UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`ZTE (USA) INC.
`SAMSUNG ELECTRONICS Co., LTD.
`SAMSUNG ELECTRONICS AMERICA, INC.,
`Petitioners,
`
`v.
`
`FUNDAMENTAL INNOVATION SYSTEMS INTERNATIONAL LLC,
`Patent Owner.
`___________________
`
`Case IPR2018-00215
`Patent No. 8,232,766
`___________________
`
`DECLARATION OF ROBERT BARANOWSKI IN SUPPORT OF
`PATENT OWNER PRELIMINARY RESPONSE
`
`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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`10495494
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`Fundamental Ex 2009-1
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`Fundamental Ex 2002-1
`ZTE et al v Fundamental
`IPR2018-00215
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`
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`ZTE (USA) INC.
`SAMSUNG ELECTRONICS Co., LTD.
`SAMSUNG ELECTRONICS AMERICA, INC.,
`Petitioners,
`
`v.
`
`FUNDAMENTAL INNOVATION SYSTEMS INTERNATIONAL LLC,
`Patent Owner.
`___________________
`
`Case IPR2018-00215
`Patent No. 8,232,766
`___________________
`
`DECLARATION OF ROBERT BARANOWSKI IN SUPPORT OF
`PATENT OWNER PRELIMINARY RESPONSE
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`10495494
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`Fundamental Ex 2009-1
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`I.
`
`Introduction
`1. My name is Robert Baranowski. I have been asked by Fundamental
`
`Innovation Systems International LLC (“Patent Owner”) to explain certain issues
`
`related to the technologies involved in U.S. 8,232,766, the technologies described
`
`in the cited references, the knowledge of a person of ordinary skill in the art at the
`
`time of the invention, and other pertinent facts and opinions regarding IPR2018-
`
`00215. My qualifications are summarized below and are addressed more fully in
`
`my CV attached as Exhibit 2009.
`
`2.
`
`I am currently the President of Left Coast Engineering in Escondido,
`
`California, an engineering service company. My position includes consulting work
`
`on a variety of power electronics and wireless communications devices. Because
`
`most of the products my company works on are portable, we work with battery
`
`chargers almost every day.
`
`3.
`
`I received a Bachelor of Electrical Engineering Degree from
`
`Villanova University in 1990, and a Master of Science in Electrical Engineering
`
`Degree from Villanova University in 1991.
`
`4.
`
`For the past 26 years, I have been involved in the design and
`
`development of electronic devices, and especially digital wireless
`
`telecommunications devices. My work has involved the design of integrated
`
`circuits that involve power management, battery charging and USB interface for
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`telecommunications devices. While at Motorola from March 1992 to November
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`1997, I worked on several telecommunications products that were battery powered
`
`and contained internal battery chargers and accessory connectors that brought
`
`external power into the device (sometimes referred to as J3). After Motorola, I
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`worked for Sony Electronics from December 1997 to September 1999, also
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`designing telecommunication devices that were battery powered. During the time I
`
`was working for Motorola and Sony, USB was starting to be looked at as a
`
`possible power source for the internal chargers for telecommunication devices. I
`
`was intimately involved in this field during the time of the U.S. 8,232,766.
`
`5.
`
`After graduating from Villanova I worked for two cellular handset
`
`manufacturers over the course of 8 years before founding the engineering product
`
`design company. For the handset manufacturers I performed product design work
`
`on various aspects of the cellular handsets, including power supplies, power
`
`distribution, battery chargers, battery monitoring, and applying a variety of
`
`techniques to reduce battery consumption, decrease battery charge times, and
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`integrate into smaller and smaller spaces available in the cellular handsets.
`
`6.
`
`As part of my design work for these handset manufacturers, I was
`
`awarded several patents. Throughout my career, I have been the sole or co-
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`inventor on 18 United States patents related to battery chargers, power regulator
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`circuits, wireless tracking systems, and other electronics-related devices and
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`systems. I am also listed as an inventor on a large number of applications. The
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`patents are listed below:
`
`
`1
`2
`3
`4
`5
`
`6
`7
`
`8
`
`9
`
`10
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`17
`18
`
`
`
`6,813,608
`
`6,411,062
`
`6,370,401
`
`6,157,173
`
`Patent No. Title
`9,701,995
`Test cartridge for use in rapid analysis of biological samples
`9,701,994
`System for rapid analysis of biological samples
`9,023,640
`Device for rapid detection of infectious agents
`8,223,073
`Apparatus and method for a directional finder
`7,564,357 Wireless tracking system and method with optical tag
`removal detection
`7,486,648 Wireless extension of local area networks
`7,443,297 Wireless tracking system and method with optical tag
`removal detection
`7,336,182 Wireless tracking system and method with optical tag
`removal detection
`System and method for enhancing user experience in a
`wide-area facility having a distributed, bounded
`environment
`Interoperable am/fm headset wireless telephone device
`6,658,267
`6,473,630 Method and apparatus for powering a wireless headset used
`with a personal electronic device
`Quick release battery and clip for portable device and
`method of implementing same
`Storage case and method for a wireless headset with a
`microphone suspended between earpieces of the headset
`Circuit and method for sharing current between a portable
`device and a battery charger
`Battery dropout correction for battery monitoring in mobile
`unit
`Battery charger with power dissipation control
`Voltage and current mode power regulator
`Adaptive radio receiver controller method and apparatus
`
`6,046,574
`
`5,703,470
`5,613,229
`5,428,820
`
`7.
`
`I have been asked by Fundamental Innovation Systems International
`
`LLC to explain the technologies involved in U.S. 8,232,766 and the cited exhibits.
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`8.
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`For the purpose of this declaration, I apply the same skill level as
`
`proposed in the Petition, although I reserve the right to explain why this level is too
`
`high. I met the qualifications of a person having ordinary skill in the art (proposed
`
`in the Petition) at the time of the ’766 patent filing date. I am being compensated
`
`for my work on this case at a fixed, hourly rate, plus reimbursement for expenses.
`
`My compensation does not depend on the outcome of this case or any issue in it,
`
`and I have no interest in this proceeding.
`
`II.
`
`Summary of Opinions
`9.
`Protocols are meant to be followed. A POSITA would recognize the
`
`importance of adhering to both USB and J3 three wire bus protocol.
`
`10. Petitioner proposes replacing the J3 connector in Theobald with a
`
`USB connector. Theobald expressly teaches signaling “according to” J3 protocol.
`
`The USB specification teaches the importance of using uniform and predictable
`
`data communication according to USB protocol. Thus, a POSITA seeking to
`
`replace the J3 connector in Theobald with a USB connector would understand the
`
`importance of adhering to USB protocol.
`
`III. The USB High Speed Data Communication Protocol
`11. USB was designed to allow for plug-and-play and expandable
`
`bidirectional communication channels and port expansion (that is, multiple devices
`
`can communicate with a host through a single port). Ex. 1007-17 (USB 1.1 Spec.).
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`Up to 127 USB devices can be directly or indirectly connected to a USB host. Ex.
`
`1008-41 (USB 2.0 Spec.). To prevent interruption to USB communications, “USB
`
`devices are required […] at all times to display behavior consistent with defined
`
`USB device states.” Id. at -50.
`
`12. The USB specification explains that “[t]he host controls all access to
`
`the USB. A USB device gains access to the bus only by being granted access by
`
`the host. The host is also responsible for monitoring the topology of the USB.” Id.
`
`at -55.
`
`13. The USB specification further explains that “[t]he USB’s bandwidth
`
`capacity can be allocated among many different data streams. This allows a wide
`
`range of devices to be attached to the USB. Further, different device bit rates, with
`
`a wide dynamic range, can be concurrently supported.” Id. at -49. “The USB
`
`Specification defines the rules for how each transfer type is allowed access to the
`
`bus.” Id.
`
`14. The USB specification also explains that “[t]he types of functionality
`
`provided by USB devices vary widely. However, all USB logical devices present
`
`the same basic interface to the host. This allows the host to manage the USB-
`
`relevant aspects of different USB devices in the same manner.” Id. at -56.
`
`15. A POSITA would understand that a USB host and a connected device
`
`negotiate for power allocation so that sufficient power can be allocated to the
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`devices without overdrawing power from the host. Ex. 1007-195 (USB 1.1 Spec.),
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`Ex. 1008-200 to -202, -271 to -272 (USB 2.0 Spec.). Overdrawing power from the
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`host could cause the host to disable source power after detecting an overcurrent
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`condition, other devices to lose power, or the host to crash whereby all devices
`
`would become disconnected.
`
`16. USB defines a handshaking protocol called enumeration by which the
`
`host identifies, addresses and configures each peripheral device. Ex. 1007-36, -195
`
`(USB 1.1 Spec.); Ex. 1008-48, -200 to -202, -271 to -272 (USB 2.0 Spec.). The
`
`USB specification states that “[d]etection of attach and detach and system-level
`
`configuration of resources” is a necessary aspect of maintaining a robust USB.
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`Configuration of the device occurs after all of the other steps in the enumeration
`
`process are complete.
`
`17. Before a device is configured, the device may only respond to
`
`standard requests, and thus none of the device-specific requests generally needed
`
`in order to operate a connected USB device are available. Ex. 2010-5 to -6 (USB
`
`Complete Book).
`
`18. After the device is configured and the enumeration process is
`
`complete, the device may send and receive operational data over the D+ and D-
`
`lines in accordance with the USB specification. Id. The USB specification states
`
`that “[b]efore a function can be used, it must be configured by the host.” Ex.1008-
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`52 (USB 2.0 Spec.).
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`19. A POSITA would understand that USB can only achieve its goal and
`
`provide a robust interface for plug-and-play connection of devices to a host by
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`ensuring that “all USB logical devices present the same basic interface to the host”
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`and thereby allow “the host to manage the USB-relevant aspects of different USB
`
`devices in the same manner.” Id. at -56 (USB 2.0 Spec.). A POSITA would also
`
`understand that enumeration is the process defined by USB specifically for
`
`identifying and configuring attached USB devices.
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`20. A POSITA would have followed the standards and processes
`
`specified in the USB protocol. A POSITA would also understand the advantages
`
`of adhering to the USB protocol. For example, a POSITA would understand that
`
`following USB protocol would allow for proper operation of any USB compatible
`
`device and reduce the risk of interrupting communication on the USB. Further, a
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`POSITA would understand that disregarding the USB specification and
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`transmitting an abnormal data signal would risk interrupting communications and
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`undermining the robustness of the USB.
`
`21. Finally, a POSITA would understand that the amount of power
`
`supplied by a USB host is limited to one unit load (100mA) until it is configured
`
`through the USB interface, at which point and if the configuration allows, can draw
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`a maximum of five unit loads (500mA). Ex. 1007-158 (USB 1.1 Spec.); Ex. 1008-
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`206 (USB 2.0 Spec.).
`
`IV. Motorola’s J3 Connector Communicates Data According To J3
`Protocol (The Three-Wire Bus Protocol)
`22.
`I worked for Motorola’s Cellular Subscriber Group from 1992 to
`
`1997. During that time, I worked on several telecommunications devices that had
`
`an accessory connector at the bottom of the device. This accessory connector was
`
`referred to as J3 when I started with Motorola. It contained power, audio, and
`
`digital signals needed to power the device, charge the battery, and interface with
`
`the device’s accessories. Motorola was producing the MicroTAC when I started,
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`and product models progressed through the StarTAC while I was there. During my
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`tenure, the J3 connector varied slightly between models, but still provided similar
`
`interfaces of power, audio, and digital signals. Several years after I left, Motorola
`
`produced its first device with a USB interface in place of the accessory connector.
`
`23. Below is a picture of the J3connector that was used with the Micro
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`TAC 5200 and 7200 flip phone:
`
`1
`
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`1 Ex. 2012, http://www.herwell-
`asia.com/mob%20phone%20conn/Motorola%20Micro%20TAC%205200%207200
`.jpg
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`24. The J3 connector has eight pins with the following functions2:
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`3
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`1 - ground
`
`2 - connection to an external battery, e.g. 7.5V.
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`3-5: - Proprietary digital serial communication bus. These are wires
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`used in the three-wire bus protocol referenced in Theobald.
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`6 - a clean ground for external speakers/microphones.
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`7 - an external speaker signal [analog]
`
`8 - an external microphone signal [analog]
`
`25. Devices and accessories that implement the J3 connector
`
`communicate data on the R, T, and C data lines (pins 3-5 in figure above)
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`according to Motorola’s J3 three wire bus protocol. Ensuring consistent data
`
`communications across the R/T/C data lines according to the J3 three wire bus
`
`protocol was critical for maintaining interoperability and backwards compatibility
`
`
`2 See, e.g. Ex. 2013 (US 5,214,774) at 6:37-48 (describing Motorola three-
`wire bus protocol and R T C data pins).
`3 Ex. 2014-35, http://qsl.net/n9zia/cell2900/motorola.txt.
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`between different Motorola devices and accessories.
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`26. Motorola’s J3 connector and J3 three wire bus protocol are
`
`proprietary. Motorola determines how devices and accessories communicate data
`
`across the R/T/C data lines on the J3 connector. Motorola is not bound by the USB
`
`specification or any other protocol. Motorola designs its products with J3
`
`connectors to strictly adhere to the J3 protocol.
`
`27. During my time designing and implementing devices with the J3
`
`connector for Motorola, I followed and adhered to the J3 three wire bus protocol.
`
`Neither I nor anyone I worked with deviated from the protocol to maintain
`
`interoperability with the large array of accessory products available. Compliance
`
`with the J3 three wire bus protocol was critical in the design of all J3 devices and
`
`accessories. It was understood by a POSITA that failing to follow the J3 three
`
`wire bus protocol would very likely create unpredictable results and device failure,
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`threatening the interruption of data communications and undermining the
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`robustness of the J3 communication lines. Adherence to the J3 three wire bus
`
`protocol ensured backwards compatibility between accessories and devices over
`
`time.
`
`V. The Petition’s Theobald/Shiga Combination
`28.
` The Petition proposes combining Theobald with Shiga as follows:
`
`In arriving at the Theobald/Shiga combination, POSITAs would have
`started with Theobald’s controller embodiment (see Section V.A.2) and
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`made a few trivial modifications: (1) using a USB interface (disclosed in
`Shiga) in place of the J3 interface; (2) using Shiga’s fourth-mode signals
`(i.e., logic high signals on D+ and D-, each signal having 3V and 50 ms) as
`the “predefined identification information” that Theobald’s controller
`embodiment calls for; and (3) implementing routine programming into
`circuitry 170 and controller 108 in order to communicate the fourth-mode
`signals. The following figure shows the structure of the resulting
`Theobald/Shiga combination.
`
`Pet. at 33-34. The Petition proposes a combined figure as follows:
`
`Id. at 34.
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`29. First, I would like to point out that this figure does not appear in either
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`Theobald or Shiga. It was created by Petitioner. Second, Theobald does not
`
`provide any express teaching to replace the J3 interface with a USB interface or for
`
`the accessory 104 to be a USB accessory. In fact, there is no mention of USB or
`
`Universal Serial Bus in Theobald.
`
`30. Even if a POSITA were to replace the J3 adapter with a USB adaptor
`
`and interface with a USB accessory (as proposed by the Petition), the POSITA
`
`would have adhered to the USB standard and protocol when making the
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`modification.
`
`31. The Petition contends that “[t]he Theobald/Shiga combination’s
`
`charging subsystem is enabled to draw this charging current (i.e., 850 mA).” Pet.
`
`at 48. In other words, the Petition contends that a POSITA would have used the
`
`same charger with the same current output on a USB interface that Theobald
`
`discloses using on a J3 interface. I disagree.
`
`32. A POSITA would have recognized that drawing 850 mA of current
`
`across a USB interface would violate the USB specification limit for current draw
`
`at no more than 500 mA. The POSITA would have ensured that the combined
`
`system interfacing with a USB adapter would not draw more than 500 mA
`
`pursuant to the USB specification, because a POSITA would have followed the
`
`USB specification power limits which require a device to draw no more than 500
`
`milliamps (mA) after configuration and 100 mA before configuration. See ¶ 21
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`(citing Ex. 1007-158; Ex. 1008-206). Neither the Petition nor the expert
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`declaration address this point or explain why a POSITA would ignore the USB
`
`specification protocol and draw current in excess of the USB limit.
`
`33. There is no teaching in Theobald for violating the three wire bus
`
`protocol in any manner. The 350 mA current for the mid-rate charger and 850 mA
`
`current for the fast rate charger disclosed in Theobald (Ex. 1005 at col. 4:41-55)
`
`are within the power limits of the J3 three wire bus protocol. Theobald discloses
`
`providing regulated power to prevent overdrawing power or current over the J3
`
`connector that could harm performance, cause overheating, or damage circuitry on
`
`electronic devices. Id.
`
`34. And the petition provides no explanation for why a POSITA reading
`
`Theobald and Shiga would expect an accessory designed for a J3 interface to be
`
`equally suitable for a USB interface. It would not, because the J3 three wire bus
`
`protocol has different power limits than the power limits defined in the USB
`
`specification. A POSITA would have designed the modified system to ensure
`
`adherence to the USB specification.
`
`35. The Petition thus does not address a fundamental issue: why a
`
`POSITA would have modified Theobald’s system with a USB connector but still
`
`left the modified device to receive the same supply voltage and draw the same
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`amount of current over a different connection type in violation of the applicable
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`USB current draw limits. Nor does the Petition point to any such teaching in the
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`cited references. The Petition does not provide a single reason why a POSITA
`
`would have drawn current at 850 mA in violation of USB limits.
`
`36. Connecting a device to a USB interface that draws 850 mA of current
`
`(over the USB limit of 500 mA) could cause a number of problems. For example,
`
`a POSITA would understand that the battery charge controller in the proposed
`
`mobile device would be configured to accommodate a 5.25V/500 mA power
`
`source in compliance with the USB specification. A POSITA would need to
`
`design and incorporate a different battery charge controller to accommodate the
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`8.6V/850mA power source in the proposed combination; or to design a new battery
`
`charger that can handle the dual input from the two different power inputs. These
`
`changes would add cost, complexity and potentially size to the resulting mobile
`
`device. A POSITA would have viewed such a consequence –increased cost,
`
`complexity and size -- as undesirable. The petition never addresses this point, or
`
`explains how a POSITA would have modified the mobile device’s charge
`
`controller to accommodate both 8.6V/850 mA and 5.25V/5 mA power sources.
`
`VI. The Petition Ignores Theobald’s Teaching of Following Communication
`Protocol
`37. The Petition states that “Theobald discloses that ‘the mid or fast rate
`
`chargers could be implemented with a logic circuit or a microcontroller that
`
`communicates predefined identification information to the controller 108 via the
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`data lines 190-192 and pins 182-184 upon attachment of the accessory 104.” Pet.
`
`at 29 (quoting Theobald 6:60-65) (second emphasis added), Fig 13 (reproduced
`
`without changes below).
`
`
`
`38. Theobald expressly teaches that data is communicated via data lines
`
`190-192 “according to the [Motorola4] three-wire bus protocol . . . or other suitable
`
`high speed data communication protocol”:
`
`[D]ata is communicated between the accessory circuitry
`170 and the controller 108 via the path of data line 190-
`
`
`4 The Petition recognizes that Theobald’s “controller” embodiment teaches
`signaling across Motorola’s proprietary J3-type connectors. See, e.g., Pet. at 33-
`34; see also Ex. 1005 (Theobald) at 1:23-35, 3:21-27, 6:6-18, 6:55-65.
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`Huawei v Fundamental
`IPR2018-00485
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`Fundamental Ex 2002-16
`ZTE et al v Fundamental
`IPR2018-00215
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`pin 181-pin 127-data line 134, the path of data line 191-
`pin 182-pin 128-data line 135, and the path of data line
`192-pin 184-pin 129-data line 136 according to the
`three-wire bus protocol utilized in radiotelephone
`products manufactured and sold by Motorola, Inc. or
`other suitable high speed data communication protocol;
`and the logic grounds are intercoupled via lines 193 and
`137 and pins 186 and 131.
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`Ex. 1005 (Theobald) at 6:10-19 (emphasis added).
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`39. Theobald’s teaching to communicate “according to” the three-wire
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`bus protocol over the R/T/C data lines is consistent with my experience designing
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`systems that interface with the J3 connector. A POSITA would understand that
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`Theobald expressly teaches signaling according to J3 specification on the J3 data
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`lines.
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`40. Based on this teaching in Theobald, the Petition states that in the
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`proposed combination “the accessory circuitry 170 communicates that predefined
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`identification information (i.e., the fourth mode signals (yellow)) to the controller
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`108 in order to identify the accessory 104 as a fast-rate charger.” Pet. 36. The
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`Petition explains that “USB connectors replace the J3 connectors, USB data lines
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`(D+, D) replace the J3 data lines (R, C, T), the USB power line (Vbus) replaces
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`the J3 power line (Ext B+), and the USB ground line (Gnd) replaces the J3 ground
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`IPR2018-00485
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`Fundamental Ex 2002-17
`ZTE et al v Fundamental
`IPR2018-00215
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`(Log Gnd).” Pet. at 34, 36, Fig 18 (reproduced without changes below).
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`41.
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`In the proposed Theobald/Shiga combination offered by the Petition,
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`the R/T/C data lines are replaced with D+ and D- USB lines. Given Theobald’s
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`teaching to adhere to the communication protocol, a POSITA would understand
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`that the combined system would also communicate over the D+ and D- data lines
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`in the proposed combination according to USB protocol.
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`VII. The Petition’s Proposed Combination Does Not Follow USB Protocol
`42. USB protocol requires devices to complete enumeration upon
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`attachment to a host or hub to configure devices so that they can function and to
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`Huawei v Fundamental
`IPR2018-00485
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`Fundamental Ex 2002-18
`ZTE et al v Fundamental
`IPR2018-00215
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`manage allocation of system resources.
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`43. The Petition stated that a POSITA would have had knowledge about
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`the USB 2.0 specification including the “Bus Enumeration” section which
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`“specifie[s] how the USB host is to configure a USB device.” Pet. at 5-6. The
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`Petition acknowledges that enumeration is the process specified by USB to
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`configure a USB device when it is attached to a powered port:
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`USB 2.0 also specified how the USB host is to configure
`a USB device. For example, USB 2.0 stated that “[w]hen
`a USB device is attached to or removed from the USB,
`the host uses a process known as bus enumeration to
`identify and manage the device state changes
`necessary.”44 In its “Bus Enumeration” section, USB 2.0
`specified the bus-enumeration requirements, including
`eight actions taken “[w]hen a USB device is attached to a
`powered port.”45
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`Id.
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`44. A POSITA who had knowledge of USB would understand that
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`enumeration is the method for signaling identification information upon the
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`connection of a device according to USB protocol. A POSITA would have
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`followed the bus enumeration protocol and signaling according to the USB
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`specification. A POSITA would further understand that bypassing enumeration
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`would limit the power received from the USB host to one unit load (100mA). See,
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`Huawei v Fundamental
`IPR2018-00485
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`Fundamental Ex 2002-19
`ZTE et al v Fundamental
`IPR2018-00215
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`Fundamental Ex 2009-20
`Huawei v Fundamental
`IPR2018-00485
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`Fundamental Ex 2002-20
`ZTE et al v Fundamental
`IPR2018-00215
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