`
`Docket No.: 0107131.00696US1
`Filed on behalf of Intel Corporation
`By: Grant K. Rowan, Reg. No. 41,278
`
`1875 Pennsylvania Avenue, NW
`Washington, DC 20006
`Telephone: (202) 663-6000
`Tel: (617) 526-6000
`Email: grant.rowan@wilmerhale.com
`haixia.lin@wilmerhale.com
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`Intel Corporation
`Petitioner
`
`v.
`
`ParkerVision, Inc.
`Patent Owner
`___________________________________________
`
`Case IPR2020-01265
`____________________________________________
`
`DECLARATION OF VIVEK SUBRAMANIAN, PH.D.
`U.S. PATENT NO. 7,110,444
`CHALLENGING CLAIMS 1, 3, 5
`
`
`
`
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`INTEL 1002
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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`TABLE OF CONTENTS
`I. 
`INTRODUCTION ........................................................................................... 1 
`QUALIFICATIONS AND PROFESSIONAL EXPERIENCE ...................... 1 
`II. 
`III.  MATERIALS CONSIDERED ........................................................................ 4 
`IV.  LEGAL PRINCIPLES ..................................................................................... 6
`A.  Obviousness ........................................................................................... 6
`B. 
`Interpretation of “Means-Plus-Function” Claim Elements ................... 9 
`LEVEL OF ORDINARY SKILL IN THE ART ........................................... 10 
`V. 
`VI.  TECHNICAL BACKGROUND ................................................................... 11 
`A. 
`Types of Data Signals Used in Wireless Communication .................. 11 
`B. 
`“Modulating” Signals for Wireless Communication .......................... 14 
`1. 
`Amplitude modulation .............................................................. 15 
`2. 
`Phase Modulation ...................................................................... 16 
`“Up-Conversion” and “Down-Conversion” ........................................ 17 
`C. 
`Circuitry Components Used in Wireless Devices ............................... 17 
`D. 
`VII.  OVERVIEW OF THE ’444 PATENT .......................................................... 20 
`A. 
`The Alleged Problem in the Art .......................................................... 20 
`B. 
`The Alleged Invention of the ’444 Patent ........................................... 21 
`C. 
`Patent Owner Added the Last Limitations to Claims 1 and 3 To
`Obtain the Challenged Claims ............................................................. 32 
`VIII.  CLAIM CONSTRUCTION .......................................................................... 36 
`A. 
`“frequency down-conversion module” (Claim 1) ............................... 37 
`B. 
`“frequency down-conversion module” (Claim 3) ............................... 40 
`C. 
`“subtractor module” (Claims 1, 3) ...................................................... 40 
`IX.  OVERVIEW OF THE PRIOR ART REFERENCES ................................... 42 
`A. 
`Tayloe .................................................................................................. 42 
`B. 
`TI Datasheet ........................................................................................ 52 
`C. 
`Kawada ................................................................................................ 55 
`D.  Motivation to Combine ....................................................................... 57 
`SPECIFIC GROUNDS FOR PETITION ...................................................... 61 
`
`X. 
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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`A.  Ground I: Claims 1, 3, and 5 Are Obvious Over Tayloe in
`View of TI Datasheet .......................................................................... 61 
`1. 
`Independent Claim 1 ................................................................. 61 
`2. 
`Independent Claim 3 ............................................................... 100 
`3. 
`Dependent Claim 5 ................................................................. 104 
`Ground II: Claims 1, 3, and 5 Are Obvious Over Tayloe in
`View of Kawada ................................................................................ 104 
`XI.  AVAILABILITY FOR CROSS EXAMINATION ..................................... 108 
`XII.  RIGHT TO SUPPLEMENT ........................................................................ 108 
`XIII.  JURAT ......................................................................................................... 108 
`
`
`B. 
`
`ii
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`
`I, Vivek Subramanian, declare as follows:
`
`I.
`
`INTRODUCTION
`1. My name is Vivek Subramanian. I am a Professor of Microtechnology
`
`at the École polytechnique fédérale de Lausanne (EPFL) (also known as the Swiss
`
`Federal Institute of Technology in Lausanne) in Switzerland. Until recently, I was
`
`also a professor of Electrical Engineering and Computer Sciences at the University
`
`of California, Berkeley. As of July 1, 2020, I have become an adjunct professor at
`
`UC Berkeley upon completion of my move to EPFL.
`
`2.
`
`I have been retained as an expert in this proceeding by counsel for Intel
`
`Corporation. I have been asked for my expert conclusions regarding the validity of
`
`claims 1, 3, and 5 of U.S. Patent No. 7,110,444 (the “’444 Patent”) (Ex. 1001-’444).
`
`For the reasons set forth below, it is my conclusion that claims 1, 3, and 5 of the ’444
`
`patent are invalid.
`
`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
`3. My qualifications are stated more fully in my curriculum vitae, which
`
`is attached as Exhibit A. Below is a summary of my education, work experience,
`
`and other qualifications.
`
`4.
`
`I received a bachelor’s degree summa cum laude in electrical
`
`engineering from Louisiana State University in 1994. I received M.S. and Ph.D.
`
`
`
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`

`

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`degrees in electrical engineering, in 1996 and 1998, respectively, from Stanford
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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`University.
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`5.
`
`Throughout the course of my education, including my B.S., M.S., and
`
`Ph.D. degrees, I was involved in designing and implementing wireless and high-
`
`speed analog systems. For example, during my PhD, I designed RF CMOS radios,
`
`including the transistor level design, simulation, layout, and characterization of the
`
`same.
`
`6.
`
`After completing my Ph.D.,
`
`I held multiple appointments
`
`simultaneously between 1998 and 2000. I served as a Consulting Assistant Professor
`
`in the Electrical Engineering Department of Stanford University. I also served as a
`
`Visiting Research Engineer in the Department of Electrical Engineering and
`
`Computer Sciences at the University of California, Berkeley, where my research
`
`focused on 25nm metal oxide semiconductor field effect transistor (MOSFET)
`
`design and fabrication. I worked on technologies for high-performance transistor
`
`processes, and I published several papers as a direct outcome of this technology
`
`development.
`
`7.
`
`In 2000, I became an assistant professor at the University of California,
`
`Berkeley in the Department of Electrical Engineering & Computer Sciences. In
`
`2005, I was promoted to the position of tenured Associate Professor, and in 2011, I
`
`was promoted to full Professor. In 2018, I became a full Professor of
`
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`

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`Microtechnology at EPFL in Switzerland, where I lead the Laboratory for Advanced
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`IPR2020-01265
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`Fabrication Technologies (LAFT). The lab focuses on the development and
`
`application of advanced additive fabrication techniques for realizing precision
`
`microelectronic and electromechanical systems. As of 2020, I have completed my
`
`move to EPFL and have therefore converted to an adjunct appointment at Berkeley.
`
`8. My research has maintained a large effort on RF systems. Specifically,
`
`throughout my many years at Berkeley, I maintained a regular research focus on
`
`RFID systems, including designing both readers and RFID tags.
`
`9.
`
`Starting in 2004, I was a founding technical advisor for Kovio. Under
`
`my leadership, Kovio re-focused on RFID and RF anti-theft systems. I led the
`
`development of Kovio’s first commercial RFID tag product, including the design of
`
`both the tag and the reader. My involvement with Kovio ended with Kovio’s
`
`acquisition by thin film electronics, but Kovio continues to focus on this area.
`
`10.
`
`I co-founded Locix Inc. in 2014. Locix develops and sells a range of
`
`wireless-enabled products, including proprietary Wi-Fi-based RF localization
`
`systems and sub-GHz low-power wireless sensor networks. As CTO of Locix, I led
`
`the development of the entire Locix RF product portfolio. I continue to be involved
`
`with Locix on a regular basis.
`
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`11.
`
`I have authored or co-authored over 200 technical papers in
`
`international journals and conferences and have been named an inventor or co-
`
`inventor on more than 50 patents, many of which cover aspects of RF circuits.
`
`12.
`
`I am being compensated for my time at my ordinary hourly rate of $650.
`
`My compensation is not dependent on the outcome of these proceedings or the
`
`content of my opinions. To the best of my knowledge, I have no financial interest
`
`in either party or in the outcome of this proceeding.
`
`III. MATERIALS CONSIDERED
`13.
`In preparing this declaration, I have reviewed the claims, specification,
`
`and file history of the ’444 patent. I understand that the ’444 patent issued on
`
`September 19, 2006 from U.S. Patent Application No. 09/632,856 (filed August 4,
`
`2000). The ’444 patent states that it is a continuation-in-part of U.S. Patent
`
`Application No. 09/525,615 (filed March 14, 2000) and a continuation-in-part of
`
`U.S. Patent Application No. 09/526,041 (filed March 14, 2000). The’444 patent also
`
`claims priority to provisional application 60/147,129 (filed on August 4, 1999).
`
`14.
`
`I have reviewed and understand the references and exhibits cited in this
`
`Declaration, including the following:
`
`Exhibit
`
`Description
`
`1001
`
`U.S. Patent No. 7,110,444 (“’444 patent”)
`
`4
`
`

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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`Declaration of Dr. Vivek SubramanianRegarding U.S. Patent No.
`7,110,444 (“Subramanian Decl.”)
`’444 patent File History
`U.S. Patent No. 6,230,000 (“Tayloe”)
`SN74CBT3253D Dual 1-of-4 FET Multiplexer/Demultiplexer (rev.
`ed. May 1998) (“TI Datasheet”)
`U.S. Patent No. 6,018,553 (“Sanielevici”)
`U.S. Patent No. 6,317,589 (“Nash”)
`U.S. Patent No. 4,985,647 (“Kawada”)
`U.S. Patent No. 5,764,693 (“Taylor”)
`“Modem,” IEEE Standard Dictionary of Electrical and Electronics
`Terms (4th ed. 1988)
`“Modem,” McGraw-Hill Dictionary of Scientific and Technical
`Terms, (5th ed. 1994)
`“Modem,” Websters New World Dictionary of American English
`(3rd ed. 1988)
`U.S. Patent No. 5,742,641 (“Dingsor”)
`“Capacitor,” Microsoft Press Computer Dictionary (2d ed. 1994)
`
`“Capacitor,” IBM Dictionary of Computing (10th ed. 1994)
`ParkerVision v. Intel Corp., No. 6:20-cv-108, D.I. 24 (June 26,
`2020) (“Trial Setting Order”)
`ParkerVision v. Intel Corp., No. 6:20-cv-108, D.I. 25 (June 26,
`2020) (“Markman Setting Order”)
`Patent Owner’s Preliminary Infringement Contentions,
`ParkerVision v. Intel Corp., No. 6:20-cv-108 (June 26, 2020)
`Declaration of Maureen M. Honeycutt (“Honeycutt Decl.”)
`
`
`
`1002
`
`1003
`1004
`1005
`
`1006
`1007
`1008
`1009
`1010
`
`1011
`
`1012
`
`1013
`1014
`
`1015
`1016
`
`1017
`
`1018
`
`1019
`
`5
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`IV. LEGAL PRINCIPLES
`15.
`I am not an attorney. For the purposes of this declaration, I have been
`
`informed by Intel’s counsel about certain aspects of the law that are relevant to my
`
`opinions, as stated in the following paragraphs. I have applied these legal principles
`
`in arriving at my conclusions expressed in this declaration.
`
`A. Obviousness
`16.
`I have been informed and understand that a patent claim is invalid if it
`
`would have been obvious to a person of ordinary skill in the art (POSITA) at the
`
`time of the alleged invention. This means that, even if all of the requirements of a
`
`claim are not found in a single prior art reference, the claim is not patentable if the
`
`differences between the subject matter in the prior art and the subject matter in the
`
`claim would have been obvious to a POSITA at the time of the alleged invention.
`
`17.
`
`I have been informed and understand that a determination of whether a
`
`claim was obvious should be based upon several factors, including, among others:
`
`(1) the level of ordinary skill in the art at the time of the alleged invention; (2) the
`
`scope and content of the prior art; (3) the differences, if any, that existed between
`
`the claimed invention and the prior art; and (4) any objective considerations of
`
`nonobviousness.
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`18.
`
`I have been informed and understand that when determining any
`
`differences between the invention covered by the patent claims and the prior art, one
`
`should not look at the individual differences between the patent claims and the prior
`
`art in isolation, but rather consider the claimed invention as a whole and determine
`
`whether or not it would have been obvious in light of all of the prior art.
`
`19.
`
`I have been informed and understand that a single reference can render
`
`a patent claim obvious if any differences between that reference and the claims
`
`would have been obvious to a POSITA. Alternatively, the teachings of two or more
`
`references may be combined in the same way as disclosed in the claims. I have been
`
`informed and understand that when deciding whether to combine the various items
`
`described in the prior art, the relevant question is whether the prior art combination
`
`would have been obvious to a person with ordinary skill in the art at the time of the
`
`invention. I have been further informed that it can be important to identify a
`
`teaching, suggestion, or motivation, in either the prior art or the knowledge of
`
`persons skilled in the art, that would have prompted a person of ordinary skill in the
`
`relevant field to combine the elements in the prior art in the way the claimed
`
`invention does.
`
`20.
`
`In determining whether a combination based on either a single
`
`reference or multiple references would have been obvious, it is appropriate to
`
`consider, among other factors:
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` whether the teachings of the prior art references disclose known concepts
`
`combined in familiar ways, and when combined, would yield predictable
`
`results;
`
` whether a POSITA would implement a predictable variation, and would
`
`see the benefit of doing so;
`
` whether the claimed elements represent one of a limited number of known
`
`design choices, and would have a reasonable expectation of success by a
`
`POSITA;
`
` whether a POSITA would have recognized a reason to combine known
`
`elements in the manner described in the claim;
`
` whether there is some teaching or suggestion in the prior art to make the
`
`modification or combination of elements claimed in the patent; and
`
` whether the innovation applies a known technique that had been used to
`
`improve a similar device or method in a similar way.
`
`21.
`
`I have been informed and understand that one of ordinary skill in the
`
`art has ordinary creativity, and is not an automaton. I have been informed and
`
`understand that in considering obviousness, it is important not to determine
`
`obviousness using the benefit of hindsight derived from the patent being considered.
`
`I have been informed and understand that a patent composed of several elements is
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`not proved obvious merely by demonstrating that each of its elements was
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`independently known in the prior art.
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`22.
`
`I have been informed and understand that to show a motivation to
`
`combine, one is not required to show how the references would be physically
`
`combined to render a claim obvious. The analysis is not focused on whether the
`
`features of one reference can be physically incorporated into the structure of another
`
`reference, but rather whether a person of ordinary skill in the art would have been
`
`motivated to combine the teachings of the references to achieve the claimed
`
`invention. For example, a person of ordinary skill in the art would understand how
`
`predictable variations of known concepts could be combined and would recognize
`
`that where multiple tools were available in a toolbox, any could be chosen.
`
`B.
`23.
`
`Interpretation of “Means-Plus-Function” Claim Elements
`I have been informed and understand that a “means-plus-function”
`
`claim term is a term that recites a certain function but does not recite sufficient
`
`structure for performing that function. I understand that means-plus-function terms
`
`are limited to the function recited in the claim term and the specific structure
`
`disclosed in the patent’s specification for performing that function and structures
`
`that are equivalent to the disclosed structures.
`
`24.
`
`I have been informed and understand that for means-plus-function
`
`limitations, a prior art reference or combination of references must disclose the
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`identical function in the claim limitation and must disclose a structure that performs
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`the function that is either identical to or the equivalent of the structure in the
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`specification of the challenged patent that performs the claimed function. I
`
`understand that a structure can be equivalent if (a) the prior art element performs the
`
`identical function specified in the claim in substantially the same way, and produces
`
`substantially the same results as the corresponding element disclosed in the
`
`specification; (b) a person of ordinary skill in the art would have recognized the
`
`interchangeability of the element shown in the prior art for the corresponding
`
`element disclosed in the specification; or (c) there are insubstantial differences
`
`between the prior art element and the corresponding element disclosed in the
`
`specification.
`
`V. LEVEL OF ORDINARY SKILL IN THE ART
`25.
`I have considered the ’444 patent from the perspective of a POSITA at
`
`the time of the alleged invention. A person of ordinary skill in the art for the ’444
`
`patent would have had at least the equivalent of a bachelor’s degree in electrical
`
`engineering or a related subject and two or more years of experience in the field of
`
`radio frequency (RF) circuit design. Less work experience may be compensated by
`
`a higher level of education, such as a master’s degree, and vice versa. At the time
`
`of the claimed invention, I would have qualified as a POSITA under this standard.
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`VI. TECHNICAL BACKGROUND
`A. Types of Data Signals Used in Wireless Communication
`26. Wireless devices (such as cellular phones and tablets (like the Apple
`
`iPad)) exchange information by transmitting and receiving electromagnetic signals.
`
`Such signals are sent from a first device’s transmitter to a second device’s receiver.
`
`Claims 1, 3, and 5 of the ’444 patent relate to receiving signals from another device.
`
`For example, representative claim 1 reads as follow.
`
`1.
`
`A wireless modem apparatus, comprising:
`a receiver for frequency down-converting an input signal
`including,
`a first frequency down-conversion module to down-convert the
`input signal, wherein said first frequency down-conversion module
`down-converts said input signal according to a first control signal and
`outputs a first down-converted signal;
`a second frequency down-conversion module to down-convert
`said input signal, wherein said second frequency down-conversion
`module down-converts said input signal according to a second control
`signal and outputs a second down-converted signal; and
`a subtractor module that subtracts said second down-converted
`signal from said first down-converted signal and outputs a down-
`converted signal;
`wherein said second control signal is delayed relative to said
`first control signal by (0.5+n) cycles of said input signal, wherein n is
`an integer greater than or equal to 1.
` (Ex. 1001-’444, claims 1, 3, and 5)
`
`
`27. Before information, such as voice information of a telephone call, is
`
`transmitted, it is in the form of a “baseband signal.” A baseband signal has a
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`relatively low frequency and is often a digital signal comprising a series of 1’s and
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`U.S. Patent No. 7,110,444
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`0’s as shown below.
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`
`
`28. When a baseband signal is transmitted wirelessly, the digital baseband
`
`signal is converted into an analog signal. An analog signal is a continuous waveform
`
`that oscillates between maximum and minimum values at a certain frequency:
`
`
`
`29. As shown above, the “amplitude” of the analog signal corresponds to
`
`how much the signal oscillates between its “zero” or equilibrium value to its
`
`maximum or minimum value. The signal’s “phase” refers to the position of the
`
`signal within its cycle as it oscillates. A full cycle of a signal is conventionally
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`
`defined as spanning 360 degrees. For instance, as shown above, the signal’s peak is
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`IPR2020-01265
`U.S. Patent No. 7,110,444
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`at 90 degrees; the signal crosses zero at 180 degrees; and the signal completes its
`
`cycle at 360 degrees. The analog signals shown below have the same frequency and
`
`amplitude but have phases that are shifted with respect to each other by 90 degrees
`
`(0.25 cycles).
`
`
`
`30. As another example, the two signal waves shown below are 180 degrees
`
`(0.5 cycles) out of phase and are essentially “opposite” to each other. These signals
`
`are also considered to be “inverted” with respect to each other.
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`B.
`“Modulating” Signals for Wireless Communication
`31. Since baseband signals have relatively low frequencies, they are not
`
`adapted to be wirelessly transmitted between wireless devices. Instead, the baseband
`
`signal must be “imprinted” onto a higher frequency signal, which is often referred
`
`to as a “carrier” signal, that is more easily transmitted over the air. Such a carrier
`
`signal “carries” the baseband signal over the air between wireless devices.
`
`32.
`
`“Imprinting” a lower frequency baseband signal onto a higher
`
`frequency carrier signal is referred to in the art as “modulation.” To perform
`
`modulation, the frequency, phase, and/or amplitude of the carrier signal can be
`
`modified (or “modulated”) based on the frequency, phase, and/or amplitude of the
`
`baseband signal. Some well-known examples of modulation are described in more
`
`detail below
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`1.
`Amplitude modulation
`“Amplitude modulation” refers to modifying the amplitude of the
`
`33.
`
`carrier signal based on the amplitude of the baseband signal, as shown below. Here,
`
`the modified carrier signal is referred to as an “amplitude modulated signal,” which
`
`can be transmitted over the air to a wireless device’s receiver.
`
`
`
`34. The receiver “knows” the amplitude of the unmodulated carrier signal
`
`ahead of time. When the receiver receives the amplitude modulated signal, it
`
`therefore, can recover the original baseband signal from the amplitude modulated
`
`signal by comparing the amplitudes of the modulated signal and unmodulated carrier
`
`signal.
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`2.
`Phase Modulation
`35. A baseband signal can also be sent over the air to another device using
`
`phase modulation. In this example, the “phase” of the carrier signal is modified
`
`based on the phase of the baseband signal, as shown below.
`
`
`
`36.
`
`In this example, the modified carrier signal is called a “phase modulated
`
`signal,” which is transmitted to a wireless receiver. As in the case of amplitude
`
`modulation, the receiver knows the phase of the carrier signal beforehand and can
`
`obtain the baseband signal from the modulated carrier signal by comparing the
`
`phases of the modulated signal and unmodulated carrier signal.
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`37. Amplitude and phase modulation were both well-known before the
`
`’444 patent.
`
`C.
`“Up-Conversion” and “Down-Conversion”
`38. Modulating a high frequency carrier signal with a low frequency
`
`baseband signal to produce a high frequency modulated signal is called “up-
`
`conversion.” The ’444 patent refers to this high frequency modulated signal as a
`
`“radio frequency” or “RF” signal. After the high frequency modulated signal is
`
`transmitted to a device’s receiver, the receiver needs to convert the modulated signal
`
`back down to the low frequency baseband signal so that the information in the
`
`baseband signal can be recovered and processed. This is achieved using a “down-
`
`conversion” method. Claims 1, 3, and 5 of the ’444 patent relate to down-converting
`
`a modulated RF signal back to a baseband signal. Down-conversion methods have
`
`been well-known in the art long before the ’444 patent.
`
`D. Circuitry Components Used in Wireless Devices
`39. Switch. As shown below, a “switch” (gray) is an electronic component
`
`that controls the flow of a signal in a circuit between an input node (purple) and an
`
`output node (orange).
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`Ex. 1005-TI Datasheet, 2
`
`40. A control signal (pink) controls the switch to be “open” or “closed.”
`
`When the switch is “open” or “off,” the signal cannot substantially flow through the
`
`switch. On the other hand, when the switch is “closed” or “on,” the signal can flow
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`unimpeded through the switch.
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`41. Figure 1B of the ’444 patent (below) shows one common way a switch
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`is typically shown in schematic diagrams depicting circuits. The switch (gray)
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`includes an input node (purple) and an output node (orange). A control signal (pink)
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`controls the switch to turn it “on” and “off.”
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`42. Capacitor. A “capacitor” is an electronic circuit device that stores
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`energy (or charge) in a circuit.
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`43. Amplifier. An “amplifier” is an electronic component that increases or
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`“amplifies” the magnitude of a signal. A “differential amplifier” is a certain type of
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`amplifier that inputs two signals, determines the difference in magnitude between
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`the signals, and amplifies the difference in magnitude. In the figure below, a
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`differential amplifier is often depicted as a triangle with an “inverting” input (shown
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`by the minus symbol (“-”)) that inputting a first signal, and a “non-inverting” input
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`(shown by the plus symbol (“+”)) for inputting a second signal.
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`44.
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` Then, the magnitude of the first signal supplied to the inverting input
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`is subtracted from the second signal supplied to the non-inverting input, and
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`afterwards, the differential amplifier outputs a signal representing the amplified
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`difference in the magnitudes of the first and second signals. Since differential
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`amplifiers output the difference in magnitude between two signals, they are also
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`referred to as “subtractors.”
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`45. Each of these components, which are recited in the ’444 patent, were
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`all known before the ’444 patent.
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`VII. OVERVIEW OF THE ’444 PATENT
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`A. The Alleged Problem in the Art
`46. The ’444 patent states that it addresses problems in receivers used in
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`wireless local area networks (“WLANs”). The patent acknowledges that “various
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`components” and “schemes” for down-converting signals received over wireless
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`networks existed at the time of the claimed invention. (Ex. 1001-’444, 2:3-7)
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`(“Additionally, various communication components exist for performing frequency
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`down-conversion, frequency up-conversion, and filtering. Also, schemes exist for
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`signal reception in the face of potential jamming signals.”). However, the patent
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`states that conventional WLAN receivers are “complex” and require “a large number
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`of circuit parts” that are costly and “result in higher power consumption.” (Id., 1:65–
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`2:3) (“Conventional wireless communications circuitry is complex and has a large
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`number of circuit parts. This complexity and high parts count increases overall cost.
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`Additionally, higher part counts result in higher power consumption, which is
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`undesirable, particularly in battery powered wireless units.”)
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`B.
`The Alleged Invention of the ’444 Patent
`47. The ’444 patent specification states that it addresses these problems
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`with a WLAN receiver that includes at least one “universal frequency translation
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`[UFT] module that frequency down-converts a received electromagnetic (EM)
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`signal.” (Id., 2:19-21) (“The WLAN receiver includes at least one universal
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`frequency
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`translation module
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`that
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`frequency down-converts a
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`received
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`electromagnetic (EM) signal.”); (see also id., 8:38-43; 9:30-32) (“The present
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`invention is related to frequency translation, and applications of same. Such
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`applications include, but are not limited to, frequency down-conversion, frequency
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`up-conversion, enhanced signal reception, unified down-conversion and filtering,
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`and combinations and applications of same. . . . The present invention is directed to
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`systems and methods of universal frequency down-conversion, and applications of
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`same. In particular, the following discussion describes down-converting using a
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`Universal Frequency Translation Module.”)
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`48. Claims 1, 3, and 5 relate to the wireless receiver shown in Figure 70A
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`(below). This receiver includes two “frequency down-conversion modules” that
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`each have a universal frequency translation UFT module that down-converts a high
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`frequency RF input signal to a low frequency baseband signal.
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`Ex. 1001-’444, Fig. 70A
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`49. The first down-conversion module 7002 (red) down-converts the high
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`frequency RF input signal 7082 (purple) to produce a first down-converted signal
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`7098 (red). (Id., 35:35-36:13) (“FIG. 70A illustrates an exemplary I/Q modulation
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`receiver 7000, according to an embodiment of the present invention. I/Q modulation
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`receiver 7000 has additional advantages of reducing or eliminating unwanted DC
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`offsets and circuit re-radiation. As will be apparent, the IQ receiver 7000 can be
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`described as a multi-phase receiver to those skilled in the arts. I/Q modulation
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`receiver 7000 comprises a first UFD module 7002 [red], a first optional filter 7004,
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`a second UFD module 7006 [green], a second optional filter 7008, a third UFD
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`module 7010, a third optional filter 7012, a fourth UFD module 7014, a fourth filter
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`7016, an optional LNA 7018, a first differential amplifier 7020, a second differential
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`amplifier 7022, and an antenna 7072. I/Q modulation receiver 7000 receives, down-
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`converts, and demodulates a I/Q modulated RF input signal 7082 to an I baseband
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`output signal 7084 [yellow], and a Q baseband output signal 7086. I/Q modulated
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`RF input signal 7082 comprises a first information signal and a second information
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`signal that are I/Q modulated onto an RF carrier signal. I baseband output signal
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`7084 comprises the first baseband information signal. Q baseband output signal 7086
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`comprises the second baseband information signal. Antenna 7072 receives I/Q
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`modulated RF input signal 7082. I/Q modulated RF input signal 7082 is output by
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`antenna 7072 and received by optional LNA 7018. When present, LNA 7018
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`amplifies I/Q modulated RF input signal 7082, and outputs amplified I/Q signal 7088
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`[purple]. First UFD module 7002 [red] receives amplified I/Q signal 7088 [purple].
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`First UFD module 7002 down-converts the I-phase signal portion of amplified input
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`I/Q signal 7088 according to an I control signal 7090 [pink]. First UFD module 7002
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`outputs an I output signal 7098 [red]. In an embodiment, first UFD module 7002
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`comprises a first storage module 7024 [brown], a first UFT module 7026 [gray], and
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`a first voltage reference 7028. In an embodiment, a switch contained within first
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`UFT module 7026 opens and closes as a function of I control signal 7090. As a result
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`of the opening and closing of this switch, which respectively couples and de-couples
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`first storage module 7024 to and from first voltage reference 7028, a down