`Fractus, S.A.
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`ZTE (USA), INC.
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`
`Case No. 2:17-cv-00561-JRG
`Expert Report on Invalidity: Chris G. Bartone, Ph.D., P.E.
`THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHAL DIVISION
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`Case No. 2:17-cv-00561-JRG
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`JURY TRIAL DEMANDED
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`Plaintiff,
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`v.
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`Defendants.
`
`EXPERT REPORT OF DR. CHRIS G. BARTONE, P.E., REGARDING VALIDITY OF:
`
`U.S. PATENT NO. 7,394,432
`
`U.S. PATENT NO. 7,397,431
`
`U.S. PATENT NO. 8,941,541
`
`U.S. PATENT NO. 8,976,069
`
`U.S. PATENT NO. 9,054,421
`
`U.S. PATENT NO. 9,240,632
`
`U.S. PATENT NO. 9,362,617
`
`
`
`
`
`
`
`Fractus S.A.
`Ex. 2018
`ZTE (USA), Inc. v. Fractus S.A.; IPR2018-01461
`Page 1 of 219
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`

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`Case No. 2:17-cv-00561-JRG
`Expert Report on Invalidity: Chris G. Bartone, Ph.D., P.E.
`TABLE OF CONTENTS
`
`
`I. 
`
`INTRODUCTION ........................................................................................... 1 
`A. 
`Engagement ........................................................................................... 1 
`B. 
`Background and Qualifications ............................................................. 2 
`C. 
`Compensation ........................................................................................ 4 
`D. 
`Information Considered ......................................................................... 4 
`E. 
`Right to Supplement .............................................................................. 4 
`STATEMENT OF LEGAL PRINCIPLES ...................................................... 4 
`II. 
`III.  OVERVIEW OF ANTENNA CHARACTERISTICS .................................... 8 
`IV.  CLAIM CONSTRUCTION .......................................................................... 12 
`V.  OVERVIEW AND BACKGROUND OF THE
`FRACTUS PATENTS AT ISSUE ................................................................ 15 
`A. 
`The ʼ432 Patent ................................................................................... 15 
`B. 
`The ʼ431 Patent ................................................................................... 20 
`C. 
`The ʼ541 Patent ................................................................................... 24 
`D. 
`The ʼ069 Patent ................................................................................... 27 
`E. 
`The ʼ421 Patent ................................................................................... 29 
`F. 
`The ʼ632 Patent ................................................................................... 33 
`G. 
`The ʼ617 Patent ................................................................................... 35 
`H. 
`Person Having Ordinary Skill in the Art (“PHOSITA”) ..................... 38 
`VI.  ADDITIONAL COMMENTS REGARDING THE FRACTUS
`PATENTS ...................................................................................................... 39 
`VII.  DESCRIPTION OF PRIOR ART THAT FORMS THE BASIS
`FOR INVALIDITY ....................................................................................... 45 
`A.  Misra I (Ex. 1021) ............................................................................... 45 
`B.  Misra II (Ex. 1022) .............................................................................. 55 
`C. 
`Grangeat (Ex. 1023) ........................................................................... 65 
`
`
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`Contains Confidential Information Subject to Protective Order
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`Case No. 2:17-cv-00561-JRG
`Expert Report on Invalidity: Chris G. Bartone, Ph.D., P.E.
`VIII.  INVALIDITY OF THE FRACTUS PATENTS ........................................... 76 
`A. 
`Invalidity of the ’432 Patent (Claim 6 Is Obvious over
`Misra I in View of Misra II) ............................................................... 76 
`Invalidity of the ’432 Patent (Claim 6 Is Obvious over
`Grangeat ) ........................................................................................... 86 
`Invalidity of the ’431 Patent (Claims 14 and 30 Are
`Obvious over Misra I in View of Misra II)......................................... 96 
`Invalidity of the ’431 Patent (Claims 14 and 30 Are
`Obvious over Grangeat) .................................................................... 103 
`Invalidity of the ’541 Patent (Claims 17 and 23 Are
`Obvious over Grangeat) .................................................................... 111 
`Invalidity of the ’541 Patent (claims 17 and 23 are
`Obvious over Misra I in View of Misra II) ....................................... 123 
`Invalidity of the ’069 Patent (Claims 32 and 46 Are
`Obvious over Grangeat) .................................................................... 134 
`Invalidity of the ’069 Patent (Claims 32 and 46 Are
`Obvious over Misra I) ....................................................................... 144 
`Invalidity of the ’421 Patent (Claims 1 and 11 Are
`Obvious over Grangeat) .................................................................... 152 
`Invalidity of the ’421 Patent (Claim 1 and 11 Are
`Disclosed or Obvious over Misra I alone or in View of
`Misra II) ............................................................................................ 164 
`Invalidity of the ’632 Patent (claims 17 Is Obvious over
`Misra I in View of Misra II) ............................................................. 177 
`Invalidity of the ’632 Patent (Claims 17 Is Obvious over
`Grangeat) .......................................................................................... 184 
`Invalidity of the ’617 Patent (Claims 17 and 19 Are
`Obvious over Misra I in view of Misra II) ....................................... 193 
`Invalidity of the ’617 Patent (Claims 17 and 19 Are
`Obvious over Grangeat) .................................................................... 201 
`Secondary Considerations of Non-Obviousness ............................... 209 
`
`
`M. 
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`Contains Confidential Information Subject to Protective Order
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`iii
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`B. 
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`C. 
`
`D. 
`
`E. 
`
`F. 
`
`G. 
`
`H. 
`
`I. 
`
`J. 
`
`K. 
`
`L. 
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`N. 
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`O. 
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`Case No. 2:17-cv-00561-JRG
`Expert Report on Invalidity: Chris G. Bartone, Ph.D., P.E.
`IX.  ADDITIONAL OPINIONS REGARDING INVALIDITY OF
`ASSERTED CLAIMS ................................................................................. 211 
`A. 
`Lack of Sufficient Written Description Regarding
`“Fractal Antenna” as Part of the ’421 (Claims 1) in
`Asserted Claims of the Fractus Patents ............................................. 211 
`Lack of Sufficient Written Description Regarding
`Antennas in a Portable Communication Device or
`Concealed Within a Portable Communication Device ..................... 213 
`CONCLUSION ............................................................................................ 214 
`
`X. 
`
`B. 
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`Contains Confidential Information Subject to Protective Order
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`Case No. 2:17-cv-00561-JRG
`Expert Report on Invalidity: Chris G. Bartone, Ph.D., P.E.
`
`I.
`
`INTRODUCTION
`A. Engagement
`
`1.
`I have been retained by the law firm of Brinks Gilson & Lione on behalf of
`ZTE (USA) Inc. to provide this expert report for technical subject matter relative to Case
`No. 2:17-cv-00561-JRG concerning the validity of U.S. Patent No. 7,394,432 (“the ’432
`Patent”, Ex. 1001), U.S. Patent No. 7,397,431 (“the ’431 Patent”, Ex. 1002), U.S. Patent
`No. 8,941,541 (“the ’541 Patent”, Ex. 1003), U.S. Patent No. 8,976,069 (“the ’069 Patent”,
`Ex. 1004), U.S. Patent No. 9,054,421 (“the ’421 Patent”, Ex. 1005), U.S. Patent No.
`9,240,632 (“the ’632 Patent”, Ex. 1006), U.S. Patent No. 9,362,617 (“the ’617 Patent”, Ex.
`1007). Throughout this report, when I refer collectively to the above Fractus Patents, I will
`do so as the “Fractus Patents”. While in general I may provide citation to the first in the
`series of these Fractus Patents (i.e., “the ’432 Patent”, Ex. 1001), the respective citation to
`the other patents applies (although the specific column and row number may be slightly
`different due to formatting of the issued patents). Furthermore, I may provide citation to
`one of the other Fractus Patents in the series of these Fractus Patents (i.e., other than
`“the ’432 Patent”, Ex. 1001), the respective citation to the other patents applies (although
`the specific column and row number may be slightly different due to formatting of the
`issued patents).
`2.
`In this report, I have been asked to render my opinion regarding the validity
`of “the Asserted Claims”, as summarized below. (Ex. 1008.) In the table below, the
`independent claims are in bold, and the disclaimed claim numbers are followed by an “x”
`and the amended claims are followed by an “a”.
`
`
`U.S. Patent No. Asserted
`Claims
`
`7,394,432
`7,397,431
`
`8,941,541
`8,976,069
`9,054,421
`9,240,632
`9,362,617
`
`Non-Asserted
`(related)
`
`1x
`13x, 12x, 1x
`1x
`
`33, 34
`10, 9, 7, 6, 5
`
`
`
`6
`14a
`30a
`17, 23
`32, 46
`1, 11
`17
`17, 19
`
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`Contains Confidential Information Subject to Protective Order
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`Case No. 2:17-cv-00561-JRG
`Expert Report on Invalidity: Chris G. Bartone, Ph.D., P.E.
`B. Background and Qualifications
`
`3.
`I am a professor of electrical engineering at Ohio University, with over 30
`years of professional experience.
`4.
`In 1983, I received my B.S. in electrical engineering from The Pennsylvania
`State University. In 1987, I received my M.S. in electrical engineering from the Naval
`Postgraduate School specializing in communication engineering. In 1998, I received my
`Ph.D. in electrical engineering from Ohio University specialization in electronic
`navigation, GPS, electromagnetics, and antennas. In the Fall of 1998 I was awarded the
`RTCA William E. Jackson Award for my outstanding Ph.D. dissertation involving
`differential GPS, and began teaching and doing research for Ohio University as a Visiting
`Assistant Professor. Within the first 5 months after begin hired by Ohio University, I began
`teaching at the graduate level in antenna and microwave theory. I am a licensed
`professional engineer in the state of Ohio, since 2002.
`5.
`I joined Ohio University as a Visiting Assistant Professor in 1998 and
`became an Assistant Professor in 1999. In 2004, I became an Associate Professor, and in
`2009, I became a Professor.
`6.
`A complete listing of electrical of electrical engineering courses I have
`taught at Ohio University are listed in my CV. (Ex. 1009.) They include the following:
`
` EE441/541/4403/5403 Antennas and Microwaves Theory, W98-99, S12-13, S13-14,
`S14-15, S16-17, S17-18.
` EE605/6053 Satellite-Based Navigation Systems, F00-01, F01-02, F03-04, W04-05,
`F06-07, F07-08, F08-09, F09-10, F10-11, F11-12, F12-13. S14-15, S16-17, S17-18.
` EE602/6023 Radar Systems, S99-00, W10-11, F15-1, F16-17.
` EE6900 Satellite Communications, F13-14, F14-15.
` EE395C/322/3223 Electromagnetics & Materials II, S02-03, S03-04, S04-05, F03-04,
`F06-07, S07-08, F09-10, S09-10, F10-11, F12-13, S10-11, F11-12, S11-12, S12-13,
`S13-14.
` EE321/3214 Electromagnetics & Materials I, W98-99, W99-00, W01-02, W02-03,
`W04-05, F12-13, F13-14, F14-15, F15-16.
` EE690/613 High-Accuracy Satellite Navigation Systems, S00-01, S01-02, W03-04,
`S06-07, W07-08, W08-09, W09-10, S10-11, S11-12, F18-19.
` EE690 GNSS Antennas, W11-12, F13-14.
` EE690 Antenna Pattern Measurements, W99-00, F06-07.
`
`Contains Confidential Information Subject to Protective Order
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`Case No. 2:17-cv-00561-JRG
`Expert Report on Invalidity: Chris G. Bartone, Ph.D., P.E.
`
` EE601/690 Electromagnetic Wave Propagation in Electronic Navigation Systems,
`F99-00, F04-05.
`
`
`
`7.
`At Ohio University, I established and run the Ohio University Shielded
`Antenna Anechoic Chamber that has been used for a wide variety of simulated and
`measured antenna characterizations. These include S-parameter, input impedance,
`reflection coefficient, standing wave ratio, radiation pattern, directivity, and gain
`predictions and measurements.
`8.
`I am named as an author on approximately 89 professional publications
`including 12 refereed journal papers, 12 refereed conference/magazine publications, 43
`conference papers, 12 patent applications (2 awarded), and 13 technical reports. I also am
`the co-author of the textbook, Global Navigation Satellite Systems, Inertial Navigation,
`and Integration, 3rd Edition, John Wiley & Sons, 2013.
`9.
`Prior to joining Ohio University, I worked for with Naval Air Warfare
`Center performing research, development, and testing on various communications,
`navigation, surveillance, and electronic warfare systems.
`10.
`In addition to my work as a professor, I also have significant experience as
`a consultant working with wireless communication, navigation and surveillance systems. I
`am president of GNSS Solutions® Ltd., a technical consulting and service firm founded in
`2006, specializing in technical seminars, technical expert legal support, and engineering
`services in the communications, navigation and surveillance areas.
`11.
`I have a significant amount of antenna design, simulation, test,
`development, and operational experience with antennas and antenna systems, dating back
`to my early days working for the Navy. While still working for the Navy, supporting the
`Naval Air Warfare Center and the Federal Aviation Administration, I pursued my Ph.D.,
`which involved the design of linear array antennas that was linked to mobile antenna
`systems. In the Fall of 1998 I was awarded the RTCA William E. Jackson Award for my
`outstanding contribution to aviation as reflected in my dissertation. These experiences
`include outdoor antenna pattern characterization, field and anechoic chamber testing of
`antennas, design and simulation of antennas using high-fidelity computational
`electromagnetic models
`including CST, HFSS, Remcom, and other numerical
`electromagnetic codes for mobile antenna systems. An overview of my background,
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`Contains Confidential Information Subject to Protective Order
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`Expert Report on Invalidity: Chris G. Bartone, Ph.D., P.E.
`
`experience, and publications is reflected in my curriculum vitae, attached to this Report as
`Exhibit A.
`
`C. Compensation
`
`12.
`I am being compensated at a rate of $625 per hour for my study and time
`related to this matter. I am also being reimbursed for reasonable and customary expenses
`associated with my work and time in this investigation. My compensation is not contingent
`on the outcome of this matter or the specifics of my testimony.
`
`D. Information Considered
`
`13. My opinions are based on my years of education, research, and experience,
`as well as my investigation and study of relevant materials. In forming my opinions, I have
`considered the materials listed as exhibits to this expert report and otherwise referenced in
`this report, as well as those items included in Ex. 1010 to this report.
`14.
`In connection with any testimony I may be asked to give to the court, I may
`use as exhibits various documents that relate to matters set forth in this Report.
`
`E. Right to Supplement
`
`15.
`I understand that discovery in this case is on-going and that the plaintiff has
`not provided their full case positions. Therefore, I reserve the right to supplement and/or
`amend the opinions expressed herein in response to the positions taken by the plaintiff or
`any of the plaintiff’s experts. I further reserve the right to amplify what is stated in this
`report, including claim charts and add additional detail, where necessary, especially in view
`of information not presently known to me or new information presented by the plaintiff’s
`positions, including the plaintiff’s experts prior to, or at trial, and to supplement this report
`should additional information be brought to my attention during the course of this
`proceeding.
`
`II.
`
`STATEMENT OF LEGAL PRINCIPLES
`
`16.
`I am a technical expert and do not offer any legal opinions. I applied the
`legal framework outlined below in rendering the opinions reflected in this report.
`17.
`It is my understanding that, to anticipate a claim under (pre-AIA) 35 U.S.C.
`§ 102, a prior art reference must teach every limitation of the claim.
`
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`Contains Confidential Information Subject to Protective Order
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`Expert Report on Invalidity: Chris G. Bartone, Ph.D., P.E.
`
`18.
`It is also my understanding that a claimed invention is unpatentable under
`(pre-AIA) 35 U.S.C. § 103 as obvious if the differences between the invention and the prior
`art are such that the subject matter as a whole would have been obvious at the time the
`invention was made to a person having ordinary skill in the art to which the subject matter
`pertains. I also understand that the obviousness analysis takes into account factual inquiries
`including the level of ordinary skill in the art, the scope and content of the prior art, and
`the differences between the prior art and the claimed subject matter. I understand that a
`patent claim may be invalid because it was obvious in view of the prior art. The
`requirements to prove obviousness are contained in (pre-AIA) 35 U.S.C. § 103(a), which
`is reproduced in pertinent part below:
`19.
`A patent may not be obtained even though the invention is not identically
`disclosed or described as set forth in section 102 of this title, if the differences between the
`subject matter sought to be patented and the prior art are such that the subject matter as a
`whole would have been obvious at the time the invention was made to a person having
`ordinary skill in the art to which said subject matter pertains. Patentability shall not be
`negated by the manner in which the invention was made.
`(pre-AIA) 35 U.S.C. § 103(a).
`20.
`I understand that multiple references may, in some circumstances, be
`combined to render a patent claim obvious. Possible sources for a reason, suggestion, or
`motivation to combine references include:
`
`
`
`
`
`the nature of the problem to be solved;
`the teachings of the prior art; and
`the knowledge of persons of ordinary skill in the art.
`21.
`I have further been advised that the following factors may support a
`conclusion of obviousness:
`
` Combining prior art elements according to known methods to yield predictable
`results;
` Simple substitution of one known element for another to obtain predictable results;
` Use of a known technique to improve similar devices (methods, or products) in the
`same way;
` Applying a known technique to a known device (method, or product) ready for
`improvement to yield predictable results;
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`Contains Confidential Information Subject to Protective Order
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`Expert Report on Invalidity: Chris G. Bartone, Ph.D., P.E.
`
` “Obvious to try” - choosing from a finite number of identified, predictable solutions,
`with a reasonable expectation of success;
` Known work in one field of endeavor may prompt variations of it for use in either the
`same field or a different one based on design incentives or other market forces if the
`variations are predictable to one of ordinary skill in the art; and
` Some teaching, suggestion, or motivation in the prior art that would have led one of
`ordinary skill to modify the prior art reference or to combine prior art reference
`teachings to arrive at the claimed invention.
`22.
`In determining whether or not a patented invention would have been
`obvious, I understand that the following factors should be considered:
`
` The scope and content of the prior art;
` The differences between the prior art and the claims at issue;
` The level of ordinary skill in the art; and
` Any evidence of secondary considerations.
`23.
`I understand that combining familiar elements according to known methods
`is likely to be obvious when it does no more than yield predictable results. Further, if a
`technique has been used to improve one device, and a person of ordinary skill in the art
`would recognize that it would improve similar devices in the same way, using the technique
`is obvious unless its actual application is beyond his or her skill.
`24.
`I understand that where the claimed invention involves more than the simple
`substitution of one known element for another, or the mere application of a known
`technique to a piece of prior art ready for the improvement, it often will be necessary to
`look to interrelated teachings of multiple patents; the effects of demands known to the
`design community or present in the marketplace; and the background knowledge possessed
`by a person having ordinary skill in the art; all in order to determine whether there was an
`apparent reason to combine the known elements in the fashion claimed. Even in such a
`case however, the analysis need not seek out precise teachings directed to the specific
`subject matter of the challenged claim; rather, the inferences and creative steps that a
`person of ordinary skill would employ can be taken into account.
`25.
`I also understand that obviousness is proven where there existed at the time
`of the claimed invention a known problem for which there was an obvious solution
`encompassed by the patent’s claims. It is not relevant whether the combination was obvious
`to the inventor, but rather whether it would have been obvious to the person of ordinary
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`Expert Report on Invalidity: Chris G. Bartone, Ph.D., P.E.
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`skill, and under the correct analysis, any need or problem known in the field, which is
`addressed by the claimed subject matter, can provide a reason for combining the elements
`in the manner claimed.
`26.
`I understand that design incentives and other market forces can prompt the
`combining of different works, either in the same field or a different field and a person of
`ordinary skill in the art would recognize the value of improvements obtained by combining
`unless its actual application of the works is beyond his or her skill. Familiar items may
`have obvious uses beyond their primary purposes, and in many cases a person of ordinary
`skill will be able to fit the teachings of multiple patents together like pieces of a puzzle.
`27.
`I understand that one of ordinary skill in the art would have been motivated
`to combine prior art references that disclose similar systems and improve upon them
`through modifications known to one of ordinary skill.
`28.
`In determining obviousness, I understand that evidence of objective indicia
`of non-obviousness (also known as “secondary considerations”), when present, is also
`considered and that this is to be done before any ultimate determination of obviousness is
`made. I have been advised that the following factors may be considered as secondary
`considerations: (1) a long-felt and unmet need in the art for the invention; (2) failure of
`others to achieve the results of the invention; (3) commercial success of the invention; (4)
`copying of the invention by others in the field; (5) whether the invention was contrary to
`accepted wisdom of the prior art; (6) expression of disbelief or skepticism by those skilled
`in the art upon learning of the invention; (7) unexpected results; (8) praise of the invention
`by those in the field; and/or (9) commercial acquiescence (licensing).
`29.
`I also understand that, in order for secondary considerations to be relevant
`to the issue of obviousness, a patentee must establish a nexus between such secondary
`considerations and the claimed invention. Stated one way, the nexus requirement means
`that the secondary consideration is sufficiently derived from merits of the claimed
`invention, rather than other factors. I understand that if the patentee comes forward with a
`showing of one or more secondary considerations and the required nexus, then the burden
`of coming forward with evidence in rebuttal shifts to the party challenging the patent.
`Further, it is my understanding that evidence of secondary considerations does not always
`overcome a strong showing of obviousness.
`
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`Expert Report on Invalidity: Chris G. Bartone, Ph.D., P.E.
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`30.
`I also understand that the patent statute includes a written description
`requirement. Specifically, I understand that a patent must describe the claimed invention
`so as to reasonably convey to persons of ordinary skill in the art that the inventor was in
`possession of the claimed invention at the time the underlying patent application was filed.
`I also understand that in evaluating the written description requirement, an objective
`analysis is applied. Finally, I also understand that the inventor’s possession must be
`demonstrated in the patent application’s specification and that a description that merely
`renders the invention obvious is insufficient to satisfy the written description requirement
`
`III. OVERVIEW OF ANTENNA CHARACTERISTICS
`
`31.
`An antenna is a physical structure that transmits and/or receives
`electromagnetic waves. For a passive antenna, in accordance with the Theory of
`Reciprocity, an antenna will have similar characteristics in a transmission or reception
`mode. An antenna acts like a channel transducer to convert signals at the signal level
`(voltages and currents) to/from electromagnetic waves.
`32.
`Antennas may have various different shapes and/or sizes. The size and
`shape of antenna will have an effect on how well the antenna performs at various
`frequencies. In general, the performance of an antenna may be scaled (up or down in
`frequency) based on the physical size of the antenna (small or large), respectively. This is
`
`, where v
`
`fv
`
`due to the direct physical relationship between frequency and wavelength
`
`
`
`is the speed of the wave and f is the frequency.
`33.
`To use or test1 an antenna it may be connected to another device (e.g.,
`transmission line) at a connection point. The performance of an antenna is often
`characterized at this connection point in terms of several related parameters including its
`input/output impedance, standing wave ratio (SWR), and return loss (LR) to assess how
`well the antenna is matched at that connection point. At that connection point the other
`
`1 I note that U.S. Patent No. 6,195,048 to Chiba et al. shows conducting simulations to show substantial
`similar radiation patterns for a multifrequency internal antenna for portable telephones for both the 800
`MHz GSM frequency band and the 1.9 GHz PHS frequency band. (Ex. 1024, 1:4-7; 6:51-61; 7:6-64;
`9:38-55.)
`
`
`Contains Confidential Information Subject to Protective Order
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`
`
` 8
`
`Fractus S.A.
`Ex. 2018
`ZTE (USA), Inc. v. Fractus S.A.; IPR2018-01461
`Page 12 of 219
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`

`Case No. 2:17-cv-00561-JRG
`Expert Report on Invalidity: Chris G. Bartone, Ph.D., P.E.
`
`
`
` [unitless] ,
`
`
`
` where,
`
` 1- :
`
`A
`
`1
`
`, and the standing wave ratio (SWR), i.e.,
`
`component (e.g., transmission line) often has a characteristic impedance of 50 ,
`represented as Z0=50 .
`34.
`To obtain the maximum power transfer between the transmission line and
`the antenna it is desirable to have impedance match between the connection point and the
`antenna input/output (e.g., connector). The antenna input/output impedance, at the antenna
`connector, may be represented as a complex quantity made up of a resistance part (i.e., real
`part) and a reactance part (i.e., capacitive or inductive). This antenna impedance may be
`represented as ZA=RA+jXA, where the antenna impedance at the antenna connector has
`resistance (RA), and reactance (XA), each in units of Ohms.
`50
`35. With reference to a nominal 50 Ohm connection to the antenna,
`0 Z
`Ohms, the reflection coefficient at the antenna connector can be calculated as:
`Z
`Z
`Z
`Z
`
`00
`
`
`
`AA
`
`
`A
`
`Voltage SWR (VSWR) using the magnitude the reflection coefficient
`
`A , is represented
`
`
`
`where,
`
`1
`
` SWR
`
`
`
`
`
` [unitless] ,
`
`, and the return loss (LR) can be
`
`
`
`
`AA
`
`11
`
`as
`
`SWR
`
`
`
`
`
`[dB] ,
`
`.
`
`calculated as
`
`-
`
`
`20log
`L
`
`R
`10
`A
`36.
`An antenna that is ideally matched at the connection point (e.g., cable with
`nominal impedance of 50 Ohms) would have a reflection coefficient (
`A ) of 0, a SWR of
`1.0 and return loss that is really big (i.e., infinity).
`37.
`At microwave frequencies, microwave measurement and electromagnetic
`simulation programs often present performance characterization data in the form of “S-
`Parameters”, (i.e., Scattering-Parameters). For a single-connection antenna a signal may be
`transmitted and received at that connection point, and able to directly measure/characterize
`the reflection coefficient, and hence the return loss and SWR. It should be noted that the
`magnitude of the S-Parameter is often displayed in terms of a negative number, which may
`equivalently be described in terms of a return loss as a positive number.
`38.
`The frequency range an antenna may operate over can be described as the
`bandwidth of the antenna. A convenient way to characterize the match at the antenna
`
`
`Contains Confidential Information Subject to Protective Order
`
`
`
` 9
`
`Fractus S.A.
`Ex. 2018
`ZTE (USA), Inc. v. Fractus S.A.; IPR2018-01461
`Page 13 of 219
`
`

`

`Case No. 2:17-cv-00561-JRG
`Expert Report on Invalidity: Chris G. Bartone, Ph.D., P.E.
`
`connection point is to use the SWR or equivalently the return loss as a metric to assess the
`bandwidth of a device.
`39.
`At microwave frequencies current may be comprised of several forms. The
`total current may be made up from conduction current (as a function of the conductivity of
`a medium) and displacement current resulting from the time variation of electromagnetic
`waves. Current may also exist in various spaces, that may be expressed in the form of a
`volume current, current, or line current. All are forms of current. As a final point, it should
`be recognized that while charge may be static, current results from charges moving. Current
`flows between different potential values in a closed path medium (e.g., circuit).
`40.
`The radiation pattern for an antenna is also an important metric that may be
`used to assess the performance of an antenna. The radiation pattern for an antenna provides
`a mathematical and/or graphical representation of the geometric coverage region of the
`antenna at a particular frequency. The radiation pattern can be expressed in terms of
`directivity, gain (that included conduction and dielectric efficiencies), or realized gain (that
`included the conduction, dielectric and match efficiencies). The directivity of an antenna
`is the ratio of the radiation intensity in a given direction, normalized by the radiation
`intensity averaged over all space.
`41.
`A ground plane is often used with an antenna structure. For a monopole type
`configuration the radiating element(s) are typically perpendicular to the ground plane. For
`a planner type configuration the ground plane is typically parallel to the radiation elements.
`42.
`A microstrip type antenna is often implemented in a largely planar
`configuration with a ground plane, substrate, and radiating elements placed on top. The
`substrate is most often a dielectric type of material with a relative permittivity (i.e., r)
`greater than one. Various types and thicknesses of dielectric materials may be used.
`Generally, the higher values of dielectric constant will help to reduce the overall size of the
`antenna and a thicker (i.e., taller) substrate will help increase the bandwidth of a microstrip
`type antenna.
`43. Many planar antenna structures, including microstrip type antennas are
`fabricated on what is commonly called a printed circuit board (PCB). While there may be
`various ways to fabricate a PCB, the term PCB has the legacy of circuit boards that were
`commonly etched using a phot