throbber
U.S. Patent No. 7,116,710
`IPR2017-00219
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`—————————————————
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`—————————————————
`APPLE INC.,
`Petitioner
`v.
`CALIFORNIA INSTITUTE OF TECHNOLOGY,
`Patent Owner.
`—————————————————
`Case IPR2017-00219
`U.S. Patent No. 7,116,710
`—————————————————
`PETITIONER’S UPDATED EXHIBIT LIST
`
`
`
`
`
`

`

`Pursuant to the Board’s authorization in Paper 52, dated February 28, 2018,
`
`U.S. Patent No. 7,116,710
`IPR2017-00219
`
`
`
`
`Petitioners hereby submits the Declaration of James A. Davis, Ph.D. and this
`
`updated Exhibit List. The Declaration of James A. Davis, Ph.D. is Exhibit 1273.
`
`
`Date: March 1, 2018
`
`
`
` Respectfully submitted,
`
`/Michael Smith /
`
`Michael H. Smith
`Registration No. 71,190
`
`
`
`
`
`
`
`
`1
`
`
`
`
`
`
`
`

`

`U.S. Patent No. 7,116,710
`IPR2017-00219
`
`
`LIST OF EXHIBITS
`
`Description
`
`U.S. Patent 7,116,710
`
`Frey, B. J. and MacKay, D. J. C., “Irregular Turbocodes,” Proc. 37th
`Allerton Conf. on Comm., Control and Computing, Monticello,
`Illinois, published on or before March 20, 2000
`
`D. Divsalar, H. Jin, and R. J. McEliece, “Coding theorems for
`"turbo-like" codes,” Proc. 36th Allerton Conf. on Comm., Control
`and Computing, Allerton, Illinois, pp. 201-10, March, 1999
`
`Luby, M. et al., “Analysis of Low Density Codes and Improved
`Designs Using Irregular Graphs,” STOC ’98, pp. 249-59, published
`in 1998
`
`Pfister et al., “The Serial Concatenation of Rate-1 Codes Through
`Uniform Random Interleavers” (Exhibit 1 to the Siegel Declaration)
`
`Declaration of Professor James Davis, Ph.D. (“Davis Declaration”)
`
`Gallager, R., Low-Density Parity-Check Codes, Monograph, M.I.T.
`Press, 1963
`
`Berrou et al., “Near Shannon Limit Error-Correcting Coding and
`Decoding: Turbo Codes," ICC ’93, Technical Program, Conference
`Record 1064, Geneva 1993
`
`Exhibit
`
`1201
`
`1202
`
`1203
`
`1204
`
`1205
`
`1206
`
`1207
`
`1208
`
`1209 MacKay, D. J. C, and Neal, R. M. “Near Shannon Limit
`Performance of Low Density Parity Check Codes,” Electronics
`Letters, vol. 32, pp. 1645-46, 1996
`
`1210
`
`Benedetto, S. et al., Serial Concatenation of Block and
`Convolutional Codes, 32.10 Electronics Letters 887-8, 1996
`
`1211
`
`Luby, M. et al., “Practical Loss-Resilient Codes,” STOC ’97, 1997
`
`
`
`2
`
`

`

`U.S. Patent No. 7,116,710
`IPR2017-00219
`
`
`f1212 Declaration of Robin Fradenburgh Concerning the “Proceedings,
`36th Allerton Conference on Communications, Control, and
`Computing” Reference
`
`1213
`
`1214
`
`1215
`
`Frey, B. J. and MacKay, D. J. C., “Irregular Turbo-Like Codes”
`presented at the 1999 Allerton Conference on Communications,
`Control, and Computing
`
`Prosecution History of the ’710 Patent, Response Dated May 5, 2005
`
`Table of Contents of Proceedings of the 37th Allerton Conference on
`Communication, Control and Computing from September 22-24,
`1999
`
`1216
`
`Joint Claim Construction Statement (Case No. 2:13-cv-07245, Dkt.
`No. 47)
`
`1217
`
`Expert Report of Dr. Brendan Frey (Case No. 2:13-cv-07245)
`
`1218
`
`1219
`
`1220
`
`1221
`
`Aamod Khandekar, “Graph-based Codes and Iterative Decoding,”
`Thesis submitted June 10, 2002
`
`Richardson, Shokrollahi, and Urbanke, “Design of Provably Good
`Low-Density Parity Check Codes”
`
`Declaration of Paul H. Siegel
`
`U.S. Provisional Application No. 60/205,095
`
`1222 Mitzenmacher, M. “Studying balanced allocations with differential
`equations,” Combinatorics, Probability & Computing 8.5, pp. 473-
`482, September 1999
`
`1223
`
`Barg et al., “Linear-time Binary Codes Correcting Localized
`Structures,” IEEE Transactions on Information Theory 45.7, pp.
`2545-2550, November 1999
`
`
`
`3
`
`

`

`U.S. Patent No. 7,116,710
`IPR2017-00219
`
`
`1224
`
`1225
`
`1226
`
`1227
`
`1228
`
`1229
`
`1230
`1231
`
`1232
`
`1233
`
`1234
`
`1235
`1236
`
`1237
`
`1238
`
`Shokrollahi, “New Sequences of Linear Time Erasure Codes
`Approaching the Channel Capacity,” Applied Algebra, Algebraic
`Algorithms and Error-Correcting Codes, pp. 65-76, 1999
`Declaration Of Richard Goldenberg In Support Of Unopposed
`Motions To Submit Replacement Exhibits Pursuant To 37 C.F.R. §
`42.104(c)
`Declaration Of Jonathan Barbee In Support Of Unopposed Motions
`To Submit Replacement Exhibits Pursuant To 37 C.F.R. § 42.104(c)
`Declaration of James M. Dowd in Support of Motion for Admission
`Pro Hac Vice
`Declaration of Mark D. Selwyn in Support of Motion for Admission
`Pro Hac Vice
`OCLC Record of Proceedings of the 36th Allerton Conference on
`Communication, Control and Computing, indicating the 36th
`Allerton Conference Proceeding was published by June 3, 1999
`Declaration of Library Expert Theodore A. Fons
`Affidavit of Pamela Stansbury (an employee in the Original
`Cataloging Unit of the Cornell University Library)
`Affidavit from Dr. Bruce Hajek (a six-time co-chair of the Allerton
`Conference, including the 36th Allerton Conference and the 37th
`Allerton Conference)
`Affidavit from Dr. Tamer Basar (a six-time co-chair of the Allerton
`Conference, including the 36th Allerton Conference)
`Affidavit from Dr. Ramavarapu Sreenivas (a two-time co-chair of
`the Allerton Conference, including the 37th Allerton Conference)
`Declaration of Dr. Brendan Frey
`A Screen Capture of an Archived Version of the Website for the 37th
`Annual Allerton Conference, dated September 9, 1999
`A Purchase Order for the 37th Allerton Conference Proceedings,
`dated December 8, 1999
`A Bill of Lading for the 37th Annual Allerton Conference
`Proceedings, with a ship date of February 21, 2000
`
`
`
`4
`
`

`

`U.S. Patent No. 7,116,710
`IPR2017-00219
`
`
`1239
`
`1240
`
`1241
`
`1243
`
`An Excerpt from the Deposition of Dr. Steven Wicker (Case No.
`2:13-cv-07245)
`An Excerpt from the Deposition of Dr. Rüdiger Urbanke (Case No.
`2:13-cv-07245)
`Jafar A. Alzubi, Omar A. Alzubi, and Thomas M. Chen, Forward
`Error Correction Based on Algebraic-Geometric Theory (2014)
`1242 MARC Record of Proceedings of the 37th Allerton Conference on
`Communication, Control and Computing, indicating the 37th
`Allerton Conference Proceeding was published in 1999
`BEACON Record of Proceedings of the 37th Allerton Conference on
`Communication, Control and Computing, indicating the 37th
`Allerton Conference Proceeding was published in 1999
`Tanner Graph for Code Described by Fig. 2 of U.S. Patent No.
`7,116,710
`Block Diagram of Accumulator
`Tanner Graph for Code Described by Divsalar
`Tanner Graph for Code Described by Luby98 Code 14
`Tanner Graph for Code Described by Ping
`Tanner Graph for Code Described by MacKay Profile 93y
`Confidential IRA.cpp with metadata
`Confidential IRA.h with metadata
`Confidential IRAsimu.cpp with metadata
`Confidential IRAsimu.cpp with metadata
`Confidential GetInter.cpp with metadata
`Confidential Excerpts from the Deposition of Dr. Hui Jin (Case No.
`16-cv-3714)
`Intentionally Left Blank
`Tanner Graph for Code Described by Divsalar (q=5)
`Tanner Graph for IRA Code
`Systematic Version of Divsalar Figure 3
`
`1244
`
`1245
`1246
`1247
`1248
`1249
`1250
`1251
`1252
`1253
`1254
`1255
`
`1256
`1257
`1258
`1259
`
`
`
`5
`
`

`

`U.S. Patent No. 7,116,710
`IPR2017-00219
`
`
`1260
`1261
`
`1262
`1263
`1263
`1264
`1265
`1266
`1267
`
`1268
`1269
`1270
`1271
`1272
`1273
`1274
`
`Divsalar Figure 3 and Frey Figure 1
`D. Divsalar, S. Dolinar, J. Thorpe, and C. Jones, “Constructing
`LDPC Codes from Simple Loop-Free Encoding Modules,” IEEE
`International Conference on Communications, Seoul, South Korea,
`pp. 658-662, August, 2005
`Transcript of the Deposition of Dr. Michael Mitzenmacher
`Transcript of the Deposition of Dr. Hui Jin [unredacted]
`Transcript of the Deposition of Dr. Hui Jin [redacted]
`Transcript of the Deposition of Dr. Dariush Divsalar
`Declaration of Dr. Brendan Frey
`Curriculum Vitae of Dr. Brendan Frey
`California Institute of Technology v. Hughes Communications Inc.,
`No. 2:13-cv-07245-MRP-JEM, 2015 WL 11089495 (C.D. Cal. May
`5, 2015)
`Simulation of Regular and Irregular Divsalar Codes
`Protective Order
`Redline against Board’s Default Protective Order
`Intentionally Left Blank
`Intentionally Left Blank
`Declaration of James A. Davis, Ph.D.
`Relevance of Deposition Questions Summary
`
`
`
`
`6
`
`
`
`
`
`

`

`U.S. Patent No. 7,116,710
`IPR2017-00219
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on March 1, 2018, a true and correct copy of the
`
`following:
`
` Petitioner’s Updated Exhibit List
`
` Exhibit 1273
`
` List of Exhibits
`
`was served via electronic mail upon the following attorneys of record:
`
`Michael Rosato (mrosato@wsgr.com)
`Matthew Argenti (margenti@wsgr.com)
`Richard Torczon (rtorczon@wsgr.com)
`Kevin P.B. Johnson (kevinjohnson@quinnemanuel.com)
`Todd M. Briggs (toddbriggs@quinnemanuel.com)
`
`
`
`
`
`
`/ Michael Smith/
`
`Michael H. Smith
`Registration No. 71,190
`
`
`
`
`
`7
`
`

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket