Marvell Semiconductor, Inc.
`
`v
`
`Uniioc 2017 LLC
`
`lPR2019-01349
`
`lPR2019-01350
`
`U.S. Patent 7,016,676
`
`Patent Owner’s Demonstrative Exhibits
`
`Before JAMESON LEE, KEVIN F. TURNER, and
`
`MICHELLE N. WORMMEESTER, Administrative Patent Judges
`
`November 12, 2020
`
`

`

`’676 Patent to Bernhard Walke and Stefan Mangold
`
`um Patent No;
`US 7.016.676 32
`(12: United States Patent
`Walk: el al.
`
`Mar. 2|. 2006[45] Date of Patent:
`
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`9 Claim 3 lit-ulna Mm
`
`
`
`DEMONSTRATIVE - NOT EVIDENCE
`
`2
`
`

`

`
`
`Claim 1
`
`1. An interface-control protocol method for a radio system which has at least
`
`one common frequency band that is provided for alternate use by a first and a
`
`second radio interface standard, the radio system comprising:
`
`stations which operate in accordance with a first radio interface standard
`
`and/or a second radio interface standard, and
`
`a control station which controls the alternate use of the frequency band,
`
`wherein the control station controls the access to the common frequency
`
`band for stations working in accordance with the first radio interface standard
`
`and renders the frequency band available for access by the stations working in
`
`accordance with the second radio interface standard if stations working in
`
`accordance with the first radio interface standard do not request access to the
`
`frequency band.
`
`DEMONSTRATIVE - NOT EVIDENCE
`
`3
`
`

`

`Claim 6
`
`6. An interface-control protocol method for a radio system which has at least
`
`one common frequency band that is provided for alternate use by a first and a
`
`second radio interface standard, the radio system comprising:
`
`stations which operate in accordance with a first radio interface standard
`
`and/or a second radio interface standard, and
`
`a control station which controls the alternate use of the frequency band,
`
`wherein the control station terminates the use of the radio interface in
`
`accordance with the second radio interface standard by transmitting in
`
`accordance with the first radio interface standard, without taking account of
`
`resulting interference in stations working in accordance with the second radio
`
`interface standard.
`
`DEMONSTRATIVE - NOT EVIDENCE
`
`4
`
`

`

`
`
`Claim 7
`
`7. An interface-control protocol method for a radio system which has at least
`
`one common frequency band that is provided for alternate use by a first and a
`
`second radio interface standard, the radio system comprising:
`
`stations which operate in accordance with a first radio interface standard
`
`and/or a second radio interface standard, and
`
`a control which controls the alternate use of the frequency band,
`
`wherein the control station controls the access to the common frequency
`
`band by stations working in accordance with the first radio interface standard
`
`and in that duration and type of control of the radio interface in accordance
`
`with the second radio interface standard is determined by a further station and
`
`transmitted to the control station.
`
`DEMONSTRATIVE - NOT EVIDENCE
`
`5
`
`

`

`
`
`Claim 8
`
`8. An interface-control protocol method for a radio system which has at least
`
`one common frequency band that is provided for alternate use by a first and a
`
`second radio interface standard, the radio system comprising:
`
`stations which operate in accordance with a first radio interface standard
`
`and/or a second radio interface standard, and
`
`a control station which controls the alternate use of the frequency band,
`
`wherein the control station, in addition to functions in accordance with the
`
`second radio interface standard, also carries out fimctions which cause radio
`
`systems in accordance with the second radio interface standard to interpret the
`
`radio channel as interfered and to seize another radio channel for its own
`
`operation.
`
`DEMONSTRATIVE - NOT EVIDENCE
`
`6
`
`

`

`
`
`Claim 9
`
`9. A wireless network comprising at
`
`least one common frequency band
`
`provided for alternate use by a first and a second radio interface standard, the
`
`wireless network comprising:
`
`stations which work in accordance with a first radio interface standard
`
`and/or in accordance with a second radio interface standard, and
`
`a control station which controls the alternate use of the common frequency
`
`band,
`
`wherein the control station controls the access to the common frequency
`
`band for stations working in accordance with the first radio interface standard
`
`and renders the frequency band available for access by the stations working in
`
`accordance with the second radio interface standard if stations working in
`
`accordance with the first radio interface standard do not request access to the
`
`frequency band.
`
`DEMONSTRATIVE - NOT EVIDENCE
`
`7
`
`

`

`Grounds Based on Sherman Fail
`
`The Petition fails to show that Sherman teaches the Claim 1
`
`recitation “wherein the control station
`
`renders the frequency
`
`band available for access by the stations working in accordance
`
`with the second radio interface standard if stations working in
`
`accordance with the first radio interface standard do not request
`
`access to the frequency band.”
`
`-1349 PO Resp. 19
`
`DEMONSTRATIVE - NOT EVIDENCE
`
`B
`
`

`

`Sherman does not teach at least the wherein clause of claim 1
`
`Sherman does not teach:
`
`'
`
`'
`
`'
`
`'
`
`any mechanism and/or technique for first determining Whether or not any 802.11
`
`stations are requesting access to the frequency band
`
`allocating the HIPERLAN/Z phase for use by HIPERLAN/2 stations Via the super-
`
`frame structure based on this determination
`
`any mechanism and/or technique for first determining whether or not any
`
`HIPERLAN/2 stations are requesting access to the frequency band
`
`allocating the broadcast phase, and/or CFP phase for use by 802.11stations via the
`
`super-frame structure (e.g., contention free period) based on this determination
`
`-1349 PO Resp. 23
`
`DEMONSTRATIVE - NOT EVIDENCE
`
`9
`
`

`

`“control station...renders the frequency band available for access...”
`
`'
`
`“if stations working in accordance with the first radio interface
`
`standard do not request access to the frequency band”
`
`° Claim 1 recites “a control station which controls the alternate use of
`
`the frequency band”
`
`'
`
`“[T]he specification clearly describes the situation where the
`
`control station is provided for releasing the common frequency
`
`band if stations operating in accordance with the first radio
`
`interface standard do not request access. EX1001, 3:7—13.” -
`
`1349 PO Resp. 31.
`
`' Unlike Schulhausex See PO Resp. 26-32, PO Sur Reply 2-4.
`
`'
`
`“[I]t would be erroneous to not give patentable weight to a wherein
`
`clause that meaningfully limits and further defines an expressly
`recited ‘controls’ limitation in terms of how it must be effected.”
`
`PO Sur Reply 3.
`
`DEMONSTRATIVE - NOT EVIDENCE
`
`1U
`
`

`

`“control station...renders the frequency band available for access...”
`
`0 “if stations working in accordance with the first
`radio interface standard do not request access to the
`frequency band”
`
`0 The “if” statement of the wherein clause is
`
`“integrated into one method or path and do[es] not
`cause the claim to diverge into two methods or
`paths.” IPR2017-007009, at *3—4.
`
`-1349 PO Sur Reply 34
`
`DEMONSTRATIVE «- NOT EVIDENCE
`
`11
`
`

`

`Grounds Based on Shellhammer Fail
`
`The Petition fails to show that Shellhammer teaches the Claim 1
`
`recitation “wherein the control station
`
`renders the frequency
`
`band available for access by the stations working in accordance
`
`with the second radio interface standard if stations working in
`
`accordance with the first radio interface standard do not request
`
`access to the frequency band.”
`
`-1349 PO Resp. 35
`
`DEMONSTRATIVE - NOT EVIDENCE
`
`12
`
`

`

`Shellhammer does not teach at least the wherein clause of claim 1
`
`For example, the disclosure in Shellhammer that the duration of the time intervals may
`
`depend on traffic characteristics and application needs, such as time critical services, does
`
`not require variable lengths of time periods at all. Rather, the resolution of traffic
`
`characteristics and application needs is likely a signal to the designer to select the time
`
`intervals depending on those needs.
`
`-1 349 PO Resp. 41
`
`DEMONSTRATIVE «- NOT EVIDENCE
`
`13
`
`

`

`The Board Correctly Determined Shellhammer Does Not Render Claim 7 Obvious
`
`° For example, there exists no teaching or suggestion within the entirety of
`Shellhammer that the AP 20, 30 (control station) receives control information from a
`
`MU 100, 110 (further station) that controls access to the common frequency band by
`stations associated with a second radio interface standard.
`
`° The MU 100, 110 controls the operation of the Bluetooth slave devices. But the MU
`
`100, 110 does not transmit any information about how the Bluetooth slave devices are
`being controlled by the MU 100, 110.
`
`' Thus, Shellhammer does not teach or suggest a control station that controls the access
`to the common frequency band by stations working in accordance with the first radio
`
`interface standard and in that duration and type of control of the radio interface in
`accordance with the second radio interface standard is determined by a further station
`and transmitted to the control station” as recited in Independent Claim 7.
`
`-1350 PO Resp. 53-54
`
`DEMONSTRATIVE - NOT EVIDENCE
`
`14
`
`