UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`ZTE (USA) Inc.,
`Samsung Electronics Co., Ltd.,
`Samsung Electronics America, Inc.,
`HTC Corporation, and
`HTC America, Inc.,
`
`Petitioner
`
`v.
`
`Evolved Wireless LLC,
`
`Patent Owner
`
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,746,916
`
`Case No. IPR2016-01277
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`Evolved Wireless, LLC Exhibit 2001-001
`Samsung/HTC/ZTE v. Evolved Wireless IPR2016-01280
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`ZTE (USA) Inc.,
`Samsung Electronics Co., Ltd.,
`Samsung Electronics America, Inc.,
`HTC Corporation, and
`HTC America, Inc.,
`
`Petitioner
`
`v.
`
`Evolved Wireless LLC,
`
`Patent Owner
`
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,746,916
`
`Case No. IPR2016-01277
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`Evolved Wireless, LLC Exhibit 2001-001
`Samsung/HTC/ZTE v. Evolved Wireless IPR2016-01280
`
`
`
`IPR of U.S. Patent No. 7,746,916
`
`Zhuang327 discloses “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,” as recited in claim 1. Claim 7 of Zhuang327
`
`makes clear that the cyclic extension is performed such that a part of the code
`
`sequence having the first length (“(K-NG) terms from the beginning of each GCL
`sequence”) is added to an end of the code sequence having the first length:
`
`“wherein when NG is smaller than K, the corresponding set of sequences of length
`K is generated by copying (K-NG) terms from the beginning of each GCL sequence
`and appending them to the end.” Ex. 1007, claim 7 at 15:66-16:2. See also
`
`Petitioner-FIG. 2 and Wells Declaration, ¶ 126.
`
`Zhuang327 discloses “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,” as
`
`recited in claim 1. For example, Zhuang327 discloses the circular shift is
`
`performed to the time-domain access signal 130 having the second length NFFT/IFFT:
`“for each ranging code, Nsh cyclic time shifts 603 of the time-domain ranging signal
`
`25
`
`Evolved Wireless, LLC Exhibit 2001-002
`Samsung/HTC/ZTE v. Evolved Wireless IPR2016-01280
`
`
`
`IPR of U.S. Patent No. 7,746,916
`
`(phase rotation in frequency domain) can be used to further increase the number of
`
`ranging opportunities. Ex. 1007, 6:30-45. See Wells Declaration, ¶¶ 127-128.
`
`More specifically, FIG. 6 (reproduced and annotated below) of Zhuang327
`
`shows three examples of cyclically-shifted access signals 140a, 140b, and 140c of
`
`the original time-domain access signal 130. To be sure, Zhuang327 discloses that a
`
`cyclic prefix (CP) can be added to the access signal 130 or to cyclically-shifted
`
`access signals 140a, 140b, and 140c to form access waveforms. Ex. 1007, 5:29-36.
`
`The resulting ranging/access waveforms are denoted as 150, 150a, 150b, and 150c
`
`in FIG. 6: the access waveform 150 results from adding CP1 from the original,
`
`non-circularly-shifted access signal 130; and the access waveforms 150a, 150b,
`
`and 150c result from adding CP2, CP3 and CP4 to the circularly-shifted access
`
`signals 140a, 140b, and 140c, respectively.8
`
`
`8 Notably, the CP1, CP2, CP3 and CP4 shown in FIG. 6 are cyclic prefixes applied
`
`to time-domain circularly-shifted access signals 140 to form access waveforms
`
`150, and are distinguished from the cyclic postfixes used to cyclically extend GCL
`
`sequences 110 to form access/ranging sequences 120. See Petitioner-FIG. 2.
`
`26
`
`Evolved Wireless, LLC Exhibit 2001-003
`Samsung/HTC/ZTE v. Evolved Wireless IPR2016-01280
`
`
`
`IPR of U.S. Patent No. 7,746,916
`
`Excerpt of FIG. 6 of Zhuang327 - with annotations by Petitioner
`
`The three circularly-shifted access signals 140a, 140b, and 140c result from
`
`circularly shifting a rear portion (CP1) of the original access signal 130 “in time
`
`domain by some multiples of L.” Ex. 1007, 6:30-45. The embodiment referred to
`
`as “3rd shift” shows that the circular shift is performed to the code sequence having
`
`the second length (i.e., non-circularly-shifted access signal 130, the “original (or 0th
`
`shift) sequence,” Ex. 1007, 6:38) such that the rear portion of the code sequence
`
`having the second length (i.e., CP1 of the original access signal 130) moves to a
`
`start of the code sequence having the second length (i.e., a start of the original
`
`27
`
`Evolved Wireless, LLC Exhibit 2001-004
`Samsung/HTC/ZTE v. Evolved Wireless IPR2016-01280
`
`
`
`IPR of U.S. Patent No. 7,746,916
`
`access signal 130). “Lastly, a CP [i.e., CP4] is added to form the final ranging
`
`waveform [150c].” Ex. 1007, 5:33-34. See Wells Declaration, ¶¶ 129-133.
`
`Zhuang327 anticipates claim 2
`2.
`Zhuang327 discloses “the part of the code sequence having the first length
`
`comprises at least a cyclic prefix or a cyclic postfix,” as recited in claim 2. Based
`
`on antecedent, “the part of the code sequence having the first length” refers to “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” as recited in claim 1.
`
`In other words, “the part of the code sequence having the first length” is the
`
`padding portion added to the sequence. See Wells Declaration, ¶ 134. Zhuang327
`
`discloses such a padding portion comprises at least a cyclic postfix as Zhuang327
`
`makes clear that “(K-NG) terms from the beginning of each GCL sequence”
`(denoted as 130 in Petitioner-FIG. 1) is appended to the end of the sequence of
`
`length NG as a cyclic postfix. Ex. 1007, 5:66-16:2. See Wells Declaration, ¶ 135.
`Zhuang327 anticipates claim 3
`3.
`Zhuang327 discloses “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,” as recited in claim
`
`3. Zhuang327 discloses that a cyclic postfix of the code sequence, having the first
`
`28
`
`Evolved Wireless, LLC Exhibit 2001-005
`Samsung/HTC/ZTE v. Evolved Wireless IPR2016-01280
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