Patent Owner’s Demonstratives
`
`Apple, Inc. et al,
`V.
`Uniloc 2017 LLC,
`
`Case IPR2019-00510
`U.S. Patent No. 6,868,079
`
`Oral Hearing
`April 23, 2020
`
`
`
`Apple, Inc. et al,
`V.
`Uniloc 2017 LLC,
`
`Case IPR2019-00510
`U.S. Patent No. 6,868,079
`
`Oral Hearing
`April 23, 2020
`
`
`
`Independent Claim 17
`
`17. A method of operating a radio communication system,
`comprising:
`allocating respective timeslots in an uplink channel to a
`plurality of respective secondary stations; and
`transmitting a respective requestfor services to establish
`required servicesfrom at least one ofthe plurality of
`respective secondary stations to a primary station in the
`respective timeslots;
`wherein the at least one ofthe plurality of respective
`secondary stations re-transmits the samerespective
`request in consecutiveallocated timeslots without waiting
`for an acknowledgementuntil said acknowledgementis
`received from the primary station,
`wherein the primary station determines whether a request
`for services has been transmitted bytheat least one of the
`plurality of respective secondary stations by determining
`whethera signal strength of the respective transmitted
`requestofthe at least oneof the plurality of respective
`
`
`
`Independent Claim 17
`
`“whereinthe at least one of the plurality of respective secondary stations
`retransmits the samerespective request in consecutive allocated timeslots
`without waiting for an acknowledgementuntil said acknowledgementis
`received from the primary station”(claim 17)
`
`v Petitioner’s Reply admits the clear deficiency in Wolfe by
`concedingthat “the Petition recognized that Wolfe did not
`fully disclose the retransmissionlimitation.” Reply at4.
`
`Y Petitioner’s reliance on Bousquet’s disclosure of systematic
`repetition of access packets in the predefined time period is
`unavailing, as such disclosurefalls far short of the required
`showing of performing retransmission in consecutive
`allocated time slots until said acknowledgementis
`received from the primary station.
`
`
`
`Independent Claim 17
`
`Bousquet’s retransmission techniqueis distinguishable at least
`in that it sends the same access packet n timesin a given time
`period, independent of whetheror not an acknowledgement
`messageis received from the station
`
`Y Bousquetdiscloses that “[t]he effect of the invention can be
`seen in FIG. 1 which showsthe probability ofcollision
`betweenaccess packetsas a function of the load on the
`temporally shared resource forn=]through 7wherenis the
`number oftimesthe sameaccesspackageis sentduringa
`predeterminedtimeperiod for a random ALOHAaccess
`system. Here the packeterror rate is 1%.” EX 1006, 3:7-13.
`
`Y Bousquetfurtherdiscloses that "the invention proposesto
`send the sameaccesspacket n times (n> 1) in a given time
`period whether an acknowledgement messageis received
`from thestation to which these packets are sent or not."
`2:53-56.
`
`
`
`Independent Claim 17
`
`Everett does not cure the deficiencies of Wolfe and Bousquet.
`Uniloc raised the following non-exhaustive points in its briefing:
`
`v Petitioner’s Reply concedes Everett uses randomly
`selected timeintervals.
`
`Y Petitionerfails to reconcile the citations to Everett
`with the unambiguous language of Bousquet,
`whichteaches retransmission of requests a
`predefined numberof times independentof
`whether an acknowledgementis receivedornot.
`
`
`
`Independent Claim 17
`
`Patsiokas does notcure the deficiencies of Wofle and Bosquet,
`with or without the combination of Everett. Uniloc’s briefing
`included the following non-exhaustive points:
`
`Y Petitionerfails to cite any portion of Wolfe, Bousquet,
`or Everett to refute Patent Owner’s contention that
`Patsiokas addresses a shortcomingin cordless radio
`telephonesystemsthat is unidentified in thesatellite
`systemsof these references.
`
`Y Wolfe’s system makesclearthat only one reference
`station exercises control.
`
`Y Petitioner’s Reply emphasizesdeficiencies of the
`Petition by impermissibly pointing to separate
`embodiments of Everett, unidentified in the Petition.
`
`
`
`Independent Claim 18
`
`18. A radio communication system, comprising:
`a primary station and a plurality of respective secondary
`stations;
`
`the primary station having meansforallocating respective
`timeslots in an uplink channelto the plurality of respective
`secondary stations to transmit respective requests for
`services to the primary station to establish required
`services;
`
`wherein the respective secondary stations have meansforre-
`transmitting the same respective requests in consecutive
`allocated time slots without waiting for an
`acknowledgementuntil said acknowledgementis received
`from the primary station,
`wherein said primary station determines whether a request
`for services has been transmittedbyat least oneof the
`respective is secondary stations by determining whether a
`signal strength of the respective transmitted requestof the
`at least one of the respective secondary stations exceeds a
`
`
`
`Independent Claim 18
`
`Board’s Decision onInstitution includes the following dispositive
`finding concerning Petitioners’ challenge of claim 18:
`
`Petitionerhas notsufficiently identified a structure(e.g.,
`algorithm) correspondingto the function “for allocating
`respective timeslots in an uplink channel to the
`plurality of respective secondary stations to transmit
`respective requests for services to the primary station to
`establish required services”recited in claim 18 as
`required for such a computer-implementedfunction.
`
`Board’s Institution Decision, Paper7 at 10.
`
`
`
`Independent Claim 18
`
`Patent Owner’s Responseincludedthe following:
`
`Patent Owner understandsthat the Board has madeits
`determination as to claim 18, and that the Board included
`the claim in thistrial only in light of SAS. Thus, Patent
`Owner neednot further address claim 18. Petitioners’
`implicit contention that the “means”limitationsrecited in
`claim 18 rendertheclaim indefinite is appropriately
`determinedonly in a proceeding that encompasses such
`issues. Neither Patent Ownernor the Board need address
`arguments based on a claim construction specifically not
`advocatedby Petitioners.
`
`Paper9 at 6.
`
`
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