UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.
`Petitioner
`
`v.
`
`INVT SPE LLC
`Patent Owner
`____________
`
`Case No. TBD
`U.S. Patent No. 7,764,711
`____________
`
`DECLARATION OF DR. ANDREW C. SINGER
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`IPR2018-01476
`Apple Inc. EX1003 Page 1
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.
`Petitioner
`
`v.
`
`INVT SPE LLC
`Patent Owner
`____________
`
`Case No. TBD
`U.S. Patent No. 7,764,711
`____________
`
`DECLARATION OF DR. ANDREW C. SINGER
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`IPR2018-01476
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`I, Andrew C. Singer, hereby declare the following:
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`I.
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`INTRODUCTION
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`1.
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`I, Andrew C. Singer, have been retained by counsel for Petitioner as a
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`technical expert in the above-captioned case. Specifically, I have been asked to
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`render certain opinions in regards to the IPR petition with respect to U.S. Patent
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`No. 7,764,711 (“the ’711 Patent”). I understand that the Challenged Claims are
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`claims 1-6. My opinions are limited to those Challenged Claims.
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`2. My compensation in this matter is not based on the substance of my
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`opinions or the outcome of this matter. I have no financial interest in Petitioner. I
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`am being compensated at an hourly rate of $500 for my analysis and testimony in
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`this case.
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`A. Materials Reviewed
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`3.
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`In reaching my opinions in this matter, I have reviewed the following
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`materials:
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`• Exhibit 1001 – U.S. Patent No. 7,764,711 to Sudo (“the ’711 Patent”);
`• Exhibit 1002 – File History of U.S. Patent No. 7,764,711;
`• Exhibit 1005 – U.S. Patent No. 6,067,290 to Paulraj et al. (“Paulraj”);
`• Exhibit 1006 – Howard Huang, Harish Viswanathan, and G.J. Foschini,
`Achieving High Data Rates in CDMA Systems Using BLAST Techniques,
`IEEE Global Telecommunications Conference – Globecom ’99 (1999)
`2316-2320 (“Huang”);
`• Exhibit 1008 – U.S. Patent No. 7,095,709 to Walton et al. (“Walton”);
`• Exhibit 1009 –U.S. Patent Application Publication No. 2002/0193146A1
`to Wallace et al. (“Wallace”);
`
`
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`• Exhibit 1010 – John C. Proakis and Masoud Salehi, Communication
`Systems Engineering, Prentice Hall (1994) (“Proakis”);
`• Exhibit 1011 – Hemanth Sampath, Shilpa Talwar, Jose Tellado, Vinko
`Erceg, Arogyaswami Paulraj, A Fourth-Generation MIMO-OFDM
`Broadband Wireless System: Design, Performance, and Field Trial
`Results, IEEE Communications Magazine, Volume: 40, Issue: 9,
`(September 2002, 143-149) (“Sampath”);
`• Exhibit 1012 – U.S. Patent No. 2,219,749 to A. A. Oswald (“Oswald”);
`• Exhibit 1013 – Lizhong Zheng and David N.C. Tse, Diversity and
`Multiplexing: A Fundamental Tradeoff in Multiple Antenna Channels,
`IEEE Transactions on Information Theory, Vol. 1, No. 8 (August 2002)
`(“Zheng”);
`• Exhibit 1014 – Siavash M. Alamouti, A Simple Transmit Diversity
`Technique for Wireless Communications, IEEE Journal on Select Areas
`in Communications, Vol. 16, No. 8 (October 1998, 1451-1458)
`(“Alamouti”);
`• Exhibit 1015 – U.S. Patent No. 5,345,599 to Paulraj et al. (“Paulraj ‘599
`Patent”); and
`• Exhibit 1016 – David Gesbert, Mansoor Shafi, Da-shan Shiu, Peter
`Smith, and Ayman Naguib, From Theory to Practice: An Overview of
`MIMO Space-Time Coded Wireless Systems, IEEE Journal on Selected
`Areas in Communications, Vol. 21, No. 3 (April 2003, 281-302)
`(“Gesbert”).
`
`B.
`
`4.
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`Background and Qualifications
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`I am currently a Professor in the Department of Electrical and
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`Computer Engineering, where I hold a Fox Family endowed Professorship. I also
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`serve as Associate Dean for Innovation and Entrepreneurship for the College of
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`Engineering at the University of Illinois at Urbana Champaign.
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`5.
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`I received a Bachelor of Science degree in Electrical Engineering and
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`Computer Science from Massachusetts Institute of Technology in 1990; a Master
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`of Science degree in Electrical Engineering and Computer Science from
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`Massachusetts Institute of Technology in 1992; and a Ph.D. in Electrical
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`Engineering from Massachusetts Institute of Technology in 1996.
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`6.
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`Since 1990, I have been active in the signal processing and
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`communications
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`fields.
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`
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`I have authored and/or co-authored numerous
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`publications, including books and refereed journal publications and conference
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`articles on the topic of signal processing and communication systems and devices.
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`A focus of many of these publications is on methods for improving the efficiency
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`and performance of systems that employ arrays of multiple transmitting elements,
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`multiple receiving elements, and systems that employ both multiple transmitting
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`and receiving elements. Such systems are often referred to as multiple-input /
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`multiple-output, or MIMO systems.
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`7.
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`I have designed, built, and patented various components of
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`communication and signal processing systems. These include various radio-
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`frequency, SONAR, LIDAR, air-acoustic and underwater acoustic signal
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`processing systems as well as wire-line, wireless, optical and underwater acoustic
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`communication systems. An important aspect in many of these systems is the
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`design of signal processing, modulation, and coding algorithms and architectures
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`for array-based and MIMO systems.
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`8.
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`I have taught both undergraduate and graduate level courses in signal
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`processing, and communication systems. For example, I have taught Digital Signal
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`Processing and Embedded DSP Laboratory classes. Additional examples of
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`courses I have taught at the University of Illinois at Urbana Champaign include:
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`Advanced Digital Signal Processing; Digital Signal Processing; Digital Signal
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`Processing Laboratory; Probability with Engineering Applications; Random
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`Processes; Optical Communication Systems; Advanced Lectures in Engineering
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`Entrepreneurship; Embedded DSP Laboratory; Developing Design Thinking;
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`Technology Commercialization; and Senior Design Laboratory. I have also
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`overseen numerous PhD and Master’s students researching topics related to signal
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`processing and communication systems.
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`9.
`
`I was the co-founder and CEO of Intersymbol Communications, Inc., a
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`communications component manufacturer focused on the development of signal
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`processing-enhanced components used in optical communication networks.
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`Intersymbol Communications, Inc. was acquired by Finisar Corporation, the
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`world's largest supplier of optical communication modules and subsystems.
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`10.
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`I was the co-founder and CEO of OceanComm, Inc., an underwater
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`acoustic communications component manufacturer focused on the development of
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`acoustic communications links for the subsea industry.
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`11.
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`I was appointed
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`the Associate Dean
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`for
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`Innovation and
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`Entrepreneurship in the College of Engineering, where I direct a wide range of
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`entrepreneurship activities. These include the campus-wide Illinois Innovation
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`Prize, celebrating our most innovative students on campus, as well as our annual
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`Cozad New Venture Competition. I am also the Principal Investigator for the
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`National Science Foundation’s Innovation Corps Sites program at the University of
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`Illinois, working with faculty and student startup companies.
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`12. My research and commercial experience led to my authoring of
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`numerous papers. I have authored over 200 papers on digital signal processing and
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`communication systems, several of which were voted "Best Paper of the Year" by
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`technical committees of the IEEE. Citing these and other contributions, I was
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`elected Fellow of the Institute of Electrical and Electronics Engineers ("IEEE")
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`“for contributions to signal processing techniques for digital communication.” I
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`was also selected as a Distinguished Lecturer of the Signal Processing Society.
`
`13.
`
`I hold ten granted U.S. patents, all in the field of communication
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`systems.
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`14.
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`In summary, I have over 25 years of experience related to signal
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`processing and communication systems.
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`15.
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`I have attached my curriculum vitae as Exhibit 1004, which includes a
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`list of all publications I have authored within the last ten years.
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`II. LEGAL FRAMEWORK
`16.
`I am a technical expert and do not offer any legal opinions. However,
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`counsel has informed me that in proceedings before the USPTO the claims of an
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`unexpired patent are to be given their broadest reasonable interpretation in view of
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`the specification from the perspective of one skilled in the art. The broadest
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`reasonable interpretation does not mean the broadest possible interpretation.
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`Rather, the meaning given to a claim term must be consistent with the ordinary and
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`customary meaning of the term (unless the term has been given a special definition
`
`in the specification), and must be consistent with the use of the claim term in the
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`specification and drawings. Further, the broadest reasonable interpretation of the
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`claims must be consistent with the interpretation that those skilled in the art would
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`reach. I have been informed that the ’711 patent has not expired.
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`17.
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`I have also been informed that the Patent Trial and Appeal Board
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`(“PTAB”) may soon apply the claim construction standard applied by Article III
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`courts (i.e., the Phillips standard) regardless of whether a patent has expired. I
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`have been informed that under the Phillips standard, claim terms are to be given
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`the meaning they would have to a person having ordinary skill in the art at the time
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`of the invention, taking into consideration the patent, its file history, and,
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`secondarily, any applicable extrinsic evidence (e.g., dictionary definitions). I
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`understand
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`that a proposed construction under
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`the broadest
`
`reasonable
`
`interpretation standard may also be in compliance with the Phillips standard.
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`18.
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`I have also been informed that the implicit or inherent disclosures of a
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`prior art reference may anticipate the claimed invention. Specifically, if a person
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`having ordinary skill in the art at the time of the invention would have known that
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`the claimed subject matter is necessarily present in a prior art reference, then the
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`prior art reference may “anticipate” the claim. Therefore, a claim is “anticipated”
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`by the prior art if each and every limitation of the claim is found, either expressly
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`or inherently, in a single item of prior art.
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`19. Counsel has also informed me that a person cannot obtain a patent on
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`an invention if his or her invention would have been obvious to a person of
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`ordinary skill in the art at the time the invention was made. A conclusion of
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`obviousness may be founded upon more than a single item of prior art. In
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`determining whether prior art references render a claim obvious, counsel has
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`informed me that courts consider the following factors: (1) the scope and content
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`of the prior art, (2) the differences between the prior art and the claims at issue, (3)
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`the level of skill in the pertinent art, and (4) secondary considerations of non-
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`obviousness. In addition, the obviousness inquiry should not be done in hindsight.
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`Instead, the obviousness inquiry should be done through the eyes of one of skill in
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`the relevant art at the time the patent was filed.
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`20.
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`In considering whether certain prior art renders a particular patent
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`claim obvious, counsel has informed me that courts allow a technical expert to
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`consider the scope and content of the prior art, including the fact that one of skill in
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`the art would regularly look to the disclosures in patents, trade publications,
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`journal articles, industry standards, product literature and documentation, texts
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`describing competitive technologies, requests for comment published by standard
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`setting organizations, and materials from industry conferences. I believe that all of
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`the references that my opinions in this IPR are based upon are well within the
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`range of references a person of ordinary skill in the art would consult to address the
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`type of problems described in the Challenged Claims.
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`21.
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`I have been informed that the United States Supreme Court’s most
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`recent statement on the standard for determining whether a patent is obvious was
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`stated in 2007 in the KSR decision. Specifically, I understand that the existence of
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`an explicit teaching, suggestion, or motivation to combine known elements of the
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`prior art is a sufficient, but not a necessary, condition to a finding of obviousness.
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`Thus, the teaching suggestion-motivation test is not to be applied rigidly in an
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`obviousness analysis. In determining whether the subject matter of a patent claim
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`is obvious, neither the particular motivation nor the avowed purpose of the
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`patentee controls. Instead, the important consideration is the objective reach of the
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`claim. In other words, if the claim extends to what is obvious, then the claim is
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`invalid.
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` I further understand the obviousness analysis often necessitates
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`consideration of the interrelated teachings of multiple patents, the effects of
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`demands known to the technological community or present in the marketplace, and
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`the background knowledge possessed by a person having ordinary skill in the art.
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`All of these issues may be considered to determine whether there was an apparent
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`reason to combine the known elements in the fashion claimed by the patent.
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`22.
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`I also understand that in conducting an obviousness analysis, a precise
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`teaching directed to the specific subject matter of the challenged claim need not be
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`sought out because it is appropriate to take account of the inferences and creative
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`steps that a person of ordinary skill in the art would employ. I understand that the
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`prior art considered can be directed to any need or problem known in the field of
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`endeavor at the time of invention and can provide a reason for combining the
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`elements of the prior art in the manner claimed. In other words, the prior art need
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`not be directed towards solving the same specific problem as the problem
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`addressed by the patent. Further, the individual prior art references themselves
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`need not all be directed towards solving the same problem. Under the KSR
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`obviousness standard, common sense is important and should be considered.
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`Common sense teaches that familiar items may have obvious uses beyond their
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`primary purposes.
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`23.
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`I also understand that a particular combination of prior art elements
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`being “obvious to try” may indicate that the combination was obvious even if no
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`one attempted the combination. If the combination was obvious to try (regardless
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`of whether it was actually tried) or leads to anticipated success, then it is likely the
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`result of ordinary skill and common sense rather than innovation. I further
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`understand that in many fields it may be that there is little discussion of obvious
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`techniques or combinations, and it often may be the case that market demand,
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`rather than scientific literature or knowledge, will drive the design of an invention.
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`I understand that an invention that is a combination of prior art must do more than
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`yield predictable results to be non-obvious.
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`24.
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`I understand that for a patent claim to be obvious, the claim must be
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`obvious to a person of ordinary skill in the art at the time of the invention. I
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`understand that the factors to consider in determining the level of ordinary skill in
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`the art include (1) the educational level and experience of people working in the
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`field at the time the invention was made, (2) the types of problems faced in the art
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`and the solutions found to those problems, and (3) the sophistication of the
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`technology in the field.
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`25.
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`I understand that at least the following rationales may support a finding
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`of obviousness:
`
`•
`
`•
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`•
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`•
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`•
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`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;
`“Obvious to try”—choosing from a finite number of identified,
`predictable solutions, with a reasonable expectation of success;
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`•
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`•
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`•
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`•
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`26.
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`A predictable variation of work in the same or a different field of
`endeavor, which a person of ordinary skill would be able to
`implement;
`If, at the time of the alleged invention, there existed a known problem
`for which there was an obvious solution encompassed by the patent’s
`claim;
`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 technological
`incentives or other market forces if the variations would have been
`predictable to one of ordinary skill in the art; and/or
`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.
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`I understand that even if a prima facie case of obviousness is
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`established, the final determination of obviousness must also consider “secondary
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`considerations” if presented. In most instances, the patentee raises these secondary
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`considerations of non-obviousness. In that context, the patentee argues an
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`invention would not have been obvious in view of these considerations, which
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`include: (a) commercial success of a product due to the merits of the claimed
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`invention; (b) a long-felt, but unsatisfied need for the invention; (c) failure of
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`others to find the solution provided by the claimed invention; (d) deliberate
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`copying of the invention by others; (e) unexpected results achieved by the
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`invention; (f) praise of the invention by others skilled in the art; (g) lack of
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`independent simultaneous invention within a comparatively short space of time;
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`(h) teaching away from the invention in the prior art.
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`27.
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` I further understand that secondary considerations evidence is only
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`relevant if the offering party establishes a connection, or nexus, between the
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`evidence and the claimed invention. The nexus cannot be based on prior art
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`features. The establishment of a nexus is a question of fact. While I understand
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`that Patent Owner has not offered any secondary considerations at this time, I will
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`supplement my opinions in the event that Patent Owner raises secondary
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`considerations during the course of this proceeding.
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`III. OPINION
`A. Background of the Technology
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`28. Electrical communication systems send information from a source to
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`one or more destinations. Ex. 1010, Proakis at 5. As shown in the following
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`functional block diagram, the typical communication system consists of an
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`information source, a transmitter, a physical channel, a receiver, and an output
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`transducer:
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`Id.
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`29. The physical channel is the physical medium that is used to send the
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`signal from the transmitter to the receiver. Id. at 7. In a wireless communications
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`system, the physical channel is the atmosphere, including the (possibly multiple)
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`paths through which the transmitted signal propagates on its way to the receiver.
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`Id. In radio communications, an antenna radiates electromagnetic energy into the
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`atmosphere in a specified frequency range. Id. at 15.
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`30.
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` Noise in the atmosphere (e.g., lightning, rain, thermal noise, etc.), in
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`the electronics implementing the communication system and other man-made
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`sources of noise can degrade the quality of the signal. Id. at 7, 19. Another form
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`of degradation in radio communications is called multipath propagation. Id.
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`Multipath propagation occurs when the transmitted signal arrives at the receiver
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`via multiple propagation paths, possibly at different delays. Id. at 16. In mobile
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`cellular transmissions, for example, signal transmissions between the base station
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`and the subscriber unit can be reflected from buildings, hills and other
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`obstructions. Id. at 696. This causes the signal to arrive at the receiver via
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`multiple propagation paths at different delays. Id. As a result, multipath
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`propagation can cause interference and signal fading. Id. at 16. The following
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`figure illustrates multipath propagation between a base station and a subscriber unit
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`in a cellular communication system:
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`Ex. 1011, Sampath at Figure 1.
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`31.
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`In radio communications, each transmitter must transmit information
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`in a specified frequency band. The extent of the continuous band of frequencies
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`the signal may occupy is referred to as the channel’s bandwidth. The channel’s
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`bandwidth and the amount of noise present in the channel limit its overall
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`achievable data rate. Ex. 1010, Proakis at 735-736.
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`32. For several decades, researchers have been devising ways of increasing
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`the data rate while decreasing the effects of noise all within the confines of
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`bandwidth constraints. Antenna diversity was developed, in part, to combat the
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`signal fading caused by multipath propagation. The concept of antenna diversity
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`dates at least to early radar systems used during World War II. However, it was
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`quickly applied to radio communication systems. As explained in U.S. Patent No.
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`2,219,749 to A. A. Oswald (Ex. 1012), which issued on October 29, 1940, “In a
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`diversity system the same transmitted signal is simultaneously received over a
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`plurality of paths through space from the signal source at the transmitting station.”
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`Ex. 1012, Oswald at page 1, column 1, lines 11-14. Oswald’s diversity system
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`included a receiving apparatus with a plurality of antennas in order “to receive
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`radio signals arriving from the same signal source over different space paths. Id. at
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`page 2, column 1, lines 7-27.
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`33. Diversity can be achieved using multiple antennas at the transmitting
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`node (i.e., transmit diversity), multiple antennas at the receiving node (i.e.,
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`“receive diversity”), or a combination of both. Ex. 1013, Zheng at 2. One well-
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`known way to achieve transmit diversity is using multiple antennas at the
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`transmitter to transmit replicas of the same information symbol. Ex. 1014,
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`Alamouti at 1452 (“Recently, some interesting approaches for transmit diversity
`
`have been suggested. . . . [A] similar scheme was suggested by Seshadri and
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`Winters . . . for a single base station in which copies of the same symbol are
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`transmitted through multiple antennas . . . .”). Receive diversity is using “multiple
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`antennas at the receiver and performing combining or selection and switching in
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`order to improve the quality of the received signal.” Id. at 1451. “By sending
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`signals that carry the same information through different paths, multiple
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`independently faded replicas of the data symbol can be obtained at the receiver
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`end; hence more reliable reception is achieved.” Ex. 1013, Zheng at 2.
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`34. By the early 1990s, researchers realized that multiple antenna systems
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`could also be used to increase the data rate in a wireless communication link. In
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`1992, Dr. Arogyaswami Paulraj and his advisor, Dr. Thomas Kailath filed the
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`application that became U.S. Patent No. 5,345,599. Ex. 1015, Paulraj ’599 Patent.
`
`The Paulraj ’599 Patent proposes increasing a channel’s data rate by splitting a
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`high data rate signal into several lower rate substreams that are simultaneously
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`transmitted from a plurality of transmitting antennas and subsequently received by
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`a plurality of receiving antennas:
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`The invention essentially consists of splitting a source signal,
`whose frequency content may exceed the allocated channel
`bandwidth, into signal components, and transmitting the
`components, each of whose frequency content is no greater than
`the allocated channel bandwidth, from spatially separated
`transmitters, all radiating into the broadcast area in the same
`frequency channel. The signals received from a plurality of
`antennas are processed to enable separation of the signals
`arriving in the same frequency channel into their separately
`transmitted
`components. These
`spatially demultiplexed
`components are then combined so as to reconstruct the original
`source signal.
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`Id. at 10:45-58.
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`Id. at Fig. 1.
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`35. This concept of transmitting independent information streams in
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`parallel though multiple spatial channels became known as in the art as “spatial
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`multiplexing.” Ex. 1013, Zheng at 2. Thus, spatial multiplexing increases data
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`rates without requiring additional bandwidth. Ex. 1015, Paulraj ’599 Patent at
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`4:3-6 (“Thus, the broadcast information capacity is increased several fold without
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`increasing the frequency bandwidth allocation.”).
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`36. By 2003, the term MIMO (“multiple-input-multiple-output”) referred
`
`to a wireless communication link where both the transmitting and receiving nodes
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`are equipped with multiple antennas. Ex. 1016, Gesbert at p. 281 (“MIMO
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`systems can be defined simply. Given an arbitrary wireless communication system,
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`we consider a link for which the transmitting end as well as the receiving end is
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`equipped with multiple antenna elements.”). The number of transmit antennas
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`need not be identical to the number of receive antennas (i.e., “square”). The figure
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`below, for example, depicts a wireless MIMO communication link where the
`
`transmitting node has N transmitting antennas and the receiving node has M
`
`receiving antennas:
`
`Id. at 282.
`
`37. At that time, MIMO systems could apply spatial multiplexing and/or
`
`diversity techniques. For example, MIMO schemes had been developed that
`
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`IPR2018-01476
`Apple Inc. EX1003 Page 19
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`would switch between diversity and spatial multiplexing modes depending on the
`
`instantaneous channel conditions. Ex. 1013, Zheng at 2.
`
`38. Researchers were also devising schemes to optimize MIMO channels
`
`by simultaneously maximizing
`
`the amount of diversity gain and spatial
`
`multiplexing gain. Ex. 1013, Zheng at 2 (“In this paper, we put forth a different
`
`viewpoint: given a MIMO channel, both gains can in fact be simultaneously
`
`obtained . . .”) (emphasis in original). Zheng, for example, proposes a MIMO
`
`system where, out of m total transmit antennas and n total receiving antennas, r
`
`transmit antennas and r receive antennas are used for spatial multiplexing and the
`
`remaining m-r transmit and n-r receive antennas are used for diversity. Id. at 3.
`
`This arrangement provides both protection against fading and the ability to
`
`accommodate a higher data rate. Id.
`
`39. Therefore, the field of MIMO communications systems was already
`
`well developed by May 2003, as were the concepts of diversity and spatial
`
`multiplexing. MIMO systems utilizing both diversity and spatial multiplexing
`
`techniques to improve both signal reliability and data rates were also well known.
`
`B.
`
`Level of a Person Having Ordinary Skill in the Art
`
`40.
`
`I was asked to provide my opinion as to the level of skill of a person
`
`having ordinary skill in the art (“PHOSITA”) of the ’711 Patent at the time of the
`
`claimed invention, which counsel has told me to assume is May 9, 2003. In
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`IPR2018-01476
`Apple Inc. EX1003 Page 20
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`determining the characteristics of a hypothetical person of ordinary skill in the art
`
`of the ’711 Patent, I considered several factors, including the type of problems
`
`encountered in the art, the solutions to those problems, the rapidity with which
`
`innovations are made in the field, the sophistication of the technology, and the
`
`education level of active workers in the field. I also placed myself back in the time
`
`frame of the claimed invention and considered the colleagues with whom I had
`
`worked at that time.
`
`41.
`
`In my opinion, a person of ordinary skill in the art would have been
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`someone having a Bachelor’s degree in electrical engineering or the equivalent
`
`plus 3 years of experience working with multi-antenna wireless communication
`
`systems or a Master’s degree in electrical engineering with an emphasis on
`
`communication systems or the equivalent plus 1 year of experience working with
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`multi-antenna wireless communication systems.
`
`42. Based on my education, training, and professional experience in the
`
`field of the claimed invention, I am familiar with the level and abilities of a person
`
`of ordinary skill in the art at the time of the claimed invention. In my 25 years
`
`active in the industry, I have developed and performed research on multi-antenna
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`wireless communication systems, including MIMO systems. I have taught courses
`
`in digital signal processing, including courses that involve MIMO signal
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`
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`IPR2018-01476
`Apple Inc. EX1003 Page 21
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`processing for communication. Thus, I was at least a person having ordinary skill
`
`in the art as of the priority date of the ’711 Patent.
`
`C. Summary of Prior Art
`
`1.
`
`Paulraj
`
`43. Paulraj describes a wireless cellular network including base stations
`
`communicating with subscriber units. Ex. 1005, Paulraj at Abstract, Figs. 1A-1C.
`
`Paulraj seeks to “improve data transfer speed in the multiple access environments
`
`currently utilized for wireless communications within the constraints of available
`
`bandwidth” by implementing spatial multiplexing. Id. at 1:46-56. “Spatial
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`multiplexing (SM) is a transmission technology which exploits multiple antennas
`
`at both the base stations(s) and at the subscriber units to increase the bit rate in a
`
`wireless radio link with no additional power or bandwidth consumption.” Id. at
`
`5:38-42.
`
`Under certain conditions, spatial multiplexing offers a linear
`increase in spectrum efficiency with the number of antennas.
`Assuming, for example, N=3 antennas are used at the
`transmitter and receiver,
`the stream of possibly coded
`information symbols is split into three independent substreams.
`These substreams occupy the same channel of a multiple access
`(MA) protocol, the same time slot in a time-division multiple
`access (TDMA) protocol, the same frequency slot in frequency-
`division multiple access (FDMA) protocol, the same code/key
`sequence in code-division multiple access (CDMA) protocol or
`the same spatial target location in space-division multiple
`access (SDMA) protocol. The substreams are applied separately
`to the N transmit antennas and launched into the radio channel.
`Due to the presence of various scattering objects (buildings,
`
`
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`IPR2018-01476
`Apple Inc. EX1003 Page 22
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`cars, hills, etc.) in the environment, each signal experiences
`multipath propagation. The composite signals resulting from
`the transmission are finally captured by an array of receive
`antennas with random phase and amplitudes. For every
`substream the set of N received phases and N received
`amplitudes constitute its spatial signature.
`
`At the receive array, the spatial signature of each of the N
`signals is estimated. Based on this information, a signal
`processing technique is then applied to separate the signals,
`recover the original substreams and finally merge the symbols
`back together.
`
`Id. at 5:42-67.
`
`44. Generally, Paulraj’s system includes a base station (BTS) 132 having,
`
`among other things, a multiple access spatial transmitter 310 and a multiple access
`
`spatial receiver 330. Id. at 12:40-44 (“The BTS 132 includes: a multiple access
`
`spatial transmitter 310, a multiple access spatial receiver 330, a controller module
`
`320 and upstream processes/logic 300, further details of which are provided in the
`
`accompanying FIGS. 4-5.”), Fig. 3. The BTS transmitter 310 includes multiple
`
`transmit antennas 134T-136T. Id. at Fig. 3.
`
`45. Likewise, the BTS receiver 330 includes multiple receive antennas
`
`134R-136R. Id. at 14:15-18 (“Composite signals corresponding thereto are
`
`received by antennas 134R-136R of the SM-- MA configurable receiver 330 of the
`
`BTS.”), Fig. 3.
`
`46. The subscriber unit (SU) 138 includes a multiple access spatially
`
`configured receiver 380 and a multiple access spatially configured transmitter 350.
`
`
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`IPR2
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