Trials@uspto.gov
`571-272-7822
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`Paper No. 30
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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 IPR2019-00047 (Patent 9,154,356 B2)
`Case IPR2019-00048 (Patent 9,154,356 B2)
`Case IPR2019-00049 (Patent 9,154,356 B2)
`______________
`
`Record of Oral Hearing
`Held: April 7, 2020
`____________
`
`
`
`
`Before SCOTT HOWARD, MICHELLE N. WORMMEESTER, and
`AARON W. MOORE, Administrative Patent Judges.
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`
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`IPR2019-00047 (Patent 9,154,356 B2)
`IPR2019-00048 (Patent 9,154,356 B2)
`IPR2019-00049 (Patent 9,154,356 B2)
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`
`
`
`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`
`BEN FERNANDEZ, ESQ.
`GREG LANTIER, ESQ.
`Wilmer, Cutler, Hale, Pickering & Dorr, LLP
`17th Street Plaza
`1225 17th Street, Unit 2600
`Denver, CO 80202
`
`
`
`ON BEHALF OF THE PATENT OWNER:
`
`
`DAVID B. COCHRAN, ESQ.
`Jones Day
`901 Lakeside Avenue E.
`Cleveland, OH 441114
`
`
`
`
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`The above-entitled matter came on for hearing on Tuesday, April 7,
`2020, commencing at 12:30 p.m., by video.
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`P R O C E E D I N G S
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`JUDGE MOORE: Good afternoon. Do we have a court reporter on
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`the line?
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`THE REPORTER: Yes, the court reporter’s here.
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`JUDGE MOORE: Okay. We are here for a combined hearing in IPR
`2019-00047, 00048 and 00049. I’m Judge Moore; Judges Wormmeester and
`Howard are present by video. Can we have appearances for the Petitioner.
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`MR. FERNANDEZ: Good afternoon, Your Honor. This is Ben
`Fernandez. I’m here with my colleague Greg Lantier for Petitioner Intel
`Corporation.
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`JUDGE MOORE: Great. And for Patent Owner.
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`MR. LANTIER: Good afternoon, Your Honors.
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`MR. COCHRAN: Good afternoon, Your Honors. Dave Cochran
`from Jones day on behalf of the Patent Owner Qualcomm.
`
`JUDGE MOORE: Great. We thank you all for your flexibility in
`participating in this all video hearing which is a little bit unusual for us.
`Because it’s a departure from our present practice I wanted to first make a
`couple of points, or a few points. First, our primary concern is that we
`preserve your right to be heard, so if at any time during the proceeding you
`encounter a technical problem that affects your ability to participate please
`let us know immediately; if you lose video speak up, if you lose audio wave
`your hand around and otherwise you can contact the staff member who set
`up the call in the first place. Second, when not speaking, please mute your
`connection. Third, please identify yourself each time you speak for the court
`reporter. Fourth, you can be aware that the panel members have the entire
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`record including demonstratives but please be sure when referring to
`demonstratives, papers, or exhibits that you identify the slide or page
`number. And finally, please be aware that members of the public may be
`listening to, but not viewing, this hearing.
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`Okay. Our Hearing Order granted each side 90 minutes and we’re
`going to start with the Petitioner.
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`MR. FERNANDEZ: Thank you, Your Honor. May it please the
`Board, again my name is Ben Fernandez and again I’m joined by my
`colleague Mr. Greg Lantier. Also joining us on the line by your feed are Mr.
`Brad Waugh and Mr. Matt Fagan, representatives of Petitioner Intel
`Corporation. Just by way of background --
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`JUDGE MOORE: I apologize, did you want to reserve time for
`rebuttal?
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`MR. FERNANDEZ: Yes, Your Honor. We would like to reserve 30
`minutes for rebuttal.
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`JUDGE MOORE: Okay. So we don’t have our clock with the light
`on it here obviously but I will keep time. I will let you know when you have
`35 minutes left and then when there are 30 minutes left of your time.
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`MR. FERNANDEZ: Thank you very much, Your Honor, and on
`behalf of Intel we’d also like to thank the panel for the ability to move
`forward with this hearing given the circumstances and I’ll ask if at any time
`I break up or become unclear please feel free to let me know or give me a
`visual signal and I will attempt to readjust the audio or the video.
`
`So with that, just a little bit of background, Judges Moore and
`Wormmeester may remember we just had a hearing on February 27th about
`the first two out of five petitions that Intel has filed against the 356 patent
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`and these grounds are summarized on slide 4 just for reference. Those are
`the Lee petitions. Slide 5 of Petitioner’s demonstratives lays out the grounds
`in the Uehara petition and then slide 6 lays out the grounds in the Jeon and
`Xiong petitions.
`Today I will be covering the claim construction questions as well as
`discussing the Uehara petition and, if amenable to the panel, my colleague
`Mr. Lantier will then discuss the Jeon and Xiong petitions and grounds.
`Today we have a lot of slides, probably (indiscernible) --
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`JUDGE WORMMEESTER: Counsel.
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`MR. FERNANDEZ: Yes.
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`JUDGE WORMMEESTER: Counsel, sorry, this is Judge
`Wormmeester. Can you just pause for one second, we have a technical
`difficulty on our side.
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`MR. FERNANDEZ: Yes, Your Honor.
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`JUDGE WORMMEESTER: Sorry about that.
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`(Pause.)
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`MR. FERNANDEZ: This is Mr. Fernandez. Can you hear me okay?
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`JUDGE WORMMEESTER: Yes, thank you.
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`MR. FERNANDEZ: All right. Judge Howard, I was just saying
`before the audio cut out that first of all thanking the panel for
`accommodating this hearing, especially given all of our circumstances and
`we had a hearing that Judges Moore and Wormmeester will of course
`remember from February 27 about the first of the new petitions out of the
`five that Intel has filed against this 356 patent and those Lee based grounds
`are summarized on slide 4 of Petitioner’s demonstratives and slide 5
`summarizes the Uehara grounds, this is the 047 petition, and slide 6
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`summarizes the grounds for the 048 and 049 petitions which are the Jeon
`and Xiong petitions. I will plan today to cover any claim constructions
`questions as well as the Uehara petition and, if amenable to the Board, my
`colleague Mr. Lantier will plan to cover the Jeon and Xiong petitions. We’d
`like to reserve 30 minutes for rebuttal, please.
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`JUDGE MOORE: Okay.
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`MR. FERNANDEZ: Before I begin with a brief technology
`background, we have a lot of slides today and I just wanted to know are
`there any questions that I can begin by answering or any particular issues
`that the panel would like to focus on in the Uehara and claim construction
`ground?
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`JUDGE WORMMEESTER: None at the moment. Thank you.
`
`MR. FERNANDEZ: All right. Well I’ll jump us ahead here to slide
`10 of our demonstratives. Slide 10 illustrates a basic receiver architecture.
`You have an antenna that receives a signal from filtering an LNA, this is a
`low noise amplifier for amplifying signals without adding a bunch of noise
`to them and then you have mixers. The mixers are shown in purple on slide
`10. The mixers are what actually separate carriers from the signal using
`local oscillator technology, and finally many of the basic receiver
`architectures have some type of filtering, especially if the signal goes to be
`further processed in the base band.
`
`Slide 11 illustrates visually carrier aggregation. The top of slide 11
`shows figure 2 from Dr. Fay’s expert report, this is Intel’s expert, and as you
`can see as signals come on to the antennae there are lots of channels, lots of
`carriers that can be present and illustrated moving from the top to the bottom
`figure on slide 11 filtering is often used to remove undesired signals but
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`within a certain desired frequency band there are carriers or channels and
`what’s interesting to note as we move to the rest of today’s discussion is that
`the 356 patent is all about receivers. It’s a receiver side hardware system
`and it really doesn’t know -- if you look at channel 1 on the left here,
`channel 2 next to it in green -- it really doesn’t know whether that orange
`carrier was sent from the same device as the green carrier or whether they’ve
`been related to one another or whether they’re logically related in any way.
`It just feeds these sets of carriers aggregated at its input use (phonetic). So
`slide 11 illustrates that visually.
`
`I’d like to move to slide 12 of Petitioner’s demonstratives. Slide 12 is
`an annotated version of a figure from the Kaukovuori reference. This was a
`reference cited against the ’356 patent and this reference teaches carrier
`aggregation and as you can see here, this example uses two carriers, a green
`carrier and an orange carrier but they’re shown as aggregated in that they are
`together coming on to the antennae and they remain together passing all the
`way through each LNA here. As you see this figure illustrates two different
`receive paths or two different RF front ends and these two carriers pass
`through the LNA they’re amplified together. It’s only when they get to the
`mixer that each mixer is then able to pull off an individual carrier using a
`local oscillator frequency and so this Kaukovuori figure helps to illustrate
`how a carrier aggregated signal moves through different parts of a receiver
`and fetcher (phonetic).
`
`JUDGE WORMMEESTER: Counsel, doesn’t Kaukovuori with
`respect to carrier aggregation say that carrier aggregation requires that each
`carrier signal be demodulated at the receiver wherafter the message data
`from each of the signals can be combined in order to reconstruct the original
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`data? I’m looking at column 1 of Kaukovuori right around line 30, right at
`line 30. So although I understand that you’re saying the signals are in your
`view aggregated because they come in at the same time, Kaukovuori seems
`to explain that they’re aggregated because not only have they come in at the
`same time but after receiving the signals they would be combined in order to
`reconstruct original data. So the receiver somehow has to know that the
`data’s related, right, or at least according to Kaukovuori.
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``MR. FERNANDEZ: And I see, Your Honor, I see the passage that
`you’re referring to. This is Intel Exhibit 1025. It’s true that that passage
`describes a situation, a particular type of carrier aggregation where the
`information on different carriers is related to each other and then recombined
`as it passes through the baseband but I think it’s important to go back to the
`claim language here of the 356 and we can look at that here on Petitioner’s
`demonstrative No. 20.
`If you look at the claim language here and ask where does the carrier
`aggregation have to be employed? Claim 1 for example says the input RF
`signal employing carrier aggregation and so even though that passage of
`Kaukovuori describes what can later be done in one example of the use of
`carrier aggregation that’s certainly not the only type, for example, of carrier
`aggregation and the claim itself is referring to the carrier aggregation as
`being present at the RF input signal. This is in the Kaukovuori diagram I
`just showed you on slide 12, that the place right before the LNAs in that
`diagram, that’s where the carrier aggregation has to occur and so physically -
`-
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`JUDGE WORMMEESTER: Wouldn’t it occur in the beginning and
`the end? I mean in order for it to work, doesn’t it have to be -- doesn’t the
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`carrier aggregation process have to start at the beginning and end at the end?
`You know, so at the input signal side and then continue on and be completed
`at the receiver end? I mean I guess I’m not separating the two places of
`where carrier aggregation occurs. I guess I understand it based on
`Kaukovuori that it occurs, you know, starting from the input all the way to
`the receiver end (indiscernible.) Is that accurate or are you able to divide
`carrier aggregation as happening in one place and happening in another
`place and those are two different types of carrier aggregation?
`MR. FERNANDEZ: Well, Your Honor, the carrier aggregation
`according to the claim refers to the RF input signal but the carrier
`aggregation described by Kaukovuori, we don’t dispute that that falls within
`the meaning of carrier aggregation but that this is just one type of carrier
`aggregation that the ’356 patent refers to and also encompasses with its
`claim term carrier aggregation. So we don’t dispute that Kaukovuori
`describes one particular type of carrier aggregation in which the data, the
`information on the carriers, may be related. But that’s not always the case in
`carrier aggregation either. Here or in LTE carrier aggregation, the data on
`the carrier may not be necessarily be related and if we --
`JUDGE WORMMEESTER: Do you have evidence to support that,
`where they’ve given us an example where they don’t need to be related
`that’s been cited in the briefing?
`MR. FERNANDEZ: Yes, Your Honor. There are -- first of all there
`are references in the ’356 patent to several different types of carrier
`aggregation and so I will like to perhaps jump to, so let’s jump to
`Petitioner’s slide 32 please. I just mentioned that the patent refers to
`multiple different types of carrier aggregation, different technologies that
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`could employ carrier aggregation and some of these, as seen on slide 32, are
`not LTEs, there are things like (indiscernible) Wi-Fi, GSM, CDMA 2000.
`So carrier aggregation as described in the ’356 patent accommodates
`multiple different radio technologies and not all of those technologies
`involve this type of detailed logical relationship between different carriers.
`So it’s not the dispute that Kaukovuori teaches carrier aggregation, it does,
`it’s this one type of carrier aggregation -- Kaukovuori teaches one type of
`carrier aggregation that is covered within the meaning of the term in the ’356
`patent.
`JUDGE MOORE: So you would say that any RF signal that uses
`multiple carriers is using carrier aggregation?
`MR. FERNANDEZ: Yes. Well the use of the carriers have to be
`simultaneous so according to our proposed construction carrier aggregation
`means simultaneous operation on multiple carriers and I think the
`simultaneous is to get the aggregation because we’re not talking about a first
`carrier received at the first time and a second carrier received at a second
`time, we’re talking about the ability to handle two carriers simultaneously
`and this goes back to what it was that Qualcomm had to add to its claims to
`get the patent granted.
`There was a portion in the file history where Qualcomm distinguished
`the Hirose reference based on having had the limitation carrier aggregation
`but ultimately the patent was granted not because of carrier aggregation
`which, as we can discuss, has a very broad meaning assigned to it by the
`patent itself, but that wasn’t the reason they got the patent. It was ultimately
`because they introduced this limitation that each amplifier stage is
`configured to be independently enabled or disabled and this relates to the
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`simultaneous concept I just mentioned because sometimes in carrier
`aggregation you receive multiple carriers and you have to be able to handle
`each one. Sometimes you only receive one carrier in a carrier aggregated
`signal and then you have to be able to process that one carrier and the ’356
`patent describes hardware circuitry that is able to turn off different amplifier
`stages when they’re not in use and this is illustrated on Petitioner’s slide 22
`which shows these two different stages and are color coded and this is
`similar coding to what’s used in our petition and you can see there are
`switches shown in yellow that are used to simply turn on or off each
`amplifier stage independently.
`JUDGE MOORE: And so the aggregation piece would be
`simultaneous?
`MR. FERNANDEZ: Your Honor, I’d say the simultaneous concept,
`that is what results in the aggregation practically speaking here. As I
`showed on the earlier slide showing the different carriers coming into the
`antenna, those are all aggregated. Physically it’s not like they’re hugging
`different sides of the same one, they’re all together along the antenna -- not
`just the antennae, along the input to the LNAs. The same set of carriers go
`to both LNAs in the two LNAs area (phonetic) and that’s aggregation.
`JUDGE MOORE: It’s just the fact that they’re received at the
`antennae at the same time means that they’re aggregated?
`MR. FERNANDEZ: Your Honor, yes. If we’re talking about the
`limitation, the input RF signal employing carrier aggregation then yes, that
`limitation is met by multiple carriers being employed simultaneously. It
`could be at the antennae input, it could also be at the input to each amplifier
`stage. It’s that location within the circuit where the carrier aggregation must
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`be employed.
`JUDGE MOORE: Okay. I’m just trying to understand what the word
`aggregation means in this context, what does it mean to Petitioner?
`MR. FERNANDEZ: So aggregation in its simplest form just means
`together and this is consistent with Patent Owner’s definition which just
`means collected together, assembled, and which Patent Owner defines at
`page 30 of their Patent Owner response. Our slide 36, if you look at our
`slide 36 this puts forth Dr. Fay’s discussion of this concept and he does say,
`Judge Moore, as you’re alluding to when the claimed RF signal employs
`simultaneous operation on multiple carriers those carriers will be aggregated
`along the entire signal. So it’s as most basic level from a physical
`perspective, those carriers are aggregated at the RF input.
`JUDGE MOORE: And so is that just because that’s your view of the
`lay meaning of aggregation or because carrier aggregation has some term of
`the art with that particular meaning? Is the term there that particular
`meaning?
`MR. FERNANDEZ: So, Your Honor, this is one explanation for
`Qualcomm’s argument that Intel’s construction reads out aggregation, it
`doesn’t. It accommodates the aggregation concept. You know, our slide 35
`also demonstrates that our construction does not read out simultaneous
`operation or carrier aggregation because, you know, this is Qualcomm’s
`argument that our construction doesn’t accommodate carrier aggregation
`because the claim already says that but as highlighted there, the claim does
`not already say simultaneous operation on multiple carriers. The patent
`itself does and our position is that the patent is clear that that’s what it
`means. It says carrier aggregation is simultaneous operation on multiple
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`carriers and I know Your Honors asked some questions along these lines at
`the last hearing but I also wanted to point out at this hearing when we talk
`about the Uehara reference with respect to carrier aggregation, the Uehara
`reference also has very strong teachings along these lines.
`So, apologies for jumping around, slide 56 of Petitioner’s slides
`begins with this discussion. Uehara itself actually uses this language
`multiple channels with multiple carrier frequencies processing for dual, for
`multi carrier signals and elsewhere within Uehara, this is Petitioner’s Exhibit
`1003 at paragraph 47, there’s also strong language about the RF signal may
`include two channels encoded around two different carrier frequencies and
`in parenthesis (i.e., dual carriers).
`JUDGE WORMMEESTER: (Indiscernible.)
`MR. FERNANDEZ: So there is some strong language --
`JUDGE WORMMEESTER: I’m sorry, go ahead.
`MR. FERNANDEZ: No, Your Honor, I was going to say there is
`some strong language in Uehara.
`JUDGE WORMMEESTER: I just wanted to follow up
`(indiscernible.) Didn’t Hirose in the prosecution history which Applicant
`distinguishes the invention over, didn’t Hirose also use multiple carrier
`signals, multiple channels, multiple carrier frequencies?
`MR. FERNANDEZ: Yes, Your Honor. The Hirose reference use
`multiple signals simultaneously but in Hirose those signals were taught by
`Hirose to include the same data so they’re in the redundancy built in and this
`is covered on our slide 33, the relevant quotes from the prosecution history.
`So these are three, you know, there’s a terrestrial signal and a satellite signal
`for example in Hirose and Patent Owner distinguished Hirose by arguing
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`that when it added carrier aggregation, it was not referring to redundant data
`at a common data rate. Instead, it was referring to increased aggregated data
`rate and this is really just another way to say -- increased aggregated data
`rate is really just another way to say not redundant data at a common data
`rate because if you have multiple signals and you’re sending different data
`across different signals, that will increase your aggregated data rate.
`JUDGE WORMMEESTER: Thank you.
`MR. FERNANDEZ: And our proposed construction accommodates
`this and our papers also, you know, discuss and we certainly discuss Hirose
`and this came up in the last hearing as well that this, if Your Honors are
`considering whether this is an express disavowal of claim scope, our
`position is that it was not. It does not rise to that level. Even if it did,
`obviously Your Honors will have to make the ultimate determination here in
`terms of how to construe this limitation and if Your Honors don’t feel that
`our proposed construction fully accommodates this then we submit that the
`proper approach would be to include some language regarding non-
`redundancy. This is covered in footnote 2 of our reply, this discussion. But
`to accommodate Hirose’s teachings that one would not go so far as to
`introduce the full tripartite claim construction proposed by Qualcomm.
`So given the -- we do have a difference here to focus on which is that
`Hirose also has very strong teachings about carrier aggregation and also the
`petitions raised the ground of the Uehara reference plus – sorry, I said
`Hirose just now, I meant Uehara -- our petition also raised the ground of
`Uehara plus Feasibility Study. Here in the Feasibility Study, this is a
`reference that Qualcomm doesn’t dispute teaches is a carrier aggregated RF
`input signal and Patent Owner argues that the Feasibility Study doesn’t teach
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`an amplifier.
`It does teach an amplifier and I’m happy to discuss those passages that
`are also highlighted in our briefing. But really what we’re using the
`Feasibility Study for here is just its signal and the architecture of the
`hardware, the structure to accommodate simultaneous multi carrier signals is
`in Uehara. Carrier aggregation is taught by Uehara but it doesn’t use the
`words carrier aggregation so if that’s the magic here to matchmake the
`combination, Feasibility Study has those teachings and Feasibility Study
`refers to the particular type of multi RF front end architectures that would
`accommodate such carrier aggregated signals and that language, it’s just a
`perfect match with what’s described in Uehara, so Feasibility Study --
`JUDGE WORMMEESTER: If Uehara already teaches – I’m sorry,
`go ahead.
`MR. FERNANDEZ: No, sorry Your Honor, there’s a bit of a lag. I
`didn’t mean to talk over you. Please go ahead.
`JUDGE WORMMEESTER: If Uehara already teaches using multiple
`signals, why would you bring in the signal from the Feasibility Study? If
`that’s --
`MR. FERNANDEZ: Well, Your Honor --
`JUDGE WORMMEESTER: -- if that’s the (indiscernible) you’re
`bringing it in?
`MR. FERNANDEZ: I think it’s a good question. I do think it would
`be perfectly reasonable to find that Uehara itself teaches carrier aggregation
`and that’s certainly the ground we’re raising. It’s just if you were to take a
`narrower view of carrier aggregation, then even that narrower view
`Qualcomm doesn’t dispute is taught by Feasibility Study. So it’s basically --
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`IPR2019-00047 (Patent 9,154,356 B2)
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`and Feasibility Study as we pointed out in our briefing, it does actually
`discuss certain benefits of LTE carrier aggregation and so, as Dr. Fay puts it
`in his declaration, in order to unlock those benefits a person of ordinary skill
`in the art would use that particular type of signal with a multi front end
`architecture and Uehara is one such architecture that doesn’t require any
`modification in order to accommodate an LTE carrier aggregated signal just
`as it already is built to accommodate any other types of multi carrier carrier
`aggregated signals and so just for the record, our slide 79 sets forth the --
`some key points about this motivation to combine Uehara with the
`Feasibility Study and it’s a fairly natural combination because, as I
`mentioned, if we’re using the signal from Feasibility Study with the
`architecture of Uehara.
`On this architecture point I think I would like to highlight a few points
`in our grounds related to the independently enabling or disabling of
`amplifier stages. This is another disputed issue in this Uehara petition. The
`claim of the ’356 patent, each claim as I mentioned recites that each
`amplifier stage is configured to be independently enabled or disabled and
`this was the final amendment that Qualcomm made in order to secure
`allowance of this patent and this is also taught by Uehara at the highest level,
`and I’m on slide 48 of our slide deck, at the highest level the ’356 patent
`describes circuitry that has switches and each amplifier stage has the switch
`to be able to turn on and off that amplifier stage.
`As we see here on slide 48 Uehara has the same architecture, the same
`physical structure that permits this activity and it’s also important to note
`that the claim doesn’t just say independently enabled or disabled, it says
`configured to be independently enabled or disabled. What does it mean by
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`IPR2019-00047 (Patent 9,154,356 B2)
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`that? Well, it means most basically that there has to be some ability to turn
`each amplifier stage on and off and we have that in Uehara.
`JUDGE MOORE: (Indiscernible.)
`JUDGE WORMMEESTER: (Indiscernible) able to -- oh, go ahead,
`
`sorry.
`
`JUDGE MOORE: Why would want to be able to turn each amplifier
`stage on or off individually if you’re using the carrier aggregated signal of
`the Feasibility Study which obviously requires both?
`MR. FERNANDEZ: Well, Your Honor, the carrier aggregated signal
`of Feasibility Study does not always require both carriers to be present and
`so this is covered on our – let’s see if I have a good slide for you here. Yes,
`slide 78 for example. Two or more combined (phonetic) carriers, there are
`other places of Feasibility Study that refer to one or more carriers as being
`part of a carrier aggregated signal and so as I believe -- and so it’s like you
`were given an example at the last hearing, sometimes you have one carrier
`and you’re streaming a video on the carrier, you don’t need a second carrier
`but maybe you also have to send a text at the same time and there’s a
`decision about including the text message on the second carrier as one
`example. So even in the LTE carrier --
`JUDGE MOORE: But that’s not aggregation as described in the
`Feasibility Study, right? That’s a different – that’s your version or your
`understanding of carrier aggregation but that’s not the type of carrier
`aggregation where the signal is being used for one purpose, right? So if you
`need to use the signal for one purpose you need both stages; is that right?
`MR. FERNANDEZ: I think if two carriers on a signal are in fact
`logically related to one another and are being simultaneously received, that
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`would be a situation in which you want to have both amplifier stages on. I
`agree with that, and then that’s similar to how the ’356 patent describes its
`amplifier stages. When you have two carriers present you have them both
`on and that’s shown in figures 6B and 6C of the ’356 patent, when you’re
`not using the second amplifier stage you turn it off.
`JUDGE MOORE: Right. That’s described in the patent, but if what
`you’re wanting to do -- if you don’t have the patent to look at and what
`you’re wanting to do is use the Feasibility Study-type carrier aggregation,
`why would you use that with a system that allows the two stages to be
`independently enabled and disabled?
`MR. FERNANDEZ: Your Honor, the term carrier aggregation as
`used in the Feasibility Study is not limited to the particular use case in which
`you happen to have two carriers on the signal. It also includes the use of this
`technology when there may be one or multiple component carriers. So I
`found the cite, it’s Intel Exhibit 1004 at the bottom of page 8 of the
`Feasibility Study. It refers to the terminal may simultaneously receive or
`transmit one or multiple component carriers.
`JUDGE MOORE: And so (indiscernible) --
`MR. FERNANDEZ: Page 8 of the Feasibility Study, page 8.
`JUDGE MOORE: Okay.
`MR. FERNANDEZ: So there it says may simultaneously receive or
`transmit one or multiple component carriers depending on its capability. So
`the Feasibility Study teaches the very specific type of carrier aggregation
`used in LTE and it basically points to all of the architectures that have
`multiple RF front ends that are able to handle those types of signals and as
`we set forth on slide 79 of our demonstratives, there are many reasons set
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`IPR2019-00047 (Patent 9,154,356 B2)
`IPR2019-00048 (Patent 9,154,356 B2)
`IPR2019-00049 (