UNITED STATES PATENT AND TRADEMARK OFFICE
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`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`______________
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`QUALCOMM INCORPORATED
`
`Petitioner
`
`v.
`
`REMBRANDT WIRELESS TECHNOLOGIES, LP
`
`Patent Owner
`
`
`
`CASE NO. IPR2020-00510
`
`U.S. PATENT 8,023,580
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`
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`SECOND DECLARATION OF JOHN VILLASENOR, PH.D.
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`- 1 -
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`Qualcomm Incorporated v. Rembrandt Wireless Techs. LP.
`IPR2020-00510
`Qualcomm Ex. 1066
`Page 1 of 5
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`
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`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________
`
`QUALCOMM INCORPORATED
`
`Petitioner
`
`v.
`
`REMBRANDT WIRELESS TECHNOLOGIES, LP
`
`Patent Owner
`
`
`
`CASE NO. IPR2020-00510
`
`U.S. PATENT 8,023,580
`
`
`
`
`SECOND DECLARATION OF JOHN VILLASENOR, PH.D.
`
`
`
`
`
`
`
`
`
`
`- 1 -
`
`Qualcomm Incorporated v. Rembrandt Wireless Techs. LP.
`IPR2020-00510
`Qualcomm Ex. 1066
`Page 1 of 5
`
`
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`1. My name is John Villasenor. I previously submitted a declaration in
`
`the above-captioned inter partes review (“IPR”) proceeding challenging U.S. Patent
`
`No. 8,023,580 (“the ’580 Patent”), and my background and qualifications are
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`described therein. EX1002 at 2-6. Additionally, my curriculum vitae is available in
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`EX1055.
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`2.
`
`In its Background section, the ’580 Patent states:
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`In existing data communications systems, a transmitter and receiver
`modem pair can successfully communicate only when the modems are
`compatible at the physical layer. That is, the modems must use
`compatible modulation methods. This requirement is generally true
`regardless of the network topology. For example, point-to-point, dial-
`up modems operate in either the industry standard V.34 mode or the
`industry standard V.22 mode. Similarly, in a multipoint architecture, all
`modems operate, for example, in the industry standard V.27bis mode.
`
`EX1001 at 1:27-36. This section references three “industry standard[s],” V.22,
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`V.34, and V.27bis. These references relate to recommendations promulgated by the
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`Telecommunication Standardization Sector of the International Telecommunication
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`Union (“ITU”), which can be obtained from the ITU’s website.
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`3.
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`The Patent’s reference to “industry standard V.22 mode” refers to the
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`ITU recommendation available for download from https://www.itu.int/rec/T-REC-
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`V.22-198811-I. EX1056. EX1057 appears to be a version of the V.22
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`recommendation available at the time the priority application to the ’580 Patent was
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`- 2 -
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`Page 2 of 5
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`filed, as it bears a 1993 copyright date. EX1057 at electronic page 2.
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`4.
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`The Patent’s reference to “industry standard V.34 mode” refers to the
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`ITU recommendation available for download from https://www.itu.int/rec/T-REC-
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`V.34-199409-S. EX1058. EX1059 appears to be a version of the V.34
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`recommendation available at the time the priority application to the ’580 Patent was
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`filed, as it bears a 1994 copyright date. EX1059 at i.
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`5.
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`The Patent’s reference to “industry standard V.27bis mode” refers to
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`the ITU recommendation available for download from https://www.itu.int/rec/T-
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`REC-V.27bis-198811-I. EX1060. EX1061 appears to be a version of the V.27bis
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`recommendation available at the time the priority application to the ’580 Patent was
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`filed, as it bears a 1993 copyright date. EX1061 at electronic page 2.
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`6.
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`ITU Recommendations V.22, V.27bis, and V.34 are individual portions
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`of a larger collection of ITU publications concerning “Data Communication Over
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`the Telephone Network” that is collectively referred to as “ITU V-Series
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`Recommendations.” See EX1057 at electronic page 1, EX1059 at electronic pages 1
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`and 2, EX1061 at electronic page 1.
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`7.
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`Each V-Series recommendation is not intended to stand alone, but
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`rather is to be viewed in the context of the other V-Series recommendations, where
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`each recommendation concerns a subpart of the entire V-Series. For example, the
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`portion of the V-Series recommendations that contains recommendations pertaining
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`- 3 -
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`Page 3 of 5
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`to V.22, V.27bis, and V.34 is described as concerning “Interfaces and voiceband
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`modems.” EX1059 at electronic page 2. Other portions of the V-Series specification
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`concern other aspects of data communication related to the telephone network. For
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`example,
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`the portion of
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`the V-Series designated V.100–V.199 concerns
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`“Interworking with other networks.” Id.
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`8.
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`One
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`recommendation
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`from
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`this portion of
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`the V-Series
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`recommendations is V.110, which concerns “Support by an ISDN of data terminal
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`equipments with V-series type interfaces;” V.110 is available for download from
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`https://www.itu.int/rec/T-REC-V.110-199209-S. EX1062. EX1063 appears to be a
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`version of the V.110 recommendation available at the time the priority application
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`to the ’580 Patent was filed, as it bears a copyright date of 1993. EX1063 at i.
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`9.
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`Another recommendation from the “Interworking with other networks”
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`portion of the V-Series recommendations is V.120, which concerns “Support by an
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`ISDN of data terminal equipment with V-series type interfaces with provision for
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`statistical multiplexing;” V.120
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`is
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`available
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`for
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`download
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`from
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`https://www.itu.int/rec/T-REC-V.120-199209-S. EX1064. EX1065 appears to be a
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`version of the V.120 recommendation available at the time the priority application
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`to the ’580 Patent was filed, as it bears a copyright date of 1993. EX1065 at i.
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`10.
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`I accessed each of the exhibits referenced herein online on July 22 and
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`23, 2020.
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`Page 4 of 5
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed on July 23, 2020
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`
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`John Villasenor
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`- 5 -
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`Page 5 of 5
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