`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________________
`
`Intel Corporation
`Petitioner
`
`v.
`
`ParkerVision, Inc.
`Patent Owner
`
`U.S. Patent No. 7,110,444
`
`Issue Date: September 19, 2006
`Title: WIRELESS LOCAL AREA NETWORK (WLAN) USING UNIVERSAL
`FREQUENCY TRANSLATION TECHNOLOGY INCLUDING MULTI-PHASE
`EMBODIMENTS AND CIRCUIT IMPLEMENTATIONS
`__________________________________________________________________
`
`Inter Partes Review No. IPR2020-01265
`__________________________________________________________________
`
`Patent Owner’s Demonstrative Exhibits
`
`
`
`Intel Corporation, Petitioner
`v.
`ParkerVision, Inc., Patent Owner
`
`Case No. IPR2020-01265
`U.S. Patent No. 7,110,444
`
`Patent Owner’s Demonstratives
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`
`
`Technology Overview
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`2
`
`
`
`Wired Communication
`
`
`Can we meet Can we meet
`
`at 11:30?at 11:30?
`
`Can we meet
`at 11:30?
`
`Audio
`
`Audio
`
`Audio
`
`Bob
`
`Alice
`
`Audio signal is at low frequency.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`3
`
`
`
`Frequency
`
`FREQUENCY = Number of Cycles per second
`
`Lower
`Frequency
`
`Higher
`Frequency
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`4
`
`
`
`Wireless Communication
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`5
`
`
`
`Wireless Communication
`
`Carrier Signal
`
`▪ Cannot transmit the audio signal over the air.
`
`▪ The audio signal must move to a higher frequency carrier
`signal.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`6
`
`
`
`Wireless Communication
`
`
`Can we meet Can we meet
`
`at 11:30?at 11:30?
`
`Can we meet
`at 11:30?
`
`Carrier Signal
`
`Bob
`
`Alice
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`7
`
`
`
`Modulation Involves Up-Conversion
`
`Baseband Information
`
`IMPRESSED ON
`
`Carrier
`
`Modulated Carrier
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`8
`
`
`
`Wireless Communication
`
`
`Can we meet Can we meet
`
`at 11:30?at 11:30?
`
`Can we meet
`at 11:30?
`
`Baseband
`(Audio)
`
`Modulated Carrier Signal
`(RF)
`
`Baseband
`(Audio)
`
`Bob
`
`Alice
`
`Modulation
`(Up-conversion)
`
`Demodulation
`(Down-conversion)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`9
`
`
`
`Demodulation Involves Down-Conversion
`
`Modulated Carrier
`
`Baseband Signal
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`10
`
`
`
`Circuit Fundamentals
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`11
`
`
`
`Circuit Fundamentals
`
`▪ Battery
`
`▪ Switch
`
`▪ Resistor
`▪ Voltage samplers featured:
`▪ Capacitor
`▪ Switch
`▪ Capacitor
`
`▪ High Impendence Load
`
`
`
`switchswitch
`
`
`
`9 V9 V
`
`
`
`capacitorcapacitor
`
`Resistor
`(R)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`12
`
`
`
`Circuit Fundamentals
`
`Charge
`
`▪ Current
`Movement of charge
`
`9 V
`
`Current
`(I)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`13
`
`
`
`Circuit Fundamentals
`
`ON (closed)
`
`OFF (open)
`
`switch
`
`9 V
`
`▪ Switch
`
`− Current flows and
`energy transfers
`when on/closed
`− Current does not flow
`and energy does not
`transfer when
`off/open
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`14
`
`
`
`Circuit Fundamentals
`
`Charge
`
`▪ Switch
`
`ON (closed)
`
`OFF (open)
`
`switch
`
`9 V
`
`− Current flows and
`energy transfers
`when on/closed
`− Current does not flow
`and energy does not
`transfer when
`off/open
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`15
`
`
`
`Circuit Fundamentals
`
`ON (closed)
`
`OFF (open)
`
`switch
`
`9 V
`
`▪ Control Signal
`− Used to close/open an
`electronic switch
`
`− Controls Frequency
`
`− Controls Duration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`16
`
`
`
`Circuit Fundamentals
`
`ON (closed)
`
`OFF (open)
`
`switch
`
`9 V
`
`▪ Control Signal
`− Used to close/open an
`electronic switch
`
`− Controls Frequency
`
`− Controls Duration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`17
`
`
`
`Circuit Fundamentals
`
`Charge
`
`ON (closed)
`
`OFF (open)
`
`switch
`
`9 V
`
`resistor
`(R)
`
`Current
`(I)
`
`Voltage
`(V)
`
`▪ Resistor
`Component that
`provides resistance to
`electrical current and
`dissipates energy
`
`▪ Voltage
`The measure of energy
`dissipated in the resistor
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`18
`
`
`
`Circuit Fundamentals
`
`Charge
`
`ON (closed)
`
`switch
`
`9 V
`
`capacitor
`
`Voltage
`(V)
`
`Current
`(I)
`
`▪ Capacitor
`Component that collects
`charge
`
`▪ Voltage
`− Difference in electrical
`potential between top
`and bottom plate
`▪ Charging
`− Capacitor charges
`when the switch is
`closed
`
`− During charging current
`(charges) flows onto
`the plates of the
`capacitor
`
`When a capacitor collects charge, it is charging.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`19
`
`
`
`Circuit Fundamentals
`
`Charge
`
`ON (closed)
`
`switch
`
`9 V
`
`
`
`capacitorcapacitor
`
`Voltage
`(V)
`
`Current
`(I)
`
`▪ Capacitor
`Component that collects
`charge
`
`▪ Discharging
`− Capacitor discharges
`when it is shorted
`
`When a capacitor loses charge, it is discharging.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`20
`
`
`
`Circuit Fundamentals
`
`Charge
`
`OFF (open)
`
`switch
`
`▪ Discharging
`− Capacitor discharges
`when the switch is
`open
`▪ Voltage samplers featured:
`− Current flows out
`▪ Switch
`from the capacitor
`▪ Capacitor
`
`▪ High Impendence Load
`
`9 V
`
`capacitor
`
`resistor
`(R)
`Current
`(I)
`
`Voltage
`(V)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`21
`
`
`
`Energy Sampling
`v.
`Voltage Sampling
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`22
`
`
`
`Energy Transfer
`(Energy Sampling)
`
`Sample and Hold
`(Voltage Sampling)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`23
`
`
`
`Energy Transfer
`(Energy Sampling)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`24
`
`
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`25
`
`
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`26
`
`
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`27
`
`
`
`O U T P U T
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`28
`
`
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`29
`
`
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`30
`
`
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`31
`
`
`
`O U T P U T
`
`F I LT E R E D O U T P U T
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`32
`
`
`
`Sample and Hold
`(Voltage Sampling)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`33
`
`
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`34
`
`
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`35
`
`
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`36
`
`
`
`Claim Construction
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`37
`
`
`
`“storage element”
`
`ParkerVision’s Construction
`“an element of an energy transfer
`system that stores non-negligible
`amounts of energy from an input
`electromagnetic signal”
`
`Intel’s Construction
`“an element that stores a non-
`negligible amount of energy from
`an input electromagnetic (EM)
`signal”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`38
`
`
`
`ParkerVision Adopted Texas District
`Court’s Construction
`
`January 26, 2021 Claim Construction Order, Case No. 6:20-cv-00108-ADA
`
`Term
`“storage element”
`(’444 patent, claim 3)
`
`Texas District Court’s Construction
`“an element of an energy transfer system that stores non-negligible amounts
`of energy from an input electromagnetic signal”
`
`Clarified on June 24, 2021, Claim Construction Order, Case No. 6:20-cv-00562-ADA
`Term
`Texas District Court’s Construction
`“storage module”
`“an element of an energy transfer system that stores non-negligible amounts
`(’706 patent, claims 105,
`of energy from an input electromagnetic signal for driving a low impedance
`114, 164, 175, 179, 186,
`load”
`190)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`39
`
`
`
`“storage element”
`
`Exhibit 2007 (’551 patent), 66:33
`
`Exhibit 2007 (’551 patent), 66:55-67
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`40
`
`
`
`“storage element”
`
`Energy transfer systems
`
`Sample and hold systems
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`41
`
`
`
`“storage element”
`
`Exhibit 2007 (’551 patent), 67:37-46
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`42
`
`
`
`’444 Patent, Claim 3
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`43
`
`
`
`Tayloe
`
`(U.S. Patent No. 6,230,000)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`44
`
`
`
`Tayloe
`
`Control input
`
`Commutating switch
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`45
`
`
`
`Tayloe
`
`Capacitors
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`46
`
`
`
`Tayloe
`
`Op-amp
`
`Summing amplifier
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`47
`
`
`
`Tayloe
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`48
`
`
`
`Tayloe
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`49
`
`
`
`Tayloe
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`50
`
`
`
`Tayloe
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`51
`
`
`
`Tayloe Does Not Disclose “Storage Elements”
`
`ParkerVision’s/Texas District Court’s Construction
`“an element of an energy transfer system that stores non-negligible amounts
`of energy from an input electromagnetic signal”
`
`• Tayloe does not disclose an energy transfer system
`
`• The capacitors in Tayloe do not store non-negligible
`amounts of energy
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`52
`
`
`
`Tayloe Is Not An Energy Transfer
`System
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`53
`
`
`
`Tayloe
`
`Exhibit 1004 (Tayloe), 2:38-41
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`54
`
`
`
`Tayloe Discloses A Voltage Sampling Circuit
`
`Modeled Tayloe Circuit
`
`Exhibit 2021 (Steer Decl.) ¶¶ 258-265
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`55
`
`
`
`Tayloe Discloses A Voltage Conversion Loss
`
`Exhibit 1004 (Tayloe), 3:1-9
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`56
`
`Exhibit 2021 (Steer Decl.) ¶¶ 268-270
`
`
`
`Contradictory Testimony Of Dr. Subramanian
`
`In his expert declarations, Dr. Subramanian states that Tayloe’s op-
`amp is a LOW impedance load
`
`Exhibit 1002 (Subramanian Decl.) ¶138
`
`Ex. 1004 (Tayloe), annotated
`snippet of FIG. 3
`
`Exhibit 1030 (Subramanian Reply Decl.) ¶19
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`57
`
`
`
`Contradictory Testimony Of Dr. Subramanian
`
`In his deposition, Dr. Subramanian admitted that an op-amp is a HIGH
`impedance load.
`
`Exhibit 2028 (Subramanian Depo.) 170:15-20
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`Exhibit 2028 (Subramanian Depo.) 138:21-139:18
`
`58
`
`
`
`ParkerVision’s ’551 Patent
`
`1 meg ohm = HIGH impedance
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`59
`
`
`
`Contradictory Testimony Of Dr. Subramanian
`
`In his expert declaration, Dr. Subramanian stated that there is NO
`reason for the green resistor to be in the circuit if the op-amp input
`impedance is high.
`
`Exhibit 1030 (Subramanian Reply Decl.)¶ 18
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`60
`
`
`
`Contradictory Testimony Of Dr. Subramanian
`
`At his deposition, Dr. Subramanian admitted there is a reason for the
`green resistor– a compensation resistor
`
`Exhibit 2028 (Subramanian Depo.), 184:9-185:6
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`61
`
`
`
`Capacitors In Tayloe Do Not Store
`Non-Negligible Amounts Of
`Energy
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`62
`
`
`
`Parties’ Constructions
`
`ParkerVision’s Construction
`“an element of an energy transfer
`system that stores non-negligible
`amounts of energy from an input
`electromagnetic signal”
`
`Intel’s Construction
`“an element that stores a non-
`negligible amount of energy from an
`input electromagnetic (EM) signal”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`63
`
`
`
`Intel’s Purported Proof
`
`• Size of capacitor
`
`• Energy being accumulated over time
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`64
`
`
`
`Dr. Subramanian Made Critical Errors
`
`• Did not consider RFILTER
`• Did not consider switching time
`
`• Did not consider capacitors in series with resistors
`(and how long it takes to charge the capacitor)
`
`• Did not consider the available power
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`65
`
`
`
`Dr. Subramanian Made Critical Errors
`
`Circuit Modeled by Dr.
`Subramanian
`
`Tayloe Circuit
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`66
`
`
`
`Dr. Subramanian Made Critical Errors
`
`Exhibit 2004 (’551 patent), 67:14-22
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`67
`
`
`
`Dr. Subramanian Made Critical Errors
`
`Equation used by Dr. Subramanian
`
`• Energy stored on a capacitor with a constant voltage V
`across it
`
`Equations Dr. Subramanian should
`have used
`
`• Maximum available power:
`(𝐸𝑃𝐸𝐴𝐾)2
`8 ∗ 𝑅𝑆
`
`𝑃𝑀𝐴𝑋 =
`
`𝐶𝑉𝑃𝐸𝐴𝐾
`
`2
`
`1 2
`
`𝐸 =
`
`• Period of a signal:
`
`𝑇 = Τ1 𝑓
`• The time the switch is closed:
`𝑇𝑂𝑁 = 𝑇/4
`• Energy available from source during time the switch is
`closed:
`
`𝑃𝑀𝐴𝑋 =
`
`(𝐸𝑃𝐸𝐴𝐾)2
`8 ∗ 𝑅𝑆
`• Time constant of a series resistor-capacitor circuit:
`τ = R * C
`• Average value of sine wave over one complete cycle:
`
`∗ 𝑇𝑂𝑁
`
`𝑉𝑃𝐸𝐴𝐾
`
`2 𝜋
`
`𝑉𝐴𝑉𝐺 =
`
`• Voltage across a capacitor charging for time TON
`through a resistor from a voltage VAVG and starting
`from 0 V:
`
`𝑉𝐶𝐴𝑃 = 𝐸𝐴𝑉𝐺 1 − 𝑒
`
`−𝑇𝑂𝑁 τ
`Τ
`
`• Energy stored on capacitor after time TON :
`
`68
`
`2
`
`𝐶𝑉𝐶𝐴𝑃
`
`1 2
`
`𝐸 =
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`
`Proper Analysis
`
`Tayloe’s capacitor: 0.193% of the energy
`transferred from an input EM signal
`
`ParkerVision’s storage element: 58.7% of the
`energy transferred from an input EM signal
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`69
`
`
`
`Tayloe Capacitors Do Not Store Non-
`Negligible Amounts Of Energy
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`70
`
`ParkerVision’s Sur-Reply, pages 20-22
`
`
`
`Tayloe Capacitors Do Not Store Non-
`Negligible Amounts Of Energy
`
`ParkerVision’s Sur-Reply, page 22
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`71
`
`
`
`ParkerVision’s “Storage Elements” Store
`Non-Negligible Amounts Of Energy
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`ParkerVision’s Sur-Reply, pages 23-24
`
`72
`
`
`
`ParkerVision’s “Storage Elements” Store
`Non-Negligible Amounts Of Energy
`
`ParkerVision’s Sur-Reply, page 25
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`73
`
`
`
`Additional Slides
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`74
`
`
`
`’551 Patent is Incorporated into ’474 Patent
`
`Exhibit 1001 (’444 patent), 9:26-42; 34:54-58
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`75
`
`
`
`Tayloe
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`76
`
`
`
`TI Datasheet
`
`Texas Instruments Datasheet for SN74CBT3253
`DUAL 1-OF-4 FET MULTIPLEXER/DEMULTIPLEXER
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`77
`
`
`
`TI Datasheet
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`78
`
`
`
`Kawada
`
`(U.S. Patent No. 4,985,647)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`79
`
`
`
`Kawada
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`80
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true and correct copy of the foregoing
`
`Patent Owner’s Demonstrative Exhibits was served in its entirety by filing this
`
`document through the PTAB E2E System, as well as by email on the following
`
`counsel of record for Petitioner:
`
`Grant Rowan (Lead Counsel)
`WILMER CUTLER PICKERING HALE AND DORR LLP
`grant.rowan@wilmerhale.com
`haixia.lin@wilmerhale.com
`brian.lambson@wilmerhale.com
`michael.summersgill@wilmerhale.com
`todd.zubler@wilmerhale.com
`WH-ParkerVision-IPRs@wilmerhale.com
`
`
`
`Dated: October 25, 2021
`
`
`
`
`
`Respectfully submitted,
`
`By: /Jason S. Charkow/
`Jason S. Charkow
`USPTO Reg. No. 46,418
`
`
`
`
`
`
`
`
`
`
`
`
`
`
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