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`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`ZTE (USA) INC.,
`
`Petitioner
`
`v.
`
`BELL NORTHERN RESEARCH, LLC,
`
`Patent Owner
`
`
`
`DECLARATION OF PAUL MIN, PH.D.
`
`
`Case No. IPR2019-01438
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`
`
`
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`ZTE, Exhibit 1015-0001
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`

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`
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`TABLE OF CONTENTS
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`I.
`
`Introduction ...................................................................................................... 1
`
`II.
`
`Background/Qualifications .............................................................................. 1
`
`III. Documents and Materials Considered ............................................................. 5
`
`IV. Legal Principles ............................................................................................... 6
`
`V.
`
`Person of Ordinary Skill in the Art ................................................................12
`
`VI.
`
`’862 Patent .....................................................................................................13
`
`A.
`
`Summary .............................................................................................13
`
`B.
`
`C.
`
`Prosecution History .............................................................................16
`
`Priority Date ........................................................................................17
`
`VII. Technology Background ................................................................................17
`
`A.
`
`Beamforming .......................................................................................17
`
`B.
`
`Singular Value Decomposition (SVD) ................................................21
`
`VIII. Claim Construction ........................................................................................25
`
`IX.
`
`Invalidity Opinions ........................................................................................27
`
`A.
`
`Li anticipates claims 9-12. ..................................................................27
`
`1.
`
`Application of Li to claims 9-12 ...............................................31
`
`A.
`
`Li in combination with Maltsev renders obvious claims 9-12. ...........58
`
`1. Maltsev ......................................................................................58
`
`2. Motivation to combine Li and Maltsev .....................................59
`
`3.
`
`Application of Li and Maltsev to claims 9-12 ..........................60
`
`B.
`
`Tong anticipates claims 9-12. ..............................................................81
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`Min Declaration
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`IPR2019-01438
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`ZTE, Exhibit 1015-0002
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`1.
`
`2.
`
`Tong ..........................................................................................81
`
`Application of Tong to claims 9-12 ..........................................83
`
`C.
`
`Tong in combination with Reinhardt renders obvious claims 10. ......99
`
`1.
`
`Reinhardt ...................................................................................99
`
`2. Motivation to combine Tong and Reinhardt ...........................101
`
`3.
`
`Application of Tong and Reinhardt to claim 10 .....................102
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`Min Declaration
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`IPR2019-01438
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`ZTE, Exhibit 1015-0003
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`
`I.
`
`Introduction
`
`1. My name is Paul Min, Ph.D. I submit this declaration on behalf of
`
`ZTE (USA) Inc., (“Petitioner”), which I understand is challenging the validity of
`
`claims 9-12 (“the challenged claims”) of U.S. Patent No. 8,416,862 (“the ’862
`
`patent”) (Ex. 1001) in a petition for inter partes review.
`
`2.
`
`I have been asked to provide an opinion on the validity of the
`
`challenged claims. In my opinion, U.S. Patent Application Publication No.
`
`2006/0068718 (“Li”) (Ex. 1005) anticipates claims 9-12 of the ’862 patent.
`
`Additionally, the combination of Li, U.S. Patent No. 7,570,696 (“Maltsev”) (Ex.
`
`1006) renders obvious claims 9-12 of the ’862 patent.
`
`3.
`
`Furthermore, it is my opinion that, U.S. Patent Application
`
`Publication No. 2008/0108310 (“Tong”) (Ex. 1007) anticipates claims 9-12 of the
`
`’862 patent. Additionally, the combination of Tong and U.S. Patent No. 5,541,607
`
`(“Reinhardt”) (Ex. 1014) renders obvious claim 10 of the ’862 patent.
`
`II. Background/Qualifications
`
`4.
`
`I summarize in this section my educational background, career
`
`history, publications, and other relevant qualifications. Appendix A to this
`
`declaration is my curriculum vitae, which sets forth my qualifications.
`
`5.
`
`I received a B.S. degree in Electrical Engineering in 1982, an M.S.
`
`degree in Electrical Engineering in 1984, and a Ph.D. degree in Electrical
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`IPR2019-01438
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`ZTE, Exhibit 1015-0004
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`Engineering in 1987 from the University of Michigan in Ann Arbor. I received
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`several academic honors, including my B.S. degree with honors, a best graduate
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`student award and a best teaching assistant award during my M.S. study, and a best
`
`paper award from a major international conference for reporting results from my
`
`Ph.D. thesis.
`
`6.
`
`After receiving my Ph.D., I worked at Bellcore in New Jersey from
`
`August 1987 until August 1990. At Bellcore, I was responsible for evolving the
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`public switched telephone network (PSTN) into a multi-services voice and data
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`network that incorporated packet switches, optical technologies, and wireless
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`technologies.
`
`7.
`
`In September 1990, I joined the faculty at Washington University in
`
`St. Louis. In July 1996, I was promoted to an Associate Professor of Electrical
`
`Engineering with tenure. I am currently a Senior Professor of Electrical and
`
`Systems Engineering at Washington University. I have also served as the Chair of
`
`the Graduate Curriculum (2000-2002) and the Chair of the Undergraduate
`
`Curriculum (2011-2014) for the Department of Electrical and Systems
`
`Engineering.
`
`8.
`
`At Washington University, I have conducted research in
`
`communication, computing, and related electronic hardware and software. My
`
`research group has pioneered a new paradigm for designing electronic circuits that
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`Min Declaration
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`IPR2019-01438
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`ZTE, Exhibit 1015-0005
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`can alleviate the speed and performance mismatch against optical technology. I
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`have received several grants from U.S. Federal Agencies, including the National
`
`Science Foundation and the Defense Advanced Research Project Agency, and
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`numerous contracts from companies and organizations around the world.
`
`9.
`
`Specifically related to the technology matters in this litigation, I have
`
`researched a variety of wireless communication technologies, including TDMA,
`
`CDMA, WCDMA, OFDM, FDD, SC-FDMA, and TDD. I have an extensive
`
`background and experience in each of these technologies.
`
`10. As a faculty member at Washington University, I have taught a
`
`number of courses in electronics, communication, and computing at both the
`
`undergraduate and graduate levels. For example, I have taught communication
`
`theory (Washington University ESE 471), transmission and multiplexing
`
`(Washington University ESE 571), and signaling and control of communication
`
`networks (Washington University ESE 572).
`
`11.
`
`I have supervised more than 50 graduate students, 12 of whom
`
`received a doctoral degree under my guidance. A number of doctoral theses that I
`
`have supervised relate specifically to wireless technology. My students and I have
`
`published a number of peer-reviewed articles on resource allocation, scheduling,
`
`modulation, mobility management, and multiplexing. Several of these articles
`
`received accolades in the field. For example, in 2011, we received a best paper
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`Min Declaration
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`ZTE, Exhibit 1015-0006
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`award in 3G WCDMA and 4G LTE related mobility and resource management at
`
`the prestigious Mobility 2011 international conference.
`
`12.
`
`In addition to my responsibilities as a university faculty member, I
`
`have founded two companies. In May 1997, I founded MinMax Technologies, Inc.,
`
`a fabless semiconductor company that developed switch fabric integrated circuit
`
`chips for the Internet. In March 1999, I founded Erlang Technology, Inc., a fabless
`
`semiconductor company that focused on the design and development of integrated
`
`circuit chips and software for the Internet. One of Erlang's products received a best
`
`product of the year award in 2004 from a major trade journal for the electronics
`
`industry.
`
`13. Outside my own start-up companies, I have also served in various
`
`technology and business advisor roles for other companies and organizations
`
`around the world. I was the main technical author for one of two winning proposals
`
`to the Korean government for CDMA wireless service licenses (1996). I was
`
`responsible for designing a commercial scale IS-95 CDMA cellular network,
`
`which I understand to be one of the earliest such networks deployed in the world. I
`
`worked with numerous engineers and scientists around the world to implement this
`
`commercial scale cellular network before IS-95 CDMA was widely accepted. This
`
`provided me with extensive insight into various components of cellular technology,
`
`which by and large are used in today's 3G and 4G networks. I have also been
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`Min Declaration
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`IPR2019-01438
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`ZTE, Exhibit 1015-0007
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`involved in a semiconductor company that specializes in semiconductor memories,
`
`such as flash EEPROMs, as a board member and as a technical advisor (2007-
`
`2011).
`
`14.
`
`I am a named inventor on ten U.S. patents, many of which are directly
`
`related to resource allocation, packet processing, and network designing. I have
`
`extensively published technical papers in international journals and at international
`
`conferences as well as technical memoranda and reports, and I have given a
`
`number of seminars and invited talks. Many of these papers are specifically within
`
`the context of the 3GPP standards. I have organized several international
`
`conferences and served as an international journal editor.
`
`15.
`
`I am a member of, and have been actively involved in, a number of
`
`professional organizations. For example, I have served as the Chair of the St. Louis
`
`Section of the IEEE, which has more than 3,000 members (2014), and a member of
`
`the Eta Kappa Nu Honor Society for electrical engineers. I have also been an
`
`Ambassador of the McDonnell International Scholars Academy (2007-2013).
`
`16.
`
`In my over 30 years of experience with telecommunications
`
`technology, I have acquired significant knowledge about telecommunications
`
`systems industry standards and standard setting organizations such as 3GPP.
`
`III. Documents and Materials Considered
`
`17. Appendix B to this declaration lists materials that I have considered in
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`ZTE, Exhibit 1015-0008
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`rendering the opinions that I express in this declaration. In forming my opinions, I
`
`have also relied on my experience and education.
`
`IV. Legal Principles
`
`18.
`
`I am not an attorney. I offer no opinions on the law. But counsel has
`
`informed me of legal standards that apply to the issue of patent validity. I have
`
`applied these standards in arriving at my conclusions.
`
`19.
`
`I understand that in an inter partes review the petitioner has the
`
`burden of proving a proposition of unpatentability by a preponderance of the
`
`evidence. I understand this standard is different from the standard that applies in a
`
`district court, where I understand a challenger bears the burden of proving
`
`invalidity by clear and convincing evidence.
`
`20.
`
`I understand that a patent claim is invalid based on anticipation if a
`
`single prior art reference discloses all of the features of that claim, and does so in a
`
`way that enables one of ordinary skill in the art to make and use the invention.
`
`Each of the claim features may be expressly or inherently present in the prior art
`
`reference. I understand that if the prior art necessarily functions in accordance
`
`with, or includes a claim’s feature, then that prior art inherently discloses that
`
`feature. I have relied on this understanding in expressing the opinions set forth
`
`below.
`
`21.
`
`I understand that a prior art reference describes the claimed invention
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`Min Declaration
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`IPR2019-01438
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`ZTE, Exhibit 1015-0009
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`if it either expressly or inherently describes each and every feature set forth in the
`
`claim; i.e., in determining whether a single item of prior art anticipates a patent
`
`claim, one should take into consideration not only what is expressly disclosed in
`
`that item, but also what is inherently present as a natural result of the practice of
`
`the system or method disclosed in that item.
`
`22.
`
`I understand that to establish inherency, the evidence must make clear
`
`that the missing descriptive matter is necessarily present in the item of prior art and
`
`that it would be so recognized by persons of ordinary skill in the art. I also
`
`understand that prior art use of the claimed patented invention that was accidental,
`
`unrecognized, or unappreciated at the time of filing can still be an invalidating
`
`anticipation.
`
`23.
`
`I understand that although multiple prior art references may not be
`
`combined to show anticipation, additional references may be used to interpret the
`
`allegedly anticipating reference and shed light on what it would have meant to
`
`those skilled in the art at the time of the invention. These additional references
`
`must make it clear that the missing descriptive matter in the patent claim is
`
`necessarily present in the allegedly anticipating reference, and that it would be so
`
`recognized by persons of ordinary skill in the art.
`
`24.
`
`I understand that a patent may not be valid even though the invention
`
`is not identically disclosed or described in the prior art if the differences between
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`Min Declaration
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`ZTE, Exhibit 1015-0010
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`the subject matter sought to be patented and the prior art are such that the subject
`
`matter as a whole would have been obvious to a person having ordinary skill in the
`
`art in the relevant subject matter at the time the invention was made.
`
`25. To determine if a claim is obvious, the following factors should be
`
`considered: (1) the level of ordinary skill in the art at the time the invention was
`
`made; (2) the scope and content of the prior art; (3) the differences between the
`
`claimed invention and the prior art; and (4) secondary considerations, including
`
`evidence of commercial success, long-felt but unsolved need, unsuccessful
`
`attempts by others, copying of the claimed invention, unexpected and superior
`
`results, acceptance and praise by others, independent invention by others, and the
`
`like.
`
`26. For example, I understand that the combination of familiar elements
`
`according to known methods is likely to be obvious when it does no more than
`
`yield predictable results. I also understand that an obviousness analysis need not
`
`seek out precise teachings directed to the specific subject matter of the challenged
`
`claim because a court can take account of the inferences and/or creative steps that a
`
`person of ordinary skill in the art would employ.
`
`27.
`
`I understand that the obviousness determination of an invention turns
`
`on whether a hypothetical person with ordinary skill and full knowledge of all the
`
`pertinent prior art, when faced with the problem to which the claimed invention is
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`Min Declaration
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`ZTE, Exhibit 1015-0011
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`addressed, would be led naturally to the solution adopted in the claimed invention
`
`or would naturally view that solution as an available alternative. Facts to be
`
`evaluated in this analysis include:
`
` The scope and contents of the prior art;
`
` Differences between the prior art and the claims at issue;
`
` The level of ordinary skill in the pertinent art; and
`
` Evidence of objective factors suggesting or negating obviousness.
`
` I understand that the following rationales may be used to determine whether
`a piece of prior art can be combined with other prior art or with other
`information within the knowledge of one of ordinary skill in the art:
`
` Combining prior art elements according to known methods to yield
`predictable results;
`
` Simple substitution of one known element for another to obtain predictable
`results;
`
` Use of known techniques to improve similar devices (methods, or products)
`in the same way;
`
` Applying a known technique to a known device (method, or product) ready
`for improvement to yield predictable results;
`
` “Obvious to try” - choosing from a finite number of identified, predictable
`solutions, with a reasonable expectation of success;
`
` Known work in one field of endeavor may prompt variations of it for use in
`either the same field or a different one based on design incentives or other
`market forces if the variations would have been predictable to one of
`ordinary skill in the art; or
`
` Some teaching, suggestion, or motivation in the prior art that would have led
`one of ordinary skill to modify the prior art reference or to combine prior art
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`IPR2019-01438
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`ZTE, Exhibit 1015-0012
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`reference teachings to arrive at the claimed invention.
`
`28.
`
`I understand that when a work is available in one field of endeavor,
`
`design incentives and/or other market forces, for example, can prompt variations of
`
`it, either in the same field or a different one. Moreover, if a person of ordinary skill
`
`can implement a predictable variation, I understand that that likely bars its
`
`patentability.
`
`29.
`
`I understand that obviousness must be tested as of the time the
`
`invention was made. I understand that the test for obviousness is what the
`
`combined teachings of the prior art references would have suggested, disclosed, or
`
`taught to one of ordinary skill in the art. In particular, it is my understanding that a
`
`patent claim is invalid based upon obviousness if it does nothing more than
`
`combine familiar elements from one or more prior art references or products
`
`according to known methods to yield predictable results. For example, I understand
`
`that where a technique has been used to improve one device, and a person of
`
`ordinary skill in the art would have recognized that it would improve similar
`
`devices in the same way, using that technique is obvious. I understand that
`
`obviousness can be proved by showing that a combination of elements was
`
`obvious to try, i.e.: that it does no more than yield predictable results; implements a
`
`predictable variation; is no more than the predictable use of prior art elements
`
`according to their established functions; or when there is design need or market
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`ZTE, Exhibit 1015-0013
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`pressure to solve a problem and there are a finite number of identified, predictable
`
`solutions. I have been further informed that when a patent claim simply arranges
`
`old elements with each element performing the same function it had been known to
`
`perform and yields results no more than one would expect from such an
`
`arrangement, the combination is obvious.
`
`30.
`
`I understand that another factor to be considered is common sense.
`
`For example, I understand that common sense teaches that familiar items may have
`
`obvious uses beyond their primary purposes, and, in many cases, a person of
`
`ordinary skill will be able to fit the teachings of multiple patents together like
`
`pieces of a puzzle.
`
`31.
`
`I understand that the Supreme Court articulated additional guidance
`
`for obviousness in its KSR decision. My understanding is that the Supreme Court
`
`said that technical people of ordinary skill look for guidance in other solutions to
`
`problems of a similar nature, and that the obviousness inquiry must track reality,
`
`and not legal fictions. I have relied on these understandings in expressing the
`
`opinions set forth below.
`
`32.
`
`I understand that a new use of an old product or material cannot be
`
`claimed as a new product; the apparatus or system itself is old and cannot be
`
`patented. I further understand that, in general, merely discovering and claiming a
`
`new benefit to an old process cannot render the process newly patentable.
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`IPR2019-01438
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`ZTE, Exhibit 1015-0014
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`V.
`
`Person of Ordinary Skill in the Art
`
`33.
`
`In order to determine the characteristics of a person of ordinary skill
`
`in the art of the ’862 Patent, I have used April 21, 2005 as the relevant time frame.
`
`My understanding is that this is the filing date of the earliest provisional
`
`application to which the ’862 Patent claims priority. For purposes of this statement,
`
`any reference to the filing date of the ’862 Patent is intended to refer to this April
`
`21, 2005 priority date of the provisional application to which the ’862 Patent
`
`claims priority. (I have not been asked to opine on whether the provisional
`
`application is sufficient to establish the priority date for the ’862 Patent; I am using
`
`this date in the following analysis because that is the priority date alleged by
`
`BNR.)
`
`34.
`
`In determining the characteristics of a person of ordinary skill for the
`
`’862 Patent, I have considered the state of the art of wireless mobile
`
`communication systems at that time, the types of problems encountered with signal
`
`fading, and the solutions that then existed such as antenna systems, including
`
`MIMO, and beamforming techniques. I have also considered the then-existing
`
`technology for wireless communication systems, such as cellular radio systems and
`
`wireless local area network systems (e.g., IEEE 802.11 Wi-Fi systems), including
`
`the sophistication of the technology involved. I have also considered the education
`
`and experience of those working in the field at that time. I have also considered my
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`ZTE, Exhibit 1015-0015
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`personal knowledge and experience with the field at that time, including those I
`
`worked and interacted with regarding wireless mobile communication systems. I
`
`have also considered the knowledge, education, and experience of those in
`
`academia and industry at that time that were working, innovating, or performing
`
`research in the field of wireless mobile communication systems, and in particular,
`
`techniques to address signal fading problems.
`
`35.
`
`It is my opinion that a POSITA for the ’862 Patent at the time of this
`
`filing date would have had a Bachelor’s degree in Electrical Engineering,
`
`Computer Engineering, Computer Science, or a related field, and at least 2 to 4
`
`years of experience in the field of wireless communication, or a person with
`
`equivalent education, work, or experience in this field.
`
`36. Based on my background and qualifications, I am currently and was
`
`as of the priority date of the ’862 Patent at least a POSITA in the subject matter of
`
`the ’862 patent.
`
`VI.
`
`’862 Patent
`
`A.
`
`Summary
`
`37. U.S. Patent No. 8,416,862 to Carlos Aldana, et al., is entitled
`
`“Efficient Feedback of Channel Information in a Closed Loop Beamforming
`
`Wireless Communication System” and was issued on April 9, 2013.
`
`38. The ’862 Patent relates to wireless communications using
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`ZTE, Exhibit 1015-0016
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`beamforming. ’862 patent at 1:20–22. “FIG. 6 is a schematic block diagram of a
`
`beamforming wireless communication where H=UDV* (H–represents the channel,
`
`U is the receiver beamforming unitary matrix, and V* is the conjugate of the
`
`transmitter beamforming unitary matrix.” ’862 patent at 12:47–51.
`
`
`
`39.
`
`In the background section, the specification explains that a receiver
`
`must provide feedback information “for a transmitter to properly implement
`
`beamforming (i.e., determine the beamforming matrix [V]).” ’862 patent at 3:14–
`
`19. “One approach for sending feedback from the receiver to the transmitter is for
`
`the receiver to determine the channel response (H) and to provide it as the
`
`feedback information.” ’862 patent at 3:19–22. Alternatively, “the receiver may
`
`decompose the channel using singular value decomposition (SVD) and send
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`ZTE, Exhibit 1015-0017
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`information relating only to a calculated value of the transmitter’s beamforming
`
`matrix (V) as the feedback information. In this approach, the receiver calculates (V)
`
`based on H=UDV*, where H is the channel response, D is a diagonal matrix, and U
`
`is a receiver unitary matrix.” ’862 patent at 3:26–33. The patent explains that each
`
`of these prior art methods results in the size of the feedback information being too
`
`large for practical applications. ’862 patent at 3:22–25, 3:33–35.
`
`40. The ’862 Patent states that it discloses the following method for
`
`feeding back transmitter beamforming information:
`
`A method for feeding back transmitter beamforming
`information from a receiving wireless communication
`device to a transmitting wireless communication device
`includes a receiving wireless communication device
`receiving a preamble sequence from the transmitting
`wireless device. The receiving wireless device estimates
`a channel response based upon the preamble sequence
`and
`then
`determines
`an
`estimated
`transmitter
`beamforming unitary matrix based upon the channel
`response and a receiver beamforming unitary matrix. The
`receiving wireless device then decomposes the estimated
`transmitter beamforming unitary matrix to produce the
`transmitter beamforming information and then wirelessly
`sends the transmitter beamforming information to the
`transmitting wireless device. The receiving wireless
`device may
`transform
`the estimated
`transmitter
`beamforming unitary matrix using a QR decomposition
`operation such as a Givens Rotation operation to produce
`the transformer beamforming information.
`
`
`’862 patent at Abst.
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`IPR2019-01438
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`ZTE, Exhibit 1015-0018
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`B.
`
`Prosecution History
`
`41. The ’862 patent issued from U.S. Patent Application No. 11/237,341,
`
`which was filed on September 28, 2005.
`
`42. On August 5, 2008, the examiner rejected the pending claims based
`
`on the combination of U.S. Patent Application Publication Nos. 2002/0187753
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`(“Kim”) and 2004/0042558 (“Huang”). Ex. 1002 (’862 file history) at 0155. In
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`response, the applicant argued that the claim element “[a mechanism for
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`decomposing] the estimated transmitter beamforming unitary matrix (V)” in the
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`independent claims is missing. Ex. 1002 (’862 file history) at 0149.
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`43. The examiner also included a rejection based on U.S. Patent No.
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`5,541,607 (“Reinhardt”) in certain dependent claims, indicating that Reinhardt
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`disclosed “converting parameters from Cartesian to polar coordinates.” Ex. 1002
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`(’862 file history) at 0162. This rejection was traversed based on arguments made
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`with respect to the independent claims. Ex. 1002 (’862 file history) at 0149-50.
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`Applicant did not specifically address whether Reinhardt disclosed conversion
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`from Cartesian to polar coordinates in a transmitter beamforming system.
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`44. On January 23, 2009, the examiner issued a final rejection, based
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`again on Kim and Huang. Ex. 1002 (’862 file history) at 0136. In response, the
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`applicant appealed to the Patent Trial and Appeal Board and successfully
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`overturned the examiner’s rejections, leading to allowance and issuance of the ’862
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`patent on April 9, 2013. See Ex. 1002 (’862 file history) at 0120; id. at 0037.
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`C.
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`Priority Date
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`45. Application No. 11/237,341, which issued as the ’862 patent, is a
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`continuation-in-part of U.S. Patent Application No. 11/168,793, filed on June 28,
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`2005 and issued as U.S. Patent No. 7,738,583. Application No. 11/237,341 also
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`claims priority to U.S. Provisional Patent Application Nos. 60/673,451 (Ex. 1003),
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`filed on April 21, 2005 and 60/698,686 (Ex. 1004), filed on July 13, 2005.
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`46. For the purposes of this report, I have been told to assume that the
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`earliest priority date of the ’862 patent is April 21, 2005.
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`VII. Technology Background
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`47.
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`In order to aid the discussions that I have presented in this declaration,
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`I have provided below a brief technology background for the ’862 patent. A
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`POSITA would be familiar with the following concepts as of the priority date of
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`the ’862 patent.
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`A. Beamforming
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`48.
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`In wireless communication, a transmitter transmits radio frequency
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`(RF) signals over the wireless medium. A particular definition varies regarding the
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`term “radio frequency signal,” but generally the radio frequency signals relate to
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`the signals utilizing frequencies greater than the audible signals and less than the
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`visible signals. In this way, an RF signal may be in tens of kilohertz (khz = 103
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`cycles per second) to tens of gigahertz (Ghz = 109 cycles per second). For example,
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`in the United States, the broadcast AM radio utilizes between about 530 khz and
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`1600 khz, and the broadcast FM radio utilizes between about 88 megahertz (Mhz =
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`106 cycles per second) and 108 Mhz.
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`49. When a transmitter transmits a sine wave (or tone) to a receiver at a
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`particular frequency, depending on the distance between the transmitter and the
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`receiver, the amplitude of the received sine wave varies. This can be seen by
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`considering a wave of water propagating on the water surface radially when a rock
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`hits the water. At any given time, the wave creates peaks and troughs on the
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`surface of the water, which can be seen at different locations.
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`50.
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`In wireless communication, an RF signal propagates as an
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`electromagnetic wave, which travels in a wireless medium at the speed of light. As
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`fast as the speed of light may be, it is still finite and for a different distance away
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`from the transmitter, it takes a different amount of time before the RF signal is
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`received.
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`51. Consider now two transmitters, each generating a sine wave at the
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`same frequency. A receiver located at certain distances away from the two
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`transmitters receives two different sine waves from the transmitters and depending
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`on the distance from each transmitter, the receiver observes a different magnitude
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`of the received signal from the individual transmitter.
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`ZTE, Exhibit 1015-0021
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`52.
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`If the two sine waves from the transmitters happen to coincide in
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`phase at the receiver, the combined wave has the magnitude equaling the sum of
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`the two sine wave amplitudes. For example, if the received signal from the first
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`transmitter is A1sin(ωt) and the received signal from the second transmitter is
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`A2sin(ωt), then the combined signal at the receiver becomes (A1 + A2)sin(ωt). If, on
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`the other hand, the two sine waves happen to coincide in opposite phase, the
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`combined wave has the magnitudes equaling the difference of the two sine wave
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`amplitudes. Following the above example, if the received signal from the first
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`transmitter is A1sin(ωt) and the received signal from the second transmitter is
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`A2sin(ωt + 180°) = -A2sin(ωt), then the combined signal at the receiver becomes
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`(A1 - A2)sin(ωt). The combination of two sine waves in phase is referred to as a
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`constructive combination and the combination of the two sine waves in opposite
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`phase is referred to as a destructive combination.
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`53. Again using the example of rocks hitting the water, when two rocks
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`hit the water at two locations at the same time, two waves start propagating
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`radially, and they meet and generate the combined wave patterns on the water
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`surface. Depending on the location on the water surface, the water waves may
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`show a greater peak or trough value (i.e., constructive combination) or show a
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`lesser displacement up or down (i.e., destructive combination).
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`54. When a transmitter transmits an RF signal, the strength of the received
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`signal depends largely on the distance from the transmitter. This is because the
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`transmitter emits the RF signal radially much like the way a rock generates a wave
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`on the water surface. Consider now that a receiver is located at certain distances
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`away from multiple transmitters, each generating sine waves at the same
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`frequency. Since the distances to different transmitters are different, the sine waves
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`from the transmitters arrive at the receiver with different time delays. At this same
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`transmitter frequency, the time del