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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`SAMSUNG ELECTRONICS CO., LTD.
`Petitioner
`
`v.
`
`BELL NORTHERN RESEARCH, LLC
`Patent Owner
`
`____________________
`
`Patent No. 8,416,862
`____________________
`
`DECLARATION OF DR. LEONARD J. CIMINI
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 8,416,862
`
`
`
`
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`Page 1 of 224
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`SAMSUNG EXHIBIT 1002
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`

`

`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`V.
`
`
`TABLE OF CONTENTS
`
`I.
`INTRODUCTION .......................................................................................... 1
`BACKGROUND AND QUALIFICATIONS ................................................ 2
`II.
`III. MATERIALS REVIEWED ........................................................................... 6
`IV. PERSON OF ORDINARY SKILL IN THE ART AND THE TIME OF
`THE ALLEGED INVENTION .................................................................... 10
`TECHNICAL BACKGROUND .................................................................. 12
`A. Multiple
`Input Multiple Output
`(MIMO) Wireless
`Communications ................................................................................. 12
`B. Matrices .............................................................................................. 29
`C.
`Channel Estimation and Beamforming, and Singular Value
`Decomposition (SVD) ........................................................................ 36
`D. Givens Decomposition ....................................................................... 43
`VI. THE ’862 PATENT ...................................................................................... 51
`A. Description ......................................................................................... 51
`B.
`The ’451 Provisional and ’793 Application ....................................... 57
`VII. CLAIM CONSTRUCTION ......................................................................... 59
`VIII. OVERVIEW OF THE PRIOR ART ............................................................ 60
`A.
`Roh ...................................................................................................... 60
`B. Maltsev ............................................................................................... 67
`C.
`Haykin................................................................................................. 75
`D.
`Yang .................................................................................................... 82
`E.
`Lin ....................................................................................................... 84
`IX. THE PRIOR ART DISCLOSES OR SUGGESTS ALL RECITED
`FEATURES OF CLAIMS 9-12 OF THE ’862 PATENT ............................ 93
`
`
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`i
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
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`
`A.
`
`
`
`
`
`
`
`c)
`d)
`
`Roh, Maltsev, and Haykin Disclose or Suggest the Features of
`Claims 9, 11, and 12 ........................................................................... 93
`1.
`Claim 9 .................................................................................... 93
`a)
`9[a] A wireless
`communication
`device
`comprising: ................................................................... 93
`9[b] a plurality of Radio Frequency (RF)
`components operable to receive an RF signal and
`to convert the RF signal to a baseband signal;
`and ................................................................................. 96
`9[c] a baseband processing module operable to: .... 106
`9[d] receive a preamble sequence carried by the
`baseband signal; ......................................................... 113
`9[e] estimate a channel response based upon the
`preamble sequence; ................................................... 124
`9[f] determine an
`estimated
`transmitter
`beamforming unitary matrix (V) based upon the
`channel response and a receiver beamforming
`unitary matrix (U); .................................................... 132
`9[g] decompose
`the estimated
`transmitter
`beamforming unitary matrix (V) to produce the
`transmitter beamforming information; and ........... 138
`9[h] form a baseband signal employed by the
`plurality of RF components to wirelessly send
`the transmitter beamforming information to the
`transmitting wireless device. ..................................... 143
`ii
`
`
`b)
`
`e)
`
`f)
`
`g)
`
`h)
`
`Page 3 of 224
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`2.
`
`
`
`Claim 11 ................................................................................ 148
`a)
`“The wireless communication device of claim 9,
`wherein the channel response (H), estimated
`transmitter beamforming unitary matrix (V),
`and the receiver beamforming unitary matrix
`(U) are related by the equation: H=UDV* where,
`D is a diagonal matrix.” ............................................ 148
`Claim 12 ................................................................................ 153
`a)
`“The wireless communication device of claim 9,
`wherein
`in
`determining
`the
`estimated
`transmitter beamforming unitary matrix (V)
`based upon the channel response and the
`receiver beamforming unitary matrix (U), the
`baseband processing module performs Singular
`Value Decomposition (SVD) operations.” ............... 153
`Roh, Maltsev, Haykin, and Yang Disclose or Suggest the Features
`of Claim 10 ....................................................................................... 155
`1.
`Claim 10 ................................................................................ 155
`
`3.
`
`B.
`
`
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`
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`iii
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`a)
`
`
`
`C.
`
`“The wireless communication device of claim 9,
`wherein in determining an estimated transmitter
`beamforming unitary matrix (V) based upon the
`channel response and a receiver beamforming
`unitary matrix (U), the baseband processing
`module is operable to: produce the estimated
`transmitter beamforming unitary matrix (V) in
`Cartesian
`coordinates; and
`convert
`the
`estimated transmitter beamforming unitary
`matrix (V) to polar coordinates.” ............................. 155
`Lin, Haykin, and Maltsev Disclose or Suggest the Features of
`Claims 9, 11, and 12 ......................................................................... 160
`1.
`Claim 9 .................................................................................. 160
`a)
`9[a] A wireless
`communication
`device
`comprising: ................................................................. 160
`9[b] a plurality of Radio Frequency (RF)
`components operable to receive an RF signal and
`to convert the RF signal to a baseband signal;
`and ............................................................................... 163
`9[c] a baseband processing module operable to: .... 173
`9[d] receive a preamble sequence carried by the
`baseband signal; ......................................................... 179
`9[e] estimate a channel response based upon the
`preamble sequence; ................................................... 187
`
`b)
`
`c)
`d)
`
`e)
`
`
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`f)
`
`
`
`transmitter
`estimated
`9[f] determine an
`beamforming unitary matrix (V) based upon the
`channel response and a receiver beamforming
`unitary matrix (U); .................................................... 195
`9[g] decompose
`the estimated
`transmitter
`beamforming unitary matrix (V) to produce the
`transmitter beamforming information; and ........... 200
`9[h] form a baseband signal employed by the
`plurality of RF components to wirelessly send
`the transmitter beamforming information to the
`transmitting wireless device. ..................................... 204
`Claim 11 ................................................................................ 209
`a)
`“The wireless communication device of claim 9,
`wherein the channel response (H), estimated
`transmitter beamforming unitary matrix (V),
`and the receiver beamforming unitary matrix
`(U) are related by the equation: H=UDV* where,
`D is a diagonal matrix.” ............................................ 209
`Claim 12 ................................................................................ 210
`
`g)
`
`h)
`
`2.
`
`3.
`
`
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`
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`v
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`

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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`a)
`
`
`
`D.
`
`“The wireless communication device of claim 9,
`wherein
`in
`determining
`the
`estimated
`transmitter beamforming unitary matrix (V)
`based upon the channel response and the
`receiver beamforming unitary matrix (U), the
`baseband processing module performs Singular
`Value Decomposition (SVD) operations.” ............... 210
`Lin, Haykin, Maltsev, and Yang Disclose or Suggest the Features
`of Claim 10 ....................................................................................... 212
`1.
`Claim 10 ................................................................................ 212
`a)
`“The wireless communication device of claim 9,
`wherein in determining an estimated transmitter
`beamforming unitary matrix (V) based upon the
`channel response and a receiver beamforming
`unitary matrix (U), the baseband processing
`module is operable to: produce the estimated
`transmitter beamforming unitary matrix (V) in
`Cartesian
`coordinates; and
`convert
`the
`estimated transmitter beamforming unitary
`matrix (V) to polar coordinates.” ............................. 212
`CONCLUSION ........................................................................................... 217
`
`X.
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`vi
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`I, Leonard J. Cimini, declare as follows:
`
`
`
`I.
`
`INTRODUCTION
`I have been retained by Samsung Electronics Co., Ltd. (“Petitioner”) as
`1.
`
`an independent expert consultant in this proceeding before the United States Patent
`
`and Trademark Office (“PTO”) regarding U.S. Patent No. 8,416,862 (“the ’862
`
`patent”) (Ex. 1001).1 I have been asked to consider whether certain references
`
`disclose or suggest the features recited in claims 9-12 (“the challenged claims”) of
`
`the ’862 patent. My opinions are set forth below.
`
`2.
`
`I am being compensated at a rate of $650/hour for my work in this
`
`proceeding. My compensation is in no way contingent on the nature of my findings,
`
`the presentation of my findings in testimony, or the outcome of this or any other
`
`proceeding. I have no other interest in this proceeding.
`
`
`
`
`
`
`1 Where appropriate, I refer to exhibits that I understand are to be attached to the
`
`petition for Inter Partes Review of the ’862 patent.
`
`
`
`
`
`1
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`II. BACKGROUND AND QUALIFICATIONS
`I presently serve as a Professor at the University of Delaware. I have
`3.
`
`
`
`almost 40 years of academic and industry experience in wireless technologies and
`
`standards, various communications technologies, networking, orthogonal frequency
`
`division multiplexing (OFDM), and physical and media access control (MAC) layer
`
`technology. Over my career, among other activities, I have worked with companies
`
`(including Fortune 500 companies)
`
`to enable
`
`the high-date-rate wireless
`
`communications systems and networks that we have today. I have published over
`
`75 journal articles and over 120 conference papers. I also am a named inventor on
`
`29 patents.
`
`4. My academic background in electrical engineering provides a technical
`
`foundation for work in high-speed transmission of data in telecommunications
`
`systems. I received a Bachelor of Science degree in Electrical Engineering from the
`
`University of Pennsylvania in 1978. A year later, I received a Master of Science
`
`degree in Electrical Engineering from the University of Pennsylvania. In 1982, I
`
`received the Doctor of Philosophy (Ph.D.) degree in Electrical Engineering, also
`
`from the University of Pennsylvania.
`
`5.
`
`After receiving my Ph.D. in 1982, I began working for AT&T Bell
`
`Laboratories, in West Long Branch, as a Member of Technical Staff. I continued to
`
`
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`2
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`work at this branch of AT&T Bell Laboratories until 1985. In my role as a Member
`
`of Technical Staff, I proposed and analyzed speech privacy techniques for cellular
`
`mobile radio systems. I further designed and demonstrated 10- and 18-GHz
`
`hardware for a personal communication system. I also proposed and analyzed the
`
`use of orthogonal frequency-division multiplexing (“OFDM”) in mobile radio
`
`systems. My proposal at that time was the first application of OFDM to wireless
`
`systems. This has become the basis for much of the current, widespread use of
`
`OFDM today.
`
`6.
`
`After that, I continued to work as a Member of Technical Staff at AT&T
`
`Bell Laboratories, but at a different branch. I held this position from 1985 to 1996.
`
`During this time, I invented and analyzed new algorithms for dynamic channel
`
`selection in wireless-communication systems, among other things. I also proposed
`
`and analyzed the use of multicarrier techniques to overcome the limitations to high-
`
`bit-rate wireless transmission caused by multipath. Further, I invented, analyzed,
`
`designed, and built a 20-Mbps packet-based wireless modem using clustered OFDM.
`
`During this phase of my career, I also devised techniques for providing reliable
`
`transmission for both light-wave (i.e., fiber), and wireless communications systems,
`
`through novel applications of error-correcting codes including Reed Solomon codes.
`
`
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`3
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`From 1996 to 2002, I was a Technology Consultant for AT&T
`
`7.
`
`Laboratories Research. During this time, I studied the effect of channel mismatch
`
`on adaptive modulation for OFDM for wireless applications. I also invented and
`
`analyzed techniques for robust channel estimation and peak power reduction in
`
`OFDM. Further, I invented and analyzed solutions to both the physical layer and
`
`MAC layer challenges for providing high-bit-rate packet data to wide-area cellular
`
`users, using OFDM.
`
`8.
`
`Since 2002, I have been a Professor at the University of Delaware. I
`
`teach undergraduate courses in linear systems, probability, and communications. I
`
`have also taught graduate courses in digital and wireless communications, and I
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`research topics such as multiuser multiple-input multiple-output (“MIMO”)
`
`networks, and cooperative networking.
`
`9.
`
`I have authored or co-authored more than 190 scientific and industry
`
`publications relating to various communications technologies, networking, and
`
`OFDM. I have also presented numerous tutorials and short courses to industry and
`
`academic audiences on these topics. I am listed as an inventor on over 20 patents
`
`that relate to these topics.
`
`10. Since receiving my Ph.D. in 1982, I was awarded nine of the industry’s
`
`most prestigious honors and awards. These awards include the 2010 Innovator’s
`
`
`
`
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`4
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
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`Award from the New Jersey Inventors Hall of Fame for innovative research related
`
`to high-speed wireless communications. I also received the 2007 James Evans
`
`Avante-Garde Award from the IEEE Vehicular Technology Society in recognition
`
`of my pioneering contributions to high-data-rate wireless communications, and the
`
`Stephen O. Rice Prize in the Field of Communications Theory for a 2009 paper in
`
`the IEEE Transactions on Communications.
`
` In 2010 I won the IEEE
`
`Communications Society’s Wireless Communications Technical Committee
`
`Recognition Award for having a high degree of visibility and contribution in the
`
`field of Wireless and Mobile Communications Theory, Systems, and Networks. In
`
`2000, I became a Fellow of the IEEE for my contributions to the theory of high-
`
`speed wireless communications.
`
`11.
`
`I am not an attorney and offer no legal opinions, but in the course of
`
`my work, I have had experience studying and analyzing patents and patent claims
`
`from the perspective of a person skilled in the art.
`
`
`
`
`
`
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`5
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`III. MATERIALS REVIEWED
`12. The opinions contained in this Declaration are based on the documents
`
`
`
`I reviewed, my professional judgment, as well as my education, experience, and
`
`knowledge regarding wireless communications systems.
`
`13.
`
`In forming my opinions expressed in this Declaration, I reviewed the
`
`’862 patent (Ex. 1001), the prosecution file history for the ’862 patent (Ex. 1004);
`
`U.S. Patent Application No. 11/168,793 (Ex. 1005); U.S. Provisional Application
`
`No. 60/673,451 (Ex. 1006); U.S. Provisional Application No. 60/698,686 (Ex.
`
`1007); Roh et al., “An Efficient Feedback Method for MIMO Systems with Slowly
`
`Time-Varying Channels” (“Roh”) (Ex. 1008); U.S. Patent No. 7,570,696 to Maltsev
`
`et al. (“Maltsev”) (Ex. 1009); Haykin et al., Modern Wireless Communications
`
`(“Haykin”) (Ex. 1010); Yang et al., “Reducing the Computations of the SVD Array
`
`Given by Brent and Luk,” Proceedings of SPIE, vol. 1152, Advanced Algorithms
`
`and Architectures for Signal Processing IV, November 14, 1989 (“Yang”) (Ex.
`
`1011); U.S. Patent No. 7,492,829 to Lin et al. (“Lin”) (Ex. 1012); Sadrabadi et al.,
`
`“A New Method of Channel Feedback Quantization for High Data Rate MIMO
`
`Systems” (“Sadrabadi”) (Ex. 1013); U.S. Patent No. 5,258,995 to Su et al. (“Su”)
`
`(Ex. 1015); Ansari et al., “Unified MIMO Pre-Coding based on Givens Rotation”
`
`(Ex. 1016); U.S. Patent No. 7,742,546 to Ketchum et al. (“Ketchum-546”) (Ex.
`
`
`
`
`
`6
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
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`1017); U.S. Patent No. 7,236,748 to Li et al. (“Li”) (Ex. 1018); Excerpt of The
`
`Authoritative Dictionary of IEEE Standard Terms (7th ed., IEEE Press 2000) (Ex.
`
`1021); Stuber et al., “Broadband MIMO-OFDM Wireless Communications,”
`
`Proceedings of the IEEE, Vol. 92, No. 2, Feb. 2004 (“Stuber”) (Ex. 1022); U.S.
`
`Patent Application Publication No. 2004/0087324 to Ketchum et al. (“Ketchum-
`
`324”) (Ex. 1023); Excerpt of Strang, et al., Linear Algebra and Its Applications (2nd
`
`ed., Academic Press 1980) (“Strang”) (Ex. 1025); U.S. Patent No. 5,986,973 to
`
`Jericevic et al. (“Jericevic”); (Ex. 1029); U.S. Patent No. 6,112,195 to Burges (Ex.
`
`1031) (“Burges”); U.S. Patent No. 7,403,539 to Tang et al. (“Tang”) (Ex. 1032);
`
`U.S. Patent No. 7,570,929 to Trompower (“Trompower”) (Ex. 1033); U.S. Patent
`
`No. 7,133,697 to Judd et al. (“Judd”) (Ex. 1034); U.S. Patent Publication No.
`
`2002/0081978 (“Hou”) (Ex. 1035); Steyskal, H., “Digital Beamforming Basics,”
`
`Journal of Electronic Defense (July 1996) (“Steyskal”) (Ex. 1036); and any other
`
`materials I refer to in this Declaration in support of my opinions.
`
`14. My opinions contained in this declaration are based on the documents
`
`I reviewed and my knowledge and professional judgment. My opinions have also
`
`been guided by my appreciation of how a person of ordinary skill in the art would
`
`have understood the state of the art, the prior art, and the claims and the specification
`
`of the ’862 patent at the time of the alleged invention.
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`I have been asked to initially consider that the time of the alleged
`
`15.
`
`invention of the ’862 patent was the mid 2000s (including April 21, 2005, the filing
`
`date of U.S. Provisional Application No. 60/673,451 (“the ’451 provisional”), which
`
`I understand is the earlier of two provisional applications to which the ’862 patent
`
`claims priority,2 up through the filing date, July 13, 2005, of U.S. Provisional
`
`Application No. 60/698,686 (“the ’686 provisional”), which I understand is the later
`
`of two provisional applications to which the ’862 patent claims priority, and up
`
`through the filing date, September 28, 2005, of the application which ultimately
`
`issued as the ’862 patent). My opinions reflect how one of ordinary skill in the art
`
`(which I described below) would have understood the ’862 patent, the prior art to
`
`the patent, and the state of the art at the time of the alleged invention as I was asked
`
`to consider noted above.
`
`
`2 As I discuss below in Section VI.B, in my opinion, the ’451 provisional fails to
`
`support all the features of claims 9-12 of the ’862 patent (which I refer to as the
`
`“challenged claims”). Similarly, U.S. Patent Application No. 11/168,793, to which
`
`I understand the ’862 patent also claims priority, fails to support all the features of
`
`the challenged claims of the ’862 patent. (See below at Section VI.B.)
`
`
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`8
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`16. Based on my experience and expertise, it is my opinion that certain
`
`references disclose or suggest all the features recited in challenged claims 9-12 of
`
`the ’862 patent, as I discuss in detail below.
`
`
`
`
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`
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`
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`9
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`IV. PERSON OF ORDINARY SKILL IN THE ART AND THE TIME OF
`THE ALLEGED INVENTION
`I am familiar with the level of ordinary skill in the art with respect to
`17.
`
`the alleged inventions of the ’862 patent as of what I understand is the claimed
`
`priority date of April 21, 2005. Specifically, based on my review of the ’862 patent,
`
`the technology, the educational level and experience of active workers in the field,
`
`the types of problems faced by workers in the field (e.g., of wireless
`
`communications), solutions to address those problems, the sophistication of the
`
`technology in the field, and drawing on my own experience, I believe a person of
`
`ordinary skill in the art at the time of the alleged invention (that I discuss above)
`
`would have had at least an undergraduate degree in electrical engineering, physics,
`
`or a related discipline (or equivalent education and/or training) and a master’s degree
`
`in electrical engineering, physics, or a related discipline (or equivalent education
`
`and/or training), and at least two years of experience in the field of wireless
`
`communications systems. More education can supplement practical experience and
`
`vice versa. Depending on the engineering background and level of education of a
`
`person, it would have taken a few years for the person to become familiar with the
`
`problems encountered in the art and become familiar with the prior and current
`
`solutions to those problems.
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`
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`10
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`18. The ’862 patent explains that the technical field of the invention “relates
`
`generally to wireless communication systems and more particularly to wireless
`
`communications using beamforming.” (Ex. 1001 at 1:19-22.) A person of ordinary
`
`skill in the art as noted above would have been familiar with, had knowledge of,
`
`and/or experience with technologies related to wireless communication systems,
`
`which may have included wireless communications using beamforming and/or
`
`related concepts and technologies.
`
`19. All of my opinions in this declaration are from the perspective of one
`
`of ordinary skill in the art, during the relevant timeframe (e.g., the time of the alleged
`
`invention), which I discussed above as including the mid 2000s (including April 21,
`
`2005, the filing date of U.S. Provisional Application No. 60/673,451, up through the
`
`filing date, July 13, 2005, of U.S. Provisional Application No. 60/698,686, and up
`
`through the filing date, September 28, 2005, of the application which ultimately
`
`issued as the ’862 patent). (Ex. 1001 at Cover.)
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`V. TECHNICAL BACKGROUND
`In this section, I present a brief overview of certain aspects of wireless
`20.
`
`
`
`communication systems, including communications involving beamforming, at the
`
`time of the alleged invention. In my opinion, the aspects I discuss below in this
`
`technical background section reflect the state of the art that a person of ordinary skill
`
`in the art would have appreciated, had knowledge of, and understood at the time of
`
`the alleged invention.
`
`Input Multiple Output
`A. Multiple
`Communications
`21. A person of ordinary skill in the art would have been familiar with
`
`(MIMO) Wireless
`
`wireless communication concepts, including concepts that I describe in this
`
`Declaration. Wireless communication was known long before the alleged invention
`
`of the ’862 patent. For example, U.S. Patent No. 5,258,995 to Su et al. (“Su”) (Ex.
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`1015) is entitled “Wireless Communication System” and was filed in 1991, over a
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`decade before the alleged invention date of the ’862 patent. Su discloses a wireless
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`communication system in which “[a] base unit communicates with a remote unit.”
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`(Ex. 1015 at Abstract.) Su’s base unit 10 and remote unit 40 are portions of a digital
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`cordless phone, and are illustrated in block diagram format in Figure 1 (base unit)
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`and Figure 2 (remote unit):
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
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`(Id. at FIG. 1 (showing base unit of a wireless communication system).)3
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`3 In this Declaration, I sometimes use “id.” to refer back to the same document /
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`exhibit that I previously discuss.
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
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`(Id. at FIG. 2 (showing remote unit of a wireless communication system).)
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`22.
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`Su’s wireless communication system uses antennas to wirelessly (e.g.,
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`over the air, or in other words, through free space) communicate data between the
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`base unit 10 and the remote unit 40. (Id. at 3:65-68 (“[T]he RF/IF unit 36 is
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`connected to a pair of antenna 26a, and 26b, with each of the antennas 26a and 26b
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`serving to both transmit and receive.”), 4:23-27 (“The remote unit transceiver 50
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`also comprises an RF/IF analog unit 56, which is similar to the RF/IF analog 36 of
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`the base unit transceiver 30, and is connected to a transmitting and receiving antenna
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`58a and a receiving antenna 58b.”), 4:60-62 (“The unit 36 is shown as comprising
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`two sets of antennas 26a and 26b both for transmitting and for receiving.”).) Thus,
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`Su discloses an example of a wireless communication system that a person of
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`ordinary skill in the art would have had knowledge of and appreciated. For example,
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`Su’s exemplary wireless communication system includes a transmitter (e.g., base
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
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`unit 10 when it is transmitting information to remote unit 40), a channel (e.g., free
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`space separating base unit 10 from remote unit 40), and a receiver (e.g., remote unit
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`40 when it is receiving information from base unit 10). As I discussed above, base
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`unit 10 includes antennas that can both transmit and receive data. That was (and still
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`is) a typical configuration in wireless communication systems, because it enables
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`two-way wireless communication. Thus, a person of ordinary skill would have
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`known that the label of what is the “transmitter” and what is the “receiver” is often
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`done in context and is sometimes determined based on the direction of a given
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`communication.
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`23. A person of ordinary skill in the art would have known that an antenna
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`in a wireless communication system (e.g., any of the antennas in Su’s system
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`discussed above) converts between electrical signals and radio waves, where radio
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`waves are electromagnetic waves at a certain band of the electromagnetic spectrum
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`called radio frequency, or RF.
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`Wireless transmission is characterized by the generation, in the
`transmitter, of an electric signal representing the desired information,
`the propagation of corresponding radio waves through space and a
`receiver that estimates the transmitted information from the recovered
`electrical signal. The transmission system is characterized by the
`antennas that convert between electrical signals and radio waves, and
`the propagation of the radio waves through space.
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
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`(Ex. 1010 at 13.)
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`24.
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`Su’s base unit 10 (shown above in Figure 1) includes a base unit
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`transceiver (i.e., combination transmitter/receiver) 30. (Ex. 1015 at FIG. 1, 3:42-44
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`(“The interface and multiplexer 18 and the application controller 22 communicate
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`with the base unit transceiver 30.”).) The base unit transceiver 30 includes an RF/IF
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`analog unit 36 coupled to antennas 26a/26b, and also includes a baseband processing
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`unit 28 connected to the RF/IF analog unit 36. (Id. at FIG. 1, 3:44-47, 3:57-63.) A
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`person of ordinary skill would have understood that “IF” in “RF/IF analog unit”
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`stands for “intermediate frequency,” and is a frequency lower than radio frequency
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`(i.e., lower than RF). Su’s RF/IF analog unit 36 and baseband processing unit 28a
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`can be understood by considering the processing chain (e.g., sequence of processing)
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`that occurs upon reception of an RF signal at, e.g., antenna 26a:
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`Referring to FIG. 3 there is shown a detailed block diagram of the RF/IF
`analog unit 36 of the base unit transceiver 30. The function of the RF/IF
`analog unit 36 is to convert the frequency of the transmitted or received
`signal by the antenna 26a and 26b from radio frequency to an
`intermediate frequency….The signal received by one of the antennas
`26a is supplied to an RF filter and low noise amplifier (LNA) 70a,
`which functions to filter and amplify the signal received from the
`antenna 26a. The output of the RF filter and LNA 70a is supplied to an
`RF-to-IF down converter 72a. The function of the RF-to-IF down
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
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`converter 72a is to convert the received RF signal into an
`intermediate frequency signal….
`From the RF-to-IF down converter 72a, the intermediate frequency is
`then supplied to an IF filter and amplifier 76a. The function of the IF
`filter and amplifier 76a is to filter the received IF signal and to amplify
`that signal. In addition the IF filter and amplifier 76a increases the gain
`of the filtered signal based upon a gain control signal supplied thereto.
`The amplified and filtered IF signal is then supplied to an I/Q
`demodulator 78a. The I/Q demodulator 78a is an in-phase and
`quadrature-phase demodulator and generates as its output thereof
`a base band frequency signal. The demodulation of the input signal is
`based upon a IF frequency signal supplied from a temperature
`compensated crystal oscillator 82. The base band frequency signal is
`then supplied to an RRC MF 80a. The RRC MF 80a is a root raised
`cosine signal matched filter whose output, in the absence of carrier
`phase error, is a positive or a negative impulse signal for each of the in-
`phase and quadrature-phase components of the signal.
`(Id. at 4:50-5:28 (emphasis added); see also id. at FIG. 3 (reproduced below).)
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`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
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`(Id. at FIG. 3; see also id. at 2:27-28 (“FIG. 3 is a detailed block level diagram of
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`the RF/IF analog portion of the base unit shown in FIG. 1.”).)
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`25.
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`In addition to showing demodulators 78a/78b along the processing
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`chain in one direction (starting with a received RF signal), Figure 3 also shows an
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`RF I/Q modulator 86 in a processing chain in the other direction (e.g., for preparing
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`an RF signal to be transmitted by antenna 26a or 26b). (Id. at FIG. 3.) Su explains
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`that “[t]he RF I/Q modulator 86 takes [a] root raised cosine signal and directly
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`converts it into a radio frequency modulated signal for transmission.” (Id. at
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`5:55-58 (emphasis added).)
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