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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`Intel Corporation
`Petitioner
`
`v.
`
`Qualcomm Incorporated
`Patent Owner
`______________________
`
`Case IPR2018-01152
`Patent 8,698,558
`______________________
`
`PATENT OWNER RESPONSE TO PETITION FOR INTER PARTES
`REVIEW PURSUANT TO 37 C.F.R. § 42.220
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`

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`I. 
`II. 
`
`TABLE OF CONTENTS
`INTRODUCTION ........................................................................................... 1 
`THE ’558 PATENT AND ITS PROSECUTION HISTORY ......................... 3 
`A.  Overview of the ’558 Patent .................................................................. 3 
`B. 
`Prosecution History of the ’558 Patent ................................................. 7 
`III.  CLAIM CONSTRUCTION ............................................................................ 9 
`IV.  LEVEL OF ORDINARY SKILL IN THE ART ............................................. 9 
`V.  OVERVIEW OF THE CITED REFERENCES ............................................ 10 
`A.  Overview of Chu ................................................................................. 10 
`B.  Overview of Choi 2010 ....................................................................... 13 
`C.  Overview of Myers .............................................................................. 16 
`VI.  GROUND III OF THE PETITION SHOULD BE DISMISSED BECAUSE
`IT IS BASED ON AN UNSUPPORTABLE CLAIM CONSTRUCTION OF
`“BASED ON THE FIRST SUPPLY VOLTAGE OR THE BOOSTED
`SUPPLY VOLTAGE” ................................................................................... 19 
`VII.  GROUND III OF THE PETITION SHOULD ALSO BE DISMISSED
`BECAUSE PETITIONER HAS FAILED TO DEMONSTRATE A
`MOTIVATION TO COMBINE CHU AND CHOI 2010 ............................. 25 
`VIII.  GROUND IV OF THE PETITION SHOULD BE DISMISSED BECAUSE
`CHOI 2010 TEACHES AWAY FROM “SELECTIVE BOOST” AND
`PETITIONER HAS FAILED TO DEMONSTRATE A MOTIVATION TO
`COMBINE MYERS WITH CHU AND CHOI 2010 ................................... 32 
`Choi 2010 Requires A Constant Boosted Supply Voltage And
`A. 
`Teaches Away From “Selectively Boosting” A Supply Voltage ........ 32 
`Petitioner Failed To Demonstrate A Motivation To Combine Myers
`With Chu And Choi 2010 .................................................................... 36 
`IX.  CONCLUSION .............................................................................................. 44 
`
`
`B. 
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`-i-
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`Pursuant to the Board’s Decision – Institution of Inter Partes Review (Paper
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`9) (“Institution Decision”), entered January 16, 2019 – Patent Owner Qualcomm,
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`Inc. (“Qualcomm” or “Patent Owner”) submits this Response in opposition to the
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`Petition for Inter Partes Review of U.S. Patent No. 8,698,558 (the “’558 Patent”)
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`filed by Intel Corporation (“Intel” or “Petitioner”).
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`I.
`
`INTRODUCTION
`Petitioner raises four grounds against three claims. Ground I is directed to
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`claims 12 and 14, and Ground II is directed to claim 14. Patent Owner does not
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`contest these grounds and agrees to cancel claims 12 and 14.
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`Grounds III and IV, directed to claim 13, are a different story. Claim 13
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`recites an envelope amplifier that “operates based on the first supply voltage or the
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`boosted supply voltage.” A person of ordinary skill in the art (“POSA”) would
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`understand this limitation as requiring a “selective boost.” Because Petitioner
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`concedes that Ground III does not disclose a selective boost, the Board should
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`dismiss Ground III.
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`Moreover, Grounds III and IV rely upon the combination of Chu and Choi
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`2010, with Ground IV additionally relying on Myers. Both grounds are flawed
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`because Petitioner has failed to meet its burden of establishing a motivation to
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`combine Chu, a reference striving to increase the efficiency of a power amplifier,
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`with Choi 2010, a reference striving to prevent the degradation of output power at
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`-1-
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`the cost of efficiency. The prior art is silent regarding how to combine Chu and Choi
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`2010 in a manner that achieves the objectives of both. A POSA therefore would not
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`be motivated to combine these disparate teachings, and Petitioner has failed to meet
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`its burden under both grounds.
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`Petitioner additionally fails to meet its burden of establishing a motivation to
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`combine Chu/Choi 2010 with Myers. Choi 2010 is premised on building a circuit
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`that requires a constant boosted voltage supply to its linear amplifier. Petitioner,
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`recognizing that neither Chu nor Choi 2010 disclose anything relating to a selective
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`boost, relies on Myers to disclose these features. Choi 2010, however, teaches away
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`from using multiple voltage sources because the entire premise of Choi 2010 is to
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`use a constant boosted supply voltage in order to achieve its objective of preventing
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`the degradation of output power. And even if the Board were to find that Choi 2010
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`does not rise to the level of teaching away, a POSA would not be motivated to
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`modify Choi 2010 with Myers because doing so would undercut the benefits Choi
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`2010 achieves. Furthermore, Myers does not disclose a linear envelope amplifier
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`and relates only to an older power-tracking paradigm that differs significantly from
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`Chu and Choi 2010. Accordingly, a POSA would not be motivated to combine
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`Myers with Chu and Choi 2010.
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`For at least these reasons, the Board should confirm the validity of claim 13
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`of the ’558 Patent.
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`-2-
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`II. THE ’558 PATENT AND ITS PROSECUTION HISTORY
`A. Overview of the ’558 Patent
`The ’558 Patent describes and claims inventions directed to managing the
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`power associated with transmitting radio frequency (“RF”) signals from a mobile
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`device. Ex. 1001 at 1:5-31. The ’558 Patent teaches improvements over known
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`power management schemes by employing a novel form of “envelope tracking.” Id.
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`at Title; 3:57-60. The ’558 Patent’s power management scheme achieves substantial
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`power savings in mobile device transmitters, thereby extending a device’s battery
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`life. Id. at 3:46-48.
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`In wireless communication systems, mobile devices communicate by
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`transmitting encoded data signals. Ex. 1001 at 1:11-17. Before transmitting through
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`a communications channel, such encoded data signals are first conditioned to
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`generate RF output signals. Id. Such conditioning typically includes an
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`amplification step performed by a power amplifier (a “PA”) that provides a high
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`transmit power. Id. at 1:21-26. A desirable characteristic of mobile device power
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`amplifiers is an ability to provide high transmit power with high power-added
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`efficiency (“PAE”) and good performance even when the device’s battery is low. Id.
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`Before the priority date of the ’558 Patent, typical PAs in a mobile device
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`were supplied with a constant power supply voltage, regardless of the PA’s output
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`power. The ’558 Patent illustrates this in Figure 2A, below with annotation:
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`Figure 2A illustrates using a battery voltage (Vbat) to supply PA 210, which
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`provides an RFout signal as an amplified version of RFin. Ex. 1001 at 4:1-3. RFout
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`has a time-varying envelope illustrated by plot 250, which is juxtaposed with voltage
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`Vbat 260. Vbat remains higher than the largest amplitude of RFout’s envelope in
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`order to prevent clipping of RFout by PA 210. Id. at 4:2-7. A drawback to this
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`scheme is that the difference between the battery voltage and the envelope of the
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`RFout signal (shaded red) represents wasted power. Id. at 4:7-9.
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`As wasted power is undesirable, especially where power is limited by battery
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`life, the ’558 Patent employs “envelope tracking” in order to better manage power
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`consumption by using only an amount of power that is needed for a particular signal.
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`A PA employing envelope tracking is illustrated in Figure 2C, with annotations,
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`below:
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`-4-
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`By employing envelope tracking to produce a PA power supply Vpa,
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`represented in plot 280, the “supply voltage closely tracks the envelope [250] of the
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`RFout signal over time.” Ex. 1001 at 4:21-27. This maximizes PA efficiency by
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`minimizing the difference between Vpa and RFout over time, which results in less
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`wasted power. Id. at 4:27-32.
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`Implementing a PA supply with envelope tracking in a mobile device poses
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`unique challenges, because operating a mobile device with a low battery voltage is
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`often desirable (e.g., to reduce power consumption, extend battery life, etc.). Ex.
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`1001 at 3:46-56. At times, a PA may need to operate with a higher voltage than a
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`battery is providing, in which case a boost converter may be employed at the expense
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`of increased cost and power consumption. Id.
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`To address these issues, the ’558 Patent discloses an efficient design for
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`envelope tracking that employs a “switcher” and an “envelope amplifier” together
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`with a boost converter, as illustrated in Figure 3, with annotations below:
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`-5-
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`Figure 3 illustrates an exemplary switcher 160a with envelope amplifier 170a
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`operating cooperatively to create a supply current Ipa as the sum of Iind from the
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`switcher and Ienv from the envelope amplifier. Ex. 1001 at 4:34-38.
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`A switcher (e.g., 160a) “has high efficiency” and may deliver “a majority of
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`the supply current for [PA] 130” in current Iind, which contains DC and low
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`frequency components. Id. at 3:14-17; 6:19-20. An envelope amplifier (e.g., 170a),
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`on the other hand operates as a linear stage and has high bandwidth. Id. at 6:20-22.
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`In the combination the switcher reduces the output current of the envelope amplifier
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`thereby improving overall efficiency, while the envelope amplifier provides the high
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`frequency components in current Ienv. Id. at 3:21-25; 6:22-24. In this way, the
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`overall efficiency increases by drawing the majority of current from the high
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`-6-
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`efficiency switcher, and only relying on the envelope amplifier for the high
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`frequency components.
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`In order to further increase the efficiency of the system, envelope amplifier
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`170a predominantly relies on Vbat for power while drawing upon Vboost (which
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`“boosts” or increases the battery voltage to a higher voltage at the expense of cost
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`and power consumption) on demand when, e.g., the magnitude of the envelope
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`signal exceeds a threshold. Id. at 3:19-21; 3:52-67; 5:31-36; 6:1-4. In this way, the
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`linear stage envelope amplifier only draws on the boosted voltage when needed.
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`Embodiments of the ’558 Patent increase efficiency by introducing an offset
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`in the switcher in order to increase the Iind current, thereby reducing the apparatus’
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`reliance on the less efficient envelope amplifier (id. at 6:52-61); by configuring the
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`envelope amplifier to rely on the boost converter dynamically and only when
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`necessary (id. at 6:28-33); or by doing both.
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`B.
`Prosecution History of the ’558 Patent
`The ’558 Patent issued from U.S. Application No. 13/167,659, filed June 6,
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`2011. Ex. 1002 at 38. Issued claim 12 was filed as original claim 18, which
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`depended from original independent claim 16. Ex. 1002 at 17-18; 207. A first Office
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`Action issued on November 23, 2012, rejecting each original independent claim,
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`including claim 16, as anticipated by Kim et al., entitled “High Efficiency and
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`Wideband Envelope Tracking Power Amplifier with Sweet Spot Tracking.” Ex.
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`-7-
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`1002 at 59-61; Ex. 1013 at Title. The Examiner provided a detailed examination of
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`original claims 16-19 in view of Kim’s Figure 3, including claims 16 and 18 that
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`together recited the subject matter of issued independent claim 12. Ex. 1002 at 62-
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`63. The Office rejected claims 16, 17, and 19 over Kim, but found original claim 18
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`to be allowable over Kim if rewritten in independent form. Ex. 1002 at 63. To
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`overcome the rejections of original independent claim 16, the Applicant
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`incorporated the subject matter of original claim 16 into original claim 18 to form
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`independent claim 18, and amended claims 17 and 19 to depend from claim 18. Ex.
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`1002 at 83-84.
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`In a subsequent Final Office Action dated May 10, 2013, the Office indicated
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`that original claims 17-19, as amended, recited allowable subject matter over the
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`prior art of record including the Kim paper. Id. at 134. Thereafter, the Applicant
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`and the Office addressed unrelated claims before a Notice of Allowance was issued
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`on Feb. 13, 2014; original claims 18, 17 and 19 issued as claims 12, 13, and 14
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`respectively. Id. at 185; 207. A typographical “copy and paste” error in claim 12
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`was corrected in a Certificate of Correction issued on June 27, 2017, deleting “a
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`power amplifier operative to receive an envelope signal and provide a second supply
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`current based on the envelope signal; and.” Id. at 220-222; 240.
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`III. CLAIM CONSTRUCTION
`Patent Owner does not believe that the terms “current sense amplifier” and
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`“envelope signal” need to be construed. To the extent the Board determines that
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`they should be construed, Patent Owner does not contest the Board’s previous
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`finding that “current sense amplifier” means “amplifier that produces a voltage from
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`a current,” and “envelope signal” means “signal indicative of the upper bound of the
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`output RF signal.”
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`Claim 13 recites “wherein the envelope amplifier operates based on the first
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`supply voltage or the boosted supply voltage.” The only reasonable interpretation
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`of this claim element, properly read within the context of the claim as a whole, is
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`that the envelope amplifier must be able to operate, selectively, based on either the
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`first supply voltage or the boosted supply voltage (referred to herein as a “selective
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`boost”). See Ex. 2005 at ¶¶48-56. Patent Owner presents its full claim construction
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`argument for “based on the first supply voltage or the boosted supply voltage” below
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`at Section VI.
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`IV. LEVEL OF ORDINARY SKILL IN THE ART
`As the Board previously stated, the POSA for the ’558 Patent would have had
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`a Master’s degree in electrical engineering, computer engineering, or computer
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`science, and would also have had at least two years of relevant experience, or a
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`Bachelor’s degree in one of those fields and four years of relevant experience. Paper
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`-9-
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`9 at 11-12. Relevant experience “refers to experience with mobile device
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`architecture as well as transmission and power circuitry for radio frequency devices.”
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`Id. Patent Owner does not dispute the Board’s statement of the level of ordinary
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`skill in the art. See also Ex. 2005 at ¶¶43-44.
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`V. OVERVIEW OF THE CITED REFERENCES
`A. Overview of Chu
`The Chu reference is an article entitled “A 10 MHz Bandwidth, 2mV Ripple
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`PA Regulator for CDMA Transmitters.” Ex. 1004 at Title. Chu describes a
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`“combined class A-B and switch-mode regulator based supply modulator with a
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`master-slave architecture achieving wide bandwidth and low ripple.” Ex. 1004 at
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`2809. Chu recognizes that power amplifiers (PAs) consume a significant portion of
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`the total power budget of battery-powered transceivers, and at higher frequencies,
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`increased power is wasted in the PA. Id. To improve efficiency, Chu explains that
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`it is “highly desirable to track the envelope variations of a modulated waveform at
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`the PA power supply. This variable supply operation ensures close to peak
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`efficiency at various signal envelope levels.” Id. Chu explains that polar modulators
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`“try to address this efficiency loss by closely tracking the envelope of an RF band-
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`pass signal and applying it onto the drain of a high efficiency, non-linear PA.” Id.
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`The process involves an envelope detector extracting the envelope waveform and
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`“applying the amplitude and phase components of RF signals separately to the power
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`supply and input of non-linear PAs,” which improves efficiency. Id.
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`Chu explains that this approach has known drawbacks, however, which
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`include spectral expansion of the envelope and phase bandwidths of CDMA signals,
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`as well as misalignment between the amplitude and phase paths. To overcome these
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`drawbacks and maximize efficiency, Chu presents “a master-slave linear and switch-
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`mode supply modulator with fast dynamic transient response. By using an accurate
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`current sensing technique, efficiency and linearity of the supply modulator is further
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`optimized.” Id. Chu’s master-slave architecture is illustrated in Figure 4 (below)
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`showing a supply modulator with switch-mode and linear amplifiers connected in
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`parallel.
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`Chu’s Figure 5 (below) illustrates a simplified block diagram of the proposed
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`regulator and ripple cancellation.
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`-11-
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`Chu discloses that a “high GBW linear amplifier in voltage follower
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`configuration ensures that output node Vo(t) tracks the reference envelope voltage
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`A(t).” Ex. 1004 at 2810. And a “current sensing circuit, high gain transimpedance
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`amplifier and switch-mode regulator form[] a global feedback control loop that
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`suppresses the current output from the linear amplifier within the switch-mode
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`regulator bandwidth.” Id. According to Chu, “[t]ypical current sensing techniques
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`utilize[ing] a small series resistor and measure[ing] the voltage drop across it … is
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`not suitable for CDMA supply modulator applications where output currents can be
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`up to 380 mA.” Id. at 2815-2816. Accordingly, Chu discloses an “accurate current
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`sensing circuit” illustrated in Chu’s Figure 16, shown below. Id.
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`-12-
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`Chu’s disclosures resulted in a maximum efficiency of 82% for the master-
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`slave modulator. “The efficiency of the master-slave supply modulator is three times
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`higher than the efficiency of [a standalone class-AB supply modulator] at 16 dBm
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`output power and indicates a significant efficiency improvement over the linear
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`supply modulator at backed-off power levels.” Id. at 2817. Chu does not include
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`any discussion or illustration of a voltage boost mechanism for boosting a battery
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`voltage.
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`B. Overview of Choi 2010
`The Choi 2010 reference is an article entitled, “Envelope Tracking Power
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`Amplifier Robust to Battery Depletion.” Ex. 1006 at Title. Choi 2010 describes a
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`“hybrid switching amplifier,” and Figure 2 illustrates how a PA supply modulator
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`topology affects the output power of the PA, as shown below:
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`-13-
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`Ex. 1006 at 1334.
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`Choi 2010’s objective is to develop an envelope tracking power amplifier that
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`prevents the degradation of output power that results from battery depletion. Ex.
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`1006 at 1333. To accomplish this objective, Choi 2010 discloses a system that
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`boosts the supply voltage of a linear amplifier to 5V, regardless of the battery voltage
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`variation, by coupling a 5V boost converter to the supply of the linear amplifier as
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`illustrated in Figure 5 below. Id. at 1333. The system in Choi 2010 boosts the linear
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`amplifier supply voltage, “while that of the buck converter is still coupled to the
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`battery in the HSA” so that “the supply modulator dynamically regulates the PA with
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`peak voltage of 4.5V.” Id.
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`-14-
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`Thus, Choi 2010 teaches that this system always boosts the battery voltage to
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`5V, regardless of battery voltage fluctuation in order to provide a stable supply
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`voltage to the RF PA. Id. at 1334. Choi 2010 recognizes that this continuous voltage
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`boost degrades efficiency of the supply, but accepts this degradation as an acceptable
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`compromise to achieve a stable supply voltage for the RF PA. Id. at 1335 (“the
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`efficiency degradation by the additional boost converter is not serious because the
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`load current provided by the linear amplifier is about 30% of the overall load
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`current”).
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`It is notable that four of the six authors of Choi 2010 were also authors of the
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`Kim paper that was distinguished during the prosecution of the ’558 Patent, and Choi
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`2010 was also considered by the Examiner during prosecution. Ex. 1013 at 255; Ex.
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`1006 at 1332; Ex. 1001 at Cover.
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`-15-
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`

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`C. Overview of Myers
`Myers is a U.S. Patent titled “Method and Apparatus for High Efficiency High
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`Dynamic Range Power Amplification.” Ex. 1012 at Title. Myers discloses an
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`envelope elimination and restoration (EER) amplifier, which is “a technique through
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`which highly efficient but nonlinear radio frequency (RF) power amplifiers can be
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`combined with other, highly efficient amplifiers to produce a high efficiency linear
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`amplifier system.” Ex. 1012 at 1:23-29. In Myers’ system, a signal to be amplified
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`is split into two paths, an amplitude path and a phase path. Id. at 1:29-31. An
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`envelope is detected and amplified in the amplitude path by a class S or other power
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`amplifier, which operates on the bandwidth of the RF envelope rather than the RF
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`bandwidth. Id. at 1:31-34. The phase component in the phase path is then amplitude
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`modulated by the amplified envelope signal, creating an amplified replica of the
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`input signal. Id. at 1:34-37. Myers explains that in an EER amplifier, the dynamic
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`range is limited by the range of the class S modulator used to amplify the envelope,
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`thus Myers discloses another type of EER amplifier with a higher dynamic range.
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`Id. at 1:37-40; 1:55-57.
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`Myers describes the use of pulsewidth modulators (PWMs) as part of a
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`switcher (i.e., class S modulator) implementation, and does not describe or relate to
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`linear envelope amplifiers. Id. at 1:62-67; 4:17-20 (“The operation of multi-range
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`modulator 200 described thus far is that of a class S modulator with a power source
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`-16-
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`of Vdd1.”); 6:1-5 (“The operation of multi-range modulator 300 described thus far
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`is that of a class S modulator with a power source of Vdd1.”). The two voltage
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`sources in Myers are applied to a switcher, not a linear amplifier in a hybrid structure,
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`and neither of the voltages are “boosted” or result from a boosted converter. The
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`PWMs are depicted in Figures 2 and 3:
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`As these figures illustrate, the PWM “outputs a pulsewidth modulated
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`waveform which has a duty cycle proportional to the amplitude of the envelope
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`signal.” Id. at 3:63-65. The driver “accepts the pulsewidth modulated signal from
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`-17-
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`PWM” and “drives switching transistor” and “logic gates.” Id. at 3:66-4:1. Myers
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`does not disclose implementing the modulator with a PMOS transistor that receives
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`a selectable power source. Specifically, although disclosing an embodiment in
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`which the multi-range modulator “shares a common switching transistor coupled to
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`ground” as shown in Figure 2, Myers never discloses an embodiment in which the
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`two voltages Vdd1 and Vdd2 are selectably received by the same switching
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`transistor. Ex. 1012 at 7:12-24; Figure 2. Rather, Myers explicitly discloses that
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`“having two separate pairs of switching transistors [as shown in Figure 3] further
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`increases efficiency.” Id.
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`Myers’ Figure 8 illustrates a flow chart for amplifying a signal:
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`-18-
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`Myers’ flowchart shows in step 820 that if the input is found to be less than
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`the reference signal, Myers describes proceeding to step 830, in which a first power
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`source is selected for use in a pulsewidth modulator. Ex. 1012 at 9:26-30. But if the
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`input is greater than the reference, Myers’ process proceeds to step 840, in which a
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`second power source, greater than the first power source, is selected for use with a
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`pulsewidth modulator. Id. at 9:29-32.
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`VI. GROUND III OF THE PETITION SHOULD BE DISMISSED
`BECAUSE IT IS BASED ON AN UNSUPPORTABLE CLAIM
`CONSTRUCTION OF “BASED ON THE FIRST SUPPLY
`VOLTAGE OR THE BOOSTED SUPPLY VOLTAGE”
`Claim 13 of the ’558 Patent, addressed in Ground III of the Petition, recites
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`“a boost converter operative to receive the first supply voltage and provide a boosted
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`supply voltage having a higher voltage than the first supply voltage, wherein the
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`envelope amplifier operates based on the first supply voltage or the boosted supply
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`voltage.” Ground III is premised on Petitioner’s unsupported allegation that claim
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`13 “requires only that the envelope amplifier operates based on one or the other of
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`the first supply voltage or the boosted supply voltage.” Paper 2 at 72. Petitioner
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`concedes that if selectivity is required, then Ground III does not render claim 13
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`obvious and instead Petitioner relies on Ground IV. Id. As detailed below, the only
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`reasonable interpretation of this claim element, properly read within the context of
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`the specification, is that the envelope amplifier must be able to operate, selectively,
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`based on either the first supply voltage or the boosted supply voltage (“selective
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`-19-
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`boost”). See Ex. 2005 at ¶¶48-56. Accordingly, the Board should dismiss Ground
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`III.
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`The specification confirms that “selective boost” is the only reasonable
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`interpretation of claim 13. Id. at ¶¶51-53. When the specification recites “based on
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`the first supply voltage or the boosted supply voltage,” it frequently follows with an
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`additional narrative describing a selective boost:
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`In one design, the envelope amplifier may further receive
`the first supply voltage and may generate the second
`supply voltage based on either the first supply voltage or
`the boosted supply voltage. For example, the envelope
`amplifier may generate the second supply voltage (i)
`based on the boosted supply voltage if the envelope signal
`exceeds a first threshold and/or if the first supply voltage
`is below a second threshold or (ii) based on the first supply
`voltage otherwise.
`
`Ex. 1001 at 1:42-50 (emphasis added). The ’558 Patent later reiterates:
`
`In one design, the envelope amplifier may further receive
`the first supply voltage and may generate the second
`supply voltage based on the first supply voltage or the
`boosted supply voltage. For example, the envelope
`amplifier may generate the second supply voltage (i)
`based on the boosted supply voltage if the envelope signal
`exceeds a first threshold, or if the first supply voltage is
`below a second threshold, or both or (ii) based on the first
`supply voltage otherwise.
`
`Id. at 8:55-62 (emphasis added). In only three instances does the ’558 Patent recite
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`the term “the first supply voltage or the boosted supply voltage” or the term “the
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`boosted supply voltage or the first supply voltage” without including the emphasized
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`portions of the passages above. See id. at 8:62-9:17; 9:21-36; 10:19-29. But in each
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`case, the passages explicitly reference Figures 3 and 5 (annotated below), which
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`illustrate an envelope amplifier that can selectively receive a first supply voltage
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`(Vbat) or a boosted supply voltage (Vboost):
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`The ’558 Patent provides a detailed description of selective boost:
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`
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`In one design, envelope amplifier 170 a operates based on
`the Vboost voltage only when needed and based on the
`Vbat voltage the remaining time in order to improve
`efficiency. For example, envelope amplifier 170 a may
`provide approximately 85% of the power based on the
`Vbat voltage and only approximately 15% of the power
`based on the Vboost voltage. When a high Vpa voltage is
`needed for power amplifier 130 due to a large envelope on
`the RFout signal, the C1 control signal is at logic low, and
`the C2 control signal is at logic high. In this case, boost
`converter 180 is enabled and generates the Vboost voltage,
`PMOS transistor 318 is turned on and provides the Vboost
`voltage to the source of PMOS transistor 314, and PMOS
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`transistor 320 is turned off Conversely, when a high Vpa
`voltage is not needed for power amplifier 130, the C1
`control signal is at logic high, and the C2 control signal is
`at logic low. In this case, boost converter 180 is disabled,
`PMOS transistor 318 is turned off, and PMOS transistor
`320 is turned on and provides the Vbat voltage to the
`source of PMOS transistor 314.
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`Id. at 5:31-49. Thus, the ’558 Patent describes a selective boost, as claimed.
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`
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`Petitioner’s construction rests entirely on the word “or.” The use of “or” is
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`sometimes an acceptable mechanism for claiming alternatives such that only one of
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`the limitations need be found in the prior art to support anticipation. See In re
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`Gaubert, 524 F.2d 1222, 187 USPQ 664 (CCPA 1975). Nevertheless, under the
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`broadest reasonable interpretation, a claim (even one reciting the word “or”) must
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`be interpreted such that it receives the broadest reasonable interpretation in light of
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`the intrinsic record. See In re Translogic Tech., 504 F.3d 1249, 1257 (Fed. Cir.
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`2007). And “[i]t is highly disfavored to construe terms in a way that renders them
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`void, meaningless, or superfluous.” Wasica Finance GmbH v. Continental
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`Automotive Sys., Inc., 853 F.3d 1272, 1288 n.10 (Fed. Cir. 2017). The claim
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`language here does not signify an alternative limitation as in In re Gaubert, because
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`such a reading is inconsistent with the language of the specification.
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`
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`Taking Petitioner’s construction to its logical conclusion would render aspects
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`of claim 13 meaningless. For example, if claim 13 were interpreted such that the
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`envelope amplifier could operate based only on a first supply voltage, as Petitioner
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`proposes, then the claim 13 limitation “a boost converter operative to receive the
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`first supply voltage and provide a boosted supply voltage having a higher voltage
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`than the first supply voltage” serves no purpose whatsoever. The only reasonable
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`interpretation is that the envelope amplifier must be able to receive both voltage
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`inputs, and selectively choose which one to use. That is, the envelope amplifier
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`operates based on one or the other supply voltage, but it must receive both and
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`selectively choose which one to use.
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`Petitioner’s expert agreed that it would not make sense to interpret the boosted
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`supply voltage as purely optional in the context of the claims. For example, when
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`asked about a similar “based on” limitation in claim 6, Dr. Apsel admitted that it
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`makes sense to interpret “based on” as requiring a boosted supply voltage to be an
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`available supply voltage. Ex 2006 at 42:19-43:9. When pressed if she could
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`interpret it any other way, Dr. Apsel responded “I’m not sure.” Id. at 43:7-8. If
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`“based on” requires that the boosted supply voltage must be an available supply
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`voltage, then it is not purely an alternative limitation.
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`The only reasonable construction, consistent with the claim as a whole and
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`the specification, is that “based on the first supply voltage or the boosted supply
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`voltage” requires that the envelope amplifier be capable of operating, selectively,
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`based on the first supply voltage or the boosted supply voltage. In other words,
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`despite the claim’s inclusion of the conjunction “or,” the “boosted supply voltage”
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`and the “first supply voltage” are not alternative options. The claimed envelope
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`amplifier must be capable of operating based on both – one or the other at any given
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`time, as selected by and based on an operational condition.
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`
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`Thus, reading the limitations of claim 13 in a purely alternative fashion, in the
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`manner discussed in In re Gaubert, would be contrary to a reading of the disclosed
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`embodiments and would be inconsistent with the claim language as a whole. And
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`because Petitioner concedes that Ground III is insufficient without this improper
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`claim interpretation (See Paper 2 at 72), the Board should dismiss Ground III of the
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`Petition.
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`VII. GROUND III OF THE PETITION SHOULD ALSO BE
`DISMISSED BECAUSE PETITIONER HAS FAILED TO
`DEMONSTRATE A MOTIVATION TO COMBINE CHU AND
`CHOI 2010
`A POSA would not have been motivated to combine Chu and Choi 2010
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`because they address different problems with different solutions that are in tension
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`with each other. Ex. 2005 at ¶¶82-83. Chu recognizes that typical PAs waste power,
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`especially at higher frequencies. Chu therefore seeks a design that “ensures close to
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`peak efficiency at various signal envelope levels.” Ex. 1004 at 2809. Choi 2010, in
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`contrast, aims to prevent the degradation of output power of the PA at the expense
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`of efficiency. Choi 2010 accepts the trade-off in efficiency in order to achieve a
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`solution to its identified problem of output power degradation. As Chu and Choi
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`2010 explain, their objectives conflict with each other and require necessary trade-
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`offs. Ex. 2005 at ¶83.
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`Petitioner’s arrival at combini