IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Aldana et al.
`In re Patent of:
`8,416,862
`
`U.S. Pat. No.:
`April 9, 2013
`Issue Date:
`Appl. Serial No.: 11/237,341
`Filing Date:
`September 28, 2005
`Title:
`EFFICIENT FEEDBACK OF CHANNEL INFORMATION IN
`A CLOSED LOOP BEAMFORMING WIRELESS
`COMMUNICATION SYSTEM
`
`Attorney Docket No.: 35548-0097IP1
`
`DECLARATION OF JONATHAN WELLS, Ph.D.
`
`1
`
`LG 1003
`
`
`
`Aldana et al.
`In re Patent of:
`8,416,862
`
`U.S. Pat. No.:
`April 9, 2013
`Issue Date:
`Appl. Serial No.: 11/237,341
`Filing Date:
`September 28, 2005
`Title:
`EFFICIENT FEEDBACK OF CHANNEL INFORMATION IN
`A CLOSED LOOP BEAMFORMING WIRELESS
`COMMUNICATION SYSTEM
`
`Attorney Docket No.: 35548-0097IP1
`
`DECLARATION OF JONATHAN WELLS, Ph.D.
`
`1
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`LG 1003
`
`
`
`TABLE OF CONTENTS
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`ASSIGNMENT ................................................................................................. 4
`I.
`II. QUALIFICATIONS ......................................................................................... 4
`III. LEGAL PRINCIPLES ...................................................................................... 8
`A. Anticipation ................................................................................................... 9
`B. Obviousness ................................................................................................... 9
`C. Claim Construction ...................................................................................... 11
`IV. PERSON OF ORDINARY SKILL IN THE ART ......................................... 13
`V. MATERIALS CONSIDERED ....................................................................... 14
`VI. BACKGROUND OF THE ’862 PATENT ..................................................... 17
`A.
`Subject Matter Overview............................................................................. 17
`B.
`File History of the ’862 Patent .................................................................... 28
`C.
`Priority Date of the ’862 Patent ................................................................... 31
`D. Background Knowledge of Matrices and their Singular Value
`Decomposition (SVD) .......................................................................................... 32
`VII. OVERVIEW OF CONCLUSIONS FORMED AND PRIOR ART
`REFERENCES ............................................................................................... 34
`VIII. ANALYSIS OF LI ’748 IN VIEW OF TONG AND MAO .......................... 35
`IX. ANALYSIS OF TONG IN VIEW OF MAO ................................................. 77
`X. ANALYSIS OF LI ’054 IN VIEW OF MAO ..............................................101
`XI. ANALYSIS OF LI ’054 IN VIEW OF MAO AND YANG ........................132
`XII. ANALYSIS OF POON IN VIEW OF MAO ...............................................137
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`2
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`XIII. SUPPORT FOR TONG IN EARLIER-FILED PROVISIONAL
`APPLICATION ............................................................................................160
`XIV. ADDITIONAL REMARKS .........................................................................163
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`3
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`I, Jonathan Wells, Ph.D. of Pleasanton, California, declare that:
`
`I.
`
`ASSIGNMENT
`
`I have been retained as a technical expert by counsel on behalf of
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`Huawei Technologies Co., Ltd. (“Huawei” or “Petitioner”). I understand that
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`Huawei is requesting that the Patent Trial and Appeal Board (“PTAB” or “Board”)
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`institute an inter partes review (“IPR”) proceeding of U.S. Patent No. 8,416,862
`
`(“the ’862 patent”) (EX1001).
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`
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`I have been asked to provide my independent analysis of the ’862
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`patent in light of the prior art publications cited below.
`
`
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`I am not, and never have been, an employee of Huawei. I received no
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`compensation for this declaration beyond my normal hourly compensation based
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`on my time actually spent analyzing the ’862 patent, the prior art publications cited
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`below, and the issues related thereto, and I will not receive any added
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`compensation based on the outcome of any IPR or other proceeding involving
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`the ’862 patent.
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`II. QUALIFICATIONS
`
`I received a B.Sc. in Physics with Physical Electronics, awarded with
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`first class honors, from the University of Bath in Bath, United Kingdom, in 1987.
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`In 1991, I earned by Ph.D., also from the University of Bath. I earned my M.B.A.,
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`awarded with distinction, from Massey University in New Zealand, in 1998.
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`4
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`I have over 30 years of wireless communications experience in areas
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`including cellular technologies, wireless devices, network infrastructure, and
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`wireless rules and regulations. I have written a textbook and multiple industry
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`reports and journal/conference papers which focus on wireless communications
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`systems. For example, I am the author of “Multi-Gigabit Microwave and
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`Millimeter-Wave Wireless Communications,” published by Artech House in 2010.
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`I have also authored four comprehensive industry reports on cellular connectivity
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`for Mobile Experts. I have lectured as part of undergraduate programs at
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`University of California, Berkeley, Carnegie Mellon University, and University of
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`Bath, and have given over two dozen lectures and conference presentations on
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`topics germane to wireless communications. I am also a listed inventor of several
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`patents, and am an author of over 40 academic and commercial publications and
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`presentations.
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`
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`I began my career in 1985, as an Engineer for Plessey Research,
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`Caswell, United Kingdom, developing high-speed fiber optic transmitter/receiver
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`devices. In 1987, I worked at British Aerospace, Filton, Bristol, United Kingdom,
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`designing and fabricating novel mixer devices, to support my Ph.D. research.
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`Later in 1990, as a Post-Doctoral Research Officer for University of Bath, I
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`designed and fabricated novel quantum amplifiers in a clean room environment
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`and developed computer models to predict semiconductor device performance.
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`5
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`In 1983, I joined Matra Marconi Space, Portsmouth, United Kingdom,
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`as a Senior Design Engineer and developed a GaAs MMIC mixer and MIC
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`transmitter board for two satellite payloads and performed theoretical analysis and
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`modeling of low noise VCOs.
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`
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`From 1994 to 1998, I worked for MAS Technology (now Aviat
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`Networks), Wellington, New Zealand, first as Senior RF Design Engineer and later
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`as RF Group Manager. I was responsible for RF hardware development for
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`cellular and telecommunications applications; developed three generations of
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`wireless transmission, switching, and multiplexing products; designed and
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`sustained responsibility for satellite ground station terminals; and was responsible
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`for company’s European regulatory approvals.
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`
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`In 1998, I joined Adaptive Broadband (now GE Digital Energy),
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`Rochester, New York, first as Engineering Group Leader and later as Director
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`Wideband Products. I was responsible for the Terrestrial Infrastructure Group,
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`providing telecommunications products for cellular and private network
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`applications; managed P&L responsibility for $4M wireless division; and was
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`responsible for the development of a family of digital radios and associated
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`switching/multiplexing equipment.
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` From 2000 to 2004, I worked for Stratex Networks (now Aviat
`
`Networks), San Jose, California, as Director Product Development. I was
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`responsible for global product development of high-end digital microwave radios
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`primarily for cellular backhaul applications; led RF/microwave development team
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`of 35 engineers based in two continents; performed technical leadership of flagship
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`Eclipse product, shipping over 250,000 units; and was responsible for technical
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`management of overseas manufacturing subcontractors.
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`
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`In 2005, I joined GigaBeam Corporation, Herndon, Virginia, as
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`Director Product Management and Global Regulatory Affairs. I was responsible
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`for product strategy for industry-transforming high data rate wireless product;
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`initiated market development in over 40 countries including in Europe, Canada,
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`Caribbean, Latin America, the Middle East, and Asia; and participated and drove
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`standard development in FCC, CEPT, and ETSI technical meetings.
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` Since 2007, I have been an independent consultant with AJIS
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`Consulting, where I provide independent technical consulting on wireless
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`communications and emerging wireless fields. The services I provide include:
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`acting as a technical expert support of 2G, 3G, 4G, and 5G cellular and wireless
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`patent litigation; providing analysis of cellular and mobile wireless patents and
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`infringing equipment; providing cellular and wireless technology technical and
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`industry analysis for companies, analysts, and investment institutions, and
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`researching and publication of analyst reports; providing wireless product
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`development and marketing strategies; providing specialized technical workshops
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`7
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`on various wireless technologies, including cellular networks, mm-wave radios,
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`security sensors, and short range radios; and providing specialized global
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`regulatory tasks and product approvals.
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` My curriculum vitae, attached to this declaration as Appendix A, sets
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`forth details of my background and relevant experience. My CV includes a listing
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`of cases for which I have provided expert testimony over the last four years and a
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`complete list of publications I have authored.
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` Based on my experience and education, I believe that I am qualified to
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`opine as to the knowledge and level of skill of one of ordinary skill in the art at the
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`time of the alleged invention of the ’862 patent (which I further describe below)
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`and what such a person would have understood at that time, and the state of the art
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`during that time. Based on my experiences, I understand and know of the
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`capabilities of persons of ordinary skill in this field during the early-to-mid 2000s
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`and specifically during the time before the time of the alleged invention of the ’862
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`patent. Indeed, I taught, participated in organizations, and worked closely with
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`many such persons in the field during that time frame.
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`III. LEGAL PRINCIPLES
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`In forming my analysis and conclusions expressed in this declaration,
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`I have applied the legal principles described in the following paragraphs, which
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`were provided to me by counsel for the Petitioner.
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`8
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`A. Anticipation
`
`I have been informed that a patent claim is invalid as anticipated if
`
`each and every element of a claim, as properly construed, is found either explicitly
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`or inherently in a single prior art reference. Under the principles of inherency, if
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`the prior art necessarily functions in accordance with, or includes the claimed
`
`limitations, it anticipates.
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`
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`I have been informed that a claim is invalid if the claimed invention
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`was known or used by others in the U.S., or was patented or published anywhere,
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`before the Applicant’s invention. I further have been informed that a claim is
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`invalid if the invention was patented or published anywhere, or was in public use,
`
`on sale, or offered for sale in this country, more than one year prior to the filing
`
`date of the patent application (critical date). Further, I have been informed that a
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`claim is invalid if an invention described by that claim was described in a U.S.
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`patent granted on an application for a patent (or in a published application for a
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`U.S. patent) that was filed by another in the U.S. before the date of invention for
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`such a claim.
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`B. Obviousness
`
`I have been informed that a patent claim is invalid as “obvious” in
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`light of one or more prior art references if it would have been obvious to a person
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`of ordinary skill in the art at the time of the alleged invention (“POSITA”), taking
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`into account (1) the scope and content of the prior art, (2) the differences between
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`the prior art and the claims, (3) the level of ordinary skill in the art, and (4) any so
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`called “secondary considerations” of non-obviousness, which include: (i) “long felt
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`need” for the claimed invention, (ii) commercial success attributable to the claimed
`
`invention, (iii) unexpected results of the claimed invention, and (iv) “copying” of
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`the claimed invention by others.
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` While I do not know the exact date that the alleged invention claimed
`
`in the ’862 patent was made, I do know that the ’862 patent claims priority to a
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`number of other patent applications. In particular, the ’862 patent is a
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`continuation-in-part of U.S. App. Serial No. 11/168,793 (“’793 application”,
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`EX1014), and claims priority to U.S. Provisional App. Serial No. 60/673,451
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`(“’451 provisional”, EX1010), filed April 21, 2005, and U.S. Provisional App.
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`Serial No. 60/698,686 (“’686 provisional”, EX1011), filed July 13, 2005. Based
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`on my analysis of the applications to which the ’862 patent claim priority
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`(explained below in Section VI.C), for purposes of my analysis here, I have
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`applied a date of July 13, 2005, as the date of the alleged invention in my
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`obviousness analysis, although in many cases the same analysis would hold true
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`even if the date of the alleged invention occurred earlier than July 13, 2005
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`(especially given the earlier publication or filing dates of the prior art in Exhibits
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`1004, 1005, 1006, 1007, 1008, and 1009, as described below). See ¶24 (below).
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`10
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`I have been informed that a claim can be obvious in light of a single
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`prior art reference or multiple prior art references. To be obvious in light of a
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`single prior art reference or multiple prior art references, there must be a reason
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`that would have prompted a POSITA to modify the single prior art reference, or
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`combine two or more references, in a manner that provides the elements of the
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`claimed invention. This reason may come from a teaching, suggestion, or
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`motivation to combine, or may come from the reference(s) themselves, the
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`knowledge or “common sense” of a POSITA, or from the nature of the problem to
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`be solved, and this reason may be explicit or implicit from the prior art as a whole.
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`I have been informed that, under the law, the combination of familiar elements
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`according to known methods is likely to be obvious when it does no more than
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`yield predictable results. I also understand it is improper to rely on hindsight in
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`making the obviousness determination.
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`C. Claim Construction
`
`I understand that, for purposes of my analysis in this inter partes
`
`review proceeding, the terms appearing in the patent claims should be interpreted
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`according to their “ordinary and customary meaning,” which is often referred to as
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`the Phillips standard. In determining the ordinary and customary meaning, I
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`understand that the words of a claim are first given their plain meaning that those
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`words would have had to a person of ordinary skill in the art at the time of the
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`11
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`alleged invention. I also understand that the structure of the claims, the
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`specification and file history also may be used to better construe a claim insofar as
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`the plain meaning of the claims cannot be understood. Moreover, I understand that
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`even treatises and dictionaries may be used, albeit under limited circumstances, to
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`determine the meaning attributed by a person of ordinary skill in the art to a claim
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`term at the time of filing. I have followed this approach in my analysis, and for all
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`of the claim terms considered in this declaration, I have applied the plain and
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`ordinary meaning of those terms. To this end, I was informed that, in the
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`concurrent litigation in which the same claim construction standard is applied, the
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`district court has already indicated that no formal constructions for the ’862 patent
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`claims were required under the Phillips standard because the plain and ordinary
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`meaning of the claim language was recognizable without adoption of any formal
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`construction. EX1020, 104:23-107:3-9 and 111:4-114:22. In particular, I was
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`informed that the district court previously explained to the parties that the phrase
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`“baseband processing module operable to…” is not a means-plus-function element
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`under §112, ¶6 because the district court agreed with Patent Owner that “a
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`baseband processing module” was a known and recognizable structure. EX1020,
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`111:4-114:22; 116:18-118:5 (“THE COURT: … I don’t see this as a 112, 6 issue.
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`This is a known processing baseband processing module.”). Additionally, I was
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`informed that the district court indicated there was no need for a formal
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`12
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`
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`construction of the phrase “decompose the estimated transmitter beamforming
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`unitary matrix (V) to produce the transmitter beamforming information” under the
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`Phillips standard because the plain and ordinary meaning of the claim language
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`was recognizable without adoption of any formal construction. EX1020, 104:23-
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`105:2, 106:20-25, 107:3-9 (“Assume the Court will not construe that claim any
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`further, that that language of ‘transmitter beamforming information’ is what it is
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`and that a person of skill in the art would understand that is the result of the
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`decomposition of the estimated transmitter beamforming matrix”).
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`
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`I also understand that the words of the claims should be interpreted as
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`they would have been interpreted by a POSITA at the time the alleged invention
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`was made (not today). Because I do not know at what date the alleged invention
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`was made, I have used the date of July 13, 2005, for reasons explained in ¶19
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`(above) and ¶¶47-49 (below). However, the plain meanings/interpretations that I
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`employed in my analysis below would have also been correct if the date of
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`invention was anywhere within the early to mid 2000s.
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`IV. PERSON OF ORDINARY SKILL IN THE ART
` Based on my knowledge and experience in the field and my review of
`
`the ’862 patent and its file history, I believe that would have had Bachelor’s degree
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`in Electrical Engineering, Computer Engineering, Computer Science, or a related
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`field, and at least 2-4 years of experience in the field of wireless communication,
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`13
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`or a person with equivalent education, work, or experience in this field. Additional
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`education could substitute for some of the experience, and substantial experience
`
`could substitute for some of the educational background. My analysis and
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`conclusions as expressed herein are thus based on the perspective of a person of
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`ordinary skill in the art having this level of knowledge and skill at the time of the
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`alleged invention of the ’862 patent.
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` Because I do not know at what date the alleged invention as claimed
`
`was made, I have used the filing date of the earliest application to which the ’862
`
`patent claims priority that supports each element of the challenged claims 9-12 as
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`the point in time from which my analysis from the perspective of one of ordinary
`
`skill in the art is based. Again, as I explain in Section VI.C, that date was July 13,
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`2005. However, my analysis of the prior art and the conclusion herein would also
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`apply even if the date of the alleged invention as claimed was anywhere within the
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`early to mid 2000s (e.g., refer to the earlier publication or filing dates of Exhibits
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`1004, 1005, 1006, 1007, 1008, 1009).
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`V. MATERIALS CONSIDERED
` My analyses set forth in this declaration are based on my experience
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`in the field of wireless communication devices and associated technologies. Based
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`on my above-described experience in the field of wireless communication devices,
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`I believe that I am considered to be an expert in the field. Also, based on my
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`14
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`experiences, I understand and know of the capabilities of persons of ordinary skill
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`in this field during the early to mid 2000s and specifically during the time before
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`the alleged priority date (July 13, 2005) for the ’862 patent, and I taught,
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`participated in organizations, and worked closely with many such persons in the
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`field during that time frame.
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` As part of my independent analysis for this declaration, I have
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`considered the following: the background knowledge/technologies that were
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`commonly known to persons of ordinary skill in this field during the time before
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`the alleged priority date for the ’862 patent; my own knowledge and experiences
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`gained from my work experience in the fields of electrical engineering and
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`wireless communication devices generally; my experience in teaching and advising
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`others in those subjects; and my experience in working with others involved in
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`those fields. In addition, I have analyzed the following publications and materials:
`
` U.S. Patent No. 8,416,862 to Aldana et al. (“the ’862 patent”) (EX1001)
` Prosecution History of the ’862 patent (Serial No. 11/237,341) (EX1002)
` U.S. Pat. No. 7,236,748 to Li et al. (“Li ’748”) (EX1004)
` U.S. Pub. No. 2008/0108310 to Tong et al. (“Tong”) (EX1005)
` U.S. Pat. No. 7,312,750 to Mao et al. (“Mao”) (EX1006)
` U.S. Pub. No. 2006/0092054 to Li et al. (“Li ’054”) (EX1007)
` Yang et al., Reducing the Computations of the Singular Value
`Decomposition Array Given by Brent and Luk, SIAM J. MATRIX ANAL.
`APPL., Vol. 12, No. 4, pp. 713-725, Oct. 1991 (“Yang”) (EX1008)
`
`
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`15
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`
`
` U.S. Pat. No. 7,710,925 to Poon (“Poon”) (EX1009)
` U.S. Provisional Application Serial No. 60/673,451 (“the ’451
`provisional”) (EX1010)
` U.S. Provisional Application Serial No. 60/698,686 (“the ’686
`provisional”) (EX1011)
` U.S. Provisional Application Serial No. 60/614,621 (“the ’621
`provisional”) (EX1012)
` U.S. Provisional Application Serial No. 60/619,461 (“the ’461
`provisional”) (EX1013)
` U.S. Patent Application Serial No. 11/168,793 (“the ’793 application”)
`(EX1014)
` Plaintiff Bell Northern Research, LLC’s Patent Rule 3-1 and 3-2
`Disclosure of Asserted Claims and Infringement Contentions Against the
`Huawei Defendants in Bell Northern Research, LLC, v. Huawei Device
`(Dongguan) Co., Ltd., Huawei Device (Shenzhen) Co., Ltd., and Huawei
`Device USA, Inc. (Case No. 3:18-cv-1784) (S.D.Cal.) (EX1015)
` Defendants’ Invalidity Contentions in Bell Northern Research, LLC, v.
`Huawei Device (Dongguan) Co., Ltd., Huawei Device (Shenzhen) Co.,
`Ltd., and Huawei Device USA, Inc. (Case No. 3:18-cv-1784) (S.D.Cal.)
`(EX1016)
` Defendants’ Joint Opening Claim Construction Brief in Bell Northern
`Research, LLC, v. Huawei Device (Dongguan) Co., Ltd., Huawei Device
`(Shenzhen) Co., Ltd., and Huawei Device USA, Inc. (Case No. 3:18-cv-
`1784) (S.D.Cal.) (EX1017)
` Plaintiff’s Opening Claim Construction Brief in Bell Northern Re-search,
`LLC, v. Huawei Device (Dongguan) Co., Ltd., Huawei De-vice
`
`
`
`16
`
`
`
`(Shenzhen) Co., Ltd., and Huawei Device USA, Inc. (Case No. 3:18-cv-
`1784) (S.D.Cal.) (EX1018)
` Defendants’ Memorandum of Points and Authorities in Support of Their
`Joint Motion for Summary Judgement on Indefiniteness in Bell Northern
`Research, LLC, v. Huawei Device (Dongguan) Co., Ltd., Huawei Device
`(Shenzhen) Co., Ltd., and Huawei Device USA, Inc. (Case No. 3:18-cv-
`1784) (S.D.Cal.) (EX1019)
` Transcript of Claim Construction Hearing, Day Two, Volume Two,
`Pages 1-122 in Bell Northern Research, LLC, v. Huawei Technologies
`CO., LTD., Huawei Device (Hong Kong) CO., LTD., and Huawei
`Device USA, Inc. (Case No. 3:18-cv-1784) (S.D.Cal.) (EX1020)
` Declaration of Jacob Munford (EX1021)
` Although this declaration refers to selected portions of the cited
`
`references for the sake of brevity, it should be understood that these are examples,
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`and that one of ordinary skill in the art would have viewed the references cited
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`herein in their entirety and in combination with other references cited herein or
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`cited within the references themselves. The references used in this declaration,
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`therefore, should be viewed as being incorporated herein in their entireties.
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`VI. BACKGROUND OF THE ’862 PATENT
`A.
`Subject Matter Overview
` The’862 patent is titled “Efficient Feedback of Channel Information
`
`in a Closed Loop Beamforming Wireless Communication System,” and it is
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`generally directed to a “receiving wireless device” that performs a “method for
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`17
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`feeding back transmitter beamforming information … to a transmitting wireless
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`communication device.” EX1001 at Abstract. The ’862 patent states that “[i]n
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`order for a transmitter to properly implement beamforming (i.e., determine the
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`beamforming matrix [V]), it needs to know properties of the channel over which
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`the wireless communication is conveyed,” so “the receiver must provide feedback
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`information for the transmitter to determine the properties of the channel.” Id. at
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`3:14-19. In order to send “feedback from the receiver to the transmitter,” the
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`receiver may “determine[s] the channel response (h) and [] provides it as the
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`feedback information.” Id. at 3:19-22. However, “[a]n issue with this approach”
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`was that “the size of the feedback packet [was] so large that, during the time it
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`takes to send it to the transmitter, the response of the channel has changed.” Id. at
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`3:22-25. To try to “reduce the size of the feedback,” one conventional approach
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`was for the receiver to “decompose the channel using singular value decomposition
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`(SVD)” using the equation H=UDV* and to “send information relating only to a
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`calculated value of the transmitter’s beamforming matrix (V) as the feedback
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`information.” Id. at 3:26-33. However, feedback size was still a problem for
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`MIMO wireless communication. Id. at 3:33-35. The ’862 patent conclude that
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`“[t]herefore, a need exist[ed] … for reducing beamforming feedback information
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`for wireless communications.” Id. at 3:49-51.
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`18
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` FIG. 1 (reproduced below) shows “a communication system 10 that
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`includes a plurality of base stations and/or access points 12, 16, a plurality of
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`wireless communication devices 18-32 and a network hardware component 34.”
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`Id. at 4:24-27.
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`Id. at FIG. 1.
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` FIG. 2 (reproduced below) is a block diagram of “a wireless
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`communication device that includes the host device 18-32 and an associated radio
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`60.” Id. at 5:4-6.
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`19
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` The ’862 patent explains that the “[w]ireless communication devices
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`18-32 may be laptop computers 18 and 26, personal digital assistant hosts 20 and
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`30, personal computer 24 and 32 and/or cellular telephone 22 and 28.” Id. at 4:29-
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`34. In order to communicate with other devices, “each of the base stations or
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`access points 12-16 has an associated antenna or antenna array.” Id. at 4:52-55.
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`“Typically, base stations are used for cellular telephone systems and like-type
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`systems, while access points are used for in-home or in-building wireless networks
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`(e.g., IEEE 802.11 and versions thereof, Bluetooth, and/or any other type of radio
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`frequency based network protocol).” Id. at 4:63-67. In any case, each device
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`“includes a built-in radio and/or is coupled to a radio.” Id. at 5:67-5:3.
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` FIG. 3 (reproduced below) is a block diagram of “a wireless
`
`communication device that includes [a] host device 18-32 and an associated radio
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`60.” Id. at 7:21-27. As shown in FIG. 3, “the host device 18-32 includes a
`
`processing module 50, memory 52, radio interface 54, input interface 58 and
`
`output interface 56.” Id. at 7:28-30. According to the ’862 patent, “[t]he radio
`
`interface allows data to be received from and sent to the radio,” and “[f]or data
`
`received from the radio 60 (e.g., inbound data), the radio interface 54 provides the
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`data to the processing module 50 for further processing and/or routing to the output
`
`interface 56.” Id. at 7:36-40. The radio interface 54 then “provides data from the
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`processing module 50 to the radio 60.” Id. at 7:43-44.
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`
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`20
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`
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`Id. at FIG. 3.
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` The radio 60 “includes a host interface 62, a baseband processing
`
`module 100, memory 65, a plurality of radio frequency (RF) transmitters 106-110,
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`a transmit/receive (T/R) module 114, a plurality of antennas 81-85, a plurality of
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`RF receivers 118-120, a channel bandwidth adjust module 87, and a local
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`oscillation module 74.” Id. at 7:51-56. Using “operational instructions stored in
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`memory 65,” the baseband processing module 100 “executes digital receiver
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`functions and digital transmitter functions, respectively,” which include “but are
`
`not limited to, digital intermediate frequency to baseband conversion,
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`
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`21
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`
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`demodulation, constellation demapping, decoding, de-interleaving, fast Fourier
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`transform, cyclic prefix removal, space and time decoding, and/or descrambling.”
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`Id. at 7:56-64. Digital transmitter functions include “encoding, scrambling,
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`interleaving, constellation mapping, modulation, inverse fast Fourier transform,
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`cyclic prefix addition, space and time encoding, and digital baseband to IF
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`conversion.” Id. at 7:64-8:1. The baseband processing module is “implemented
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`using one or more processing devices,” such as “a microprocessor, micro-
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`controller, digital signal processor, microcomputer, central processing unit, field
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`programmable gate array, programmable logic device, state machine, logic
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`circuitry, analog circuitry, digital circuitry, and/or any device that manipulates
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`signals (analog and/or digital) based on operational instructions.” Id. at 8:1-9.
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` The “baseband processing module 100, based on the mode selection
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`signal 102 produces one or more outbound symbol streams 104 from the outbound
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`data 94.” Id. at 8:46-48. “Depending on the number of outbound streams 104
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`produced by the baseband module 10, a corresponding number of the RF
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`transmitters 106-110 will be enabled to up convert the output symbol streams 104
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`into outbound RF signals 112.” Id. at 8:56-59. The RF transmitters 106-110 may
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`include “a digital filter and upsampling module, a digital to analog conversion
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`module, a frequency up conversion module, a power amplifier, and a radio
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`frequency bandpass filter. Id. at 8:60-64. To transmit an RF signal, the “RF
`
`
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`22
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`
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`transmitters 106-110 provide the outbound RF signals 112 to the transmit/receive
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`module 114, which provides each outbound RF signal to a corresponding antenna
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`81-85.” Id. at 8:64-67.
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`
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`In a receive mode, “the transmit/receive module 114 receives one or
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`more inbound RF signals 116 via the antennas 81-85 and provides them to one or
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`more RF receivers 118-122.” Id. at 9:1-4. Then the RF receiver uses “settings
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`provided by the channel bandwidth adjust module 87” in order to “down convert[]
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`the inbound RF signals 116 into a corresponding number of inbound symbol
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`streams 124.” Id. at 9:4-7. Then the baseband processing module 100 “converts
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`the inbound symbol streams 124 into inbound data 92, which is provided to the
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`host device 18-32 via the host interface.” Id. at 9:9-12.
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` Figure 5 (reproduced below) is a block diagram of a “baseband
`
`receive processing 100-RX that includes a plurality of fast Fourier transform (FFT)
`
`modules 140, 142, a beamforming (U) module 144, a plurality of constellation
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`demapping modules 146, 148, a plurality of interleaving modules 150, 152, a
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`switch, a depuncture module 154, and a decoding module 156 for converting a
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`plurality of inbound symbol streams 124 into inbound data 92.” Id. at 11:60-67.
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`
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`23
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`
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`Id. at FIG. 5.
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` Figure 7 (reproduced below) is a flow chart showing a conventional
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`method 700 for providing beamforming feedback information from a receiver to a
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`transmitter. Id. at 13:25-27. The method “addresses the feed back of observed
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`transmitter beamforming information from a receiving wireless communication
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`device to a transmitting wireless communication device.” Id. at 13:27-32.
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`The ’862 patent states that the steps of Figure 7 are “typically performed by a
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`baseband processing module” of a receiving wireless device. Id. at 13:32-35.
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`
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`24
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`
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`Id. at FIG. 7 (annotated).
`
` The method starts at 702 “with the receiving wireless communication
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`device receiving a preamble sequence from the transmitting wireless device and
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`estimating a channel response from the preamble sequence,” where estimating the
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`channel response “includes comparing received training symbols of the preamble
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`to corresponding expected training symbols using any of a number of techniques
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`that are known in the art.” Id. at 13:36-44. At step 704, the “receiving wireless
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`
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`25
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`
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`device then determines an estimated transmitter beamforming unitary matrix (V)
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`based upon the channel response and a known receiver beamforming unitary
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`matrix (U).” Id. at 13:44-47. “The channel response (H), estimated transmitter
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`beamforming unitary matrix (V), and the known receiver beamforming unitary
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`matrix (U) are related by the equation H=UDV*, where, D is a diagonal matrix.
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`Singular Value Decomposition (SVD) operations may be employed to produce the
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`estimated transmitter beamforming unitary matrix (V) according to this equation.”
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`Id. at
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