Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D. (Exhibit 2004)
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE, INC.
`Petitioner
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`v.
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`SAINT LAWRENCE COMMUNICATIONS LLC
`Patent Owner
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`Case: IPR2017-01244
`Patent No. 6,807,524
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`DECLARATION OF ODED GOTTESMAN, PH.D.
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`Exhibit 2004
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`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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`SLC 2004
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`Declaration of Oded Gottesman, Ph.D. (Exhibit 2004)
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`APPLE, INC.
`Petitioner
`
`v.
`
`SAINT LAWRENCE COMMUNICATIONS LLC
`Patent Owner
`
`Case: IPR2017-01244
`Patent No. 6,807,524
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`DECLARATION OF ODED GOTTESMAN, PH.D.
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`Exhibit 2004
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`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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`
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`SLC 2004
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`I.
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
`TABLE OF CONTENTS
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`II.
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`INTRODUCTION ........................................................................................... 1
`A.
`Background ........................................................................................... 1
`B.
`Qualifications ........................................................................................ 2
`LIST OF DOCUMENTS CONSIDERED IN FORMULATING MY
`OPINIONS ...................................................................................................... 6
`III. TECHNICAL BACKGROUND AND THE ‘524 PATENT ....................... 11
`IV. PERSON OF ORDINARY SKILL IN THE ART ........................................ 23
`V.
`THE CLAIMS OF THE ‘524 PATENT ....................................................... 24
`VI. LEGAL STANDARDS ................................................................................. 25
`A.
`Requirements of a Method and System Patent ................................... 25
`B.
`Obviousness ........................................................................................ 26
`VII. CLAIM CONSTRUCTION .......................................................................... 31
`VIII. SUMMARY OF PRIOR ART TO THE ’524 PATENT ALLEGED IN
`THIS PETITION ........................................................................................... 31
`IX. THE PETITIONER FAILED TO DEMONSTRATE THAT IT IS
`REASONABLY LIKELY TO PREVAIL ON ANY OF ITS
`PROPOSED OBVIOUSNESS REJECTIONS ............................................. 44
`BIBLIOGRAPHY ......................................................................................... 67
`X.
`DR. ODED GOTTESMAN ..................................................................................... 69
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`i
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`I, Oded Gottesman, hereby declare as follows:
`
`I.
`
`INTRODUCTION
`A. Background
`1. My name is Oded Gottesman. I am a researcher and consultant
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`working in areas related to speech and audio coding and enhancement, digital
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`signal processing, telecommunications, networks, and location and positioning
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`systems.
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`2.
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`I have been retained to act as an expert witness on behalf of SAINT
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`LAWRENCE COMMUNICATIONS Inc. (“Patent Owner”) in connection with the
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`above captioned Petition for Review of U.S. Patent No. 6,807,524 (“Petition”)
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`submitted by APPLE, INC. (“Petitioner”). I understand that this proceeding
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`involves U.S. Patent No. 6,807,524 (“the ‘524 Patent”), titled “Perceptual
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`weighting device and method for efficient coding of wideband signals.” The ‘524
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`Patent is provided as Exhibit 1001.
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`3.
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`I understand that Petitioner challenges the validity of Claims 1-21 and
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`29-42 of the ‘524 Patent (the “challenged claims”).
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`4.
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`I have reviewed and am familiar with the ‘524 Patent as well as its
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`prosecution history. The ‘524 prosecution history is provided as Exhibit 1003.
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`Additionally, I have reviewed materials identified in Section III.
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`1
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`As set forth below, I am familiar with the technology at issue as of the
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`5.
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`effective filing date of the ‘524 patent. I have been asked to provide my technical
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`review, analysis, insights, and opinions regarding the prior art references that form
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`the basis for the Petition. In forming my opinions, I have relied on my own
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`experience and knowledge, my review of the ‘524 Patent and its file history, and of
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`the prior art references cited in the Petition.
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`6. My opinions expressed in this Declaration rely to a great extent on my
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`own personal knowledge and recollection. However, to the extent I considered
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`specific documents or data in formulating the opinions expressed in this
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`Declaration, such items are expressly referred to in this Declaration.
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`7.
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`I am being compensated for my time in connection with this covered
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`patent review at my standard consulting rate, which is $525 per hour. My
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`compensation is not contingent upon and in no way affects the substance of my
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`testimony.
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`B. Qualifications
`I am a citizen of the United States, and I am currently employed as the
`8.
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`Chief Technology Officer (“CTO”) of Compandent, Inc.
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`9. My curriculum vitae, including my qualifications, a list of the
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`publications that I have authored during my career, and a list of the cases in which,
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`during the previous four years, I have testified as an expert at trial or by deposition,
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`2
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`is attached to this report as Attachment A. I expect to testify regarding my
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`background, qualifications, and experience relevant to the issues in this
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`investigation.
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`10.
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`I earned my Bachelor of Science degree in Electrical Engineering
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`from Ben-Gurion University in 1988.
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`11.
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`In 1992, I earned my Master of Science degree in Electrical and
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`Computer Engineering from Drexel University, which included performing
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`research at AT&T Bell Labs, Murray Hill, at the time considered the world “holy
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`grail” of speech processing research. My research was in the area of wideband
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`speech coding, and titled “Algorithm Development and Real-Time Implementation
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`of High-Quality 32kbps Wideband Speech Low-Delay Code-Excited Linear
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`Predictive (LD-CELP) Coder”. The work continued a prior research by E.
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`Ordentlich, and Y. Shoham who was also my M.Sc. research advisor. As a part of
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`my work, I have also implemented that algorithm in DSP Assembly Language on
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`two DSPs running in parallel. I subsequently co-authored and published two
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`articled about this work.
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`12.
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`I earned my Doctorate of Philosophy in Electrical and Computer
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`Engineering from the University of California at Santa Barbara in 2000.
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`13.
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`I have worked in the field of digital signal processing (“DSP”) for
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`over 25 years, and have extensive experience in DSP research, design, and
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`3
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`development, as well as the design and development of DSP-related software and
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`hardware. Presently, I am the CTO of Compandent, a technology company that
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`develops and provides telecommunication and DSP-related algorithms, software
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`and hardware products, real-time DSP systems, speech coding and speech
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`enhancement-related projects, and DSP, software, and hardware-related services.
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`While at Compandent, I have contributed to a speech coding algorithm and noise
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`canceller algorithm that has been adopted for secure voice communication by the
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`U.S. Department of Defense & NATO. Currently, I am supporting the DoD’s and
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`NATO’s use of these algorithms, and am performing real-time implementation
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`projects for DoD and NATO vendors, as well as the Defense Advanced Research
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`Projects Agency (DARPA).
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`14.
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`I have worked for numerous different companies in the field of digital
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`signal processing during my career. I am very familiar with most, if not all, speech
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`coding, speech enhancement, audio coding, and video coding techniques for
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`various applications. As part of my work, I have developed real-time DSP
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`systems, DSP software for telephony applications, various serial communication
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`software and hardware, and Internet communication software. I have led real-time
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`DSP and speech coding engineering groups in two high-tech companies before my
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`present company (Comverse Technology, Inc. and Optibase Ltd.), and, at DSP
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`4
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`Communications, Inc., I was involved with echo cancellation, noise cancellation,
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`and the creation of state-of-the-art chipsets for cellular telephones.
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`15.
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`I have been working with, and have written programs for, personal
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`computers since around 1986. Initially on DOS, and later on Windows 3.1,
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`Windows 96, Windows 98, and Windows 2000, Windows NT, Windows XP,
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`Windows 7, Windows 10, Apple computers, iOS, Unix, Linux, and Android
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`operating systems, ARM processors, as well as numerous Digital Signal Processors
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`(DSP). Much of my programming concerned digital signal processing, particularly
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`speech, audio and image coding, and communications.
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`16. From 2001, I also have been providing expert technology services in
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`patent disputes. My biography and experience relevant to my work in these
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`matters is more fully detailed in Attachment A.
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`17.
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`I have been the co-recipient, with Dr. Allen Gersho, of the Ericsson-
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`Nokia Best Paper Award for the paper: “Enhanced Waveform Interpolative Coding
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`at 4 kbps,” IEEE Workshop on Speech Coding, Finland, 1999. The IEEE
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`Workshop on Speech Coding is an exclusive workshop for speech-coding
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`researchers from around the world.
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`18.
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`I have authored and co-authored approximately eight journal
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`publications, in addition to conference proceedings, technical articles, technical
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`papers, book chapters, and technical presentations concerning a broad array of
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`5
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`signal processing technology. I have also developed and taught many courses
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`related to digital signal processing and signal processing systems. These courses
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`have included introductory level and advanced courses.
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`19.
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`I have several international patents related to the field of audio signal
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`enhancement, including U.S. Patent Nos. 6,614,370; 7,643,996; 7,010,482; and
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`7,584,095.
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`20.
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`I am being compensated at the rate of $525 per hour for my work in
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`connection with this matter. The compensation is not dependent in any way on the
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`contents of this report, the substance of any further opinions or testimony that I
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`may provide, or the ultimate outcome of this matter.
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`II. LIST OF DOCUMENTS CONSIDERED IN FORMULATING MY
`OPINIONS
`In formulating my opinions, I have reviewed and considered all of the
`21.
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`following documents:
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`EXHIBIT
`NO.
`1001
`1002
`1003
`1004
`1005
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`1008
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`
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`DESCRIPTION
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`U.S. Patent No. 6,807,524
`File history of U.S. Patent No. 6,807,524
`Declaration of Jordan Cohen, Ph.D., Under 37 C.F.R. § 1.68
`Curriculum Vitae of Jordan Cohen, Ph.D.
`Kroon, et al. (“Kroon”), 1986, “Regular-Pulse Excitation-A
`Novel Approach to Effective and Efficient Multipulse Coding
`of Speech,” IEEE TRANS. ON ACOUSTICS, SPEECH, AND
`SIGNAL PROCESSING, ASSP-34(5), pg. 1054-1063,
`obtained from the Library of Congress
`Salami, R., LaFlamme, C., Adoul, J-P. (“Salami”), 1992,
`“Real-Time Implementation of a 9.6 Kbit/s ACELP Wideband
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`6
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`1012
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`1014
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`1014
`1018
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`1019
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`1021
`1022
`1023
`1024
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`1025
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`1026
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`1027
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`Speech Coder,” ORLANDO GLOBECOM ’92
`COMMUNICATION FOR GLOBAL USERS, Vol. 1, pg. 447-
`451, obtained from the United States Naval Academy Nimitz
`Library.
`Salami, R., LaFlamme, C., Adoul, J-P., 1992, “Real-Time
`Implementation of a 9.6 Kbit/s ACELP Wideband Speech
`Coder,” Orlando Globecom ’92 Communication for Global
`Users, Vol. 1, pp.447-451, obtained from the Library of
`Congress.
`Lim, J., Oppenheim, Alan (“Lim”), 1979, “Enhancement and
`Bandwidth Compression of Noisy Speech,” PROC. OF THE
`IEEE, Vol. 67, pp.1586-1604, obtained from the Library of
`Congress
`Declaration of Christian Loyau Under 37 C.F.R. § 1.68
`Joint Claim Construction Chart in Saint Lawrence
`Communications LLC v. Apple Inc., et al., 2-16-cv-00082
`(E.D. Tex 2017).
`Claim Construction Order in Saint Lawrence Communications
`LLC v. ZTE Corporation, et al., 2-15-cv-00349 (E.D. Tex
`2016).
`U.S. Patent No. 5,295,224 to Makamura et al. (“Makamura”)
`U.S. Patent No. 5,235,669 to Ordentlich et al. (“Ordentlich”)
`U.S. Patent No. 7,599,832 to Lin et al. (“Lin”)
`“A wideband codec at 16/24 kbit/s with 10 ms frames,” IEEE
`WORKSHOP ON SPEECH CODING FOR TELECOM., 103-
`104 (Sept. 1997) to R. Salami and R. Lefebvre et al. (“Salami-
`97”)
`“Energy-Based Effective Length of the Impulse Response of a
`Recursive Filter,” ICASSP ’98 PROCEEDINGS OF THE 1998
`IEEE INTERNATIONAL CONFERENCE ON ACOUSTICS,
`SPEECH, AND SIGNAL PROCESSING, Vol. 3, 1253-56
`(May 1998) to Laakso et al. (“Laakso”)
`“Fast CELP coding based on algebraic codes,” ICASSP ’87,
`PROC. 1987 IEEE INTL. CONF. ACOUSTICS, SPEECH,
`AND SIGNAL PROCESSING (1987) to Adoul et al.
`(“Adoul”)
`“Predictive Coding of Speech Signals and Subjective Error
`Criteria,” IEEE TRANS. ACOUSTICS, SPEECH, AND
`SIGNAL PROCESSING (1979) to Atal et al. (“Atal 1979”)
`
`7
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`
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`1028
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`1029
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`1030
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`1031
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`1032
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`1033
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`1034
`1035
`1036
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`1037
`1038
`1039
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`1040
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`1041
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`“A New Model of LPC Excitation for Producing Natural-
`Sounding Speech at Low Bit Rates,” ICASSP ’82, PROC. 1982
`IEEE INTL. CONF. ACOUSTICS, SPEECH, AND SIGNAL
`PROCESSING (1982) to Atal et al. (“Atal 1982”)
`“Efficient Vector Quantization of LPC Parameters for
`Harmonic Speech Coding,” PH.D. THESIS, SIMON FRASER
`UNIV. (Oct. 1996) to B. Bhattacharya (“Bhattacharya”)
`“Speech Processing with Linear and Neural network Models,”
`PH.D. THESIS, UNIV. OF CAMBRIDGE (1996) to T. L.
`Burrows (“Burrows”)
`“Waveform Interpolation Speech Coder at 4 kb/s,” M.S.
`THESIS, MCGILL UNIVERSITY (Aug. 1998) to E. Choy
`(“Choy”)
`“Efficient Calculation of Spectral Tilt from Various LPC
`Parameters,” NAVAL COMMAND, CONTROL AND
`OCEAN SURVEILLANCE CENTER (NCCOSC), No. 92152-
`52001 (May 1996) to Goncharoff et al. (“Goncharoff”)
`“On Fast FIR Filters Implemented as Tail-Canceling IIR
`Filters,” IEEE TRANS. SIGNAL PROCESSING (Jun 1997) to
`Wang et al. (“Wang”)
`GSM 06.10, v5.0.1 (1997) (“GSM 06.10”)
`GSM 06.60, v5.0.0 (1996) (“GSM 06.10”)
`“Analog to Digital Conversion of Voice by 2,400 Bit/Second
`Linear Predictive Coding,” FEDERAL STANDARD 1015
`(Dec. 1996) (“FS1015-LPC10”)
`ITU G.728 (1992) (“G.728”)
`ITU G.729 (1996) (“G.729”)
`“16 kbps Wideband and Speech Coding Technique Based on
`Algebraic CELP,” ICASSP ’91 PROCEEDINGS OF THE
`1991 IEEE INTERNATIONAL CONFERENCE ON
`ACOUSTICS, SPEECH, AND SIGNAL PROCESSING
`(1991) to Laflamme et al. (“Laflamme”)
`“High Quality Coding of Wideband Audio Signals Using
`Transform Coded Excitation (TCX),” ICASSP ’94
`PROCEEDINGS OF THE 1994 IEEE INTERNATIONAL
`CONFERENCE ON ACOUSTICS, SPEECH, AND SIGNAL
`PROCESSING (1994) to Lefebvre, et. al. (“Lefebvre”)
`“RPCELP: A high quality and low complexity scheme for
`narrow band coding of speech,” CONF. PROC. ON AREA
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`8
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`
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`
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`1042
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`1043
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`1044
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`1045
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`1046
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`1047
`
`2001
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`2002
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`2003
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`2005
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`2006
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`2007
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`COMM. EUROCON-88 (1988) to Lever et al. (“Lever”)
`“Low Delay Code Excited Linear Predictive (LD-CELP)
`Coding of Wide Band Speech at 32kbits/sec,” M.S. THESIS,
`MASSACHUSETTS INSTITUTE OF TECHNOLOGY (April
`1, 1990) to E. Ordentlich (“Ordentlich Thesis”)
`“Extrapolation of Wideband Speech From the Telephone
`Band,” MASTER’S THESIs, UNIVERSITY OF TORONTO
`(1997) to A. A. Pyke (“Pyke”)
`“Design and Description of CS-ACELP: A Toll Quality 8 kb/s
`Speech Coder,” IEEE TRANS. SPEECH AND AUDIO
`PROCESSING (Mar. 1998) to Salami et al. (“Salami-1998)
`“A 13.0 kbit/s Wideband Speech Codec Based on SB-ACELP,”
`ICASSP ’98 PROCEEDINGS OF THE 1998 IEEE
`INTERNATIONAL CONFERENCE ON ACOUSTICS,
`SPEECH, AND SIGNAL PROCESSING (1998) to J.
`Schnitzler (“Schnitzler”)
`“Code-Excited Linear Prediction (CELP): High-Quality Speech
`at Very Low Bit Rates,” ICASSP ’85, PROC. 1985 IEEE
`INTL. CONF. ACOUSTICS, SPEECH, AND SIGNAL
`PROCESSING (1985) to Schroeder, et. al. (“Schroeder”)
`“Speech Coding: A Tutorial Review,” PROC. OF THE IEEE,
`vol. 82, no. 10 (Oct. 1997) to Spanias (“Spanias”)
`P. Mermelstein, “G.722, A new CCITT Coding Standard for
`Digital Transmission of Wideband Audio Signals,” IEEE
`Comm. Mag., Vol. 26, No. 1, pp. 8-15, Jan. 1988.
`Fuemmeler et. al, “Techniques for the Regeneration of
`Wideband Speech from Narrowband Speech,” EURASIP
`Journal on Applied Signal Processing 2001:0, 1-9 (Sep. 2001).
`C.H. Ritz et. al., “Lossless Wideband Speech Coding,” 10th
`Australian Int’l. Conference on Speech Science & Technology,
`p. 249 (Dec. 2004).
`“Discrete-Time Signal Processing,” by Alan V. Oppenheim,
`Ronald W. Schafer
` https://www.mathworks.com/help/matlab/math/random-
`numbers-with-specific-mean-and-variance.html
`Transcript of Deposition of Dr. Johnson
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`9
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`2008
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`2009
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`2010
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`2011
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`2012
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`2013
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`2014
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`2015
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`2016
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`2017
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`2018
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`O. Gottesman and A. Gersho, “Enhanced Waveform
`Interpolative Coding at Low Bit Rate,” in IEEE Transactions
`on Speech and Audio Processing, vol. 9, November 2001, pp.
`786-798
`O. Gottesman and A. Gersho, “Enhancing Waveform
`Interpolative Coding with Weighted REW Paramertric
`Quantization,” in IEEE Workshop on Speech Coding
`Proceedings, pp. 50-52, September 2000, Wisconsin, USA
`O. Gottesman and A. Gersho, “High Quality Enhanced
`Waveform Interpolative Coding at 2.8 kbps,” in Proc. IEEE
`ICASSP’2000, vol. III, pp. 1363-1366, June 5-9, 2000,
`Istanbul, Turkey.
`O. Gottesman and A. Gersho, “Enhanced Analysis-by-
`Synthesis Waveform Interpolative Coding at 4 kbps,”
`EUROSPEECH’99, pp. 1443-1446, 1999, Hungary
`O. Gottesman and A. Gersho, “Enhanced Waveform
`Interpolative Coding at 4 kbps,” IEEE Workshop on Speech
`Coding Proceedings, pp. 90-92, 1999, Finland
`O. Gottesman, “Dispersion Phase Vector Quantization For
`Enhancement of Waveform Interpolative Coder,” IEEE
`ICASSP’99, vol. 1, pp. 269-272, 1999
`O. Gottesman and Y. Shoham, “Real-Time Implementation of
`High Quality 32 kbps Wideband Speech LD-CELP Coder,”
`EUROSPEECH’93, 1993
`Oded Gottesman, “Redundant compression of techniques for
`transmitting data over degraded communication links and/or
`storing data on media subject to degradation,” U.S. Patent
`6,614,370
`Oded Gottesman, “Enhanced waveform interpolative coder,”
`U.S. Patent 7,643,996
`Oded Gottesman and Allen Gersho, “REW parametric vector
`quantization and dual-predictive SEW vector quantization for
`waveform interpolative coding”, U.S. Patent 7,584,095
`Oded Gottesman and Allen Gersho, “REW parametric vector
`quantization and dual-predictive SEW vector quantization for
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`waveform interpolative coding”, U.S. Patent 7,010,482
`Rabiner and Schafer, “Digital Processing Of Speech Signals,”
`Prentice Hall Inc., 1978.
`
`22.
`
`I have reviewed and am familiar with the response to Petition
`
`submitted on behalf of Patent Owner with this Declaration and I agree with the
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`technical analysis that underlies the positions set forth in the response to Petition.
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`23.
`
`I have reviewed and am familiar with the Petition submitted by
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`Petitioner, and I disagree with some of it, and with its conclusions. I have
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`reviewed and considered Dr. Cohen’s Report submitted on behalf of Petitioner, and
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`I disagree with some of it, and with its conclusions.
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`24.
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`I may consider additional documents as they become available or that
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`are necessary to form my opinions. I reserve the right to revise, supplement, or
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`amend my opinions based on new information and on my continuing analysis.
`
`III. TECHNICAL BACKGROUND AND THE ‘524 PATENT
`25. As evidenced by its title, the patent in dispute relates to a perceptual
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`weighting device and to a method for efficient coding of wideband signals. This
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`title already expresses clearly the most important features of the present invention.
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`First of all, the title already indicates that the invention deals with the processing of
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`wideband signals. This means signals, in particular speech signals, covering a
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`frequency range of approximately 50 Hz – 7,000 Hz. Therefore, with respect to the
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`frequency range covered by them, these wideband signals differ distinctly from
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`narrowband and/or telephone band signals which merely cover the frequency range
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`of 200 Hz to 3,400 Hz.
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`26.
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`In order to be able to transmit speech data with high quality in mobile
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`communications networks despite the limited transmission capacities of mobile
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`communications networks, the speech data have to be encoded efficiently. For
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`speech data in the telephone band the CELP method is a technology for this
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`purpose, which significantly reduces the quantity of data to be transmitted without
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`impairing the speech quality excessively. Due to the particular properties of
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`wideband signals, however, it is not readily possible to use the CELP method for
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`them. In order to be able to use the CELP method for wideband signals, it must
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`therefore be adapted to the specific properties of the wideband signals in many
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`respects. The ‘524 patent deals with one of these adaptations.
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`27. The ‘524 patent relates to the digital encoding of wideband signals, in
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`particular speech signals. In detail it relates to a perceptual weighting device and to
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`a method for producing a perceptually weighted signal in response to a wideband
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`signal (approximately 50 – 7,000 Hz) in order to reduce a difference between a
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`weighted wideband signal and a subsequently synthesized weighted wideband
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`signal.
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`Declaration of Oded Gottesman, Ph.D.
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`28. As is detailed in the patent in dispute, Code Excited Linear Prediction
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`(CELP) technology is a technology for encoding speech/audio signals which is
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`capable of achieving good speech quality with moderate bit rate.
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`29. When applying the CELP model to wideband signals, however,
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`practical problems of calculating precision will occur if a so-called fixed point
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`implementation is required, as was the case at the filing date due to the then very
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`restricted computer capacity in mobile communications applications. The
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`consequence of a fixed point implementation is that only a restricted number of
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`decimals are available for the sum of integer places and decimal places in the case
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`of calculating operations. This means that rounding takes place for the respective
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`calculating operations. This has a correspondingly disadvantageous effect in the
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`case of complex arithmetic calculations, for instance, of the coefficients of the LP
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`synthesis filter 1/A(𝑧). Moreover, in wideband signals, due to the larger difference
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`between maximum and minimum values of the speech signal in the frequency
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`range as compared to narrowband signals, with a predetermined number of bits per
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`signal value even less decimals are available. Therefore, due to the fixed point
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`implementation, rounding errors have a stronger effect with wideband signals than
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`with narrowband signals.
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`30. For the teaching of the ‘524 patent, a perceptual weighting filter,
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`which requires complex calculating operations is significant. With a view to
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`additional calculative requirements in the case of wideband signals it is, pursuant
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`to the findings of the inventors of the ‘524 patent, deemed to be necessary that the
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`perceptual weighting filter is modified. The calculating operations are simplified
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`with the perceptual weighting filter used in accordance with the invention and the
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`requirements of fixed point implementation are met more favorably.
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`31. When encoding speech signals by means of the CELP technology,
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`noise which is based on encoding losses, i.e. deviations between the encoded
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`speech signal and the speech signal to be encoded, will inevitably be produced.
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`The corresponding noise signal has, due to the kind of its determination as a “mean
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`square error”, a flat spectrum, i.e. the energy of the noise signal is distributed
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`evenly across all frequencies.
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`32. The function of the perceptual weighting filter is to shape the
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`spectrum of the encoding noise signal by means of re-weighting such that with
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`frequencies at which the speech signal has high energy the amplitudes of the noise
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`signal are also emphasized. An example of the mentioned noise spectrum which is
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`flat prior to re-weighting is illustrated in the following as a straight dashed line
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`(red).
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`33. The illustration shows that it is a problem that the unshaped flat noise
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`spectrum with respect to the amplitude size (energy) partially lies distinctly above
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`the speech spectrum (continuous blue line), especially with low frequencies (thick
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`green arrow), but also with high frequencies (thick violet arrow). As a result,
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`especially the resulting high noise levels with low frequencies would be strongly
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`audible and irritating for the human ear.
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`34.
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`In order to avoid this effect of the flat noise spectrum, the noise
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`spectrum is weighted in analysis-by-synthesis encoders by a perceptual weighting
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`filter whose transmission function comprises something of the formant structure of
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`the input signal. The formant structure describes the distribution of frequencies
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`with high amplitudes of the speech signal and the corresponding amplitude
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`strength. Thus, the perceptual weighting filter uses the masking property of the
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`human ear by shaping the error spectrum. As a result, the noise spectrum filtered
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`through the perceptual weighting filter has more energy in the formant regions of
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`the speech spectrum where it is masked and/or concealed by the strong signal
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`energy available in these regions.
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`35. The above illustration shows an example of a perceptually shaped
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`noise spectrum as a red continuous line. This means that the energy of the noise
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`signal is concentrated at those frequencies at which it is “covered” (in technical
`
`terminology “masked”) by the speech signal which is even stronger there, and thus
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`cannot be perceived by human ears. Contrary to this, the energy of the noise signal
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`is correspondingly decreased at those frequencies at which the speech signal has a
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`comparatively low energy. Thus, the noise which is otherwise “louder” as
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`compared to the speech signal is masked. This is also called “noise masking” (by
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`the perceptual properties of the human ear).
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`The known perceptual weighting filter requires complex arithmetic
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`calculations. With wideband signals such calculations are, however, a particular
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`challenge, especially within the limits of fixed point implementation. This is due to
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`the fact that a voiced speech signal typically has a comparatively high energy
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`content at low frequencies and a comparatively low energy content at high
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`frequencies. Now, wideband signals ranging from approximately 50 Hz to 7,000
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`Hz extend over a distinctly larger bandwidth than narrowband signals whose
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`bandwidth only covers the range of 200 Hz to 3,400 Hz.
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`36. Accordingly, due to the above described typical energy distribution
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`with voiced speech signals due to the larger bandwidth the difference between the
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`amplitude of the signal portion with the most energy at low frequency and that of
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`the signal portion with the least energy at high frequency (the so-called “spectral
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`dynamics”) is larger with the wideband speech signal than with the narrowband
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`speech signal. In a spectral presentation this fact may be illustrated in a simplified
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`manner as an inclined line (in the figure below) starting out from the signal portion
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`with the most energy at low frequency to the signal portion with the least energy at
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`high frequency. This is called spectral tilt in the ‘524 patent.
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`Spectral Tilt
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`37. For the reasons mentioned, the spectral tilt is larger with the wideband
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`signal than with the narrowband signal:
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`38. Consequently, the speech encoder for a wideband signal, contrary to a
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`narrowband signal and in the light of the limitations by the fixed point
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`implementation and the resulting rounding errors, has to overcome two problems,
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`namely:
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`effect a good noise masking by a suitable perceptual weighting filter, and
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`concurrently get under control the large spectral tilt with the arithmetic
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`calculations required for encoding.
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`39. As explained in the `524 Patent, a known perceptual weighting filter
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`was, due to inherent limitations, not suitable for solving these problems. The
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`known filter is inter alia not capable of taking into adequate account the spectral
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`tilt and concurrently shaping the spectrum of the encoding noise such that it is, in
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`the regions with a strong speech signal – namely the regions of the formants -
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`covered or masked by the latter (“modelling the formant structure”).
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`40. A part of the solution in accordance with the invention is, on the one
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`hand, to use a modified filter instead of the known perceptual weighting filter and,
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`on the other hand, to mitigate the larger spectral tilt (and the resulting calculating
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`problems) by emphasizing the energy content of the speech signal and hence the
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`course of the speech signal spectrum at high frequencies prior to encoding (“pre-
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`emphasis” by a so-called “pre-emphasis filter”). This reduces the dynamics and
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`hence the “tilt” in the speech signal spectrum from high values at low frequencies
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`to low values at high frequencies. This in turn mitigates the problems of
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`calculating precision mentioned if fixed point implementations are to be used for
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`the magnitudes to be calculated in the scope of encoding.
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`41. The use of such a pre-emphasis filter is, however, not readily possible
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`because spectral tilt and formant structure are coupled, so that the spectral tilt
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`normally cannot be modified without the quality of modelling of the formant
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`Inter Partes Review of USPN 6,807,524
`Declaration of Oded Gottesman, Ph.D.
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`structure being influenced. A further contribution of the solution according to the
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`invention thus is the proposal of how to decouple these magnitudes.
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`42. The object (the technical problem) underlying the patent in dispute is
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`therefore to provide a perceptual weighting device and method adapted to
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`wideband signals, using a modified perceptual weighting filter to obtain a high
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`quality reconstructed speech signal (by synthesis), these device and method
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`enabling fixed point algorithmic implementation.
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`43. The solution proposed by the `524 Patent provides a signal pre-
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`emphasis filter for filtering the speech input signal to be encoded, to calculate the
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`synthesis filter coefficients on the basis of the pre-emphasized signal, and to use a
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`modified perceptual weighting filter with fixed denominator (i.e., with a
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`denominator filter function that does not change with time and is independent of
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`the speech signal) whereby the weighting of the wideband signal in a formant
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`region is substantially decoupled from a spectral tilt of the wideband signal.
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`44. The signal pre-emphasis filter for reducing the spectral tilt of a
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`wideband signal to be encoded is accordingly a central aspect of the invention of
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`the patent in dispute. Another important aspect consists in choosing the modified
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`perceptual weighting filter with fixed denominator such that the weighting of the
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`wideband signal in a formant region is substantially decoupled from the signal pre-
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`emphasis for reducing the spectral tilt of the wideband signal.
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