Intel Corporation
`v.
`Qualcomm Incorporated
`
`IPR2019-00128
`IPR2019-00129
`U.S. Patent No. 9,154,356
`Patent Owner’s Demonstrative Exhibits
`
`1
`
`
`v.
`Qualcomm Incorporated
`
`IPR2019-00128
`IPR2019-00129
`U.S. Patent No. 9,154,356
`Patent Owner’s Demonstrative Exhibits
`
`1
`
`
`
`U.S. Patent No. 9,154,356
`
`A—\,— -M..,
`
`
`
`
`
` Vwrw “
`
`(12) United States Patent
`LS 9,154,356 32
`(l0) Patent No.:
`
`Tasic el al.
`(45) Date of Patent:
`Oct. 6, 2015
`
`
`
`
`
`
`
`
`---‘
`
`
`
`Amplifier
`I Stage 2
`
`I :
`
`Matching
`Circuit
`
`,
`7
`
`Intel 1301, Fig. 6A*
`* All Citations are to IPR2019-00128, unless othelwis‘e’ noted;
`
`(54)
`
`(75)
`
`(73)
`
`(’)
`
`(21)
`(22)
`
`LOW NOISE AMPLIFIERS FOR (.‘ARRII‘IR
`AGGREGATION
`Inventors: Altluandar Mlodrag ‘l'nlc. San Mega
`(‘A (US): Anoth Homl lhvkrwalla.
`Sun Diego. (“A (US)
`Assigncc: QUALCOMM Incorporated. San
`Diego. (‘.\ (US)
`Subject to any disclaimer. the (em: ol'lhjs
`pmem is extended or adjusted under 35
`lJ.S,(‘. 154(1)] by Odnys.
`.-\ppL No; 13/590,423
`Filed:
`Aug. 21,2012
`
`Notice:
`
`(an
`
`( N
`c N
`
` W
`
`
`
`
`
`Relervncen Cited
`L'. S, PATENT DOCUMENTS
`3.9ll.354 A
`40“.?“ A
`
`FOREIG
`H:
`
`m m
`
`
`
`Instituted Grounds
`
`Ground I (IPR2019-00128): Claims 1, 7, 8, 11, 17 and 18 as Anticipated by Lee
`
`Ground II (IPR2019-00128): Claims 7 and 8 as Obvious over Lee
`
`Ground III (IPR2019-00128): Claims 1, 7, 8, 11, 17 and 18 as Obvious over Lee and
`
`Feasibility Study
`
`Ground I (IPR2019-00129): Claims 2, 3, 4, 5 and 6 as Anticipated by Lee
`
`Ground II (IPR2019-00129): Claim 10 as Obvious over Lee and Youssef
`
`Ground III (IPR2019-00129): Claims 2, 3, 4, 5 and 6 as Obvious over Lee and
`
`Feasibility Study
`
`Ground IV (IPR2019-00129): Claim 10 as Obvious over Lee, Feasibility Study and
`
`Youssef
`
`'JJ
`
`~_|
`L
`lPR2019-00128, InstitutionDecifionIp.32 '
`
`IPR 2019-00129, Institution Dec s_10n, p. 36:
`
`
`
`Patentability
`
`1)
`
`2)
`
`3)
`
`4)
`
`The Petition Relies on an Overly Broad Interpretation of
`“Carrier Aggregation”
`
`Lee is Unrelated to Carrier Aggregation
`
`The POSA Would Not Combine Lee with the Feasibility Study
`
`Petitioner Relies Improperly on Two Different Lee
`Embodiments for Claim 7
`
`‘
`
`Patent Owner Response, pp. 11-29, 34:37, 40-47‘“
`
`.
`
`i'.
`
`_
`
`.
`
`_
`
`
`
`Patentability
`
`1) “mu-MWMd
`‘13th
`
`2)
`
`3)
`
`4)
`
`Lee is Unrelated to Carrier Aggregation
`
`The POSA Would Not Combine Lee with the Feasibility
`Study
`
`Petitioner Relies Improperly on Two Different Lee
`Embodiments for Claim 7
`
`Patent Owner Response, pp. 11-29;
`
`Patent Owner Sur—Reply, pp. 2-18
`
`
`
`Claim Construction — “Carrier Aggregation”
`
`“it.
`. -------\ ------- .
`
`.Z
`
`: Amplifier
`| Stage 2
`
`1. An apparatus comprising:
`
`a first amplifier stage configured to be independently
`
`enabled or disabled, the first amplifier stage further
`configured to receive and amplify an input radio
`frequency (RF) signal and provide a first output RF
`
`signal to a first load circuit when the first amplifier
`stage is enabled, “h”umu RX"!
`“ comprising transmissions sent on multiple
`carriers at different frequencies to a wireless device, the
`first output RF signal including at least a first carrier of
`
`
`
`
` Input
`
`RFin
`
`Matehlng
`Cirwit
`
`.
`
`the multiple carriers; and
`
`a second amplifier stage configured to be independently
`enabled or disabled, the second amplifier stage further
`
`configured to receive and amplify the input RF signal
`and provide a second output RF signal to a second load
`
`circuit when the second amplifier stage is enabled, the
`
`second output RF signal including at least a second
`carrier of the multiple carriers different than the first
`carrier.
`
`6
`
`Intel 1301, 20:43-61, Fig'. 7'6
`
`*
`
`
`
`Claim Construction — “Carrier Aggregation”
`
`Patent Owner’s
`
`Petitioner’s
`
`bandwidth”
`
`“simultaneous operation 011 multiple
`carriers that are combined as a single
`Viitual chamlel to provide higher
`
`Pro u osed Construction
`
`Pro u osed Construction
`
`“simultaneous operation 011 multiple
`cairiers“
`
`Patent Owner Response, p. 11
`
`
`
`Claim Construction — “Carrier Aggregation”
`
`0 mmmmw
`0‘de
`
`° Petitioner’s Construction Contradicts the Written
`
`Description
`
`° Petitioner’s Construction Violates the Doctrine of
`
`Prosecution History Disclaimer
`
`° Patent Owner Did Not Redefine “Carrier Aggregation”
`
`°
`
`“Carrier Aggregation” Has a Well Understood Meaning
`
`8
`
`Patent Owner Response,pp} 28729;
`Patent Owner SuI-Reply, pp: 15-16
`
`,
`
`g
`
`_
`
`
`
`Petitioner’s Construction Reads “Carrier
`
`Aggregation” Out of the Claims
`
`1. An apparatus comprising:
`
`a first amplifier stage configured to be independently enabled or
`disabled, the first amplifier stage further configured to receive and
`amplify an input radio frequency (RF) signal and provide a first output
`RF signal to a first load circuit when the first amplifier stage is
`
`enabled, the input RF signal employing wet—aggregation
`[flag-huflufll] comprising
`u-.#m at different frequencies to a
`wireless device, the first output RF signal including at least a first
`
`carrier of the multiple carriers; and
`
`9
`
`Patent Owner Résporise, p129.
`
`.; >_
`
`
`
`Petitioner’s Construction Reads “Carrier
`
`Aggregation” Out of the Claims
`
`1. (Currently amended) An apparatus comprising:
`
`a first amplifier stage configured to receive and amplify an input radio frequency (RF) signal
`
`carrier of the multiple carriers different than the first carrier.
`
`and provide a first output RF signal to a first load circuit when the first amplifier stage
`
`is
`
`enabled.
`
`the
`
`input RF signal_ comprising
`
`transmissions sent on multiple carriers at different frequencies to a wireless device.
`
`the first output RF signal including at least a first carrier of the multiple carriers: and
`
`a second amplifier stage configured to receive and amplify the input RF signal and
`
`provide a second output RF signal
`
`to a second load circuit when the second
`
`amplifier stage is enabled. the second output RF signal including at least a second
`
`Intel Ex. 1315 (Amendm'jht) at 2;
`
`Patent Owner Response, £25 ‘
`
`
`
`Petitioner’s Construction Reads “Carrier
`
`Aggregation” Out of the Claims
`
`
`
`THE OXFORD
`
`ENGLISH
`
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`
`Ex. 2025, p. 4;
`
`Patent Owner Response, p. 29
`
`
`
`
`
`Claim Construction — “Carrier Aggregation”
`
`Petitioner’s Construction Reads “Carrier Aggregation”
`Out of the Claims
`
`WMMhWfl-
`
`W P
`
`etitioner’s Construction Violates the Doctrine of
`
`Prosecution History Disclaimer
`
`Patent Owner Did Not Redefine “Carrier Aggregation”
`
`“Carrier Aggregation” Has a Well Understood Meaning
`
`Patent Owner Response, pp.’ 12-14, 29;“
`
`
`
`
`
`Petitioner’s Construction Contradicts
`
`-—\,. —‘.\._,
`
`the Written Description
`
`Vfi.v WM~W “
`
`(I2) United States Patent
`LS 9,154,356 32
`(IO) Patent No.:
`Tasic el al.
`
`(45) Date of Patent: Oct. 6, 2015
`
`(75)
`
`(5-1) LUW NOISE AMPLIFIERS FOR CARRIER
`AGGREGATION
`Inventors: Aleksandar Mlodrag ’l'nslc. San [Mega
`("A (US): Anotli Buml lhvlerwallm
`Sun Diego. (',‘\ (US)
`(73) Assigncc: QUALCOMM lncorpornted.$oxi
`Diego. (‘.\ (US)
`Subject to any disclaimer. lhetemi ol'lhis
`patent is extended or adjusted under 35
`us (‘. 154(bl by Odnys.
`(21) AppLNoJ 13,590,423
`(22)
`Filed:
`Aug. 21. 2012
`
`l ’ ) Notice:
`
`(56
`
`J
`
`Helen-lice: (filed
`[LS PATF’NT DOCUMENTS
`
`3,9“.364 A
`4‘0“]le A
`
`101075 Inngpthcan,
`71077 Ishllxmm a alt
`«(H-minus]!
`
`
`
`FIG. 3 shows a block diagram of an exemplary design of
`wireless device 110 in FIG. 1. In this exemplary design,
`wireless device 110 includes a transceiver 320 coupled to a
`primary antenna 310, receivers 322 coupled to a secondary
`antenna 312, and a data processor/controller 380. Transceiver
`320 includes multiple (K) receivers 33 0aa to 33001: and mu]-
`ti 1e (K) transmitters 3600 to 360kto
`Receiv-
`_ multiple radio technologies,
`ers 322 include multi
`le (M) receivers 330ba to 3301)»: to
`— multiple radio
`technologies, receive diversity, MIMO transmission,-
`
`Intel Ex. 1301, 3:39-49;
`
`Patent Owner Response, p. 29
`
`
`
`Claim Construction — “Carrier Aggregation”
`
`° Petitioner’s Construction Reads “Carrier Aggregation”
`Out of the Claims
`
`° Petitioner’s Construction Contradicts the Written
`
`Description
`
`0 mammal-number
`MM“
`
`° Patent Owner Did Not Redefine “Carrier Aggregation”
`
`'
`
`“Carrier Aggregation” Has a Well Understood Meaning
`
`14
`
`Patent Owner Response,pp} 24727;
`Patent Owner SuI-Reply, pp: 12-15
`
`,
`
`g
`
`_
`
`
`
`Patent Owner Narrowed Claims to Overcome Hirose
`
`N,“
`
`_
`
`1. (Currently amended) An apparatus comprising:
`
`a first amplifier stage configured to receive and amplify an input radio frequency (RF) signal
`
`and provide a first output RF signal to a first load circuit when the first amplifier stage
`
`input RF signal— comprising
`the
`is enabled.
`transmissions sent on multiple carriers at different frequencies to a wireless device.
`
`the first output RF signal including at least a first carrier of the multiple carriers: and
`
`a second amplifier stage configured to receive and amplify the input RF signal and
`
`provide a second output RF signal
`
`to a second load circuit when the second
`
`amplifier stage is enabled. the second output RF signal including at least it second
`
`carrier of the multiple centers different than the first carrier.
`
`
`
`
`
`Intel Ex. 1315 (Amendment) at 2;
`
`Patent Owner Response, p. 25
`
`
`
`Application/Control Number: 13/590.423
`Art Unit: 2631
`
`Page 3
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Flegarding claim 1,—an apparatus (FIG. 6 digital broadcast
`
`receiver) comprising:
`
`a first amplifier stage configured to receive and amplify an input radio frequency
`
`(RF) signal and provide a first output RF signal to a first load circuit when the first
`
`amplifier stage is enabled (variable gain amplifier 15. cerresponding to the claimed first
`
`amplifier stage. receiving Input RF signal (e.g. satellite wave signal and ground wave
`
`signal) and providing an output to intermediate frequency demodulation stage (for
`
`ground wave). which corresponds to the claimed first load circuit (see column 5 lines 1-
`
`30 and FIG. 6) ;
`
`——
`
`, the first output RF signal including at least a first
`
`carrier of the multiple carriers (as recited above,—
`
`—(column 5 lines 1-4) and the output to intermediate
`
`frequency demodtlation stage for ground wave, corresponding to the claimed first
`
`carrier of the multiple carriers);
`
`
`
`
`
`Intel Ex. 1314 (Office Action) at 4;
`
`Patent Owner Response, p. 25
`
`
`
`Patent Owner Narrowed Claims to Overcome Hirose
`
`Office Action alleges:
`
`receiving input RF signal (cg. satellite wave signal and ground
`Hirose discloses
`wave signal)
`(Office Action. p. 32 emphasis added)
`
`and so time diversity is presented
`
`— as claimed by Applicant iIt amended independent
`
`claims 1 and 17. As stated, Applicant's amended independent claims I and I7 recite, inter nliu,
`
`“the [] input RF signal employing carrier aggregation." while Hirose discloses redundant data
`
`at a common data rate. Specifically. Hirose discloses:
`
`In an area where it is difficult to receive a radio wave from an elliptical orbit satellite or
`in an urban area where it is difficult to receive a satellite broadcast radio wave. a
`
`radio broadcast receiver receives in some cases a radio wave (ground wave) from
`
`a ground repeater which is controlled 1)
`
`a Geu stutiutlat orbit satellite.
`
`RF amplifier. FIG. 2 shows the spectrum of radio waves to be received by the
`receiver. The center frequency of this spectrum is approximately 2.3 GHZ, and the
`satellite wave and ground wave have both the band width of about 4 MHz.
`Although the satellite wave #1 and the ground wave are received at the same
`timing, the satellite wave #2 is received at the timing delayed by several seconds.
`
`t its wide band
`
`Intel Ex. 1315 (Amendment) _at 18;?
`Patent Owner Response, p. 26
`i
`
`16
`
`ti
`
`
`
`Petitioner’s Proposed Construction Reads on Hirose
`
`FIG. 2
`
`Petitioner Construction
`
`
`GROUND
`
`“
`
`”
`_
`.
`earner aggregatron means
`“simultaneous operation on
`multiple carriers”
`
`
`
`In an area where it is difficult to receive a radio wave from
`
`an elliptical orbit satellite or in an urban area where it is
`diflicult to receive a satellite broadcast radio wave a radio
`broadcast receiver receives in some cases a radio wave
`(ground wave) from a ground repea
`
`'
`
`
`ra 10 waves 0
`receive
`by the receiver. lhe center
`frequency of this spectrum is approximately 2. 3 GHz and
`the satellite wave and ground
`
`of about 4 MHz. Althou
`
`the satellite
`
`
`
`wave
`rs receive
`at tie tuning
`e ayed by several
`seconds, and so time diversity is presented. Of three satellite
`
`
`
`_
`_
`Intel 1325 (Huose)’ 1: 26'42’Flg‘ 2
`Intel Ex- 1315 (Amendment) at 8;
`Patent Owner Response, p. 25
`
`
`
`Petitioner’s Construction Violates the Doctrine of
`
`Prosecution History Disclaimer
`
`“[C]laims that have been narrowed in order to obtain
`
`the issuance of a patent by distinguishing the prior art
`cannot be sustained to cover that which was previously
`by limitation eliminated from the patent.” Graham v.
`
`John Deere Co. ofKansas City, 383 US. l, 33 (1966)
`1275, 1285 (Fed. Cir. 2010)
`
`“[A]n amendment that clearly narrows the scope of a
`claim, such as by the addition of a new claim limitation,
`constitutes a disclaimer of any claim interpretation that
`would effectively eliminate the limitation or that would
`otherwise recapture the claim’s original scope.”
`Schindler Elevator Corp. v. Otis Elevator Co., 593 F.3d
`
`18
`
`Patent Owner Response, p. 2i}
`Patent Owner Sur-Reply, p. 13
`
`3‘
`
`-;
`
`
`
`Claim Construction — “Carrier Aggregation”
`
`Petitioner’s Construction Reads “Carrier Aggregation”
`Out of the Claims
`
`Petitioner’s Construction Contradicts the Written
`
`Description
`
`Petitioner’s Construction Violates the Doctrine of
`
`Prosecution History Disclaimer
`
`mmwmmww
`
`“Carrier Aggregation” Has a Well Understood Meaning
`
`19
`
`Patent Owner Response,'ppl 11722: ,
`
`g
`
`_
`
`Patent Owner Sur-Reply, ppr2-6, 16-17
`
`
`
`
`
`Patent Owner Did Not Redefine “Carrier Aggregation”
`
`xx-
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`-7 _,77
`7
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`
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`
`
`
`(:2) United States Patent
`Tasic et al.
`
`(10) Patent No.:
`
`US 9,154,356 82
`
`HHV~~——w Vfi—a
`
`
`
`
`
`
`(54) LOW NOISE AMPLIFIERS FOR CARRIER
`AGGREGATION
`
`(56)
`
`(75)
`
`Inventors: Aleksandr" Mlodrag Tattle. San Diego.
`(‘A (US): Ath Boml Ihvk-rwallu.
`San Diego. CA (US)
`(73) Assignee: QUALCOMM Incorporated. San
`Diego. (‘A (US)
`Subject to any disclaimer. the term ol'this
`patent is extended or adjusted under 35
`U.Sr(‘. l54(b) by Odays.
`
`( ‘ ) Notice:
`
`
`
`
`
`33;;
`
`. A carrier ma)r
`or communication and
`requencres u
`re er to a range 0
`may be associated with certain characteristics. For example, a
`carrier may be associated with system information describing
`operation on the carrier. A carrier may also be referred to as a
`component carrier (CC), a frequency channel, a cell, etc. It is
`desirable to efficiently support carrier aggregation by the
`
`(21) Appl. No.: 13/590,423
`wireless device.
`(22)
`rum;
`Aug.21.2012
`
`
`Carrier a gregation
`
`
`
`
`
`
`carrier aggregation,
`
`
`ewce
`may e a
`e to operate 11] ow-
`rom 698 to
`960 megahertz (MHz). mid-band from 1475 to 2170 MHZ.
`and/or high-band from 2300 to 2690 and 3400 to 3800 MI 12.
`Low-band. mid-band. and high-band refer to three groups of
`bands (or band groups). with each band group including a
`number of frequency bands (or simply. “bands"). Each band
`may cover up to 200 MHZ and may include one or more
`carriers. Each carrier may cover up to 20 MHz in LTE. LTE
`Release 11 supports 35 bands. which are referred to as LTE/
`UMTS bands and are listed in 3GPP TS 36.101. Wireless
`
`Intel 1301,]:32-40; 2:53-67
`
`device 110 may be configured with up to 5 carriers in one or
`two bands in [TE Release 1 l.
`
`
`
`
`
`Patent Owner Employed a Distinctive
`Format for Defining Terms
`
`~
`
`-A~~/\___/
`
`
`
`
`
`
`
`
`
`»__- _-«vK , J- -—~- xx- _/\/-7_/A7_’q~\-v v\_
`
`O
`(12) Ulllted States Patent
`Tasic et al.
`
`(10) Patent No.:
`(45) Date of Patent:
`
`US 9,154,356 BZ
`Oct. 6, 2015
`
`(54) Low NOISE AMPLIFIERS FOR CARRIER
`AGGREGATION
`
`(7S)
`
`.
`lnvcnlors: Aleksandar Mlodrag Taslc. San Diego.
`(‘A (US): Ath Boml Ihvk-rwullu.
`San Diego. CA (US)
`
`(73) Assignec: QUALCOMM Incorporated. San
`Diego. (‘A (US)
`
`( ‘ ) Notice:
`
`Subjcd to any disclaimer. lhc term oflhis
`patent is extended or adjusted under 35
`U.S.(‘. l54(b) by Odays.
`
`(56)
`
`Refcnnccs (flu-d
`
`11.5, PATENT DOCUMENTS
`
`3.9l 1.364 A
`4.035.728 A
`
`10 I975 Izngseth el a].
`7 I977 lshikmm cl al.
`
`((‘Unlinuuh
`FOREIGN PATENT DOCUMENTS
`
`(‘N
`
`”23912 A
`
`82004
`
`Appl.No.: 13/590,423
`mm;
`..\ug.2l.2012
`
`
`
`.
`n
`‘
`resent dISClOSUI‘e canbe racnced
`
`Intel 1301,229-11;
`
`Patent Owner SuI-Reply, p. 4
`
`
`
`Claim Construction — “Carrier Aggregation”
`
`° Petitioner’s Construction Reads “Carrier Aggregation”
`Out of the Claims
`
`° Petitioner’s Construction Contradicts the Written
`
`Description
`
`° Petitioner’s Construction Violates the Doctrine of
`
`Prosecution History Disclaimer
`
`° Patent Owner Did Not Redefine “Carrier Aggregation”
`
`0 “WMmama-h.
`
`IJ U)
`
`Patent Owner Response, pp. $42," 27-29;
`
`Patent Owner Sur-Reply, pp. 6-12
`
`
`
`“Carrier Aggregation” Has a Well Understood Meaning
`
`> Supported by the Intrinsic Record
`
`° The Specification Supports the Patent Owner’s
`Construction
`
`° The File History Supports the Patent Owner’s
`Construction
`
`> Supported by Extrinsic Evidence
`
`°
`
`Intel Patents Support Patent Owner’s Construction
`
`° The Feasibility Study Supports Patent Owner’s
`Construction
`
`°
`
`Industry Publications Support Patent Owner’s
`Construction
`
`Patent Owner Response, pp. 1L22, 27-29;“
`
`.
`
`_
`
`'
`
`.
`
`i'.
`
`
`
`“Carrier Aggregation” Has a Well Understood Meaning
`
`) mun-mm
`
`° The Specification Supports the Patent Owner’s
`Construction
`
`° The File History Supports the Patent Owner’s
`Construction
`
`> Supported by Extrinsic Evidence
`
`°
`
`Intel Patents Support Patent Owner’s Construction
`
`° The Feasibility Study Supports Patent Owner’s
`Construction
`
`°
`
`Industry Publications Support Patent Owner’s
`Construction
`
`Patent Owner Response, pp. 1L322, 27-29;
`
`.
`
`_
`
`‘
`
`. 3‘
`
`.
`
`
`
`The Specification Supports Patent Owner’s Construction
`
`
`
`(12) United States Patent
`(10) ngflt N05“ USV9,15$3§6_§_2~
`_
`-
`a“
`Tasic et al.
`(45) I)
`'.
`‘
`— A Wireless dev1ce may suppOI—, which
`
`
`is simultaneous operation on multip 6 carriers. A carrier may
`(54) LOW NOISE AMPLIFIERS FOR CARRIER
`M’Ru’mo
`,.
`‘
`,
`refer to a range of frequenmes used for communication and
`Inventors: Aleksandar Mlodrng laslc.banl)tego.
`.
`.
`.
`.
`.
`
`
`m (US): Anosh Boml Duvk-rw-lla.
`3.911. may be assocrated With certain charactensttcs. For example, a
`.
`'.
`I
`4,035‘
`.
`.
`.
`.
`.
`.
`.
`5““ ”"1“ C" (US)
`carrier may be assomat
`'
`
`
`
`(73) Assignee: QU.»\I.('0MM Incorporated. San
`
`Diego. m (US)
`0
`ration on the manic
`
`
`
`
`
`a requellcy C 311118 . a CC . etc.
`I IS
`.
`'
`.
`‘
`support camel' aggregation by the
`
`
`(75)
`
`
`
`( ’ ) Notice:
`
`Subject to any disclaimer. the term ol‘this
`patent
`Is extended or adjusted under 35
`U.S.(‘. 154(b) by Odays.
`(21) Appl.No.213/590,423
`(22)
`Filed:
`Aug.2|.2012
`
`(56)
`
`('N
`CN
`
`wireless device.
`
`L
`
`
`
`.
`
`
`
`
`
`
`
`
`
`
`
`which is operation on multiple carriers. Carrier aggregation
`may also be referred to as multi-carrier operation. Wireless
`device 110 may be able to operate in low-band from 698 to
`960 megahertz (MHZ). mid-band from 1475 to 2170 MHZ.
`and/or high-band from 2300 to 2690 and 3400 to 3800 MHz.
`Low-band, mid-band. and high-band refer to three groups of
`bands (or band groups). with each band group including a
`number of frequency bands (or simply. “bands”). Each band
`may cover 11
`to 200 MHz and ma
`include one or more
`
`
` device 110 may be configured with up to 5 carriers in one or
`
`
`two bands in [TE Release 1 l.
`
`
`
`
`
`
`
`
`
`Intel Ex. 1301, 1:32-40, 2:53-67
`
`Patent Owner Response, pp. 12-14
`
`
`
`The Specification Supports Patent Owner’s Construction
`
`
`
`
`which is operation on multiple carriers. Carrier aggregation
`may also be referred to as multi-carrier operation. Wireless
`device 110 may be able to operate in low-band from 698 to
`960 megahertz (MHz). mid-band from 1475 to 2170 MHZ.
`and/or high-band from 2300 to 2690 and 3400 to 3800 MHz.
`Low-band, mid-band. and high-band refer to three groups of
`bands (or band groups). with each band group including a
`number of frequency bands (or simply. “bands”). Each band
`
`
`include one or more may cover 11 to 200 MHz and ma
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`device 110 may be configured with up to 5 carriers in one or
`two bands in LTE Release 11.
`
`
`
`
`5.1
`
`General
`
`p to 100MHz and for spectrum aggregation.
`
`LTE-Advanced extends LTE Rel.-8 with su
`
`rt fo
`
`2 _
`
`Intel Ex. 1301, 2:53-67; -'
`
`Ex. 1304 (“Feasibility Study”), 1] 5.1
`
`Patent Owner Response, pp. 12-14
`
`
`
`The File History Supports Patent Owner’s Construction
`
`Regarding amended independent claims 1 and 17, Applicant’s amended independent
`
`claims I and I7 recite. intpr ”Ii/I. “the [] input RF signal employing narripr nggrpgnfinn," which
`
`over different paths which results in redundant data at a common data rate. Specifically. the
`
`w 3
`
`Patent Owner Responéie, pp; 15-16;
`
`Intel Ex. 1315 at 7.
`
`'
`
`
`
`The File History Supports Patent Owner’s Construction
`
`(12)
`
`United States Patent
`Kaukovuori et ai.
`
`(10) Patent No.:
`(45) Date of Patent:
`
`US 8,442,473 BI
`May 14, 2013
`
`20l0’0118923 Al
`207
`
`5,-20l0 Pal
`
`(54)
`
`(75)
`
`(73)
`
`METHODS Oi" RECEIVING AND RECEIVERS
`
`inventors: Jounl Kristian Kaukowrori. Vantaa
`(Fl); AamoTapio Parssinen. Espoo (Fl):
`Antti ()skari lmmoncn. liclsinki (i’l)
`
`Assignce: Renesas Mobile Corporation. Tokyo
`(JP)
`
`(‘)
`
`Notice:
`
`Subject to any disclaimer. the term of this
`patent is extended or adjusted under 35
`U.Sr(‘. 154(b) by 35 days.
`
`(2|)
`
`(22)
`
`Appl‘ No.:
`
`iii/300.004
`
`Filed:
`
`Nov. 18. 20]]
`
`O
`0.0
`
`Kaukovuori was relied
`
`on by the Examiner of
`the ‘356 Patent.
`
`Patent Owner Response, pp. 15-16;
`Intel Ex. 1325 at 1:19-35.
`
`Long Term Evolution (LTE) Advanced is a mobile tele-
`communication standard proposed by the 3rd Generation
`Partnership Project (3GPP) and first standardised in 3GPP
`Release 10. In order to provide the peak bandwidth require-
`ments of a 4’” Generation system as defined by the Interna-
`tional Telecommunication Union Radiocommunication
`
`(ITU-R) Sector. while maintaining compatibility with legacy
`mobile cormnunication equipment. LTE Advanced proposes
`the aggregation of multiple carrier signals in order to provide
`a higher aggregate bandwidth than would be available if
`
`
`
`.amcr. ggregation can euscd
`a so in ot er ra 10 communication protocols such as High
`Speed Packet Access (HSPA).
`
`EP
`EP
`
`WW
`
`tigi
`
`t
`
`WW
`
`(
`
`R4-
`Ror
`
`
`
`“Carrier Aggregation” Has a Well Understood Meaning
`
`> Supported by the Intrinsic Record
`
`° The Specification Supports the Patent Owner’s
`Construction
`
`° The File History Supports the Patent Owner’s
`Construction
`
`> “yum
`
`°
`
`Intel Patents Support Patent Owner’s Construction
`
`° The Feasibility Study Supports Patent Owner’s
`Construction
`
`°
`
`Industry Publications Support Patent Owner’s
`Construction
`
`Patent Owner Response, pp. 1L322, 27-29;
`
`.
`
`_
`
`‘
`
`. 3‘
`
`.
`
`
`
`“Carrier Aggregation” Has a Well Understood Meaning
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` c-~~ r~Ai_/‘_._/ k . _»- -—v- -7 ,«7 _ v xx- _/\/A _/
`
`
`
`—1---v\/ ?~‘__
`
`(12) United States Patent
`Han et al.
`
`us 9,161,254 32
`(10) Patent No.:
`osmium,131mm; W? 99;1112.91; ¢_ -vanpwmwd __ -
`
`PERIODIC CHANNEL STATE INFORMATION
`REPORTING FOR TIME DIVISION DUPLEX
`(’I'DD) CARRIER AGGREGA'I‘ION SYSTEMS
`
`(56)
`
`Applicant: INTEL CORPORATION. Santa Clara.
`CA (US)
`lm-‘mtors: Seunghee Ilan.Anyangslii (KR):Ilung
`He. Beijingtcm; .long-Kae l-‘wu.
`Sunnyvale. (‘A (US); Alexei Dmydov.
`Nizhny Novgorod (R1J); "3,. 30.0““.
`”Wm-V ”WSW“ (RU)
`Assignw—Sama Clara.
`C‘A‘ (US)
`
`.
`.
`In Camcr aggregatlon
`I‘llll llp e component Cilfl‘lel'S CC) can _be aggregated
`‘
`and Jomtly used for transmissmn to/trom a Single tenmnal.
`.
`.
`.
`.
`.
`.
`,
`Camers can be Signals in pennitted frequency domains onto
`which infomiation is placed. The amount of information that
`can be placed on a carrier can be determined by the aggre-
`gated carrier’s bandwidth in the frequency domain. The per-
`
`-‘_.— v»_—_~_.-—_ ~—_——~__._
`
`d—M
`
`
`streaming video or communicating large data files.
`
`Carrier aggregation (CA) enables multiple carrier signals
`to be simultaneously communicated between a user’s wire-
`less device and a node. Multiple different carriers can be used.
`In some instances. the carri
`'
`'
`
`The greater bandwidth can be used to
`communicate bandwidth intensive operations,
`such as
`
`Patent Owner Response, p. 18;
`
`Ex. 2013, 3:19-28, 45-53
`
`
`
`“Carrier Aggregation” Has a Well Understood Meaning
`
`(12) United States Patent
`Kazmi et al.
`
`(10) Patent No.:
`(45) Date of Patent:
`
`US 10,044,613 32
`Aug. 7, 2018
`
`(54) MULTIPLE RADIO LINK CONTROL (Rl.(.‘)
`GROUPS
`
`(7|) Applicant: INTEL IP CORPORATION. Santa
`Clara. (‘A (US)
`
`(58) Fleld of (‘lusslflcatlon Search
`(w ............... Him, 45x74; r1041, 12mm; H04W
`2840252: 1104W 720433; “04W 4/02:
`
`(73) hump m.
`
`S ' C '.(‘.-
`
`In.
`
`t
`
`
`
`(72)
`
`Inventors: Zalgham Kazml. San Marcos. (‘A
`(US): Ana Lucla Plnhelru. Portland.
`OR (US)
`
`.-
`
`:
`
`56
`
`(
`
`)
`
`200500
`
`mm
`
`"
`'
`-'
`'
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`‘
`_ one technique for pl‘OV 'dmg addmona
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`'
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`‘
`'
`"
`
`
`
`
`
`
`a Wire ess
`ewce e.g..
`n camer aggrega-
`) multiple component carriers (CC) can be aggre—
`.
`gated and jointly used for transmission toffrom a single
`terminal Carriers can be signals in permitted frequency
`domains onto which information is placed. The amount of
`information that can be placed on a carrier can be deter-
`mined by the aggreggited carrier’s bandwidth in the fre
`quency domain- The pemtitted frequency domains are often
`limited in bandwidth. The bandwidth limitations can
`
`become more severe when a large number of users are
`simultaneously using the bandwidth in the permitted fre-
`quency domains.
`
`
`
`Patent Owner Response, p. 18;
`
`Ex. 2018, 3:27-41
`
`'4) lo)
`
`
`
`“Carrier Aggregation” Has a Well Understood Meaning
`
`3GPP TR 36.912 vg.1.0 (2009-12)
`
`Technical Report
`
`3rd Generation Partnership Project;
`Technical Specification Group Radio Access Network;
`Feasibility study for
`Further Advancements for E-UTRA (LTE-Advanced)
`,, (Release 9),
`
`5.1
`
`General
`
`LIE-Advanced extends LTE Rel.-8 with 511 on to
`
`up to lOONIHz and for spectnun aggregation.
`
`Patent Owner Response, p. 19;
`Ex. 1304 (“Feasibility studf’), 11 5.1
`
`
`
`“Carrier Aggregation” Has a Well Understood Meaning
`
`QUALCOAMA
`
`Oualcomm, Inc.
`
`Strategies to win in LTE and evolve to
`LTE Advanced
`
`Carrier aggregation, as the name suggests, combines multiple carriers (a.k.a. channels) at the device to
`
`provide a bigger data pipe to the user. A bigger data pipe means higher data rates, both peak data rates (as
`
`high as over 1 Gbps) and, more importantly, higher user date rates across the cell coverage area. The higher
`
`data rates can be traded off to get increased capacity for bursty applications such as browsing, social media
`
`apps, smartphone usage and more.
`
`
`3.1 Carrier aggregation and its evolution
`
`
`
`
`
`
`
`
`
`
`
`
`
`Up (0
`700 MHZ
`
`As a first step, the commercial launch supported aggregation of two 10 M
`{ Carrier 1
`.
`_
`'
`,,
`3....
`MHz carriers, enabling a 150 Mbps peak data rate (Cat4 terminals).
`4,
`This also doubles the user data rates across the cell, whether the user Ml Carrier 2
`is close to the cell or at the cell edge. As mentioned before, this higher
`,--::':I:: measures
`.
`.
`. M Carrier 3
`DATA PIPE
`data rate can also be traded off to provrde tWIce (or more) the capacrty
`W ::.
`for bursty apps, under typical loading conditions.
`M Cam" 4
`Carrier aggregation continues to evolve to utilize all spectrum resources
`"ll H Cam" 5
`
`carriers (up to five defined in LTE Advanced) and more band combinations
`.
`,
`,
`_
`(more than 45 being defined In 3GPP). There Will be many different types
`
`
`
`Fig- 3-21 LTE Advanced SUDDOFtS earlier aggregation of
`up to 5 carriers (100 MHz)
`
`Patent Owner Response, p. 18;
`
`Ex. 2019, p. 6
`
`
`september 201 3
`
`
`
`that operators have access to. There could be aggregation across more
`
`. ........................ , ......
`
`_
`
`,/
`
`‘
`
`
`
`“Carrier Aggregation” Has a Well Understood Meaning
`
`
`
`
`(1‘)) United States
`(12) Patent Application Publication (10) Pub. No.: US 2013/0217398 A1
`
`
`
`
`(43) Pub. Date:Winiecki et al. Aug. 22, 2013
`
`(54) TRANSCEIVER ARRANGEMENT
`
`
` (7|)
`
`Applicant: SEQUANS COMMUNICATIONS,
`Ixrl).. (US)
`
` (72)
`
`Inventors: Thomas Winiecki. Reading ((iB):
`Jackson Harvey. Savage. MN (US)
`
`
`
`(73) Assigncc: SEQUANS COMMUNICATION S.
`I.TD.. Reading (GB)
`.g.over-t1e-air1nter ace
`tween a ase station and
`
`
`
`a user equipment). The technique of carrier aggregation thus
`allows an expansion of the effective bandwidth which can be
`
`utilized in wireless communication by concurrent utilization
`of radio resources across multiple carriers. Multiple compo-
`nent carriers are aggregated to form a larger overall transmis-
`sion bandwidth. Carrier aggregation spreads the available
`signal power over a wider bandwidth, and greatly improves
`throughput for high-order modulation schemes.
`
`
`
`
`
`
`
`Patent Owner Response, p. 18;
`
`Ex. 2020, 1] [0003]
`
`
`
`
`
`
`
`
`
`
`
`Patentability
`
`1)
`
`Petition Relies on an Overly Broad Interpretation of “Carrier
`Aggregation”
`
`2) 1.inWW
`
`3)
`
`4)
`
`The POSA Would Not Combine Lee with the Feasibility Study
`
`Petitioner Relies Improperly on Two Different Lee Embodiments for
`Claim 7
`
`3 6
`
`Patent Owner Response, pp. 32-35
`
`‘
`
`I
`
`. _
`
`;.
`
`
`
`Lee is Unrelated to Carrier Aggregation
`
`(19) United States
`
`(12) Patent Application Publication (10) Pub. No.: US 2012/0056681 A1
`Lee
`(43) Pub. Date:
`Mar. 8, 2012
`
`(54) SIGNAL AMPLIFK'ATION CIRCUITS FOR
`RI-XTICIVI NG/TRANSMITTING SIGNAI .S
`ACCORDING TO INPUT SIGNAL
`
`(76)
`
`Inventor:
`
`(filth-[lung lxc.(‘11iayi llsicn
`('l‘W)
`
`('21)
`
`App]. No‘:
`
`1 2376.23 7
`
`(22)
`
`Filed:
`
`Sep. 6. 2010
`
`Publicatlon Classification
`
`(51)
`
`Int. Cl.
`”03!“ 3/04
`
`(2006.01 )
`
`(52)
`
`U.S.(.‘I.
`
`330/3"!
`
`A
`
`1 TRACT
`
`
`
`[0017] FIG. 1 is a diagram illustrating a first exemplary
`implementation of a signal amplification circuit according to
`the present invention. The exemplary signal amplification
`circuit 100 is for processing an input signal VIN to be
`received/transmitted. In other words the signal amplification
`
`circuit 100 can be part ofa receiver or pa antenna not 5 own . an a p ura 1ty of received signals cor-
`
`responding to the radio-frequency signals are generated as
`outputs of the signal amplification circuit 100. Regarding
`
`Patent Owner Response, mi. 32434;
`
`Intel Ex. 1335 (Lee), 1l[0017].
`
`
`
`Lee is Unrelated to Carrier Aggregation
`
`“Lee never describes the VIN signal (or anything else)
`as ‘employing carrier aggregation.’ Instead, Lee
`consistently refers throughout to two separate and
`distinct input signals ‘(e.g., a Bluetooth signal and a
`WiFi signal) received by a single antenna).’. .. In fact,
`Lee is clear that a key goal of his invention is to provide
`outputs of the WiFi and Bluetooth inputs that are kept
`
`separate.”
`
`Ex. 2024 (Declaration of Dr. Foty),' 139...
`Patent Owner Response, p. 32
`V
`
`i
`
`‘
`
`
`
`Patentability
`
`1)
`
`Petition Relies on an Overly Broad Interpretation of “Carrier
`Aggregation”
`
`2)
`
`Lee is Unrelated to Carrier Aggregation
`
`3) fiMVflNflmhflme
`
`4)
`
`Petitioner Relies Improperly on Two Different Lee Embodiments for
`Claim 7
`
`39
`
`i
`
`Patent Owner Response, Lp. 40-47 '
`
`.3
`
`,
`
`.
`
`_
`
`
`
`Lee Describes a Multi-Radio Device
`
`(5') mfg/W
`
`
`
`
`(19) United States
`
`(12) Patent Application Publication (10) Pub. No.: US 2012/0056681 A1
`
`
`(43) Pub. Date:Lee Mar. 8, 2012
`
`
`
`
`SIGNAL AMPLIFICA111
`
`
`'
`RECEIVING/TRANSMI
`'0002]
`ACCORDING TO lNPU'l
`
`
`
`
`
` (Thlh-llunInventor:
`
`
`(TW)
`
`
`App]. No.:
`12/876,231
`
`
`
`(22) Hm;
`Sep.6.20]
`at the aamc 1mc._
`_
`
`
`connections are Implemented 1
`
`Publlcatlon (The
`
`viduallv. the hardware cost and t e c p Size ma)r
`
`
`
`(2“ Therefore. regarding a multi-radio device. thereis a need for
`receivinga'transmitting signals according to ‘
`
`. Ii a low--noise urnplifier (LNA) 0
`“an be configured to commonly ampli
`ra p ura It}; of
`
`* as a low-noise amplifierin a receiver 01 a
`
`chip size of the multi-m
`amplification circuit
`according to one inpu
`designers in this field.
`
`
`
`
`Patent Owner Response, p. 40
`4‘: .”
`Intel Ex. 1335, 11 1] [0002], [0017]
`
`
`
`WiFi connection woul
`
`
`
`
`
`I'zuiio-frequencyr signals. the LNA shared between different
`
`radio connections. such asjhe Bluetooth coimection and the
`
`
`impedance matching. In a case where the sig
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