Patent Owner’s Demonstratives
`
`Apple, Inc. et al.,
`
`v
`
`Uniloc 201 7 LLC,
`
`Case IPR2019-00510
`
`US. Patent No. 6,868,079
`
`Oral Hearing
`April 23, 2020
`
`
`
`Apple, Inc. et al.,
`
`v
`
`Uniloc 201 7 LLC,
`
`Case IPR2019-00510
`
`US. 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 time slots in an uplink channel to a
`plurality of respective secondary stations; and
`
`transmitting a respective request for services to establish
`required services from at least one of the plurality of
`respective secondary stations to a primary station in the
`respective time slots;
`
`wherein the at least one of the plurality of respective
`
`secondary stations re-transmits the same respective
`request in consecutive allocated time slots without waiting
`for an acknowledgement until said acknowledgement is
`received from the primary station,
`
`wherein the primary station determines whether a request
`
`for services has been transmitted by the at least one of the
`plurality of respective secondary stations by determining
`whether a signal strength of the respective transmitted
`request of the at least one of the plurality of respective
`
`
`
`Independent Claim 17
`
`“wherein the at least one of the plurality of respective secondary stations
`retransmits the same respective request in consecutive allocated time slots
`
`without waiting for an acknowledgement until said acknowledgement is
`received from the primary station" (claim 17)
`
`/ Petitioner’s Reply admits the clear deficiency in Wolfe by
`conceding that “the Petition recognized that Wolfe did not
`fully disclose the retransmission limitation.” Reply at 4.
`
`\/ Petitioner’s reliance on Bousquet’s disclosure of systematic
`repetition of access packets in the predefined time period is
`
`unavailing, as such disclosure falls far short of the required
`showing of performing retransmission in consecutive
`allocated time slots until said acknowledgement is
`received from the primary station.
`
`
`
`Independent Claim 17
`
`Bousquet's retransmission technique is distinguishable at least
`
`in that it sends the same access packet 11 times in a given time
`period, independent of whether or not an acknowledgement
`message is received from the station
`
`/ Bousquet discloses that “[t]he effect of the invention can be
`seen in FIG. 1 which shows the probability of collision
`between access packets as a function of the load on the
`temporally shared resource .flu’hlh.
`—d_h-_-hl-h~n
`M-w for a random ALOHA access
`system. Here the packet error rate is 1%." EX 1006, 3:7 -13.
`
`\/ Bousquet further discloses that "the invention proposes to
`send the same access packet n times (n> 1) in a given time
`period whether an acknowledgement message is received
`from the station 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:
`
`\/ Petitioner’s Reply concedes Everett uses randomly
`selected time intervals.
`
`/ Petitioner fails to reconcile the citations to Everett
`
`with the unambiguous language of Bousquet,
`
`which teaches retransmission of requests a
`predefined number of times independent of
`whether an acknowledgement is received or not.
`
`
`
`Independent Claim 17
`
`Patsiokas does not cure the deficiencies of Wofle and Bosquet,
`with or without the combination of Everett. Uniloc’s briefing
`
`included the following non-exhaustive points:
`
`\/ Petitioner fails to cite any portion of Wolfe, Bousquet,
`or Everett to refute Patent Owner's contention that
`
`Patsiokas addresses a shortcoming in cordless radio
`telephone systems that is unidentified in the satellite
`systems of these references.
`
`\/ Wolfe’s system makes clear that only one reference
`station exercises control.
`
`\/ Petitioner’s Reply emphasizes deficiencies 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 means for allocating respective
`
`time slots 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;
`
`wherein the respective secondary stations have means for re-
`
`transmitting the same respective requests in consecutive
`allocated time slots without waiting for an
`acknowledgement until said acknowledgement is received
`from the primary station,
`
`wherein said primary station determines whether a request
`
`for services has been transmitted by at least one of the
`respective is secondary stations by determining whether a
`signal strength of the respective transmitted request of the
`at least one of the respective secondary stations exceeds a
`
`
`
`Independent Claim 18
`
`Board’s Decision on Institution includes the following dispositive
`
`finding concerning Petitioners’ challenge of claim 18:
`
`Petitioner has not sufficiently identified a structure (e.g.,
`algorithm) corresponding to the function “for allocating
`respective time slots 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-implemented function.
`
`Board’s Institution Decision, Paper 7 at 10.
`
`
`
`Independent Claim 18
`
`Patent Owner’s Response included the following:
`
`Patent Owner understands that the Board has made its
`
`determination as to claim 18, and that the Board included
`
`the claim in this trial only in light of SAS. Thus, Patent
`Owner need not further address claim 18. Petitioners’
`
`implicit contention that the “means” limitations recited in
`claim 18 render the claim indefinite is appropriately
`determined only in a proceeding that encompasses such
`issues. Neither Patent Owner nor the Board need address
`
`arguments based on a claim construction specifically not
`advocated by Petitioners.
`
`Paper 9 at 6.
`
`
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