IPR2020-01265
`U.S. Patent No. 7,110,444
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`Intel Corporation
`Petitioner
`
`v.
`
`ParkerVision, Inc.
`Patent Owner
`___________________________________________
`
`Case IPR2020-01265
`____________________________________________
`
`REPLY DECLARATION OF VIVEK SUBRAMANIAN, PH.D.
`
`Intel v. ParkerVision
`IPR2020-01265
`Intel 1030
`
`
`U.S. Patent No. 7,110,444
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`Intel Corporation
`Petitioner
`
`v.
`
`ParkerVision, Inc.
`Patent Owner
`___________________________________________
`
`Case IPR2020-01265
`____________________________________________
`
`REPLY DECLARATION OF VIVEK SUBRAMANIAN, PH.D.
`
`Intel v. ParkerVision
`IPR2020-01265
`Intel 1030
`
`
`
`
`
`IPR2020-01265
`U.S. Patent No. 7,110,444
`
`I.
`II.
`
`TABLE OF CONTENTS
`INTRODUCTION ........................................................................................... 1
`ANALYSIS OF THE AMOUNT OF ENERGY STORED BY
`TAYLOE’S CAPACITORS ............................................................................ 2
`III. ANALYSIS OF TAYLOE’S LOAD IMPEDANCE ...................................... 7
`IV. AVAILABILITY FOR CROSS EXAMINATION ....................................... 15
`V.
`RIGHT TO SUPPLEMENT .......................................................................... 15
`VI.
`JURAT ........................................................................................................... 15
`
`
`
`i
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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`
`I, Vivek Subramanian, declare as follows:
`
`I.
`
`INTRODUCTION
`1.
`I am the same Vivek Subramanian who submitted a prior Declaration
`
`in this matter, which I understand was filed as Exhibit 1002 on July 13, 2020. I am
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`a Professor of Microtechnology at the École polytechnique fédérale de Lausanne
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`(EPFL) (also known as the Swiss Federal Institute of Technology in Lausanne) in
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`Switzerland. Until recently, I was also a professor of Electrical Engineering and
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`Computer Sciences at the University of California, Berkeley. As of July 1, 2020, I
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`have become an adjunct professor at UC Berkeley upon completion of my move to
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`EPFL.
`
`2. My background and qualifications remain as stated in paragraphs 1-12
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`and Appendix A of my first Declaration (Ex. 1002).
`
`3.
`
`Since my prior Declarations, I have reviewed Patent Owner’s Response
`
`(“POR”), the Declaration of Dr. Michael Steer (Ex. 2021), and the exhibits
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`referenced in this Declaration.
`
`4.
`
`I confirm that the technical analysis included in my first Declaration
`
`(Ex. 1002) remains true to the best of my knowledge, as does my understanding of
`
`the relevant legal principles stated in paragraphs 15-24 of my first Declaration.
`
`
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`1
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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`II. ANALYSIS OF THE AMOUNT OF ENERGY STORED BY TAYLOE’S
`CAPACITORS
`5.
`I understand that both Intel and the Patent Owner have proposed
`
`constructions for the “storage element” term recited in claim 3 of the ’444 patent.
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`Intel proposes construing the “storage element” term as “an element that stores a
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`nonnegligible amount of energy from an input electromagnetic (EM) signal.” The
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`Patent Owner proposes construing the term as “an element of an energy transfer
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`system that stores nonnegligible amounts of energy from an input electromagnetic
`
`signal.” Both Intel and the Patent Owner thus agree that a “storage element” must
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`“store[] non-negligible amounts of energy from an input electromagnetic signal.”
`
`6.
`
`Tayloe’s capacitors 72, 74, 76, and 78 shown in Fig. 3 (reproduced
`
`below) and the capacitors disclosed in its other embodiments store non-negligible
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`amounts of energy from an input electromagnetic signal.
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`2
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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`(Ex. 1004-Tayloe, Fig. 3; see also id., Figs. 5-7 and corresponding description of
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`capacitors in Figs. 3, 5-7.)
`
`7.
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`By way of background, the amount of energy that a capacitor stores
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`equals the amount of work needed to charge the capacitor to a particular voltage
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`level. This amount of stored energy can be calculated with the well-known
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`mathematical expression
`
`, where E denotes the amount of energy stored
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`by the capacitor, V denotes the voltage across the capacitor, and C denotes the
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`capacitance of the capacitor. Thus, a large capacitor has the capacity to store more
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`energy than a smaller capacitor when charged to a given voltage value.
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`8.
`
`Tayloe’s capacitors 72, 74, 76, and 78 in Fig. 3 (and the capacitors
`
`shown in Figs. 5-7) store non-negligible amounts of energy from the input signal.
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`
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`3
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`
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`Tayloe explains that each capacitor charges to a voltage value substantially equal to
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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`the average value of the input signal during the capacitor’s respective quadrant:
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`During the time that commutating switch 38 connects input 36 to output
`42, charge builds up on capacitor 72. Likewise, during the time
`commutating switch 38 connects input 36 to output 44, charge builds
`up on capacitor 74. The same principle holds true for capacitors 76 and
`78 when commutating switch 38 connects input 36 to outputs 46 and
`48 respectively. As commutating switch 38 cycles through the four
`outputs, capacitors 72-78 charge to voltage values substantially equal
`to the average value of the input signal during their respective
`quadrants. Each of the capacitors functions as a separate integrator,
`each integrating a separate quarter wave of the input signal. This
`principle is described more fully with respect to FIG. 4 below.
`
`(Ex. 1004-Tayloe, 2:33-45.1)
`
`9.
`
`Tayloe further explains:
`
`In operation, under control of control signal f2 at input 153,
`commutating switch 154 operates as follows: input 151 is connected to
`output 162 for substantially 90 degrees at the frequency of the input
`signal f1 thereby allowing capacitor 157 to charge to the average value
`of the input signal during the period which commutating switch 154
`was closed on output 162. Then, input 151 is connected to output 164
`
`
`1 All emphasis added unless otherwise noted.
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`
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`4
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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`for substantially 90 degrees at the frequency of the input signal f1
`thereby allowing capacitor 156 to charge to the average value of the
`input signal during the period which commutating switch 154 was
`closed on output 164. As a result of the operation of product detector
`150, baseband in-phase signal 158 and baseband quadrature signal 160
`represent integrated samples of the input waveform where the samples
`have been taken substantially 90 degrees apart. Product detector 150
`can be substituted into direct conversion receiver 30 (FIG. 3) to reduce
`the parts count at the expense of some gain.
`
`(Id., 4:28-45; see also id., 4:46-67 (“the remaining resistor/capacitor pairs also form
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`integrators, each of which preferably integrates for substantially 90 degrees of the
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`input signal”).)
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`10. This transfer of energy will result in the capacitors storing non-
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`negligible amounts of energy. For example, Tayloe discloses an embodiment in
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`which the value of the capacitance of capacitors 72-78 is 0.3 microfarads (μF). (Ex.
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`1004-Tayloe, 5:49-52.) This capacitance, which is equivalent to 300,000 picofarads
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`(pF), is sufficient to store a non-negligible amount of energy. For example, the ’551
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`patent (which is incorporated by reference into the ’444 patent at 1:17-22) discloses
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`that an example of the capacitance value for a “storage capacitance” or “storage
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`module” is 18 picofarads. (Ex. 2007-’551, 67:22-25 (“For example, in an
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`embodiment, the storage capacitance 8208 has a value in the range of 18 pF”).) The
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`
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`5
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`
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`capacitance of Tayloe’s capacitors 72-78 (300,000 pF) is thus tens of thousands of
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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`times larger than the capacitance of the “storage element” of the ’551 patent’s
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`disclosed “energy transfer” system (18 pF). Tayloe’s capacitors therefore have the
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`ability to store vastly more energy from the input signal than the “storage element”
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`of the ’551 patent’s “energy transfer” system. Since the ’551 patent’s storage
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`element is large enough to store non-negligible energy, Tayloe’s capacitors 72-78
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`are necessarily also large enough to store non-negligible energy.
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`11. Tayloe’s storage of non-negligible amounts of energy is further
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`confirmed by Tayloe’s description of capacitors 72-78 as “integrating” the input
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`signal. (Ex. 1004-Tayloe, 2:42-44 (“Each of the capacitors functions as a separate
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`integrator, each integrating a separate quarter wave of the input signal”).) This
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`language indicates an accumulation of energy on the capacitors, and it matches the
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`’551 patent’s description of its storage element as “integrat[ing]” non-negligible
`
`amounts of energy. (Ex. 2007-’551, cl. 198-202 (“said storage module receives and
`
`integrates the non-negligible amounts of energy from the carrier signal”).)
`
`12. The quantity of energy stored on the Tayloe capacitor also supports my
`
`conclusion that Tayloe stores non-negligible amounts of energy. The Tayloe
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`embodiment described above discloses an input signal that has a voltage value that
`
`oscillates between 0 volts and 4 volts and is centered on 2 volts (2,000 mV). (Ex.
`
`
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`6
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`
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`1004-Tayloe, 5:38-41, 5:49-52.). Based on the voltage and capacitance values
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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`disclosed in Tayloe, the amount of energy stored in one of Tayloe’s capacitors 72-
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`78 is E = ½CV2 = ½ x (300,000 pF) x (2,000 mV)2 = 0.6 μJ (microjoules). A
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`POSITA would understand that this quantity is a significant amount of energy in the
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`context of a down-conversion system such as that disclosed in Tayloe.
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`13. Further supporting my conclusion that Tayloe stores non-negligible
`
`amounts is the fact that the energy transferred is distinguishable from noise. The
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`transferred energy is also not minor or inconsequential but rather is important for the
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`formation of the down-converted signal in Tayloe.
`
`14. Thus, Tayloe’s capacitors are “storage elements” that store “non-
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`negligible amounts of energy from an input electromagnetic signal” as required by
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`claim 3 of the ’444 patent under both Intel’s construction and the Patent Owner’s
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`construction of “storage element.”
`
`III. ANALYSIS OF TAYLOE’S LOAD IMPEDANCE
`15. Patent Owner contends that Tayloe’s load impedance is high such that
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`“no energy will be discharged” from capacitors 72-78. (POR, 62.) However, this
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`position is inconsistent with Tayloe’s teachings. Tayloe teaches discharging non-
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`negligible energy from capacitors 72-78 into amplifiers 50 and 52 (i.e., the load),
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`which indicates that the load impedance is low, not high.
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`7
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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`16. The discharge of non-negligible energy (yellow) from the capacitors 72
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`and 76 to amplifier 50 is indicated by the presence of the resistors (red, green, and
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`purple) shown in the portion of Fig. 3 of Tayloe reproduced below:2
`
`
`
`(Ex. 1004-Tayloe, Fig. 3 (annotated).)
`
`17. The green resistor between capacitor 76 and the non-inverting input (+)
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`of the operational amplifier (shown as a triangle) in amplifier 50 creates a “voltage
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`drop” across the green resistor, such that the voltage to the right of the green resistor
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`(applied to the operational amplifier input (+)) is lower than the voltage to the left of
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`the green resistor (applied from capacitor 76).
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`2 Amplifier 52 and capacitors 74 and 78 have the same configuration and teach
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`non-negligible energy discharge for the same reasons.
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`8
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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`18. The use of the green resistor indicates that non-negligible current (and
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`thus energy) is flowing through the green resistor and into the non-inverting
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`inverting input (+) of the operational amplifier, which is connected in series with the
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`green resistor. Based on Ohm’s law, the voltage drop (V) across the green resistor
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`equals the product of the green resistor’s resistance (R) and the current (I) flowing
`
`through the resistor (V=IR). If the impedance of the non-inverting input (+) of the
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`operational amplifier were high, only a negligible amount of current would flow into
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`the input, which, in turn, would mean that only a negligible amount of current would
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`flow through the green resistor. The voltage drop across the green resistor would
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`also be negligible, based on the V=IR relationship. But if the voltage drop across
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`the green resistor were negligible, the circuitry would be effectively be the same as
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`the case where the green resistor was not even there. In other words, if the
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`impedance of the non-inverting input (+) of the operational amplifier were high,
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`there would be no need to include the green resistor in the circuit. A POSITA would
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`understand that a circuit designer would not add an element to a circuit that would
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`not serve any purpose, given the additional cost, complexity, and size associated
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`with an extra element. Since Tayloe includes the green resistor, the impedance at
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`the non-inverting input (+) of the operational amplifier is not high but low such that
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`9
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`non-negligible amounts of energy (i.e., charge times voltage) flow through the green
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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`resistor into the non-inverting input (+) of the operational amplifier.
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`19. The low impedance at the non-inverting input (+) of the operational
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`amplifier means that the impedance at the bottom input of amplifier 50 (i.e., to the
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`left of the green resistor) is also low. A POSITA would understand that the green
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`resistor in Tayloe would not have a high resistance, which would create large voltage
`
`drop and would significantly weaken the signal that the operational amplifier needs
`
`to process. Thus, the combined impedance of the green resistor (a low impedance)
`
`and the impedance at the non-inverting input (+) of the operational amplifier (a low
`
`impedance) is low, such that non-negligible amounts of energy will flow from
`
`capacitor 76 to the load.
`
`20. The impedance at the top input of amplifier 50 is also low. A POSITA
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`would understand that the impedances of the two inputs of amplifier 50 should be
`
`nearly the same, so that capacitors 72 and 76 discharge at the same rate.
`
`21. The impedance at the top input of amplifier 50 is determined by the red
`
`resistor and the “feedback loop” that includes the purple resistor and connects the
`
`output of the operational amplifier with its inverting input (-). The node (identified
`
`by the blue arrow) formed at the inverting input (-) of the operational amplifier is
`
`commonly called a “virtual ground” in the art. The voltage at the node typically
`
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`10
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`
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`does not have a constant value of zero volts, as in the case of an “actual ground,” but
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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`the “virtual ground” forces the voltages at the inverting input (-) and non-inverting
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`input (+) of the operational amplifier to be the same. By causing the voltage at the
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`inverting input (-) of the operational amplifier to be equal to the voltage at the non-
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`inverting input (+) of the operational amplifier, the feedback loop will create a low
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`impedance at the top input of amplifier 50 (on the left side of the red resistor). In
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`addition, since operational amplifiers are generally designed to be symmetric
`
`between inverting and non-inverting inputs, it follows that both inputs of the
`
`operational amplifier will see a low impedance such that non-negligible current
`
`flows through both the green and red resistors. This, in turn, indicates a low
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`impedance on the left side of the red resistor coupled to capacitor 72 for the same
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`reasons discussed above where I explained why the green resistor would not have a
`
`high resistance. Accordingly, the impedance at the top input to amplifier 50 will be
`
`low such that non-negligible energy will flow from capacitor 72 to the load.
`
`22. At paragraph 251, footnote 12, of Dr. Steer’s Declaration, he states:
`
`I note that a circuit designer would not design the summing
`amplifiers 50, 52 the way in which they are draw in Tayloe. Indeed,
`the circuit of Tayloe would not work properly using the summing
`amplifiers 50, 52 as drawn. As the summing amplifiers 50, 52 are
`drawn in Tayloe, there is no choice of resistor values in block 50 that
`would enable the summing amplifier in block 50 to sum or subtract
`11
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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`the voltages on the capacitors 72 and 76. Similarly, there is no choice
`of resistor values in block 52 that would enable the summing
`amplifier in block 52 to sum or subtract the voltages on the capacitors
`74 and 78.
`(Ex. 2021-Steer Decl., ¶251, n.12.)
`
`23.
`
`I disagree. Dr. Steer’s conclusion that there are no values of the
`
`resistors connected to amplifiers 50 and 52 that would enable them to work properly
`
`is based on his incorrect premise that amplifiers 50 and 52 have a high impedance.
`
`If amplifiers 50 and 52 have a sufficiently low impedance that non-negligible current
`
`flows through both the green and red resistors, they would operate correctly with the
`
`resistors connected as shown in Fig. 3 of Tayloe. The fact that amplifiers 50 and 52
`
`would not operate properly if they are high impedance loads (as Dr. Steer opines),
`
`but would operate properly if they are low impedance loads (as I have explained),
`
`further confirms my conclusion that Tayloe teaches a system with a low impedance
`
`load.
`
`24. Dr. Steer’s further testimony that Tayloe “prevent[s] energy in the
`
`capacitor from being discharged to form the down-converted signal” is similarly
`
`based on the incorrect premise that Tayloe’s system uses a high impedance load.
`
`(Ex. 2021, ¶¶146, 257; see also POR, 60.) As I have explained, Tayloe discloses a
`
`system with a low impedance load. Dr. Steer acknowledges that “the use of a low
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`12
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`
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`impedance load enables the capacitor to … discharge the energy to form the
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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`baseband signal (i.e., the discharged energy itself becomes part of the baseband
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`signal).” (Ex. 2021, ¶160; POR, 22.) It follows that Tayloe’s low impedance load
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`(amplifiers 50 and 52) enables capacitors 72-78 to discharge energy to form the
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`baseband signal.
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`25.
`
`In fact, Tayloe expressly teaches that the energy that is integrated and
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`stored on the capacitors is used to form the down-converted signal. Tayloe teaches
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`that the capacitors each integrate portions of the signal and charge to voltage values
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`substantially equal to the average value of the input signal during their respective
`
`quadrants, and that the resulting signals are summed to produce the baseband signal:
`
`A commutating switch is used in combination with capacitors [72-78
`in Fig. 3] to integrate portions of the input signal. The in-phase and
`quadrature signals that result represent the signal of interest [62 in
`Fig. 3] at baseband.
`(Ex. 1004-Tayloe, 1:67-2:3.)
`During the time that commutating switch 38 connects input 36 to
`output 42, charge builds up on capacitor 72. Likewise, during the
`time commutating switch 38 connects input 36 to output 44, charge
`builds up on capacitor 74. The same principle holds true for
`capacitors 76 and 78 when commutating switch 38 connects input 36
`to outputs 46 and 48 respectively. As commutating switch 38 cycles
`through the four outputs, capacitors 72-78 charge to voltage values
`
`
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`13
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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`substantially equal to the average value of the input signal during their
`respective quadrants. Each of the capacitors functions as a separate
`integrator, each integrating a separate quarter wave of the input signal.
`(Id., 2:33-44.)
`
`
`Output 42 represents the average value of the input signal during the
`first quarter wave of the period, and is termed the 0 degree output.
`Output 44 represents the average value of the input signal during the
`second quarter wave of the period, and is termed the 90 degree output.
`Output 46 represents the average value of the input signal during the
`third quarter wave of the period, and is termed the 180 degree output.
`Output 48 represents the average value of the input signal during the
`fourth quarter wave of the period, and is termed the 270 degree output.
`The outputs of commutating switch 38 are input to summing
`amplifiers 50 and 52. Summing amplifier 50 differentially sums the
`0 degree output and the 180 degree output, thereby producing
`baseband in-phase signal 54. Summing amplifier 52 differentially
`sums the 90 degree output and the 270 degree output, thereby
`producing baseband quadrature signal 56. Baseband in-phase signal
`54 and baseband quadrature signal 56 are input to phase delay 58
`which shifts the phase of baseband quadrature signal 56 by 90
`degrees relative to baseband in-phase signal 54. The resulting signals
`are then summed by summing amplifier 60 to produce the signal of
`interest 62.
`(Id., 2:46-67.)
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`14
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`U.S. Patent No. 7,110,444
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`26.
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`In sum, Tayloe down-converts by transferring energy from the RF input
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`signal to capacitors 72, 74, 76, and 78. The energy stored by these capacitors is
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`transferred to a subtractor module (amplifier 50 or 52) to produce the down-
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`converted signal, and Tayloe’s down-converted signal therefore includes the energy
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`from the RF signal.
`
`IV. AVAILABILITY FOR CROSS EXAMINATION
`27.
`In signing this declaration, I recognize that the declaration will be filed
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`as evidence in a contested case before the Patent Trial and Appeal Board of the
`
`United States Patent and Trademark Office. I also recognize that I may be subject
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`to cross examination in the case and that cross examination will take place within
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`the United States. If cross examination is required of me, I will appear for cross
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`examination within the United States during the time allotted for cross examination.
`
`V. RIGHT TO SUPPLEMENT
`28.
`I reserve the right to supplement my opinions in the future to respond
`
`to any arguments that the Patent Owner raises and to take into account new
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`information as it becomes available to me.
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`VI. JURAT
`29.
`I declare 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
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`15
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`further that these statements were made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code.
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`Dated: August 5, 2021
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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`
`/Vivek Subramanian/
`Vivek Subramanian
`
`
`
`17
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`
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