IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`In re Patent of: Eberlein et al.
`U.S. Patent No.: 6,314,289
`Issue.Date: November 6, 2001
`Serial No.: 09/202,729
`Title: Apparatus and Method for
`Transmitting Information and
`Apparatus and Method for Receiving
`Information
`Inter Partes Review No.: IPR2018-
`00690
`
`DECLARATION OF ERNST EBERLEIN
`
`I, Ernst Eberlein, declare as follows:
`
`I am a co-inventor of U.S. Patent No. 6,314,289 ("the '289 patent").
`1.
`The other co-inventors of the ' 289 patent are Marco Breiling, Jan Stoessel, and
`Heinz Gerhauser.
`
`I graduated as Engineer from the University in Erlangen and joined
`2.
`Fraunhofer Gesellschaft zur Forderung der Angewandten Forschung eV ("the
`Fraunhofer Institute") in 1985.
`
`From 1987 to 1994, I supported the audio and multimedia department
`3.
`of the Fraunhofer Institute. As a group leader in this department, I was involved in
`the development of th~ mp3 audio coding scheme. In 1992, I was a co-recipient of
`the Joseph von Fraunhofer Award for this work.
`
`In 1995, I began working on the physical layer of digital
`4.
`communication systems. In connection with that work, I became heavily involved
`in the design and implementation of satellite-based digital radio systems for mobile
`
`&fr{_
`3/31 /zo zo
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`reception. In 2002, the results of my work in this area were elected to the Space
`Technology Hall of Fame. 1
`
`Throughout 1998, my primary project at Fraunhofer, together
`5.
`with my colleagues Sabah Badri, Stephan Buchholz, Stefan Lipp, and Jan Stoessel,
`was the development of a new satellite-based digital radio system. Others involved
`in the development of the system during this time included Marco Breiling, Robert
`Fischer (both employees of the University Erlangen, working on a sub-contract
`basis for Fraunhofer), Albert Heuberger (head of department and senior advisor),
`and Heinz Gerhaeuser (head of institute and senior advisor). Others at Fraunhofer
`were further involved in additional aspects of building and testing this system,
`including field experiments and/or chipset design.
`
`6. My co-inventors and I collaborated together to conceive a new
`proposal for a satellite-based digital radio system utilizing diversity combining no
`later than October 1998. Exhibit 2051 is a true and correct copy of invention
`disclosure materials related to that proposal, which were prepared in October 1998.
`I will refer to Exhibit 2051 as "the ' 289 IDF." I completed drafting the '289 IDF
`on October 26, 1998, as indicated on the first page. Exhibit 2051 at 1. The ' 289
`IDF formed the basis for international patent application PCT/EP98/07850 that
`was filed on December 3, 1998 (Exhibit 2052) and which ultimately matured into
`the ' 289 patent.
`
`As evidenced by Exhibits 2051-2054 and the facts set forth in
`7.
`this declaration, the inventions as claimed in each of claims 1-6, 8-15, 17-23, 25-33
`and 35 of the ' 289 patent were conceived no later than October 26, 1998 and
`diligently reduced to practice no later than the December 3, 1998 filing date of
`international application PCT/EP98/07850 (Exhibit 2052), the parent application of
`U.S. application 09/202,729, which issued on November 6, 2001 as the ' 289
`patent.
`
`Other aspects of the '289 patent invention are further disclosed
`8.
`in a document entitled, "Proposal for Puncturing Pattern for 3/8 code," which I
`prepared on or about November 23, 1998. A true and correct copy of this
`document is attached as Exhibit 2053. This disclosure describes specific generator
`polynomials used by the convolutional encoder of the system, as recited in
`dependent claims 7 and 24 of the '289 patent. These claims were conceived no
`
`1 See <https://www .spacefoundation.org/space _technology_ hal/satellite-radio(cid:173)
`technology />.
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`)
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`later than November 23, 1998 and were likewise diligently reduced to practice no
`later than December 3, 1998, as reflected in this declaration.
`
`Following the conception of these inventions, my colleagues and I
`9.
`diligently and continuously worked to reduce them to practice (including both
`actual and constructive reduction to practice). For example, work toward creating
`an embodiment of the inventions was undertaken with the objective of preparing a
`final "specification (waveform and chipset) by January 15th, 1999." See, e.g.,
`Exhibit 2051 at 5. Our ongoing efforts in this regard proceeded according to the
`schedule set forth in Exhibit 2051, including (1) evaluating through October 30,
`1998 whether data "indicates that post-Viterbi and post-Reed-Solomon· decoding
`are not sufficient or an additional gain of 2-4 dB will improve the service
`availability significant[ly ]"; (2) additional analysis performed from October "until
`the end of November (1998]" including "[a]nalysis of 'Code rate 1/3 approach' by
`system simulation," "( d]evelopment of draft chipset spec.," use of "external
`memory ... for the delay," and a "Viterbi decoder for code rate 1/3"; (3) use of
`"preliminary results" at the "beginning of December (1998]" to "adapt the draft
`specification." Id. at 5-6. As part of this work, we "developed and tested"
`simulations of an embodiment of the inventive system. See, e.g., id. at 5
`( describing our "simulation setup"). I also personally prepared the Simulation Plan
`dated November 9, 1998 that is included here as Exhibit 2054. This document
`references the October 26, 1998 memorandum (Exhibit 2051) in which conception
`of the inventions is described. Exhibit 2054 at 4. It also sets forth a schedule of
`activity for "Theoretical Analysis'~ (id. at 5-6) and "Validation using broadcast
`channel data only" (id. at 7-8), which describe work performed related to
`analyzing, simulating, and testing aspects of the invention with deliverable dates
`on November 17, 20, 24 and December 4, 1998. Note that I was continuously in
`Fraunhofer Institute's employ throughout this time period, and this was my sole,
`full-time project at least during the last quarter (October through December) of
`1998. We also continued to develop and refine aspects of an embodiment of this
`invention, as shown, for example, by the November 23, 1998 disclosure entitled,
`"Proposal for Puncturing Pattern for 3/8 code," which is included as Exhibit 2053,
`in which further work to reduce to practice an embodiment of the invention is
`disclosed, including puncturing patterns and generator polynomials for the
`convolutional encoder. The technical specification and the simulation work were
`the basis for the chipset implementation.
`
`10. Moreover, in accordance with the Fraunhofer Institute's standard
`invention disclosure procedures, my co-inventors and I disclosed our idea to
`Fraunhofer Institute management so that it could be submitted to patent counsel for
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`(
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`the purpose of drafting a patent application. Beginning in October 1998, we, the
`inventors, and other Fraunhofer Institute personnel (totaling about 20 individuals)
`worked continuously to reduce the invention to practice, including work on
`developing the air-interface specification, validation by simulation, chipset
`specification, and field experiments to test the system, as well as working with
`patent counsel in preparing, reviewing and revising the specification, figures and
`claims of international application PCT/EP98/07850 (Exhibit 2052) up to its
`December 3, 1998 filing date. This international application is the parent
`application of U.S. application 09/202,729 which issued on November 6, 2001 as
`the '289 patent.
`
`11. The following is a detailed description elaborating some of the
`evidence that demonstrates the conception and reduction to practice of the claims
`of the '289 patent on an element-by-element basis.
`
`12. The '289 IDF describes a method and an apparatus for transmitting
`information. For example, it describes how "[t]he output of the convolutional
`encoder and puncturing unit is demultiplexed," after which "4 bits out of 8 are
`transmitted over satellite l" and "[t]he other 4 bits are transmitted over satellite 2."
`Exhibit 2051 at 2.
`
`13. The '289 IDF describes a bitstream source foi: providing a bitstream
`representing information. For example, it shows a "transmission system"
`comprising a "Bit stream source":
`
`f-!1t ·team
`
`Fon\arrt
`Frmr
`Corrccuon
`
`IJe(cid:173)
`mulbplc:-.
`
`Dela\
`
`a1el111e
`' )
`
`Lbannel - - - - l<.t.'CCl\'Cf
`
`Id. at 1.
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`14. The ' 289 IDF further describes a redundancy adding encoder for
`generating an encoded bitstream based on the bitstream provided by the bitstream
`source wherein the encoder is arranged to output, for a first number of input bits, a
`second number of output bits, the second number of output bits having at least
`twice as many output bits as the first number of input bits. For example, it shows
`the disclosed transmission system includes a Forward Error Correction component
`for encoding the output of the Bit Stream source to add redundancy:
`
`~.
`
`Satellite
`
`Lhmmel _ _ _ 1<.ecc1,·er
`
`tl1t team
`
`F<ll"\\:trd
`1-rmr
`Corr~ctu111
`
`Ue(cid:173)
`mulhplc,
`
`Dela,
`
`Id. at 1. The ' 289 IDF further describes an implementation of forward error
`correction utilizing "a convolutional encoder with code rate 1/3." Id. at 2. The
`convolutional encoder with code rate 1/3 is further illustrated by the '289 IDF,
`showing a convolutional encoder taking one input bit and yielding three output
`bits:
`
`I
`
`H
`
`gl
`
`B·
`
`~3
`
`I
`I
`
`I
`I
`
`I
`I
`
`Com oluuoMJ ctiJcr
`
`Pun tunn~
`lllllt
`
`f'aralk-1 tc1
`·rial and
`De-
`multipl ·\
`tc.1 -
`bttstrcams
`
`.
`
`f---f,
`
`l>da}
`h; I!( 4
`SC mds)
`
`I----+
`
`Id.
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`15. The '289 IDF further describes the second number of output bits
`including two portions of output bits. For example, it describes how 8 bits of the
`convolutional encoder output (i.e., two portions of 4 bits each) " are de-multiplexed
`to the two output bitstreams." Id. at 3. This is further illustrated in the following
`figure, showing an input bit sequence of three bits which, after emerging from the
`convolutional encoder, yield two 4 bit portions of output bits, one portion labeled E
`and the other portion labeled L:
`Input bit sequence:
`
`After convolutional encoder
`
`- - -+ time
`
`C: = Bit transmitted over early satellite
`I = Rit tr;Jnsmitted over latP. satellite
`X = not transmitted (punctured) bit
`
`Id. at 4 . .
`
`The ' 289 IDF further describes each portion of output bits
`16.
`individually allowing the retrieval of information represented by the first number
`of input bits. For example, it describes how, "[i]f only one signal is available the
`input of the Viterbi decoder is considered as convolutional code of code rate 1/3
`punctured to a code rate of 3/4." Id. at 4. It further states, in relation to the
`operation of a Viterbi decoder for decoding the encoded bitstream, "[if] only one
`satellite is available only all bits transmitted over the missing satellite are replaced
`by the ' unknown' bits. This is equivalent to puncturing of code rate 1/3=3/9 down
`to 3/4." Id. at 7.
`
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`17. The '289 IDF further describes the first portion of output bits being
`coded based on the bitstream in a different way with respect to the second portion
`of output bits. For example, it shows a convolutional encoder having comprising
`three generator polynomials: gl, g2 and g3.
`
`,-
`
`I
`
`p, I
`
`H !:'::i
`g5
`
`I
`
`I
`I
`
`I
`I
`
`Com l)lUtJOnnl 1-'.t'lder
`
`run tunng
`unn
`
`Parallel t,
`nal and
`De-
`mulhpln
`to l
`t>1tstr:ams
`
`1----f
`
`!)elm
`(C ~ -1 ~
`· •c;onds)
`
`Id. at 2. The output of the convolutional encoder is shown below, with each row
`corresponding to one of the three generator polynomials:
`
`Input bit sequence:
`
`1 1
`
`__ ..., tima
`
`After convolutional encoder
`
`C .,. Bit transmitted over early satellite
`I = Rit transmitted over late satellite
`X = not transmitted (punctured) bit
`Id. at 4. Accordingly, the bits for the early satellite (labeled E) include outputs of
`generator polynomials gl and g2, while the bits for the late satellite (labeled L)
`include outputs of generator polynomials g2 and g3. This is stated explicitly in the
`'289 IDF as well. Id. at 5 ("Using gl and g2 for satellite #1 and g2 and g3 for
`satellite #2 ... "). The '289 IDF further states, "The signals transmitted over the
`early and late satellite are different ... " Id. at 8.
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`18. The ' 289 IDF further describes a partitioner for partitioning the
`second number of output bits into the two portions of output bits. For example, it
`states, "The output of the convolutional encoder and puncturing unit is
`demultiplexed. 4 bits out of 8 are transmitted over satellite 1. The other 4 bits are
`transmitted over satellite 2." Id. at 2. This is further illustrated in the following
`figure:
`
`l'lmctunn~
`lll1 11
`
`. I
`l
`
`H
`
`gt
`
`g2
`
`g3
`
`I
`
`I
`
`I
`
`'om olulwni.11 coder
`
`Id. at 2.
`
`Pnrallcl to
`·nal anJ
`De-
`multiple.
`
`bttstrcam
`
`lt) - - cc • .j
`
`Dela,
`
`,__
`
`sc ·onds )
`
`19. The ' 289 IDF further describes one or more transmitters for
`transmitting the output bits of the first portion via a first channel and the output bits
`of the second portion via a second channel, the second channel being spatially
`different from the first channel. For example, it describes how, "[u]sing two
`satellites 8 channel bits are transmitted for 3 information bits." Id. at 1. In another
`example, it describes, "a system where the bitstream is de-multiplexed to two
`streams and transmitted using 2 QPSK modulators." Id. at 2. In still another
`example, the ' 289 IDF describes "building blocks" for a "simulation setup" to
`include "2* QPSK modulator." Id. at 5.
`
`20. The '289 IDF further describes first and second channels being
`defined by respective first and second transmitters and a receiver, or by a
`transmitter and respective first and second positions of a mobile receiver. For
`example, it describes how "[t]or each useful bit 4 channel bits are generated," and
`"4 bits are transmitted over early satellite," while "[t]he other 4 bits are transmitted
`over the late satellite." Id. at 7.
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`21. The '289 IDF further describes delay means for delaying the second
`portion of output bits transmitted via the second channel such that time diversity is
`obtained. For example, it states that "[a] delay can be inserted for one signal." Id.
`at 2. This is further illustrated in the following figure:
`
`I
`
`H
`
`!_.!. I
`
`g2
`
`gJ
`
`I
`I
`
`I
`
`I
`
`C m oluuona l coJt.1
`
`Plm ~turinp,
`Lm1t
`
`Para t! ·I h)
`;;crml a nti
`De-
`m1:11L1plc.
`to 2
`tmslream
`
`1---1
`
`DchJ\
`( C P, -I
`Sl..'COOOS)
`
`i - -
`
`Id. The '289 IDF further describes "building blocks" for a "simulation setup,"
`including "delay for one signal." Id. at 5;
`
`The ' 289 IDF further describes first and second transmitters including
`22.
`two satellites in different orbital positions, such that the first channel is defined by
`an uplink connection from earth to the first satellite and a downlink connection
`from the first satellite to a receiver on earth, and such that the second channel is
`defined by a uplink connection from earth to the second satellite and a downlink
`connection from the second satellite to the receiver on earth. For example, it
`describes how "[t]he output of the convolutional encoder and puncturing unit is
`demultiplexed," "4 bits out of 8 are transmitted over satellite l ," and "[t]he other 4
`bits are transmitted over satellite 2." Id. at 2. In another example, it describes how
`"[t]he output of two shift registers are transmitted over the early satellite," and
`"[t]he output of the other two shift registers is transmitted over the late satellite."
`Id. at 7. The '289 IDF further states that, "[t]he signals transmitted over the early
`and late satellite are different ... " Id. at 8.
`
`23. The '289 IDF further describes one transmitter including a satellite.
`For example, it describes how "4 bits out of 8 are transmitted over satellite l ." Id.
`at 2.
`
`24. The ' 289 IDF further describes the other transmitter including a
`terrestrial sender such that terrestrial diversity is obtained. For example, it
`describes a "terrestrial waveform" corresponding to a "bitstream received from the
`early satellite." Id. at 5.
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`25. The '289 IDF further describes the redundancy adding encoder
`including a convolutional encoder for obtaining a code rate less than or equal to
`0.5, wherein the code rate is the ratio of the first number of input bits to the second
`number of output bits, the convolutional encoder combining a current input bit to
`be encoded with at least one of a certain number of preceding input bits. For
`example, it describes employing "a convolutional encoder with code rate 1/3,"
`which is less than or equal to 0.5. Id. at 2. The '289 IDF also describes the use of
`three specific generator polynomials in connection with its convolutional encoder:
`gl = 1001111 , g2 = 1101101 , and g3 = 1010111. Id. at 4. These polynomials
`encode a current input bit with six preceding input bits.
`
`26. The '289 IDF further describes the certain number of preceding bits is
`6. For example, it describes the use of three specific generator polynomials in
`connection with its convolutional encoder: gl = 1001111 , g2 = 1101101 , and g3 =
`1010111. Id. at 4. These polynomials encode a current input bit with six
`preceding input bits. Exhibit 2053 further describes the use of the following three
`generator polynomials (in octal): Gl = 147, G2 = 135, G3 = 163. Exhibit 2053 at
`2. Converted from octal to binary, these become G 1 = 1100111 , G2 = 1011101 ,
`G3 = 1110011. This disclosure supports the recitation in dependent claims of the
`'289 patent that the convolutional encoder comprises three generator polynomials
`g1, g2 and g3 having the following binary form: g1=1100111 , g2=1011101 , and
`g3=lll00ll.
`
`27. The ' 289 IDF further describes the redundancy adding encoder being
`operative to code the bitstream provided by the bitstream source in a bit-by-bit
`fashion. For example, it shows a Convolutional coder converting each input bit
`into three output bits.
`
`I
`
`H
`
`i;! l
`
`l':,
`
`g~
`
`'
`I
`
`I
`I
`
`I
`
`I
`
`Com oluuonnl ~o<lcr
`
`I lln lllill)g
`Wlll
`
`Parallel t
`serial and
`De-
`mult,pk
`l (l !
`bttstr.:.am.,;
`
`- - f
`
`l)da}
`(cid:157) ~
`I • I.(
`· , onds1
`
`Exhibit 2051 at 2. It further describes the use of three specific generator
`polynomials in connection with its convolutional encoder. Id. at 4. These
`polynomials encode one current input bit, taking into account six preceding input
`bits, in a bit-by-bit fashion.
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`The '289 IDF further describes a puncturing unit operative to discard
`28.
`at least one predetermined bit of the encoded bitstream such that the second
`number of output bits is an even number, wherein the first and second portions of
`output bits comprise the same number of output bits. For example, it shows a
`"Puncturing unit" following the "Convolutional coder":
`
`I
`
`H
`
`gl
`
`g.2
`
`g.~
`
`I
`
`I
`•
`
`I
`
`Conrnluuonul cod~
`
`,l'unctunng '
`Llllll
`
`!'until ·I lo
`· ·nal and
`lJ~-
`multiple,
`to 2
`hllstrc.am.
`
`-- ( C fl -l
`
`Dela\
`
`:...:conds ,
`
`i--+
`
`Id. at 2. It further describes how "[ o ]ne bit out of 9 is removed by the puncturing
`unit," such that "[t]he remaining 8 bits are de-multiplexed to the two output
`bitstreams according to the scheme shown" in the following figure:
`
`Input bit sequence:
`
`t 1
`
`-
`
`-
`
`-
`
`time
`
`After convolutional encoder
`
`I 1;1:1~1111
`
`E = Bit transmitted over early satellite
`L = Bit transmitted over late satellite .
`X = not transmitted (punctured) bit
`
`Id. at 2-4
`
`The '289 IDF further describes the partitioner including a parallel
`29.
`storage for storing a predetermined amount of output bits of the convolutional
`encoder. For example, it describes a parallel-to-serial converter in connection with
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`a de-multiplexer, the latter of which partitions the serial output bitstream into two
`bitstreams:
`
`.,
`·1
`
`f--tl
`L--f
`
`g. l
`
`P.-
`
`g3
`
`I
`
`I
`
`I
`I
`
`Conrnluuonnl cn.kr
`
`Ptmctunng
`tmll
`
`l'nrnllcl to '
`scrrnl and
`De-
`mull1pk,
`to 2
`h1tstremn
`
`1---t
`
`Dda,
`..j ~
`( Cf!.
`seconds)
`
`Id. at 2. The parallel-to-serial converter includes parallel storage for storing nine
`output bits of the convolutional encoder, which are subsequently punctured to
`eight:
`
`Input bit sequence:
`
`I I
`
`After convoh.rtional encoder
`
`- - - time
`
`C - Bit transmitted over early satellite
`l = Rit transmitted ovP.r 1~1A satP.llite
`X = not transmitted (punctured) bit
`
`Id. at 4.
`
`30. The '289 IDF further describes a parallel-to-serial converter for
`producing a serial stream of the stored bits to be partitioned into the first and
`second portion of output bits is provided. For example, it describes a parallel-to(cid:173)
`serial converter in connection with a de-multiplexer, the latter of which partitions
`the serial output bitstream into two bitstreams:
`
`J/1{ jr1,1JW
`e;S(__ r
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`..
`-ti
`
`I
`
`gl
`
`g:!
`
`g3
`
`I
`I
`
`I
`
`I
`
`I
`
`Com luuonal co.Jct
`
`Pun tunng
`uml
`
`.
`
`l'un.dlcl to
`scnal an<l
`De:-
`mulhplc\.
`lo -
`h1uream
`
`.
`
`.
`
`-I -
`
`Dda\
`( l! .g
`seconds)
`
`i - -
`
`Id. at 2.
`
`31. The '289 IDF further describes a de-multiplexer for performing the
`partition of the serial stream of output bits into the first and second portions is
`provided. For example, it states that "[t]he output of the convolutional encoder and
`puncturing unit is demultiplexed," such that "4 bits of out of 8 are transmitted over
`satellite 1," and "[t]he other 4 bits are transmitted over satellite 2." Id. at 2. This is
`further illustrated below:
`
`g l
`
`I
`
`~ g~
`
`g3
`
`I
`
`I
`
`I
`
`Com uluuon.al coJcr
`
`Ptm turing
`umt
`
`Pru: llcl to
`-.crml and
`Ik-
`mult1pk'-
`lo 2
`h1ts1Temn;;
`
`----
`
`Dela\
`IC g -1 ~
`·cconds)
`
`Id.
`
`32. The '289 IDF further describes a method and an apparatus for
`receiving information, the information being represented by an encoded bitstream.
`For example, it describes how "[t]he receiver requires one Viterbi decoder only,"
`and further illustrates "[a] simplified block diagram of t}:le receiver" as follows:
`
`(J./1.___
`7 I '}{ /'1v io
`
`- 13 -
`
`Fraunhofer Ex 2050-p 13
`Sirius v Fraunhofer
`IPR2018-00690
`
`

`

`QP'K
`DcmoJ
`
`TDM
`lkmw,
`
`QP, K
`l)cmoJ
`
`TDM
`!)emu,
`
`Id. at 4.
`
`De(cid:173)
`Puncture
`
`Viterbi
`l:kcodcr
`
`Ra:J(cid:173)
`s ,t,11non
`
`33. The '289 IDF further describes the encoded bitstream being encoded
`such that its redundancy is at least doubled with respect to a bitstream from which
`the encoded bitstream is derived, and that, for a first number of bits of the
`bitstream, the encoded bitstream comprises a second number of bits, the second
`number of bits having at least twice as many bits as the first number. For example,
`it describes receiving an encoded bitstream from an encoder implementing forward
`error correction that utilizes "a convolutional encoder with code rate 1/3," that is
`taking one input bit and yielding three output bits. Id. at 2.
`
`34. The ' 289 IDF further describes receiving means for receiving the first
`portion of bits via a first channel and the second portion of bits via a second
`channel, the first and the second channels being spatially different from each other.
`For example, it describes "[a] simplified block diagram of the receiver" as follows:
`
`QP K
`D,:moJ
`
`TDM
`!)emu.,
`
`Oelm
`( Mcm<lf:
`
`(JP 'K
`J)cmoJ
`
`Tl M
`J)cmu,
`
`De-
`Puncture
`
`Viterbi
`l).:c1\dcr
`
`Rew-
`Solo111on
`
`Id. at 4. It further describes how, "[u]sing two satellites 8 channel bits are
`transmitted for 3 information bits." Id. at 1.
`
`35. The ' 289 IDF further describes a combiner for combining the first and
`the second portions the combiner including a depuncturing unit for performing a
`depuncturing operation on the first and second portions of bits to compensate for a
`puncturing operation performed in a transmitter. For example, it describes "[a]
`simplified block diagram of the receiver" as follows:
`
`- 14 -
`
`Fraunhofer Ex 2050-p 14
`Sirius v Fraunhofer
`IPR2018-00690
`
`

`

`(.)P K
`IA-'lllOU
`
`TDM
`!:>emu:,
`
`Dela\
`( Memo~)
`
`QPSK
`DcmoJ.
`
`Tf>M
`Dcnm,
`
`De-
`Purn.:lurc
`
`Vth:rbi
`lkcodcr
`
`Re..'<l-
`Solomon
`
`Id. at 4. It further describes that, following the de-puncture unit, "[t]he optimal
`combining according to the signal quality of the two signals is automatically
`performed by the Viterbi decoder." Id.
`
`36. The ' 289 IDF further describes a decoder for decoding the coded
`bitstream by removing redundancy from the coded bitstream, the decoder using the
`first and second portions of bits combined by the combiner. For example, it states
`that "[t]he receiver requires one Viterbi decoder only," and shows the following
`"simplified block diagram of the receiver":
`
`QP K
`DcmoJ.
`
`TOM
`l:>cmu"
`
`D·ln\.
`(Mcmon J
`
`QP~K
`J)cmoJ.
`
`rtJM
`lxmu,
`
`De-
`Puncturt·
`
`V1tcrb1
`lkco<lcr
`
`Reed-
`Solomon
`
`Id. at 4. It further states that "[t]he Viterbi decoding performs maximum likelihood
`decoding using the channel state information (='metric' )." Id. The ' 289 IDF
`further describes Reed-Solomon decoding following the Viterbi decoder. Id.
`
`37. The ' 289 IDF further describes the receiving means further including
`delay means for delaying the portion of bits received via one channel to
`compensate for a delay imposed on the portion of bits received via the other
`channel. For example, it includes a "Delay (Memory)" to compensate for a
`corresponding delay in one transmission channel, as illustrated below:
`
`- 15 -
`
`Fraunhofer Ex 2050-p 15
`Sirius v Fraunhofer
`IPR2018-00690
`
`

`

`QP K
`Ot!m~><l
`
`TDM
`DcmLL\
`
`l>dn~
`l Mcmon)
`
`QP K
`lkmo<l
`
`rDM
`Dcmu,
`
`Punctw-c
`
`Viterbi
`lkC(ldcr
`
`RC\.,--d-
`~olmnon
`
`Id. at 4. It further describes how, "[ o ]n the receiving side ... the signal of the early
`signal must be delayed ... " Id. at 7.
`
`38. The '289 IDF further describes the combiner including a multiplexer
`for multiplexing first and second portions into a form suitable for the decoder. For
`example, it describes "building blocks" of a "simulation setup" including "2*
`TDM bitstream multiplex" and a "multiplex of the two softquantized bitstreams."
`Id. at 5. It further describes how, "[ o ]n the receiving side the bits from the early
`and late satellite are multiplexed to one stream." Id. at 7.
`
`39. The '289 IDF further describes the decoder comprising a soft decision
`decoder processing probabilities in that a received bit represents a high or low state
`rather than an actual wave form characteristic of the received bitstream. For
`example, it states that "[t]he receiver requires one Viterbi decoder only," and
`shows the following "simplified block diagram of the receiver":
`
`p K
`Ot!mod
`
`T M
`J)cmu.
`
`Ddm
`cMcmon l
`
`QP K
`lkmoJ
`
`TDM
`J)cmu,
`
`De-
`Pwtclw-c
`
`V1h;rb1
`IJcco<lcr
`
`Recd-
`Solomon
`
`Id. at 4. It further states that "[t]he Viterbi decoding performs maximum likelihood
`decoding using the channel state information (='metric')." Id. The ' 289 IDF
`further describes Reed-Solomon decoding following the Viterbi decoder. Id.
`
`40. The '289 IDF further describes depuncturing means for compensating
`for a puncturing operation in a transmitter and attributing to a bit to be depunctured
`equal probabilities for the high and low states. For example, it describes "[a]
`simplified block diagram of the receiver" as follows:
`
`- 16 -
`
`Fraunhofer Ex 2050-p 16
`Sirius v Fraunhofer
`IPR2018-00690
`
`

`

`U ·la,
`( Memor~
`
`()PSK
`D, .. mo<l
`
`QPSK
`Dem,)\.(
`
`TDM
`l.>cmLL,
`
`TDM
`!)emu,
`
`lk
`Pum.:turc
`
`V1terb1.
`IJ..:co<lcr
`
`Re4.'<l-
`Sulrnnon
`
`Id. at 4. It also states that, following the de-puncture unit, "[t]he optimal
`combining according to the signal quality of the two signals is automatically
`performed by the Viterbi decoder." Id.
`
`41. The ' 289 IDF further describes the decoder including a Viterbi
`decoder performing maximum likelihood decoding using the state information of
`the first and second channels. For example, it describes "[a] simplified block
`diagram of the receiver" as follows:
`
`<.)P'K
`Ocmo<l
`
`TUM
`J)cmu.
`
`Dctu,
`( Mcmon)
`
`QI SK
`l)cmoJ
`
`WM
`l)cm u,
`
`Puncture
`
`V1h.:rhi
`l)..:coJcr
`
`Reed-
`Solomon
`
`Id. at 4. It further describes that, following the de-puncture unit, "[t]he optimal
`combining according to the signal quality of the two signals is automatically
`performed by the Viterbi decoder." Id.
`
`42. The ' 289 I~F further describes the decoder further comprising a
`Reed-Solomon decoder fed by the Viterbi decoder for undoing a Reed-Solomon
`encoding performed in the transmitter. For example, it shows "[a] simplified block
`diagram of the receiver" as follows:
`
`Dclm
`( M·mo~ ,
`
`Qf SK
`0..>Jno<l
`
`QP K
`l)cmo<l
`
`TDM
`J.>emu'\
`
`T M
`!)emu'\
`
`[ ~-
`Pw-icturc
`
`V11t:rb1
`lkco<lcr
`
`Ra•J-
`Solomon
`
`- 17 -
`
`Fraunhofer Ex 2050-p 17
`Sirius v Fraunhofer
`IPR2018-00690
`
`

`

`Id. at 4. The '289 IDF further describes Reed-Solomon decoding following the .
`Viterbi decoder. Id.
`
`43. The '289 IDF further describes the receiving means comprising, for
`each channel, a QPSK demodulator for providing the first and the second portions
`of bits. For example, it shows "[a] simplified block diagram of the receiver" as
`follows:
`
`(,.)PSK
`INrnoJ
`
`fDM
`INmu.,
`
`V•lm
`( M ·mon.
`
`(JPSK
`DcmoJ
`
`f'DM
`Dcmu,
`
`Punctur·
`
`V1ti.:rh1
`Dr..:co<lc.:r
`
`RwJ-
`Solomon
`
`Id. at 4. This shows a QPSK demodulator for each channel. The '289 IDF further
`describes "building blocks" of a "simulation setup" including "2* QPSK
`demodulators." Id. at 5.
`
`I hereby declare under penalty of perjury under the laws of the United
`44.
`States of America that all statements made herein of my own knowledge are true
`and correct and that all statements made on information and belief are believed to
`be true and correct; and further that these statements were made with the
`knowledge that willful false statements and the like so made are punishable by fine
`or imprisonment, or both, under Section 1001 of the Title 18 of the United States
`Code and that such willful false statements may jeopardize the validity of the
`application or.any patents issued thereon.
`
`Ernst Eberlein
`
`- 18 -
`
`Fraunhofer Ex 2050-p 18
`Sirius v Fraunhofer
`IPR2018-00690
`
`