`
`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
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`
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`IPR of U.S. Patent No. 7,746,916
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`Zhuang327 discloses “wherein the cyclic extension of the code sequence
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`having the first length is performed such that a part of the code sequence having
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`the first length, having a length corresponding to a difference between the first
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`length and the second length, is added to either a start or an end of the code
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`sequence having the first length,” as recited in claim 1. Claim 7 of Zhuang327
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`makes clear that the cyclic extension is performed such that a part of the code
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`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:
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`“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
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`Petitioner-FIG. 2 and Wells Declaration, ¶ 126.
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`Zhuang327 discloses “wherein the circular shift is performed to the code
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`sequence having the second length such that either a rear portion of the code
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`sequence having the second length moves to a start of the code sequence having
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`the second length, or a front portion of the code sequence having the second
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`length moves to an end of the code sequence having the second length,” as
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`recited in claim 1. For example, Zhuang327 discloses the circular shift is
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`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
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`25
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`Evolved Wireless, LLC Exhibit 2001-002
`Samsung/HTC/ZTE v. Evolved Wireless IPR2016-01280
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`
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`IPR of U.S. Patent No. 7,746,916
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`(phase rotation in frequency domain) can be used to further increase the number of
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`ranging opportunities. Ex. 1007, 6:30-45. See Wells Declaration, ¶¶ 127-128.
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`More specifically, FIG. 6 (reproduced and annotated below) of Zhuang327
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`shows three examples of cyclically-shifted access signals 140a, 140b, and 140c of
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`the original time-domain access signal 130. To be sure, Zhuang327 discloses that a
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`cyclic prefix (CP) can be added to the access signal 130 or to cyclically-shifted
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`access signals 140a, 140b, and 140c to form access waveforms. Ex. 1007, 5:29-36.
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`The resulting ranging/access waveforms are denoted as 150, 150a, 150b, and 150c
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`in FIG. 6: the access waveform 150 results from adding CP1 from the original,
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`non-circularly-shifted access signal 130; and the access waveforms 150a, 150b,
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`and 150c result from adding CP2, CP3 and CP4 to the circularly-shifted access
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`signals 140a, 140b, and 140c, respectively.8
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`8 Notably, the CP1, CP2, CP3 and CP4 shown in FIG. 6 are cyclic prefixes applied
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`to time-domain circularly-shifted access signals 140 to form access waveforms
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`150, and are distinguished from the cyclic postfixes used to cyclically extend GCL
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`sequences 110 to form access/ranging sequences 120. See Petitioner-FIG. 2.
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`26
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`Evolved Wireless, LLC Exhibit 2001-003
`Samsung/HTC/ZTE v. Evolved Wireless IPR2016-01280
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`IPR of U.S. Patent No. 7,746,916
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`Excerpt of FIG. 6 of Zhuang327 - with annotations by Petitioner
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`The three circularly-shifted access signals 140a, 140b, and 140c result from
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`circularly shifting a rear portion (CP1) of the original access signal 130 “in time
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`domain by some multiples of L.” Ex. 1007, 6:30-45. The embodiment referred to
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`as “3rd shift” shows that the circular shift is performed to the code sequence having
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`the second length (i.e., non-circularly-shifted access signal 130, the “original (or 0th
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`shift) sequence,” Ex. 1007, 6:38) such that the rear portion of the code sequence
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`having the second length (i.e., CP1 of the original access signal 130) moves to a
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`start of the code sequence having the second length (i.e., a start of the original
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`27
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`Evolved Wireless, LLC Exhibit 2001-004
`Samsung/HTC/ZTE v. Evolved Wireless IPR2016-01280
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`IPR of U.S. Patent No. 7,746,916
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`access signal 130). “Lastly, a CP [i.e., CP4] is added to form the final ranging
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`waveform [150c].” Ex. 1007, 5:33-34. See Wells Declaration, ¶¶ 129-133.
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`Zhuang327 anticipates claim 2
`2.
`Zhuang327 discloses “the part of the code sequence having the first length
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`comprises at least a cyclic prefix or a cyclic postfix,” as recited in claim 2. Based
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`on antecedent, “the part of the code sequence having the first length” refers to “a
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`part of the code sequence having the first length, having a length corresponding to
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`a difference between the first length and the second length” as recited in claim 1.
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`In other words, “the part of the code sequence having the first length” is the
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`padding portion added to the sequence. See Wells Declaration, ¶ 134. Zhuang327
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`discloses such a padding portion comprises at least a cyclic postfix as Zhuang327
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`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
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`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
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`postfix of the code sequence having the first length, having the length
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`corresponding to the difference between the first length and the second length, is
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`added to the end of the code sequence having the first length,” as recited in claim
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`3. Zhuang327 discloses that a cyclic postfix of the code sequence, having the first
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`28
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`Evolved Wireless, LLC Exhibit 2001-005
`Samsung/HTC/ZTE v. Evolved Wireless IPR2016-01280