is invalid if the claimed invention
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`would have been obvious to a person of ordinary skill in the field at the time of the
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`claimed invention. This means that even if all of the requirements of the claim cannot
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`be found in a single prior art reference that would anticipate the claim, the claim can
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`still be invalid.
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`14
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`ZTE/SAMSUNG/HTC 1003-0014
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`18. As part of this inquiry, I have been asked to consider the level of ordi-
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`nary skill in the field that someone would have had at the time the claimed invention
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`was made. In deciding the level of ordinary skill, I considered the following:
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`the levels of education and experience of persons working in the field;
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`the types of problems encountered in the field; and
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`the sophistication of the technology.
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`19. To obtain a patent, a claimed invention must have, as of the priority
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`date, been nonobvious in view of the prior art in the field. I understand that an in-
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`vention is obvious when the differences between the subject matter sought to be
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`patented and the prior art are such that the subject matter as a whole would have
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`been obvious at the time of the invention to a person having ordinary skill in the art.
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`20.
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`I understand that a person of ordinary skill in the art provides a refer-
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`ence point from which the prior art and claimed invention should be viewed. This
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`reference point prevents one from using his or her own insight or hindsight in decid-
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`ing whether a claim is obvious.
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`21.
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`I also understand that an obviousness determination includes the con-
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`sideration of various factors such as (1) the scope and content of the prior art, (2) the
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`differences between the prior art and the asserted claims, (3) the level of ordinary
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`skill in the pertinent art, and (4) the existence of secondary considerations such as
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`commercial success, long-felt but unresolved needs, failure of others, etc.
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`15
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`ZTE/SAMSUNG/HTC 1003-0015
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`22.
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`I understand that an obviousness evaluation can be based on a combi-
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`nation of multiple prior art references. I understand that the prior art references
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`themselves may provide a suggestion, motivation, or reason to combine, but other
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`times the nexus linking two or more prior art references is simple common sense. I
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`further understand that obviousness analysis recognizes that market demand, rather
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`than scientific literature, often drives innovation, and that a motivation to combine
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`references may be supplied by the direction of the marketplace.
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`23.
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`I understand that if a technique has been used to improve one device,
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`and a person of ordinary skill in the art would recognize that it would improve sim-
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`ilar devices in the same way, using the technique is obvious unless its actual appli-
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`cation is beyond his or her skill.
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`24.
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`I also understand that practical and common sense considerations
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`should guide a proper obviousness analysis, because familiar items may have obvi-
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`ous uses beyond their primary purposes. I further understand that a person of ordi-
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`nary skill in the art looking to overcome a problem will often be able to fit together
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`the teachings of multiple publications. I understand that obviousness analysis there-
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`fore takes into account the inferences and creative steps that a person of ordinary
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`skill in the art would employ under the circumstances.
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`25.
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`I understand that a particular combination may be proven obvious
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`merely by showing that it was obvious to try the combination. For example, when
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`16
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`ZTE/SAMSUNG/HTC 1003-0016
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`there is a design need or market pressure to solve a problem and there are a finite
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`number of identified, predictable solutions, a person of ordinary skill has good rea-
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`sons to pursue the known options within his or her technical grasp because the result
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`is likely the product not of innovation but of ordinary skill and common sense.
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`26. The combination of familiar elements according to known methods is
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`likely to be obvious when it does no more than yield predictable results. When a
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`work is available in one field of endeavor, design incentives and other market forces
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`can prompt variations of it, either in the same field or a different one. If a person of
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`ordinary skill can implement a predictable variation, the patent claim is likely obvi-
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`ous.
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`27.
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`It is further my understanding that a proper obviousness analysis fo-
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`cuses on what was known or obvious to a person of ordinary skill in the art, not just
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`the patentee. Accordingly, I understand that any need or problem known in the field
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`of endeavor at the time of invention and addressed by the patent can provide a reason
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`for combining the elements in the manner claimed.
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`28.
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`I understand that a claim can be obvious in light of a single reference,
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`without the need to combine references, if the elements of the claim that are not
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`found explicitly or inherently in the reference can be supplied by the common sense
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`of one of skill in the art.
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`17
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`ZTE/SAMSUNG/HTC 1003-0017
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`29.
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`I understand that secondary indicia of non-obviousness may include (1)
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`a long felt but unmet need in the prior art that was satisfied by the invention of the
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`patent; (2) commercial success of processes covered by the patent; (3) unexpected
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`results achieved by the invention; (4) praise of the invention by others skilled in the
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`art; (5) taking of licenses under the patent by others; (6) deliberate copying of the
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`invention; (7) failure of others to find a solution to the long felt need; and (8) skep-
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`ticism by experts. I understand that evidence of secondary indicia of non-obvious-
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`ness, if available, should be considered as part of the obviousness analysis.
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`30.
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`I also understand that there must be a relationship between any such
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`secondary considerations and the invention. I further understand that contempora-
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`neous and independent invention by others is a secondary consideration supporting
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`an obviousness determination.
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`31.
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`In sum, my understanding is that prior art teachings are properly com-
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`bined where a person of ordinary skill in the art having the understanding and
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`knowledge reflected in the prior art and motivated by the general problem facing the
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`inventor, would have been led to make the combination of elements recited in the
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`claims. Under this analysis, the prior art references themselves, or any need or prob-
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`lem known in the field of endeavor at the time of the invention, can provide a reason
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`for combining the elements of multiple prior art references in the claimed manner.
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`18
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`ZTE/SAMSUNG/HTC 1003-0018
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`32.
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`I understand that obviousness in an inter partes review must be shown
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`by a preponderance of the evidence.
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` My Understanding of Claim Construction
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`33.
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`I understand that, during an inter partes review, claims are to be given
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`their broadest reasonable construction in light of the specification as would be read
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`by a person of ordinary skill in the relevant art at the time of invention. For the
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`purpose of this proceeding, I have used November 28, 2005 as the approximate time
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`of the invention.1
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`V. Level of Ordinary Skill in the Art
`34. A person of ordinary skill in the art at or before the time of the invention
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`of the ’916 patent2 (“POSA”) would have had a Master’s of Science Degree in an
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`academic area emphasizing Electrical Engineering, Physics, Computer Engineering,
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`1 The ’916 patent claims priority to three Korean applications, the earliest of
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`which was filed on November 28, 2005. I have been asked to use this as the inv