UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`APPLE INC.
`Petitioner,
`
`v.
`
`OPTIS CELLULAR TECHNOLOGY, LLC
`Patent Owner.
`
`
`
`___________________
`
`Case IPR2020-00465
`Patent No. 8,102,833
`___________________
`
`DECLARATION OF PROFESSOR VIJAY MADISETTI IN SUPPORT OF
`PATENT OWNER'S PRELIMINARY RESPONSE
`
`Mail Stop "PATENT BOARD"
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
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`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`APPLE INC.
`Petitioner,
`
`v.
`
`OPTIS CELLULAR TECHNOLOGY, LLC
`Patent Owner.
`
`
`
`___________________
`
`Case IPR2020-00465
`Patent No. 8,102,833
`___________________
`
`DECLARATION OF PROFESSOR VIJAY MADISETTI IN SUPPORT OF
`PATENT OWNER'S PRELIMINARY RESPONSE
`
`Mail Stop "PATENT BOARD"
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`10845144
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`TABLE OF CONTENTS
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`Case IPR2020-00465
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`Page
`
`Introduction ................................................................................................... 1
`I.
`"Serially Multiplexing" and "Mapping" In the '833 Patent ........................ 12
`II.
`III. No "Serially Multiplexing" In Cho ............................................................. 16
`IV. Number of Ways to Arrange the Data Signals and Control Signals .......... 18
`District Court's Claim Construction ........................................................... 19
`V.
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`I.
`
`Introduction
`1.
`My name is Dr. Vijay K. Madisetti. I am a Professor of Electrical and
`
`Computer Engineering at Georgia Tech, in Atlanta, GA. I have been retained by
`
`Patent Owner in connection with this inter partes review. In particular, I have
`
`been asked to provide very targeted explanations regarding U.S. Pat. No. 8,102,833
`
`("the '833 patent") and the prior art references asserted against it, in support of the
`
`Patent Owner's Preliminary Response. If I do not specifically respond to a
`
`statement or topic in the Petition or the declarations, that does not mean I agree
`
`with it, only that because of the procedural posture at this stage of the IPR
`
`proceeding, I have not been asked to comment on them.
`
`2.
`
`My qualifications can be found in my Curriculum Vitae, which
`
`includes a complete list of my publications, and is attached as Exhibit A. Some of
`
`my background and experience that qualifies me to offer the opinions offered in
`
`this declaration set forth as an expert in the technical issues in this case are as
`
`follows.
`
`3.
`
`I received my Bachelor of Technology (Honors) in Electronics and
`
`Electrical Communication Engineering at the Indian Institute of Technology (IIT)
`
`in Kharagpur, India, in 1984. I obtained my Ph.D. in Electrical Engineering and
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`Computer Science at the University of California, Berkeley, in 1989. I received the
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`Demetri Angelakos Outstanding Graduate Student Award from the University of
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`California, Berkeley, and the IEEE/ACM Ira M. Kay Memorial Paper Prize in
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`1989.
`
`4.
`
`I now am a tenured Professor in Electrical and Computer Engineering
`
`at Georgia Tech and currently serve as its representative to ETSI/3GPP. I am
`
`knowledgeable and familiar with wireless communications, microprocessor
`
`architecture, hardware, RF, cellular networks, ASIC design, computer engineering,
`
`embedded systems, digital signal processing, and associated software and firmware
`
`design for wireless and telecommunications terminals and base stations in general
`
`and ETSI/3GPP/3GPP2 standards based cellular architecture and infrastructure in
`
`particular. I also am familiar with ETSI protocols and procedures.
`
`5.
`
`I have created and taught undergraduate and graduate courses in
`
`hardware and software design for signal processing and wireless communication
`
`circuits at Georgia Tech for the past twenty years. I also have supervised the Ph.D.
`
`dissertations of over twenty engineers in the areas of computer engineering, signal
`
`processing, communications, rapid prototyping, and system-level design
`
`methodology, of which five have resulted in thesis prizes or paper awards. I also
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`have graduated more than 20 Ph.D. students that now work as professors or in
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`technical positions around the world.
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`6.
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`Additionally, I have been active in the areas of wireless
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`communications, digital signal processing, integrated circuit design (analog and
`
`digital), software engineering, system-level design methodologies and tools, and
`
`software systems.
`
`7.
`
`I have been the principal investigator ("PI") or co-PI in several active
`
`research programs in these areas, including DARPA's Rapid Prototyping of
`
`Application Specific Signal Processors, the State of Georgia's Yamacraw Initiative,
`
`the United States Army's Federated Sensors Laboratory Program, and the United
`
`States Air Force Electronics Parts Obsolescence Initiative. I have received an IBM
`
`Faculty Award and NSF's Research Initiation Award.
`
`8.
`
`I have designed several specialized computer and communication
`
`systems over the past two decades at Georgia Tech for tasks such as wireless audio
`
`and video processing and protocol processing for portable platforms, such as cell
`
`phones and PDAs. I have worked on designing systems that are efficient from
`
`performance, size, weight, area, and thermal considerations.
`
`9.
`
`I have developed courses and classes for the industry on these topics,
`
`and many of my lectures in advanced computer system design, developed under
`
`the sponsorship of the United States Department of Defense in the late 1990s, are
`
`available for educational use at http://www.eda.org/rassp and have been used by
`
`several U.S. and international universities as part of their course work.
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`10.
`
`I have been working in the area of wireless communications and
`
`signal processing, since the early 1980s. Some of my recent publications in the
`
`area of design of wireless communications systems and associated protocols are
`
`listed in Exhibit A.
`
`11.
`
`In the 1980s, I designed and prototyped a very low RF frequency
`
`(VLF) receiver for submarine communications utilizing MSK (Minimum Shift
`
`Key) modulation/demodulation techniques in hardware.
`
`12.
`
`In the early 2000‐2001 timeframe, I designed three GSM multiband
`
`mobile phones for a leading telecom equipment manufacturer in Asia.
`
`13.
`
`In the 2002-2007 timeframe, I developed wireless baseband and
`
`protocol stack software and assembly code for a leading telecommunications
`
`handset vendor that focused on efficient realization of speech codecs and echo‐
`
`cancellation and for another in the optimization of their 3G software stack. My
`
`work in this regard included creation of software code, and analysis and revision of
`
`existing software code.
`
`14.
`
`I have been an active consultant to industry and various research
`
`laboratories (including Massachusetts Institute of Technology Lincoln Labs and
`
`Johns Hopkins University Applied Physics Laboratory). My consulting work for
`
`MIT Lincoln Labs involved high resolution imaging for defense applications,
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`where I worked in the area of prototyping complex and specialized computing
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`systems. My consulting work for the Johns Hopkins Applied Physics Lab ("APL")
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`mainly involved localization of objects in image fields, where I worked on
`
`identifying targets in video and other sensor fields and identifying computer
`
`architectures and circuits for power and space‐efficient designs.
`
`15.
`
`I have founded three companies in the areas of embedded software,
`
`military chipsets involving imaging technology, and wireless communications. The
`
`first of the companies I founded, VP Technologies, offers products in the area of
`
`semiconductor integrated circuits, including building computing systems for
`
`imaging systems for avionics electronics for the United States Air Force and the
`
`United States Navy, since 1995. I remain a director of VP Technologies. The
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`second of these companies, Soft Networks, LLC, offers software for multimedia
`
`and wireless computing platforms, including the development of a set-top box for
`
`Intel that decodes MPEG‐2 video streams, wireless protocol stacks, and imaging
`
`codecs for multimedia phones. The technology involved with the design,
`
`development, and implementation of the set-top box included parsing the bit
`
`streams, decoding communications protocols, extracting image and video data, and
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`then processing for subsequent display or storage. The third of these companies,
`
`Elastic Video, uses region of interest based video encoding or decoding for
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`capturing high quality video at very low bit rates, with primary application for
`
`wireless video systems.
`
`16.
`
`I have authored more than sixty refereed journal publications and
`
`around forty peer reviewed conference publications. I have been active in research
`
`in the area of wireless and mobile communications and some of my recent peer‐
`
`reviewed publications in this area include: (i) Mustafa Turkboylari & Vijay K.
`
`Madisetti, Effect of Handoff Delay on the System Performance of TDMA Cellular
`
`Systems, Proceedings of the Fourth IEEE Conference on Mobile and Wireless
`
`Communications Network 411-15 (Sept. 9-11, 2002); (ii) Loran A. Jatunov &
`
`Vijay K. Madisetti, Computationally‐Efficient SNR Estimation for Bandlimited
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`Wideband CDMA Systems, 5 IEEE Transactions on Wireless Communications,
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`no. 12 (2006) at 3480-91; and (iii) Nimish Radio, Ying Zhang, Mallik Tatipamula
`
`& Vijay K. Madisetti, Next Generation Applications on Cellular Networks: Trends,
`
`Challenges, and Solutions, 100 Proceedings of the IEEE, no. 4 (April 2012) at 841-
`
`54.
`
`17.
`
`I have extensive experience analyzing, designing, and testing systems
`
`based on 3GPP Technical Specifications, including specifications describing
`
`WCDMA and HSDPA technologies. I have been active in the area of location‐
`
`based services and wireless localization techniques since the mid-1990s, and have
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`authored several papers on location-based services, including, Vijay K. Madisetti
`
`et al., Mobile Fleet Application Using SOAP and System on Devices (SyD)
`
`Middleware Technologies, Communications, Internet, and Information Technology
`
`(2002) at 426‐31. I have served as associate editor or on the editorial board for
`
`technical journals, including IEEE Transactions on Circuits & Systems II,
`
`International Journal in Computer Simulation, and International Journal in VLSI
`
`Signal Processing.
`
`18.
`
`I have authored or co‐authored several books, including VLSI
`
`Digital Signal Processors (IEEE Press 1995) and the Digital Signal Processing
`
`Handbook (CRC Press, 1998, 2010). I co-authored Quick‐Turnaround ASIC
`
`Design in VHDL (Kluwer Academic Press 1996) and Platform‐Centric Approach
`
`to System‐on‐Chip (SoC) Design (Springer 2004). I am also the editor of
`
`several books, including the three-volume DSP Handbook set: Volume 1: Digital
`
`Signal Processing Fundamentals, Volume 2: Video, Speech, and Audio Signal
`
`Processing and Associated Standards, and Volume 3: Wireless, Networking,
`
`Radar, Sensory Array Processing, and Nonlinear Signal Processing, published in
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`2010 by CRC Press, Boca Raton, Florida. More recently I have authored Cloud
`
`Computing (2014, CreateSpace Press), and Internet of Things (2014, CreateSpace),
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`and the book, Cloud Computing, was nominated as a Notable Book of 2014 by the
`
`Association of Computing Machinery (ACM) in July 2015.
`
`19.
`
`I have been elected a Fellow of the IEEE, for contributions to
`
`embedded computing systems. The Fellow is the highest grade of membership of
`
`the IEEE, a world professional body consisting of over 300,000 electrical and
`
`electronics engineers, with only one-tenth of one percent (0.1%) of the IEEE
`
`membership being elected to the Fellow grade each year. Election to Fellow is
`
`based upon votes cast by existing Fellows in IEEE. I have also been awarded the
`
`2006 Frederick Emmons Terman Medal by the American Society of Engineering
`
`Education for contributions to Electrical Engineering, including authoring a widely
`
`used textbook in the design of VLSI digital signal processors. I was awarded
`
`VHDL International Best Ph.D. Dissertation Advisor Award in 1997 and the NSF
`
`RI Award in 1990. I was Technical Program Chair for both the IEEE MASCOTS
`
`in 1994 and the IEEE Workshop on Parallel and Distributed Simulation in 1990.
`
`In 1989, I was recognized with the Ira Kay IEEE/ACM Best Paper Award for Best
`
`Paper presented at the IEEE Annual Simulation Symposium.
`
`20.
`
`I have submitted approximately 40 invention disclosures and
`
`provisional patents over the past ten years. I am listed as the inventor on 15 or so
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`allowed or issued U.S. Patents.
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`I am generally familiar with issues involving patents and with
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`21.
`
`determining the meaning of patent claim terms from the perspective of a "person of
`
`ordinary skill in the art" ("POSITA") at the time the invention was made.
`
`22.
`
`I have completed reports, depositions, and provided testimony
`
`regarding communications systems in more than 20 proceedings over the past six
`
`years. About half of the proceedings in which I have testified were in the area of
`
`2G/3G/4G/MIMO wireless receiver design, including hardware and software
`
`features of base stations and/or mobile devices.
`
`23.
`
`I also have followed, tested compliance requirements, participated in,
`
`and contributed to activities of Standards Setting Organizations ("SSOs") such as
`
`the IEEE, IETF, ETSI, TIA, and others, as part of my work as a teacher and
`
`researcher in advanced telecom, wireless and computer technologies since the
`
`1990s. I have been extensively involved in the activities of one of the premier
`
`SSOs in the world, the IEEE, since the 1980s, and I have participated in the
`
`development of standards for hardware design and description languages, such as
`
`VHDL, used in design of computer chips –IEEE 1076.6. This standard is now
`
`used worldwide in design of advanced computer chips and associated design
`
`automation tools for VLSI. I have also taught courses and authored papers and
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`books on how to comply with these standards in terms of writing code for design
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`of chipsets.
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`24.
`
`The Internet Engineering Task Force (IETF)
`
`(https://www.ietf.org/how/wgs/) is the premier SSO in the area of computer
`
`networks and associated technologies, and creates a number of working groups
`
`(WG) that focus on specific deliverables (guidelines, standards specifications, etc.)
`
`and focus on creating and improving existing network protocols. I have
`
`contributed draft proposals for such improvement to standardized protocols over
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`the past several years that include contributed to mobile wireless, stream-controlled
`
`transport protocols, networking, encryption and voice/video transmission.
`
`25.
`
`I have developed speech and video codecs that comply with 3GPP
`
`standards, such as a Wideband AMR and the AMR. These tasks involved
`
`developing software to implement the associated 3GPP standards and also tests to
`
`verify compliance to these standards. The families of these 3GPP standards
`
`include TS 26.071 – TS 26.204, covering over a hundred standard specification
`
`documents. The software that I developed that complies with these standards is
`
`now available commercial on millions of 3G and 4G handsets worldwide. My
`
`codecs were tested on live 3G and 4G networks in Europe and USA since the early
`
`2004 – 2006 timeframe.
`
`26.
`
`I have also developed several speech and VOIP codecs that conform
`
`with the ITU (International Telecommunications Union) standards G.723.1, G.729
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`and Echo Cancellers conforming with the ITU G.168 standards (see
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`https://www.itu.int/rec/T-REC-G.723/en).
`
`27. The software and code I have developed and tested based on
`
`technologies essential to the ITU standards are now used by one of the leading
`
`suppliers of VOIP/Internet telephones in the world. This software is also part of
`
`commercially released soft switches for internet telephony used extensively in
`
`Asia. See for example URL
`
`https://www.thehindubusinessline.com/bline/2002/04/09/stories/200204090066070
`
`0.htm.
`
`28. As part of earlier litigation-related consulting work, I tested
`
`compliance of several smartphones (3G and 4G) in their use of standards-essential
`
`patents (SEP) related to 3GPP and 3GPP2 standards, primarily in the area HARQ
`
`and encryption. This work involved use of commercial 3GPP test equipment that
`
`included base stations and UEs to evaluate compliance to the standard and further
`
`opine on the issue of alternatives.
`
`29. Further, as stated above, I serve as the official representative of
`
`Georgia Tech to ETSI. In that role, I manage Georgia Tech's relationship with
`
`ETSI and am responsible for representing Georgia Tech's interests as they relate to
`
`ETSI, including to choose technical areas to which Georgia Tech may contribute,
`
`to determine which meetings to attend, and participating in technical work related
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`to various technologies, including those in the area of 5G, 4G, and IoT. In
`
`addition, as noted, prior to assuming this role, in the past twenty years I have been
`
`retained to test various commercial mobile and wireless products to determine if
`
`they comply with various ETSI, 3GPP, and TIA (including 3GPP2) standards.
`
`II.
`
`"Serially Multiplexing" and "Mapping" In the '833 Patent
`
`30. Claim 1, steps (a) and (b) of the '833 patent recite:
`
`(a) serially multiplexing first control signals and data signals in a
`mobile station, wherein the first control signals are placed at a front
`part of the multiplexed signals and the data signals are placed at a rear
`part of the multiplexed signals;
`
`(b) mapping the multiplexed signals to a 2-dimensional resource
`matrix comprising a plurality of columns and a plurality of rows,
`wherein the columns and the rows of the 2-dimensional resource
`matrix correspond to single carrier frequency divisional multiple
`access (SC-FDMA) symbols and subcarriers for each SC-FDMA
`symbol, respectively, wherein a number of columns of the 2-
`dimensional resource matrix corresponds to a number of SC-FDMA
`symbols within one subframe except specific SC-FDMA symbols
`used for a reference signal, and wherein the multiplexed signals are
`mapped from the first column of the first row to the last column of the
`first row, the first column of the second row to the last column of the
`second row, and so on, until all the multiplexed signals are mapped to
`the 2-dimensional resource matrix. Ex. 1001, 9:6-21
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`31.
`
`The '833 patent refers to the above as “serially multiplexing” and
`
`"mapping." The '833 patent explains that "time-first mapping" refers to mapping
`
`information sequence to be transmitted in the uplink one by one based on the SC-
`
`FDMA symbols, which are arranged along the time-axis. Ex. 1001, 5:49-51. That
`
`is, the information sequenced to be transmitted are mapped or represented as
`
`shown below in Figure 6. The '833 patent explains that "[t]his is called time-first
`
`mapping because the SC-FDMA symbols are segmented temporarily." Id., 5:51-
`
`52.
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`32.
`
`The reason why the SC-FDMA symbols are segmented temporally is
`
`because SC-FDMA symbols are arranged along the time axis.
`
`33. Here, I would like to note one potential misunderstanding by the
`
`Petitioner in their understanding of the claim requirement (although this
`
`disagreement probably would not affect the analysis of the asserted art). That is,
`
`the claim construction (Pet. 24) does not require either filling the memory with the
`
`information sequence of the multiplexed signals or "filling" the 2-dimensional
`
`matrix with all the signals to transmitted before the signals are transmitted column
`
`(SC-FDMA symbol) by column. In other words, the claim just requires a virtual
`
`mapping of the control information, data information and ACK/NACK to the 2-
`
`dimensional matrix so that when the control information and data information
`
`becomes available, they each occupy its "pre-assigned" position in the matrix and
`
`gets transmitted together with other signals in the same SC-FDMA column at a
`
`time associated with the SC-FDMA symbol (SC-FDMA symbols are arranged
`
`along the time axis).
`
`34.
`
`The "mapping" is similar to seat assignment "representation" to
`
`passengers on a commercial air flight, where the business class passengers are
`
`mapped to particular seats in the front of the plane while economy class passengers
`
`are seated in particular seats at the back. But there is no requirement that the
`
`passengers board row by row from the front of the plane, waiting for each row to
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`be filled before the next row is initiated. Indeed, at the time of the invention, in
`
`LTE or any wireless standard, it was unheard of, and impractical, to require all SC-
`
`FDMA symbols (i.e., 14 SC-FDMA symbols corresponding to 14 TTIs within a 1
`
`ms time slot in LTE) to be stored in a matrix-oriented memory first, before a
`
`particular SC-FDMA symbol is transmitted. The approach suggested by the
`
`petitioner as required by the asserted claims is thus unacceptable from a throughput
`
`and latency viewpoint. The district court in a previous case recognized this.
`
`Ex. 2006 at 17-36 (this Markman order sets forth the reasoning for the agreed-to
`
`construction that Petitioner cites but apparently misinterprets in its Petition).
`
`35.
`
`In that respect, the '833 patent's use of "temporal" or "temporally"
`
`does not refer to the fact that the matrix must be filled out (in memory or
`
`otherwise) before transmission. For example, the specification states, "[t]he
`
`information sequence to be transmitted to the uplink can be arranged temporally in
`
`the time-frequency mapper . . . ." Ex. 1001, 5:60-63. This means the sequence is
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`to be arranged by the SC-FDMA symbols that are arranged along the time axis. To
`
`be mapped temporally just means to be mapped along the SC-FDMA symbols'
`
`time axis. It does not require pre-filling of the 2-dimensional resource matrix
`
`before transmission as Petitioner seems to imply with its description that the matrix
`
`is filled row by row.
`
`III. No "Serially Multiplexing" In Cho
`
`36. As construed by the court, there is no disclosure of "serially
`
`multiplexing first control signals and data signals" in Cho.
`
`37.
`
`In Cho, it is said that "the control information 602 is multiplexed with
`
`the data in each symbol block period 604 and is transmitted after being distributed
`
`to the multiple symbol block periods in the TTI 600." Ex. 1005, [0062]. Because
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`control and data are multiplexed to each symbol block period, a POSITA reading
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`Cho would not have understood it as disclosing "serially multiplexing" as
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`construed by the Court. In this mapping method, the information sequence to be
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`transmitted is virtually mapped (or represented, without requiring any physical
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`movement) from the first row of the first column to the last row of the first column,
`
`the first row of the second column to the last row of the second column, and so on,
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`until all the multiplexed signals are mapped to the 2-dimensional resource matrix.
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`10845144
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`Case IPR2020-00465
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`38. Assuming that in each symbol block time, there is only 1 control
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`information 602 and N number of data information 601, multiplexing control and
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`data signals in Cho according to the Petitioner’s expert would disclose the
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`following:
`
`39. As is shown above, the claim limitation of "serially multiplexing" as
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`construed by the court requires "first control signals and data signals are mapped
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`with a sequence in which one is directly after the other, wherein the first control
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`signals are placed at a front part of the multiplexed signals and the data signals are
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`placed at rear part of the multiplexed signals." Ex. 2005 at 58. In Cho, however,
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`as described by Dr. Wells, the control bits and the data bits in the information
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`sequence are interleaved. That is, in Cho's information sequence to be transmitted
`
`as described by Dr. Wells, the control signals and the data bits are not placed in a
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`way that one is directly after the other, with the control signals placed at a front
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`10845144
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`Optis Cellular Ex 2001-p. 19
`Apple v Optis Cellular
`IPR2020-00465
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`part of the multiplexed signals and the data signals placed at a rear part of the
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`Case IPR2020-00465
`Patent No. 8,102,833
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`multiplexed signals. To one of ordinary skill in the art, the disclosure of Cho,
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`utilizing the row-filling/column-filling interpretation (which I do not agree with) of
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`Petitioner and its expert, would not disclose or render obvious the step of "serially
`
`multiplexing."
`
`
`IV. Number of Ways to Arrange the Data Signals and Control Signals
`
`40.
`
`I have been asked to explain how many ways there are to arrange N
`
`bits of control signals and M bits of data signals if no constraint such as those
`
`placed by the '833 patent is imposed. This is a classical combinatorial problem
`
`whose answer is NCN+M. For example, if there are 2 control symbols and 4 data
`
`symbols, the number of possible combination is 2C6 or 6×5÷(1×2) = 15.
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`C
`
`C
`
`C
`
`C
`
`C
`
`D
`
`C
`
`D
`
`D
`
`D
`
`D
`
`C
`
`D
`
`C
`
`D
`
`D
`
`D
`
`C
`
`D
`
`D
`
`C
`
`D
`
`C
`
`D
`
`D
`
`D
`
`D
`
`C
`
`D
`
`D
`
`D
`
`C
`
`D
`
`D
`
`C
`
`D
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`10845144
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`Optis Cellular Ex 2001-p. 20
`Apple v Optis Cellular
`IPR2020-00465
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`Case IPR2020-00465
`Patent No. 8,102,833
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`7
`
`8
`
`9
`
`D
`
`D
`
`D
`
`10 D
`
`11 D
`
`12 D
`
`13 D
`
`14 D
`
`15 D
`
`C
`
`C
`
`C
`
`D
`
`D
`
`D
`
`D
`
`D
`
`D
`
`D
`
`D
`
`D
`
`C
`
`C
`
`C
`
`D
`
`D
`
`D
`
`C
`
`D
`
`D
`
`C
`
`D
`
`D
`
`C
`
`C
`
`D
`
`D
`
`C
`
`D
`
`D
`
`C
`
`D
`
`C
`
`D
`
`C
`
`D
`
`D
`
`C
`
`D
`
`D
`
`C
`
`D
`
`C
`
`C
`
`41.
`
`For a resource block with 12 SC-FDMA symbols (14 if including the
`
`reference symbol columns) and 7 subcarriers, there are 12×7=84 signals.
`
`Assuming 15 control signals and 69 data signals, that would yield 15C84 or
`
`1.48×1016 ways of arranging the control and data signals in the multiplexed
`
`sequence. That is a large number of options.
`
`V.
`
`District Court's Claim Construction
`
`42.
`
`In the parallel district court action, the Court has construed the
`
`following terms. Ex. 2005 at 57-58.
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`IPR2020-00465
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`
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`43. Finally, I do not offer opinions about other claim limitations that are
`
`not discussed in this declaration, and this should not be construed as an admission
`
`that these are present, disclosed or rendered obvious by any of the cited prior art.
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`Optis Cellular Ex 2001-p. 22
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`I declare under the penalty of perjury that all statements made herein of my
`
`own knowledge are true and that all statements made on information and belief are
`
`believed to be true; and further that these statements were made with the
`
`knowledge that willful false statements and the like so made are punishable by fine
`
`or imprisonment, or both, under Section 1001 of Title 18 of the United States
`
`Code.
`
`______________________
`Vijay Madisetti, Ph.D.
`Date: June 18, 202
`
`10845144
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`Professor Vijay K. Madisetti, ECE
`
`Dr. Vijay K. Madisetti
`Fellow, IEEE
`vkm@madisetti.com
`Cell: 770-527-0177
`Address:
`56 Creekside Park Drive
`Johns Creek, GA 30022
`
`Employment:
`
`· 1984-1989: Post Graduate Researcher (UC Berkeley),
`· 1989-present: Full Professor of Electrical & Computer
`Engineering (Georgia Tech, Atlanta, GA 30332).
`
`Areas of Technical Interest – Wireless & Mobile Communications,
`Computer Engineering, Circuit Design (Analog/Digital), Software
`Engineering, Digital Signal Processing, Wireline & Wireless Computer
`Networks, Software Systems, Control Systems, Cloud Computing.
`
`Education: PhD (EECS, University of California at Berkeley, 1989), B.Tech
`(Hons) in Electronics and Electrical Communications Engineering (Indian
`Institute of Technology, Kharagpur, 1984).
`
`Startup Companies:
`
`Director, VP Technologies, Inc. (1995- ): A startup commercialized
`through Georgia Tech’s Advanced Technology Development Corporation
`(ATDC) focusing on digital software and hardware design services for military
`market. http://www.vptinc.net
`
`Director, Soft Networks, LLC (2001-2007): A startup commercialized
`through Georgia Tech support focusing on software development tools and
`compilers for Cellular/WiFi/VOIP/telecommunication products.
`http://www.soft-networks.com
`
`Director, Elastic Video Inc. (2007- 2009): A startup commercialized
`through Georgia Tech’s VentureLab (http://venturelab.gatech.edu)
`development image and video processing software for wireless & IP
`networking.
`
`1
`
`Optis Cellular Ex 2001-p. 24
`Apple v Optis Cellular
`IPR2020-00465
`
`
`
`Professor Vijay K. Madisetti, ECE
`
`Litigation Experience (2015-2019) With Testimony
`(Note: There may be multiple cases between the parties, e.g., District Court v. ITC, US versus
`Foreign Cases)
`
`Chrimar v. Adtran, Alcatel, et al.
`Technology: Power over Ethernet (2015-2017)
`Submitted reports & Deposition & Trial
`
`Chamberlain v. Ryobi/TTI
`Case No: 1:16-cv-06097 (ND Illinois)
`Expert for Ryobi
`Technology: Wireless/IoT/Barrier Movement (2016 – 2019)
`Submitted reports & deposition & trial testimony
`
`IOEngine v. IMC/Imation
`Case No: cv-14-1572-GMS (US Delaware)
`Expert for IMC/Imation
`Technology: Networked Storage Device (2016-2017)
`Submitted reports & deposition & trial testimony
`
`Huawei v. Samsung
`Case No: 3:16-cv-2787-WHO (ND Cal)
`Expert for Samsung
`Technology: 4G/LTE Random Access Protocols (2016-2019)
`Submitted reports & deposition
`
`Hitachi Maxell v. ZTE/Huawei
`Case No: 5:16-cv-00178-RWS (ED Texas)
`Expert for Hitachi Maxell
`Technology: Digital Cameras
`Submitted reports & deposition (2017 – 2018)
`
`Hitachi Maxell v. Apple
`Case No: 5:19-cv-00036-RWS
`Expert for Hitachi Maxell
`Technology: Digital Cameras
`Submitted Expert Reports (2020-)
`
`Qualcomm v. Apple
`Case No: 17-ccv-0108-GPC-MDD (SD Cal) Also, Related ITC/FTC Matters
`Expert for Qualcomm
`Technology: 4G/Wireless Communications/Smartphones (2017-2019)
`Submitted Reports and Deposition
`
`2
`
`Optis Cellular Ex 2001-p. 25
`Apple v Optis Cellular
`IPR2020-00465
`
`
`
`Professor Vijay K. Madisetti, ECE
`
`Qualcomm v. Apple
`Case No: 3:17-cv-01375-DMS-MDD (SD Cal)
`Expert for Qualcomm
`Technology: 4G/Wireless Communications/Smartphones (2017-2019)
`Submitted Reports and Deposition
`
`Optis v. Huawei
`Case No: 2:17-cv-123 (E.D. Texas)
`Expert for Optis Wireless
`Technology: 4G/Video (2017-2019)
`Submitted reports & deposition
`
`Beckman Coulter v. Sysmex
`Case No: 1:17-cv-24049-DPG (ND Illinois)
`Expert for Sysmex
`Technology: Medical Instrumentation Automation (2017-present)
`Testifying Expert
`
`TQ De
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