`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________
`
`LG ELECTRONICS, INC., HTC AMERICA, INC., and
`LENOVO (UNITED STATES) INC.,
`Petitioners,
`
`v.
`
`KONINKLIJKE KPN N.V.,
`Patent Owner.
`
`__________
`
`Cases IPR2018-00558, IPR2018-01639 and IPR2018-01645
`Patent 9,014,667 B2
`__________
`
`Record of Oral Hearing
`Held April 11, 2019
`__________
`
`
`
`
`Before KEVIN F. TURNER, JONI Y. CHANG, and
`MICHELLE N. WORMMEESTER, Administrative Patent Judges.
`
`
`
`
`
`IPR2018-00558, IPR2018-01639 and IPR2018-01645
`Patent 9,014,667 B2
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`
`
`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`
`JEREMY J. MONALDO, ESQ.
`W. KARL RENNER, ESQ.
`JUN LI, ESQ.
`Fish & Richardson, P.C.
`1000 Maine Avenue, S.W.
`Suite 1000
`Washington, D.C. 20024
`202-626-7717 (Monaldo)
`202-626-6447 (Renner)
`
`
`
`ON BEHALF OF THE PATENT OWNER:
`
`
`LAWRENCE P. COGSWELL III, PHD, ESQ.
`MARK R. TREDINNICK, ESQ.
`Hamilton, Brook, Smith & Reynolds, P.C.
`155 Seaport Boulevard
`Boston, Massachusetts 02210
`617-607-5907 (Cogswell)
`978-202-3413 (Tredinnick)
`
`
`
`
`The above-entitled matter came on for hearing on Thursday, April
`
`11, 2019, commencing at 1:00 p.m. at the U.S. Patent and Trademark Office,
`600 Dulany Street, Alexandria, Virginia.
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`P R O C E E D I N G S
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`(1:01 p.m.)
`JUDGE WORMMEESTER: Good afternoon everyone. We have
`our final hearing in Case IPR2018-00558, which concerns U.S. Patent
`Number 9,014,667.
`We note that cases IPR2018-01639, and IPR2018-01645 have been
`joined with this case.
`I'm Judge Wormmeester. Judge Chang is here with me. And Judge
`Turner is appearing remotely.
`Let's get the parties' appearances, please. Who do we have for
`petitioner?
`MR. MONALDO: Thank you, Your Honor. For petitioner, LG
`Electronics, Incorporated, we have Jeremy Monaldo, Karl Renner, and Jun
`Li.
`
`We also have two co-petitioners in this case, and I think we have
`with us David Reed and Russ Korn, on behalf of Lenovo, and Joe Palys on
`behalf of HTC.
`JUDGE WORMMEESTER: Okay. And who will be presenting the
`argument?
`MR. MONALDO: I will be presenting, Your Honor.
`JUDGE WORMMEESTER: Okay, great. Thank you. And for
`patent owner, who do we have?
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`DR. COGSWELL: Good afternoon, Your Honors. Lawrence
`Cogswell, on behalf of patent owner, KPN. I will be presenting. And with
`me is co-counsel, Mark Tredinnick.
`JUDGE WORMMEESTER: Thank you. We set forth the procedure
`for today's hearing in our trial order, but just to remind everyone the way
`this will work.
`Each party will have 60 minutes to present arguments. Petitioner has
`the burden and will go first, and may reserve time for rebuttal.
`Patent owner will then have the opportunity to present its response.
`Please remember that Judge Turner will be unable to hear you unless
`you speak into the microphone.
`And when referring to any demonstrative, please state the slide
`number so that he can follow along.
`Also, this is a reminder that any of the demonstratives you submitted
`are not part of the record.
`The record of the hearing will be the transcript.
`We will give you a warning when you're into your rebuttal time or
`reaching the end of your argument time.
`Are there any questions before we start?
`MR. MONALDO: No questions from petitioner.
`DR. COGSWELL: No questions from patent owner, Your Honor.
`JUDGE WORMMEESTER: Okay, great. Will you be reserving
`time today?
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`MR. MONALDO: Yes, Your Honor. We'd like to reserve about 30
`minutes, depending on how the questioning goes.
`JUDGE WORMMEESTER: Okay.
`JUDGE TURNER: Judge Wormmeester, can I ask a quick question
`before we start?
`JUDGE WORMMEESTER: Of course.
`JUDGE TURNER: I -- from going through the record, it didn't look
`like patent owner actually had filed demonstratives. Is that correct?
`DR. COGSWELL: Yes, that's correct, Your Honor.
`JUDGE TURNER: Okay. So you're going to be referring to pages
`in the record, I hope, so that I don't get completely lost?
`DR. COGSWELL: Absolutely, Your Honor.
`JUDGE TURNER: Okay, thank you.
`I wanted to stress that because I, being remote, sometimes rely on the
`demonstratives, but I'm happy to, you know, look at pages of the record as
`long as you -- you're quite diligent about helping me out. So thank you.
`DR. COGSWELL: Absolutely. Thank you.
`JUDGE WORMMEESTER: All right counsel, when you're ready.
`MR. MONALDO: All right, Your Honor, we have printed copies of
`demonstratives that will be helpful to the local judges.
`JUDGE WORMMEESTER: Sure. Thank you.
`MR. MONALDO: May it please the board, my name is Jeremy
`Monaldo and I'm representing petitioner LG Electronics.
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`Today, we're here to discuss one IPR proceeding involving KPN’s
`’667 Patent.
`Moving to slide 3, you'll see we have just two instituted grounds in
`this proceeding involving just three claims.
`Importantly, only Claim 35 remains asserted in the District Court
`litigation between the parties.
`For that reason, my plan today is to focus on issues related to Claim
`35, in the ground 2 combination of Obhan, Taniguchi, and Budka.
`Moving to slide 4, you'll see that we provided a list of issues that are
`disputed in this case.
`The first issue, Issue 1, relates to the interpretation of the good till
`time disclosed in the Obhan reference, which is relevant to all of the claims
`in the proceeding.
`Issue 2 relates to arguments specific to Claims 31 and 33, and Issue
`3 relates to arguments specific to Claim 35.
`Because Claims 31 and 33 are no longer asserted in the litigation, my
`plan today is to start with Issue 1, have a discussion on Obhan's good till
`time, and then move to Issue 3 to discuss the issue specific to Claim 35.
`And in particular, the combination of Obhan and Taniguchi.
`I'll plan to rest on the briefing on Issue 2, in Claims 31 and 33, unless
`Your Honors have any questions on those claims, which I'd be happy to
`address.
`But I'd like to do so after we discuss Claim 35, and vet any questions
`on Claim 35.
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`So with that background, unless Your Honors have any questions
`before we begin, I'd like to discuss Obhan's good till time and move over to
`slide 6.
`So on slide 6, you'll see here Obhan's good till time presented in
`Figure 9B. The ACB includes three columns.
`It's the corridor number, the minimum access class, and the good till
`
`time.
`
`So, the ACB is the admission control block that is used in Obhan to
`govern access to its system.
`There's no dispute over the interpretation of corridor number or
`minimum access class. The dispute is over this good till time in column 3.
`Now, turning to Obhan specification, the text from Obhan on the
`lower portion of slide 6 describes the good till time as being a timestamp
`through which the respective ACB record is quote, valid.
`As we discuss in the petition, this timestamp specifies how long the
`ACB information is valid.
`In other words, how long the defined minimum access class is
`effective for use in controlling access to corridor 1.
`So let's take a look at an example. You can see here in the red
`highlighted record, the first record of the ACB, we have Corridor Number 1,
`a minimum access class of 9.
`And that is good until the clock value of 12:22:24. As such, this
`timestamp specifies that the minimum access class of 9 is valid for Corridor
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`1 until 12:22:24. And subscriber units with access classes lower than the
`number 9 will be denied access until that time is reached.
`After that time is reached, after 12:22:24, this record becomes
`invalid, and the minimum access class of 9 is no longer effective for use as
`an access restriction in corridor 1.
`So from this description, a person of ordinary skill in the art
`would've understood that Obhan's good till time specifies when the
`minimum access class for the corridor is valid, thereby defining a time slot
`when subscriber units with lower access classes will be denied access.
`So for these reasons, as we explained in the petition, Obhan's good
`till time defines a deny access time interval as set forth under the broadest
`reasonable interpretation of the ’667 Patent.
`Now, mind you, while this section of Obhan discusses validity of the
`ACB information, Obhan discusses updates to this ACB elsewhere.
`And you can see that in our slide 7. So moving to slide 7, we have
`two examples here where Obhan describes updating the ACB.
`Neither of these examples uses the good till time. The portion of
`Obhan reproduced at the left side of slide 7 confirms that Obhan's ACB is
`updated in response to a triggering event.
`And what are these triggering events?
`The triggering events include, and I'll quote, expiration of a periodic
`timer, notification from a base station that a BTS watermark has been
`passed, or another event which initiates an update by the SYM system.
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`None of these events use the good till time. The portion of Obhan
`reproduced at the right-hand side of slide 7 describes that Obhan updates the
`ACB when, quote, a periodic interval is met.
`Again, no mention of the good till time.
`Now, moving to slide 8, here you see two additional portions of
`Obhan's disclosure, where Obhan explains how the ACB is periodically
`updated in 15 minute time periods.
`As these portions set forth, Obhan's system measures -- and takes
`measurements of operational measurement data.
`And that's collected periodically in 15 minute time periods, and then
`used to update the ACB.
`These 15 minutes update periods are not defined -- do not coincide
`with the good till time that we saw in Figure 9B or in Figure 9A, which
`provides another depiction of the good till time.
`JUDGE WORMMEESTER: Counsel, if they did coincide with a
`good till time -- like, if the good till time was updated every 15 to 30
`minutes, would that change your analysis?
`MR. MONALDO: If the timers coincided with the good till time?
`JUDGE WORMMEESTER: Yes.
`MR. MONALDO: No, it would not change our analysis. That
`would just be an occurrence of the system where the timers themselves
`actually map to the ACB good till time. That could happen.
`JUDGE WORMMEESTER: Okay.
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`MR. MONALDO: Timers could coincide with the values, but at the
`end of the day, we have to look at the difference between the wording used.
`The good till time specifying when the record's valid, and these 15
`time periods would be when the ACB is updated.
`And you'd still need to look at the good till time to know whether
`your record is valid or not.
`JUDGE WORMMEESTER: Right. Okay. Thank you.
`MR. MONALDO: Yep, no problem. And so, we actually asked
`patent owner's experts, Mr. Bates, about these update periods during
`deposition, and he actually agreed with us that these portions of Obhan
`disclosed these 15 minute update time periods.
`But with that recognition, Mr. Bates could not explain how KPN's
`theory is supported in view of the disclosure in the example shown in
`Obhan's Figure 9A.
`So let's look at -- take a look at his testimony. It's in slide 10. As
`shown in testimony, the upper right side of slide 10 -- during deposition, as
`mentioned, we asked KPN's expert about these 15 minute time updates, and
`the expert confirmed, according to Obhan, the ACB is updated periodically,
`and it says there every 15 or 30 minutes.
`However, as you can see on the left-hand slide -- side of slide 10, we
`have a reproduction of Obhan's Figure 9A, where good till times for some of
`the cells -- for example, cell 4 and cell 8, which are circled in the graphic --
`they have update times that are set to 1800. These update times are more
`than five hours away from other update times shown in the ACB.
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`So these update times cannot be a timestamp that's defining these 15
`minute update periods. With the separation in time, it's just impossible.
`When we pointed out these discrepancies to KPN's expert, he
`couldn't offer any reasonable explanation.
`You can see he contends only that these times are anomalies, which
`are not explained by Obhan.
`So as his testimony confirms, KPN's update theory for the good till
`time simply just does not align with Obhan's disclosure, and cannot be used
`to explain Figure 9A.
`So with this background, to agree with KPN's interpretation of
`Obhan's good till time, you have to do three things.
`First, you have to ignore Obhan's use of the term valid, instead of the
`term update, when describing the good till time in Figures 9A and Figure
`9B.
`
`Second, you have to ignore Obhan's consistent disclosure of
`updating the ACB elsewhere without any reference to the good till time.
`And three, you have to accept that Obhan's disclosure has
`unexplained anomalies.
`The more reasonable option is to side with the interpretation offered
`by our expert, Mr. Bishop, where the good till time specifies the time slot
`during which the ACB record is valid.
`And Obhan checks that good till time to ensure the information it's
`using when controlling access through the ACB is actually valid at that time.
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`That it's not going and using invalid data. That would not be
`appropriate for access control.
`So for these reasons, a person of ordinary skill in the art would not
`view Obhan's good till time as the time that's specifying the update to the
`ACB.
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`Instead, as Mr. Bishop explained, a person of ordinary skill would
`have viewed Obhan's good till time as a deny access time interval that
`specifies a time slot where certain subscribers -- those subscribers below the
`minimum access class -- would be denied access.
`It's simple as that. That's our interpretation. Unless there are any
`questions on our interpretation --
`JUDGE TURNER: Sure, counsel. I'll take your invitation. I have a
`question.
`Going back to slide 10 -- I'm not sure if you're still there -- and
`looking at 9A, cell 1 is an access class 10 and has a certain good till time.
`And cell 8 is also a class 10 and has a different good till time.
`So, that would sort of suggest that perhaps the access class and the
`good till times don't have a one on one correspondence -- is maybe you're
`suggesting, or maybe I'm misunderstanding your --
`MR. MONALDO: I think that's right. There -- the good till time is
`not linked to any particular access class.
`So, what the -- what Obhan system does is it comes in and it looks at
`real-time load on the network, potential load on the network -- those are the
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`subscribers that we know exist but are not currently connected -- and it looks
`at historical load on the network.
`From that, what it does then is it derives two properties. The access
`class that's going to be supported, and the good till time. The time slot
`during which that access class will be valid.
`So there's not a one to one relationship where you link access classes
`of two good till times.
`Rather, what the system does is it looks at each corridor, looks at the
`demand, and then figures out both, one, the access class that it's going to
`support, and how long it's going to be supported.
`I think it's perhaps instructive -- maybe Jun, if we could show some
`description of Figure 4 in the specification?
`(No audible response.)
`MR. MONALDO: Anyways, I'll just refer to it.
`So if you're looking at Figure 4, there's some discussion in Figure 4
`about what these corridors really are and how these access classes are used.
`And so as one example they describe a dense, urban corridor. That
`dense, urban corridor is known to historically have high access during
`working hours. So that's shown and represented by this data.
`So when we know we're going to have high access during working
`hours, we maybe set a longer good till time -- know that we're going to need
`to restrict our low priority users for longer, such as the record is showing in
`Figure 4 with an 1800 time frame.
`Does that answer your question, Judge Turner?
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`JUDGE TURNER: It does. I guess my only -- my question in
`response would be, does that comport with what the claim says about denied
`access time interval?
`If they're not really -- if there's not a direct one on one
`correspondence, is it the same?
`I mean, I think patent owner is sort of suggesting that it has a
`different functionality, and you seem to be saying, oh yeah, there's a
`different functionality, but I guess it still comports with the claim?
`
`Maybe I'm -- again, maybe I'm missing something.
`MR. MONALDO: So, yeah, yeah. So, let me clarify. I'm not
`suggesting it has a different functionality.
`I'm suggesting that you can have the same access class with two
`different good till times.
`So in cell 1, you have access to class 10. You have good till time.
`20 -- 12:22:24, right?
`In cell 8, you have access to class 10. The same access class. You're
`using the same criteria threshold for gating what subscriber units can gain
`access to the network.
`You have a different good till time. 1800. But the good till time is
`serving the exact same purpose for cell 1 as it is for cell 8.
`In both cases, it's defining how long that access class is -- 10 -- is
`valid for that cell.
`So in cell 1, your access class of 10 is valid up until 12:22:24. So
`what the system's going to do is, if you have an access class that's lower -- a
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`device with a lower access class that's trying to access the network up until
`12:22:24, that access is going to be denied.
`Similarly, in cell 8, if you have a device -- a subscriber unit that
`comes in with an access class that's lower than 10, it's going to be denied,
`but it's going to be denied all the way up through 1800.
`It's not going to be denied at -- you know, it's going to be denied all
`the way up through 1800.
`It's not the same as cell number 1, but the functionality of the good
`till time in each case is the same.
`It's just a different time. That's all we're saying. And so maybe I can
`elaborate a little bit further.
`So in cell 1, at say 1:00 p.m., that's after the good till time. Well,
`this record is no longer valid.
`So that data would not be used by the system to restrict access in cell
`1. But, in cell 8 at 1:00 p.m., your data's still valid.
`It's before 1800. You're still within your deny access time interval.
`You're still within your slot.
`And the functionality of the good till time is used in the exact same
`way, but in this case, to continue denying access. Does that help?
`JUDGE TURNER: No, no, I understand your position. Thank you.
`MR. MONALDO: Okay. Thank you, Your Honor. All right, so is
`there any other questions on the good till time?
`(No audible response.)
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`MR. MONALDO: Okay, great. So with no further questions on the
`good till time and our interpretation, I'd like to move over to slide 24.
`And slide 24 relates to Issue 3 and Claim 35. And as shown on slide
`24, we've identified three sub-issues related to this ground 2 in our challenge
`to Claim 35.
`The first sub-issue relates to the combination of Obhan and
`Taniguchi.
`The second sub-issue relates to disclosure and obviousness of a
`message comprising information relating to a deny access time interval.
`And the third sub-issue relates to obviousness of transmission of an
`access request in accordance with that deny access time interval.
`Because the discussion of the combination and how this combination
`works I think largely covers the second and third sub-issues, my plan will be
`to start with discussion of the combination of Obhan and Taniguchi, and
`then see whether additional discussion is needed on the individual features
`of Claim 35.
`So moving to slide 25. On slide 25, we've reproduced here some
`very important disclosure from Obhan as it relates to this particular
`combination.
`Now recall, Obhan is an access control system that uses its ACB to
`control access to its network.
`As we've discussed, the ACB includes records that define for each
`cell or corridor, a minimum access class and an associated deny access time
`interval, the good till time.
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`When Obhan’s system receives an access request, such as initiation
`of a call, the system checks the ACB and allows that access request if the
`record is valid, and the access class for the requesting device actually meets
`the minimum access class set forth in the ACB.
`So the portion of Obhan on slide 25 describes an important example,
`where the subscriber units actually self-regulate their own access based on
`knowledge of whether or not the subscriber unit has access to the system.
`So, I'd like to take a look at the lower left text box on slide 25. Now,
`as shown in this text box, Obhan describes two different scenarios.
`The first scenario is described just above the highlighted text in this
`portion of slide 25.
`And that's a scenario where the subscriber unit knows whether or not
`it has access to the system.
`The second scenario is described just under the highlighted text. It is
`the scenario where the subscriber unit does not know whether it has access
`to the system.
`In the second scenario, the subscriber unit does not self-regulate.
`The subscriber unit -- it decides, do I want to make a call? And if it
`does, it sends that call and initiates the call, and the network is relied on to
`block the attempted call if the subscriber unit does not have access.
`In contrast, the first scenario is where the subscriber unit does know
`whether or not it has access, and actually self-regulates and prevents its own
`access to Obhan’s system based on that knowledge.
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`IPR2018-00558, IPR2018-01639 and IPR2018-01645
`Patent 9,014,667 B2
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`So let's review the highlighted text for a minute, and I'll quote. In
`the case of a low priority voice user, or a low priority data user, e.g. a
`vending machine, the origination of calls will be controlled by the subscriber
`unit to preclude call initiation when the subscriber unit does not have access.
`In this scenario, the subscriber unit is self-regulating its access to
`Obhan system, and it does not initiate an access request when it knows it
`will be denied.
`The detail missing from Obhan is how does the subscriber unit gain
`this knowledge? The knowledge of whether or not it has access.
`We know in this first scenario, Obhan’s subscriber unit has the
`knowledge. Obhan tells us that.
`Obhan simply fails to state where the subscriber unit received or
`learned of this information.
`So as discussed in our petition, an obvious solution for providing a
`subscriber unit with this knowledge is for the system to send a message
`informing the subscriber unit of its access restriction.
`Because Obhan's ACB resides in the network and controls access to
`the system, an obvious choice for providing Obhan’s subscriber unit with the
`knowledge needed to self-regulate would be to send that subscriber unit the
`relevant ACB information, including the minimum access class, and the
`good till timestamp.
`The subscriber unit could then use this information to self-regulate
`its access to the system by only initiating calls when it knows it meets valid
`ACB information received from the network.
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`Now, Taniguchi is used in reference to reinforce this point.
`Taniguchi confirms that it was well-known to provide a terminal with
`knowledge of when it is denied access by a base station sending to that
`terminal a message with access restriction information.
`You can see this in the portion of Taniguchi reproduced on slide 25,
`where Taniguchi describes a base station transmitting to a mobile terminal, a
`communication restriction signal, including communication restriction
`period information, which then Taniguchi's mobile terminal uses to self-
`regulate its own access to the system.
`This disclosure in Taniguchi informs how a person of ordinary skill
`in the art would've provided Obhan’s subscriber unit with the knowledge of
`whether or not it has access, the knowledge needed to perform Obhan's
`described self-regulation.
`As such, Taniguchi offers a well-known and suitable option of
`transmitting a message with access restriction period information to perform
`Obhan's first scenario. It's very simple.
`Because Obhan does not provide that detail of how a subscriber unit
`learns of the knowledge needed to implement Obhan's first scenario, a
`person of skill would've turned to Taniguchi and found use of a message to
`have been a predictable and obvious solution. So moving to slide 26. Mr.
`Bishop confirmed these very points in his declaration.
`As shown in paragraph 51 -- we've reproduced here on slide 26, Mr.
`Bishop explains that by including Taniguchi's restriction period information
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`and notifications to mobile terminals, the terminals would've achieved
`improved performance.
`Because they would avoid unnecessary access requests in situations
`and intervals where the access request will be denied.
`As shown in paragraph 52 of Mr. Bishop's declaration, on the right
`side of slide 26, Mr. Bishop explained that this combination of Obhan and
`Taniguchi would provide improved efficiency and meet -- and serve the
`stated goal of Obhan, which is providing the knowledge needed for
`terminals to self-regulate their own access requests to the system and to the
`network.
`With these motivations, a person of ordinary skill would've found
`this combination to have been obvious, resulting in a system where Obhan’s
`subscriber unit receives a message with deny access time interval
`information, whether it be the good till time or Taniguchi's communication
`restriction period, and then self-regulates its access in accordance with that
`received information.
`KPN does not dispute that Taniguchi's communication restriction
`period is a deny access time interval, and with this operation in this
`combination, Obhan and Taniguchi render all of the limitations of Claim 35
`obvious.
`So unless there are any questions on this combination and on Claim
`35, that's what I have, and I'd like to reserve the remaining time for rebuttal.
`JUDGE WORMMEESTER: Okay. Do you have any questions?
`
`Okay.
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`Patent 9,014,667 B2
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`MR. MONALDO: Thank you, Your Honors.
`JUDGE WORMMEESTER: Okay. And we will B I'll let you know
`how much time you have left. Thank you.
`DR. COGSWELL: Good afternoon, Your Honors. I think for large
`portions of the material, I will refer to the briefing.
`I think one of the things that may be especially helpful to the board --
`and I'll take your guidance on this -- is I think there are aspects of this
`material that are a bit confusing to absorb and digest, and I'd like to highlight
`a couple of differences between the ’667 Patent and the Obhan system,
`specifically with reference to the deny access time interval and good till
`time, which I think really permeates the entire petition, it forms the basis for
`whether or not a Graham analysis was adequately done and these differences
`were pointed out, as well as the substantive limitations.
`So at a high level, the ’667 Patent and the Obhan reference are
`achieving access control in different kinds of ways.
`As an example, in the ’667 Patent, you're looking at a particular
`IMSI, a particular identifier of a terminal. That's stored in association with
`time periods.
`For example, you look to see are you within one of those time
`periods, and you make an access decision. Okay?
`This is a time period based access method that is implemented where
`you'll have a unique identifier for a terminal, and you have associated time
`periods.
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`In contrast, the Obhan system -- it's not unique identifier based. It's
`not really time based. What it is, is it's load based. I mean, you have a
`massive telecommunication system and you have a problem.
`You have scattered antennas with all sorts of base stations. You're
`trying to maximize use of it, and you're trying to approximate as much in
`real-time as you can what the actual loading conditions are in particular
`corridors so you can respond to them, and then determine a minimum access
`class in various regions. Right?
`And then, how does that relate? Well, I guess in a particular
`corridor, you have a particular access class, so the access class is associated
`with a corridor.
`You then have a terminal that's associated with a user. The user, I
`guess, is -- has various subscriber services, or various classes of service.
`Probably more than one.
`I mean, I might have premium voice, and you know, budget data.
`And so, determining -- you know, based on where a particular terminal is at
`a particular point in time, an access control block is looked up.
`What kind of phone call am I trying to make? Is it voice, is it data,
`what's my minimum access class? Is the call allowed or denied?
`So, obviously in that kind of system, you know, perhaps the ideal
`would be, you know, you have, you know, continuous update of your, you
`know, monitored load in the network, but I mean, computationally, it's
`prohibitively expensive.
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`I mean, it takes resources. So we have periodic updates. You know,
`what is the current loading in a particular corridor, in a particular cell?
`And as a result of the determination of what that loading is -- an
`expected load, and perhaps some other factors -- there's a determination of
`what minimum access class is going to be supported for a particular period
`of time until you get the next update
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