`
`
`
`
`
`
`
`
`
`
`
`
`
`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
`
`
`
`
`
`Page 1 of 184
`
`SAMSUNG EXHIBIT 1002
`
`

`

`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 .............................................................................................. 28
`C.
`Channel Estimation and Beamforming, and Singular Value
`Decomposition (SVD) ........................................................................ 35
`D. Givens Decomposition ....................................................................... 43
`VI. THE ’862 PATENT ...................................................................................... 49
`A. Description ......................................................................................... 49
`B.
`The ’451 Provisional and ’793 Application ....................................... 54
`VII. CLAIM CONSTRUCTION ......................................................................... 56
`VIII. OVERVIEW OF THE PRIOR ART ............................................................ 57
`A. Maltsev ............................................................................................... 57
`B.
`Haykin................................................................................................. 65
`C.
`Sadrabadi ........................................................................................... 71
`D.
`Yang .................................................................................................... 77
`IX. THE PRIOR ART DISCLOSES OR SUGGESTS ALL RECITED
`FEATURES OF CLAIMS 9-12 OF THE ’862 PATENT ............................ 79
`
`
`
`
`
`i
`
`
`
`Page 2 of 184
`
`

`

`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`b)
`
`A. Maltsev, Haykin, and Sadrabadi Disclose or Suggest the
`Features of Claims 9, 11, and 12 ........................................................ 79
`1.
`Claim 9 .................................................................................... 79
`a)
`9[a] A wireless
`communication
`device
`comprising: ................................................................... 79
`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 ..................................................................... 82
`9[c] a baseband processing module operable to: ...... 96
`9[d] receive a preamble sequence carried by the
`baseband signal; ......................................................... 104
`9[e] estimate a channel response based upon the
`preamble sequence; ................................................... 114
`9[f] determine an
`estimated
`transmitter
`beamforming unitary matrix (V) based upon
`the
`channel
`response
`and
`a
`receiver
`beamforming unitary matrix (U); ............................ 124
`9[g] decompose
`the estimated
`transmitter
`beamforming unitary matrix (V) to produce the
`transmitter beamforming information; and ........... 143
`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. ..................................... 159
`
`c)
`d)
`
`e)
`
`f)
`
`g)
`
`h)
`
`
`
`
`
`ii
`
`
`
`Page 3 of 184
`
`

`

`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`2.
`
`Claim 11 ................................................................................ 167
`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.” ................................ 167
`Claim 12 ................................................................................ 171
`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.” ............... 171
`B. Maltsev, Haykin, Sadrabadi, and Yang Disclose or Suggest the
`Features of Claim 10 ........................................................................ 173
`1.
`Claim 10 ................................................................................ 173
`
`3.
`
`
`
`
`
`iii
`
`
`
`Page 4 of 184
`
`

`

`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`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.” ............... 173
`CONCLUSION ........................................................................................... 179
`
`X.
`
`
`
`
`
`
`
`iv
`
`
`
`Page 5 of 184
`
`

`

`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”)
`1.
`
`as 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
`
`
`
`Page 6 of 184
`
`

`

`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 work at this branch of AT&T Bell Laboratories until 1985. In my role as a
`
`
`
`
`
`2
`
`
`
`Page 7 of 184
`
`

`

`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`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.
`
`7.
`
`From 1996 to 2002, I was a Technology Consultant for AT&T
`
`Laboratories Research. During this time, I studied the effect of channel mismatch
`
`3
`
`
`
`
`Page 8 of 184
`
`

`

`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`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
`
`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 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
`
`4
`
`
`
`
`Page 9 of 184
`
`

`

`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`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.
`
`
`
`
`
`
`
`5
`
`
`
`Page 10 of 184
`
`

`

`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,” volume 2 of Proceedings of 2004 IEEE Wireless
`
`Communications and Networking Conference, March 21-25, 2004, Atlanta, GA
`
`(“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.
`
`
`
`
`
`6
`
`
`
`Page 11 of 184
`
`

`

`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`1016); U.S. Patent No. 7,742,546 to Ketchum et al. (“Ketchum-546”) (Ex. 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); U.S. Patent Application Publication No. 2004/0184398 to
`
`Walton et al. (“Walton”) (Ex. 1024); 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
`
`7
`
`
`
`
`Page 12 of 184
`
`

`

`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`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.
`
`15.
`
`I have been asked to initially consider that the time of the alleged
`
`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.)
`
`
`
`
`
`8
`
`
`
`Page 13 of 184
`
`

`

`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.
`
`
`
`
`
`
`
`
`
`9
`
`
`
`Page 14 of 184
`
`

`

`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.
`
`
`
`
`
`10
`
`
`
`Page 15 of 184
`
`

`

`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.)
`
`
`
`
`
`
`
`
`
`11
`
`
`
`Page 16 of 184
`
`

`

`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. 1015) is entitled “Wireless Communication System” and was filed in
`
`1991, over a decade before the alleged invention date of the ’862 patent. Su
`
`discloses a wireless communication system in which “[a] base unit communicates
`
`with a remote unit.” (Ex. 1015 at Abstract.) Su’s base unit 10 and remote unit 40
`
`are portions of a digital cordless phone, and are illustrated in block diagram format
`
`in Figure 1 (base unit) and Figure 2 (remote unit):
`
`
`
`
`
`12
`
`
`
`Page 17 of 184
`
`

`

`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`(Id. at FIG. 1 (showing base unit of a wireless communication system).)3
`
`
`
`
`
`
`
`
`3 In this Declaration, I sometimes use “id.” to refer back to the same document /
`
`exhibit that I previously discuss.
`
`
`
`
`
`13
`
`
`
`Page 18 of 184
`
`

`

`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`(Id. at FIG. 2 (showing remote unit of a wireless communication system).)
`
`
`
`22.
`
`Su’s wireless communication system uses antennas to wirelessly (e.g.,
`
`over the air, or in other words, through free space) communicate data between the
`
`base unit 10 and the remote unit 40. (Id. at 3:65-68 (“[T]he RF/IF unit 36 is
`
`connected to a pair of antenna 26a, and 26b, with each of the antennas 26a and 26b
`
`serving to both transmit and receive.”), 4:23-27 (“The remote unit transceiver 50
`
`also comprises an RF/IF analog unit 56, which is similar to the RF/IF analog 36 of
`
`the base unit transceiver 30, and is connected to a transmitting and receiving
`
`antenna 58a and a receiving antenna 58b.”), 4:60-62 (“The unit 36 is shown as
`
`comprising two sets of antennas 26a and 26b both for transmitting and for
`
`receiving.”).) Thus, Su discloses an example of a wireless communication system
`
`that a person of ordinary skill in the art would have had knowledge of and
`
`appreciated. For example, Su’s exemplary wireless communication system
`
`includes a transmitter (e.g., base unit 10 when it is transmitting information to
`
`remote unit 40), a channel (e.g., free space separating base unit 10 from remote
`
`unit 40), and a receiver (e.g., remote unit 40 when it is receiving information from
`
`base unit 10). As I discussed above, base unit 10 includes antennas that can both
`
`transmit and receive data. That was (and still is) a typical configuration in wireless
`
`communication systems, because it enables two-way wireless communication.
`
`Thus, a person of ordinary skill would have known that the label of what is the
`
`14
`
`
`
`
`Page 19 of 184
`
`

`

`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`“transmitter” and what is the “receiver” is often done in context and is sometimes
`
`determined based on the direction of a given communication.
`
`23. A person of ordinary skill in the art would have known that an
`
`antenna in a wireless communication system (e.g., any of the antennas in Su’s
`
`system discussed above) converts between electrical signals and radio waves,
`
`where radio waves are electromagnetic waves at a certain band of the
`
`electromagnetic spectrum called radio frequency, or RF.
`
`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.
`(Ex. 1010 at 13.)
`
`24.
`
`Su’s base unit 10 (shown above in Figure 1) includes a base unit
`
`transceiver (i.e., combination transmitter/receiver) 30. (Ex. 1015 at FIG. 1, 3:42-
`
`44 (“The interface and multiplexer 18 and the application controller 22
`
`communicate with the base unit transceiver 30.”).) The base unit transceiver 30
`
`includes an RF/IF analog unit 36 coupled to antennas 26a/26b, and also includes a
`
`baseband processing unit 28 connected to the RF/IF analog unit 36. (Id. at FIG. 1,
`
`
`
`
`
`15
`
`
`
`Page 20 of 184
`
`

`

`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`3:44-47, 3:57-63.) A person of ordinary skill would have understood that “IF” in
`
`“RF/IF analog unit” stands for “intermediate frequency,” and is a frequency lower
`
`than radio frequency (i.e., lower than RF). Su’s RF/IF analog unit 36 and baseband
`
`processing unit 28a can be understood by considering the processing chain (e.g.,
`
`sequence of processing) that occurs upon reception of an RF signal at, e.g., antenna
`
`26a:
`
`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 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.
`
`
`
`
`
`16
`
`
`
`Page 21 of 184
`
`

`

`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`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).)
`
`
`
`
`
`
`
`
`
`17
`
`
`
`Page 22 of 184
`
`

`

`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`(Id. at FIG. 3; see also id. at 2:27-28 (“FIG. 3 is a detailed block level diagram of
`
`the RF/IF analog portion of the base unit shown in FIG. 1.”).)
`
`25.
`
`In addition to showing demodulators 78a/78b along the processing
`
`chain in one direction (starting with a received RF signal), Figure 3 also shows an
`
`RF I/Q modulator 86 in a processing chain in the other direction (e.g., for
`
`preparing an RF signal to be transmitted by antenna 26a or 26b). (Id. at FIG. 3.)
`
`Su explains that “[t]he RF I/Q modulator 86 takes [a] root raised cosine signal and
`
`directly converts it into a radio frequency modulated signal for transmission.”
`
`(Id. at 5:55-58 (emphasis added).)
`
`26. Thus, as was (and is) typical for wireless communication systems,
`
`Su’s system uses modulation to prepare an RF signal for transmission along an RF
`
`carrier wave across a wireless channel. (Id.; see also Ex. 1008 at 760-761
`
`(describing aspects of multiple
`
`input multiple output (MIMO) wireless
`
`communication systems that include RF signal transmissions and processes for
`
`improving the efficiency and performance of such systems).)
`
`27. A person of ordinary skill in the art would have understood that RF
`
`signals, which are typically at a higher frequency than baseband signals, need to be
`
`downconverted to baseband signals (with a lower frequency) because the high
`
`frequency of the RF signals makes it more difficult for processor(s)/component(s)
`
`
`
`
`
`18
`
`
`
`Page 23 of 184
`
`

`

`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`of a device such as Lin’s device to process such RF signals. For example, it was
`
`known at the time of the alleged invention that
`
`[t]he simple approach of directly sampling and digitizing the
`incoming microwave signal is not yet practical because of digital
`hardware speed limitations.
` Therefore, the modules comprise
`complete
`heterodyne
`receivers,
`performing
`frequency
`downconversion, filtering, and amplifying
`to a power
`level
`commensurate with the A/D converter….
`(Ex. 1036 at 50-51.)
`
`28. Other references disclose similar technologies known to a person of
`
`ordinary skill in the art. (See, e.g., Ex. 1010 at 226 (Haykin disclosing performing
`
`modulation at the transmitter of a wireless communication system “to prepare [a]
`
`signal for transmission over the wireless channel”).) A person of ordinary skill
`
`would have been knowledgeable about modulation, because modulation is
`
`fundamental to how wireless communication systems operate. Haykin describes
`
`modulation, which is “the process by which some characteristic of a carrier wave is
`
`varied in accordance with an information-bearing signal.” (Ex. 1010 at 105.)
`
`Haykin explains that “[m]odulation is used to shift the spectral content of a
`
`message signal so that it lies inside the operating frequency band of the wireless
`
`communication channel.” (Id.; see also id. at 106.) Haykin describes various
`
`modulation techniques. (Id. at 107-173.) Haykin further discloses that “[t]he
`
`
`
`
`
`19
`
`
`
`Page 24 of 184
`
`

`

`Declaration of Dr. Leonard J. Cimini
`U.S. Patent No. 8,416,862
`
`
`generated RF modulated signal s(t) is transmitted over the narrowband wireless
`
`channel whose midband is centered on the carrier frequency fc.” (Id. at 227.) In
`
`other words, Haykin describes modulating a signal (that is to be transmitted) to
`
`radio frequency (RF), so that it can be transmitted (e.g., using an RF antenna)
`
`along an RF channel (e.g., using a carrier electromagnetic wave having a frequency
`
`in the RF band of the electromagnetic spectrum).
`
`29. A person of ordinary skill would have known that demodulation is an
`
`inverse operation to modulation, and that demodulation is applied in wireless
`
`communication signals to bring a higher-frequency signal to a lower-frequency
`
`signal. As I discussed above, Su’s I/Q demodulator 78a converts an intermediate
`
`frequency (IF) signal to a baseband frequency signal (i.e., baseband signal). A
`
`person of ordinary skill would have known that conversion down to intermediate
`
`frequency (IF) (e.g., from RF) is a