UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`ZTE (USA) Inc.,
`HTC Corporation, and
`HTC America, Inc.,
`
`Petitioner
`
`v.
`
`Evolved Wireless LLC,
`
`Patent Owner
`
`
`
`DECLARATION OF PAUL S. MIN, PH.D
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`
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`Case No. IPR2016-00758
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`SAMSUNG 1014-0001
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`I. 
`
`II. 
`
`TABLE OF CONTENTS
`
`Introduction & Summary of Opinions ............................................................. 1 
`
`Background/Qualifications .............................................................................. 2 
`
`III.  Documents and Materials Considered ............................................................. 6 
`
`IV.  Legal Principles ............................................................................................... 7 
`
`V. 
`
`Challenged Claims of 481 Patent .................................................................. 13 
`
`VI.  Person of Ordinary Skill in the Art ................................................................ 15 
`
`VII.  Technical Background ................................................................................... 16 
`
`VIII.  State of the Art ............................................................................................... 19 
`
`IX.  Prior Art References ...................................................................................... 20 
`
`A. 
`
`B. 
`
`C. 
`
`Panasonic 792 ...................................................................................... 20 
`
`Panasonic 114 ...................................................................................... 22 
`
`Chu ...................................................................................................... 23 
`
`X. 
`
`Claim Construction ........................................................................................ 24 
`
`XI. 
`
`Invalidity Analysis of 481 Patent .................................................................. 24 
`
`A. 
`
`Claims 1-2 and 8-9 are anticipated by and/or obvious in view of
`Panasonic 792. ..................................................................................... 24 
`
`1. 
`
`2. 
`
`3. 
`
`4. 
`
`Independent Claim 1 ................................................................. 24 
`
`Dependent Claim 2 ................................................................... 29 
`
`Independent Claim 8 ................................................................. 29 
`
`Dependent Claim 9 ................................................................... 32 
`
`B. 
`
`Claims 3, 4, 10, and 11 are invalid based on Panasonic 792 and
`Panasonic 114. ..................................................................................... 32 
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`Min Declaration
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`1. 
`
`2. 
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`3. 
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`4. 
`
`5. 
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`Dependent Claim 3 ................................................................... 32 
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`Dependent Claim 4 ................................................................... 33 
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`Dependent Claim 10 ................................................................. 35 
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`Dependent Claim 11 ................................................................. 35 
`
`Reasons to Combine the Panasonic References ....................... 36 
`
`C. 
`
`Claims 6 and 13 are invalid based on Panasonic 792, Panasonic
`114, and Chu. ....................................................................................... 38 
`
`1. 
`
`2. 
`
`3. 
`
`Dependent Claim 6 ................................................................... 38 
`
`Dependent Claim 13 ................................................................. 40 
`
`Reasons to Combine the Panasonic References and Chu ......... 40 
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`XII.  Public Availability of Prior Art References .................................................. 41 
`
`A. 
`
`B. 
`
`C. 
`
`Panasonic 792 (Exhibit 1002) was available to members of the
`general public as of at least March 21, 2006, without any
`restrictions. .......................................................................................... 41 
`
`Panasonic 114 (Exhibit 1003) was available to members of the
`general public as of at least May 2, 2006, without any restrictions. ... 51 
`
`Chu (Exhibit 1004) was available to members of the general public
`as of at least July 1972, without any restrictions. ............................... 58 
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`I.
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`Introduction & Summary of Opinions
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`1. My name is Paul Min. I submit this declaration on behalf of ZTE
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`(USA) Inc., HTC Corporation, and HTC America, Inc. (“Petitioner”), which I
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`understand are challenging the validity of claims 1-4, 6, 8-11, and 13 (“the
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`challenged claims”) of U.S. Patent No. 8,218,481 (“the 481 patent”) in a petition
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`for inter partes review.
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`2.
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`I have been asked to provide an opinion on the validity of the
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`challenged claims. In my opinion, for the reasons in the following sections, the
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`challenged claims are invalid on the following grounds:
`
`(1)
`
`claims 1, 2, 8, and 9 of the 481 patent are anticipated by and/or
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`obvious in view of Panasonic 792 (Exhibit 1002);
`
`(2)
`
`claims 3, 4, 10, and 11 of the 481 patent are obvious in view of
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`Panasonic 792 (Exhibit 1002) and Panasonic 114 (Exhibit 1003); and
`
`(3)
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`claims 6 and 13 are obvious in view of Panasonic 792 (Exhibit 1002),
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`Panasonic 114 (Exhibit 1003), and Chu (Exhibit 1004).
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`3.
`
`I have also been asked to provide an opinion on whether Exhibits
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`1002, 1003, and 1004 to the petition were available to interested members of the
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`public before June 9, 2006, which is the claimed priority date of the 481 patent. In
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`my opinion, for the reasons in the following sections:
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`(1) Exhibit 1002 (Panasonic 792) was available to members of the general
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`public, including interested members of the public, without restriction
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`as of at least March 21, 2006;
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`(2) Exhibit 1003 (Panasonic 114) was available to members of the general
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`public, including interested members of the public, without restriction
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`as of at least May 2, 2006; and
`
`(3) Exhibit 1004 (Chu) was available to members of the general public,
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`including interested members of the public, without restriction as of at
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`least July 1972.
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`II. Background/Qualifications
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`4.
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`Appendix A to this declaration is my curriculum vitae, which sets
`
`forth my qualifications.
`
`5.
`
`I received a B.S. degree in Electrical Engineering in 1982, an M.S.
`
`degree in Electrical Engineering in 1984, and a Ph.D. degree in Electrical
`
`Engineering in 1987 from the University of Michigan in Ann Arbor. I received
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`several academic honors, including my B.S. degree with honors, a best graduate
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`student award and a best teaching assistant award during my M.S. study, and a best
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`paper award from a major international conference for reporting results from my
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`Ph.D. thesis.
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`6.
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`After receiving my Ph.D., I worked at Bellcore in New Jersey from
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`August 1987 until August 1990. At Bellcore, I was responsible for evolving the
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`public switched telephone network (POTS) into a multi-services voice and data
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`network that incorporated packet switches, optical technologies, and wireless
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`technologies.
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`7.
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`In September 1990, I joined the faculty at Washington University in
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`St. Louis. In July 1996, I was promoted to an Associate Professor of Electrical
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`Engineering with tenure. I am currently a Senior Professor at Washington
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`University of the Electrical and Systems Engineering. I have also served as the
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`Chair of the Graduate Curriculum (2000-2002) and the Chair of the Undergraduate
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`Curriculum (2011-2014) for the Electrical and Systems Engineering department.
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`8.
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`At Washington University, I have conducted research in
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`communication, computing, and related electronic hardware and software. My
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`research group has pioneered a new paradigm for designing electronic circuits that
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`can alleviate the speed and performance mismatch against optical technology. I
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`have received several grants from the U.S. Federal Agencies, including the
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`National Science Foundation and the Defense Advanced Research Project Agency,
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`and numerous contracts from companies and organizations around the world.
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`Specifically related to the technology matters in this Investigation, I have
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`researched a variety of wireless communication technologies, including CDMA,
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`WCDMA, OFDM, FDD, SC-FDMA, and TDD. I have an extensive background
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`and experience in each of these technologies.
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`9.
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`As a faculty member at Washington University, I have taught a
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`number of courses in electronics, communication, and computing at both the
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`undergraduate and graduate levels. For example, I have taught communication
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`theory (Washington University ESE 471), transmission and multiplexing
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`(Washington University ESE 571), and signaling and control of communication
`
`networks (Washington University ESE 572).
`
`10.
`
`I have supervised more than 50 students, 12 of whom received a
`
`doctoral degree under my guidance. A number of doctoral theses that I have
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`supervised relate specifically to LTE technology. In particular, my students and I
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`have published a number of peer-reviewed articles on resource allocation,
`
`scheduling, modulation, mobility management, and multiplexing. Several of these
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`articles received accolades in the field. For example, in 2011, we received a best
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`paper award in 3G WCDMA-related mobility and resource management at the
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`prestigious Mobility 2011 international conference.
`
`11.
`
`In addition to my responsibilities as a university faculty member, I
`
`have founded two companies. In May 1997, I founded MinMax Technologies, Inc.,
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`a fabless semiconductor company that developed switch fabric integrated circuit
`
`chips for the Internet. In March 1999, I founded Erlang Technology, Inc., a fabless
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`semiconductor company that focused on the design and development of integrated
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`circuit chips and software for the Internet. One of Erlang’s products received a best
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`product of the year award in 2004 from a major trade journal for the electronics
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`industry.
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`12. Outside my own start-up companies, I have also served in various
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`technology and business advisor roles for other companies and organizations
`
`around the world. I was the main technical author for one of two winning proposals
`
`to the Korean government for CDMA wireless service licenses (1996). I was
`
`responsible for designing a commercial scale IS-95 CDMA cellular network,
`
`which I understand to be one of the earliest such networks deployed in the world. I
`
`worked with numerous engineers and scientists around the world to implement this
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`commercial-scale cellular network before IS-95 CDMA was widely accepted. This
`
`provided me with extensive insight into various components of CDMA technology,
`
`which by and large are used in WCDMA network. I have also been involved in a
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`semiconductor company that specializes in semiconductor memories such as flash
`
`EEPROMs as a board member and as a technical advisor (2007-2011).
`
`13.
`
`I am a named inventor on nine U.S. patents, many of which are
`
`directly related to resource allocation, packet processing, and network designing. I
`
`have extensively published technical papers in international conferences and
`
`journals, technical memoranda and reports, and given a number of seminars and
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`invited talks. Many of these papers are specifically within the context of the 3GPP
`
`standard. I have organized several international conferences and served as an
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`international journal editor.
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`14.
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`I am a member of and have been actively involved in a number of
`
`professional organizations. For example, I have served as the Chair of the Saint
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`Louis Section of the IEEE with more than 3,000 members (2014), and a member of
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`the Eta Kappa Nu Honor Society for electrical engineers. I have also been an
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`Ambassador of the McDonnell International Scholars Academy (2007-2013).
`
`15.
`
`In my nearly 30 years of experience with telecommunications
`
`technology, I have acquired significant knowledge about telecommunications
`
`systems industry standards, standard setting organizations such as 3GPP, and the
`
`rules and document policies that those organizations have in place to develop
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`industry standards.
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`III. Documents and Materials Considered
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`16. Appendix B to this declaration lists materials that I have considered in
`
`rendering the opinions that I express in this declaration.1 I have also reviewed, and
`
`navigated through, portions of the websites for 3GPP (www.3gpp.org) and ETSI
`
`(www.etsi.org) that are identified in this declaration. In forming my opinions, I
`
`have also relied on my experience and education.
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`
`1
`For convenience, this declaration refers to certain documents by the exhibit
`numbers that I understand Petitioner use in its petition.
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`IV. Legal Principles
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`17.
`
`I am not an attorney. I offer no opinions on the law. But counsel has
`
`informed me of legal standards that apply to the issue of patent validity. I have
`
`applied these standards in arriving at my conclusions.
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`18.
`
`I understand that in an inter partes review the petitioner has the
`
`burden of proving a proposition of unpatentability by a preponderance of the
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`evidence. I understand this standard is different from the standard that applies in a
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`district court, where I understand a challenger bears the burden of proving
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`invalidity by clear and convincing evidence.
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`19.
`
`I understand that a patent claim is invalid based on anticipation if a
`
`single prior art reference discloses all of the features of that claim, and does so in a
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`way that enables one of ordinary skill in the art to make and use the invention.
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`Each of the claim features may be expressly or inherently present in the prior art
`
`reference. I understand that if the prior art necessarily functions in accordance
`
`with, or includes a claim’s feature, then that prior art inherently discloses that
`
`feature. I have relied on this understanding in expressing the opinions set forth
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`below.
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`20.
`
`I understand that a prior art reference describes the claimed invention
`
`if it either expressly or inherently describes each and every feature set forth in the
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`claim; i.e., in determining whether a single item of prior art anticipates a patent
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`claim, one should take into consideration not only what is expressly disclosed in
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`that item, but also what is inherently present as a natural result of the practice of
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`the system or method disclosed in that item.
`
`21.
`
`I understand that to establish inherency, the evidence must make clear
`
`that the missing descriptive matter is necessarily present in the item of prior art and
`
`that it would be so recognized by persons of ordinary skill in the art. I also
`
`understand that prior art use of the claimed patented invention that was accidental,
`
`unrecognized, or unappreciated at the time of filing can still be an invalidating
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`anticipation.
`
`22.
`
`I understand that although multiple prior art references may not be
`
`combined to show anticipation, additional references may be used to interpret the
`
`allegedly anticipating reference and shed light on what it would have meant to
`
`those skilled in the art at the time of the invention. These additional references
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`must make it clear that the missing descriptive matter in the patent claim is
`
`necessarily present in the allegedly anticipating reference, and that it would be so
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`recognized by persons of ordinary skill in the art.
`
`23.
`
`I understand that a patent may not be valid even though the invention
`
`is not identically disclosed or described in the prior art if the differences between
`
`the subject matter sought to be patented and the prior art are such that the subject
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`matter as a whole would have been obvious to a person having ordinary skill in the
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`art in the relevant subject matter at the time the invention was made.
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`24. To determine if a claim is obvious, the following factors should be
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`considered: (1) the level of ordinary skill in the art at the time the invention was
`
`made; (2) the scope and content of the prior art; (3) the differences between the
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`claimed invention and the prior art; and (4) secondary considerations, including
`
`evidence of commercial success, long-felt but unsolved need, unsuccessful
`
`attempts by others, copying of the claimed invention, unexpected and superior
`
`results, acceptance and praise by others, independent invention by others, and the
`
`like.
`
`25. For example, I understand that the combination of familiar elements
`
`according to known methods is likely to be obvious when it does no more than
`
`yield predictable results. I also understand that an obviousness analysis need not
`
`seek out precise teachings directed to the specific subject matter of the challenged
`
`claim because a court can take account of the inferences and/or creative steps that a
`
`person of ordinary skill in the art would employ.
`
`26.
`
`I understand that the obviousness determination of an invention turns
`
`on whether a hypothetical person with ordinary skill and full knowledge of all the
`
`pertinent prior art, when faced with the problem to which the claimed invention is
`
`addressed, would be led naturally to the solution adopted in the claimed invention
`
`or would naturally view that solution as an available alternative. Facts to be
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`evaluated in this analysis include:
`
`
`
`
`
`
`
`
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`The scope and contents of the prior art;
`
`Differences between the prior art and the claims at issue;
`
`The level of ordinary skill in the pertinent art; and
`
`Evidence of objective factors suggesting or negating obviousness.
`
`27.
`
`I understand that the following rationales may be used to determine
`
`whether a piece of prior art can be combined with other prior art or with other
`
`information within the knowledge of one of ordinary skill in the art:
`
`
`
`
`
`
`
`
`
`
`
`
`
`Combining prior art elements according to known methods to yield
`
`predictable results;
`
`Simple substitution of one known element for another to obtain
`
`predictable results;
`
`Use of known techniques to improve similar devices (methods, or
`
`products) in the same way;
`
`Applying a known technique to a known device (method, or product)
`
`ready for improvement to yield predictable results;
`
`“Obvious to try” - choosing from a finite number of identified,
`
`predictable solutions, with a reasonable expectation of success;
`
`Known work in one field of endeavor may prompt variations of it for
`
`use in either the same field or a different one based on design
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`incentives or other market forces if the variations would have been
`
`predictable to one of ordinary skill in the art; or
`
`
`
`Some teaching, suggestion, or motivation in the prior art that would
`
`have led one of ordinary skill to modify the prior art reference or to
`
`combine prior art reference teachings to arrive at the claimed
`
`invention.
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`28.
`
`I understand that when a work is available in one field of endeavor,
`
`design incentives and/or other market forces, for example, can prompt variations of
`
`it, either in the same field or a different one. Moreover, if a person of ordinary skill
`
`can implement a predictable variation, I understand that that likely bars its
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`patentability.
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`29.
`
`I understand that obviousness must be tested as of the time the
`
`invention was made. I understand that the test for obviousness is what the
`
`combined teachings of the prior art references would have suggested, disclosed, or
`
`taught to one of ordinary skill in the art. In particular, it is my understanding that a
`
`patent claim is invalid based upon obviousness if it does nothing more than
`
`combine familiar elements from one or more prior art references or products
`
`according to known methods to yield predictable results. For example, I understand
`
`that where a technique has been used to improve one device, and a person of
`
`ordinary skill in the art would have recognized that it would improve similar
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`devices in the same way, using that technique is obvious. I understand that
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`obviousness can be proved by showing that a combination of elements was
`
`obvious to try, i.e.: that it does no more than yield predictable results; implements a
`
`predictable variation; is no more than the predictable use of prior art elements
`
`according to their established functions; or when there is design need or market
`
`pressure to solve a problem and there are a finite number of identified, predictable
`
`solutions. I have been further informed that when a patent claim simply arranges
`
`old elements with each element performing the same function it had been known to
`
`perform and yields results no more than one would expect from such an
`
`arrangement, the combination is obvious.
`
`30.
`
`I understand that another factor to be considered is common sense.
`
`For example, I understand that common sense teaches that familiar items may have
`
`obvious uses beyond their primary purposes, and, in many cases, a person of
`
`ordinary skill will be able to fit the teachings of multiple patents together like
`
`pieces of a puzzle.
`
`31.
`
`I understand that the Supreme Court articulated additional guidance
`
`for obviousness in its KSR decision. My understanding is that the Supreme Court
`
`said that technical people of ordinary skill look for guidance in other solutions to
`
`problems of a similar nature, and that the obviousness inquiry must track reality,
`
`and not legal fictions. I have relied on these understandings in expressing the
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`opinions set forth below.
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`32.
`
`I understand that a new use of an old product or material cannot be
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`claimed as a new product; the apparatus or system itself is old and cannot be
`
`patented. I further understand that, in general, merely discovering and claiming a
`
`new benefit to an old process cannot render the process newly patentable.
`
`V. Challenged Claims of 481 Patent
`
`33.
`
`I understand that Petitioner is challenging the validity of claims 1-4, 6,
`
`8-11, and 13 of the 481 patent in this proceeding. Those claims follow.
`
`1. A method of transmitting a preamble sequence in a
`mobile communication system, the method comprising:
`
`repeating a specific sequence, having a length (L), N
`times to generate a consecutive sequence having a
`length (N*L);
`
`generating said preamble sequence by concatenating a
`single cyclic prefix (CP) to a front end of said
`consecutive sequence; and
`
`transmitting, on a random access channel, said
`preamble sequence to a receiving side.
`
`
`2. The method of claim 1, further comprising
`generating said specific sequence from a Constant
`Amplitude Zero Auto Correlation (CAZAC) sequence.
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`3. The method of claim 2, further comprising applying
`a cyclic shift to said specific sequence generated from
`said CAZAC sequence.
`
`4. The method of claim 3, wherein a value of said
`applied cyclic shift is determined as an integer multiple
`of a predetermined circular shift unit.
`
`6. The method of claim 3, wherein applying said
`cyclic shift comprises multiplying said specific sequence
`by an exponential sequence.
`
`8. A transmitter for transmitting a preamble sequence
`in a mobile communication system, the transmitter
`comprising:
`
`a preamble generation unit configured to generate said
`preamble sequence by
`repeating a specific
`sequence, having a length (L), N times to generate
`a consecutive sequence having a length (N*L) and
`concatenating a single cyclic prefix (CP) to a front
`end of said consecutive sequence;
`
`a transmission unit configured to transmit, on a
`random access channel, said preamble sequence to
`a receiving side.
`
`
`9. The transmitter of claim 8, wherein said preamble
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`generation unit is further configured to generate said
`specific sequence from a Constant Amplitude Zero Auto
`Correlation (CAZAC) sequence.
`
`10. The transmitter of claim 9, wherein said preamble
`generation unit is further configured to apply a cyclic
`shift to said specific sequence generated from said
`CAZAC sequence.
`
`11. The transmitter of claim 10, wherein a value of
`said applied cyclic shift is determined as an integer
`multiple of a predetermined circular shift unit.
`
`13. The transmitter of claim 10, wherein said
`preamble generation unit is further configured to apply
`said cyclic shift by multiplying said specific sequence by
`an exponential sequence.
`
`VI. Person of Ordinary Skill in the Art
`
`34. The person of ordinary skill in the art of the subject matter of the 481
`
`patent would have had a master’s degree in electrical engineering with 2-3 years of
`
`experience in cellular communication systems, and would have been aware of the
`
`efforts of the Third Generation Partnership Project (“3GPP”) and its various
`
`groups. Alternatively, that person would have had a Ph.D. in electrical engineering
`
`with the same familiarity with the work of the 3GPP and its various groups.
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`VII. Technical Background
`
`35.
`
`In 2006, before the 481 patent’s claimed priority date, the
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`telecommunications industry was developing the cellular standard now known as
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`Long Term Evolution (“LTE”). (Ex. 1033, Dahlman, at 21.) Development of LTE
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`took place in a standard-setting organization called the Third Generation
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`Partnership Project (“3GPP”). (Id.) 3GPP had members from virtually every
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`telecommunications company or organization in the world. (See, e.g., Ex. 1031,
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`44bis Participant List; Ex. 1032, 45 Participant List.)
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`36.
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`3GPP had several groups. (Ex. 1033, Dahlman, at 9.) Relevant here is
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`Technical Specification Group Radio Access Network (“TSG RAN”). (Id. at 10.)
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`TSG RAN developed LTE’s radio access network, which allows user equipment
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`(“UE”), such as a smartphone, to communicate with the cellular network. (Id.)
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`TSG RAN itself had several working groups, of which Working Group 1 (“WG1”)
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`is relevant here. (Id.)
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`37. WG1 was developing the Random Access Channel (“RACH”) of
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`LTE. (See, e.g., Ex. 1006, Huawei 797, at 1.) The RACH had a few purposes. (Ex.
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`1033, Dahlman, at 432-434.) It would allow a UE to access a cellular network for
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`the first time, for example, when the UE powers up. (Id. at 432.) The RACH would
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`also allow the cellular network to perform a handover, a process by which the
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`network transfers a UE from one cell of the network to another cell. (Id.) Finally,
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`the RACH would allow the UE to become time-synchronized with the network.
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`(Id.) This was all well-known in WG1 before the 481 patent’s claimed priority
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`date.
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`38. Also well-known was that each UE should ideally use a different
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`RACH sequence, called a preamble sequence. (See, e.g., Ex. 1003, Panasonic 114,
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`at 1.) At a given time, several UEs can perform respective random access
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`procedures, each ideally using a different RACH preamble sequence to identify
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`itself to a base station, or an eNodeB in the context of LTE. (Id.) There are a
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`number of RACH preambles available for a given eNodeB, and when a UE
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`performs a random access procedure, the UE selects, often randomly, a RACH
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`preamble among the multitude of RACH preambles available for the eNodeB.
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`Because the UEs do not communicate among themselves, when two or more UEs
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`happen to use the same RACH preamble sequence at the same time, the eNodeB
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`cannot differentiate these UEs, and for that matter, the eNodeB may not even know
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`there are multiple UEs performing the random access procedure at the same time.
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`(Id.) To correctly perform the random access procedure, different UEs should use
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`different RACH preamble sequences. (Id.) Well aware of this problem, WG1 was
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`working on designing a sufficiently large number of preamble sequences that
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`would be available to the UEs such that when selected randomly, the probability of
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`multiple UEs choosing the same RACH preamble is reduced. (Id. at 4.)
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`39. Two mathematical functions guided WG1’s design: (1) auto-
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`correlation, and (2) cross-correlation. (See, e.g., Ex. 1006, Huawei 797, at 1.) The
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`auto-correlation function compares a signal to a time-shifted version of itself. (See,
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`e.g., Ex. 1007, Samsung 028, at 2:17-35.) The cross-correlation function compares
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`a signal to a time-shifted version of a different signal. (Id.) For both functions, a
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`result of zero is ideal, while a higher value can lead to a higher probability of
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`interference. (Id.) When a signal is periodic, slightly different terminology applies.
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`An auto-correlation of a periodic signal is called a circular auto-correlation; a
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`cross-correlation of that signal is called a circular cross-correlation; and the time
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`shift of that signal is called a cyclic shift. (See, e.g., Ex. 1034, TI 062, at 2.)
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`40. WG1 members knew these properties well. (See, e.g., Ex. 1034, TI
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`062, at 2.) WG1 members also knew that the RACH preamble sequence they were
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`designing should have excellent auto-correlation and cross-correlation properties
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`so that the time estimation can be performed accurately and RACH preamble
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`sequences would not interfere with one another. (See, e.g., Ex. 1006, Huawei 797,
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`at 1; Ex. 1012, TI 867, at 1.) Finally, WG1 members knew that sequences called
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`Constant Amplitude Zero Auto Correlation (“CAZAC”) sequences were well-
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`suited to be used as RACH preamble sequences. (See, e.g., Ex. 1010, Motorola
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`884, at 1; Ex. 1011, Nortel 908, at 1; Ex. 1013, NTT/NEC 992, at 1.)
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`VIII. State of the Art
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`41. The challenged claims are directed to a RACH preamble that includes
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`a single cyclic prefix followed by repetitions of a cyclic-shifted CAZAC sequence.
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`(See Ex. 1001, 481 Patent, at claims 1-4, 6, 8-11, 13.) Before the 481 patent’s
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`claimed priority date, this concept was well-known to persons of ordinary skill in
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`the art.
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`42.
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`It was well-known that the RACH preamble could include a CAZAC
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`sequence. In July 1972, David C. Chu authored an IEEE article that introduced a
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`type of CAZAC sequence now known as the Zadoff-Chu sequence. (See Ex. 1004,
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`Chu.) Citing to the Chu article more than 30 years later, several companies
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`proposed to WG1 that the RACH preamble include a Zadoff-Chu sequence or
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`other CAZAC sequence. (Ex. 1002, Panasonic 792, at 2, 7; Ex. 1003, Panasonic
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`114, at 1, 4-5; Ex. 1006, Huawei 797, at 2; Ex. 1007, Samsung 028, at 8:8-11; Ex.
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`1010, Motorola 884, at 1; Ex. 1011, Nortel 908, at 1; Ex. 1012, TI 867, at 5.)
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`43.
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`It was also well-known that the RACH preamble could use cyclic
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`shifts of a CAZAC sequence. For example, in May 2006, Panasonic employees
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`studied cyclic-shifted Zadoff-Chu sequences (which are CAZAC sequences) and
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`concluded that the RACH preamble should use those cyclic-shifted sequences. (Ex.
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`1003, Panasonic 114, at 1.)
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`44. Those skilled in the art also knew that the RACH preamble could be
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`constructed using a repeating code, including a repeating CAZAC sequence. In
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`1999, Motorola and Texas Instruments proposed a RACH preamble structure
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`formed of 256 repeated codes. (Ex. 1008, Motorola/TI 893, at 3.) In August 2005,
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`citing to the 1999 paper, Texas Instruments proposed that same preamble structure
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`for the RACH in LTE. (Ex. 1009, TI 058, at 1.) Motorola and Texas Instruments’
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`papers also disclosed multiplying the repetitions of the code with another code.
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`(Ex. 1008, Motorola/TI 893, at 3; Ex. 1009, TI 058, at 1.) In March 2006, NTT
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`DoCoMo and NEC specifically proposed a RACH preamble with a repeating
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`CAZAC sequence. (Ex. 1013, NTT/NEC 992, at 1.) Similarly, Panasonic proposed
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`that the RACH preamble contain repetitions o