Declaration of Dr. Wells for Inter Partes Review of U.S. Patent No. 10,512,027
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`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner
`
`v.
`
`TELEFONAKTIEBOLAGET LM ERICSSON
`Patent Owner
`
`
`U.S. PATENT NO. 10,512,027
`
`Case IPR2021-TBD
`
`
`DECLARATION OF JONATHAN WELLS UNDER 37 C.F.R. § 1.68
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW OF
`U.S. PATENT NO. 10,512,027
`
`
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`Declaration of Dr. Wells for Inter Partes Review of U.S. Patent No. 10,512,027
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`
`CONTENTS
`INTRODUCTION ........................................................................................... 1
`I.
`QUALIFICATIONS ........................................................................................ 2
`II.
`III. UNDERSTANDING OF PATENT LAW ...................................................... 7
`IV. SUMMARY OF MY OPINIONS ................................................................... 9
`V. OVERVIEW OF THE TECHNOLOGY ....................................................... 10
`A.
`Cellular Networks ................................................................................ 10
`B.
`Long-Term Evolution (LTE) and New Radio (NR) ........................... 11
`C.
`System Information (SI) and System Information Blocks (SIBs) ...... 12
`D. Using Preambles to Request System Information ............................... 14
`VI. OVERVIEW OF THE ’027 PATENT .......................................................... 15
`VII. PERSON OF ORDINARY SKILL IN THE ART ........................................ 17
`VIII. OVERVIEW OF THE PRIMARY REFERENCES ..................................... 18
`A. U.S. Patent No. 10,455,621 to Agiwal et al. (Ex. 1002) ..................... 18
`1.
`Agiwal’s Provisional Applications ........................................... 21
`2.
`The Agiwal Provisional Applications Support Claim 1 of
`Agiwal ....................................................................................... 24
`U.S. Patent Application Publication No. 2019/0174554 to
`Deenoo et al. (Ex. 1003) ...................................................................... 28
`1.
`Deenoo’s Provisional Applications .......................................... 31
`2.
`The Deenoo Provisional Applications Support Claim 1 of
`Deenoo ...................................................................................... 34
`U.S. Patent Application Publication No. 2016/0234736 to
`Kubota et al. (Ex. 1004) ...................................................................... 37
`IX. ANALYSIS .................................................................................................... 39
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`C.
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`B.
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`Declaration of Dr. Wells for Inter Partes Review of U.S. Patent No. 10,512,027
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`A. Ground I: Claims 1-8, 10-18, and 20-21 are obvious in view of
`Agiwal ................................................................................................. 39
`1.
`Claim 1 ...................................................................................... 40
`2.
`Claim 2 ...................................................................................... 50
`3.
`Claim 3 ...................................................................................... 52
`4.
`Claim 4 ...................................................................................... 54
`5.
`Claim 5 ...................................................................................... 54
`6.
`Claim 6 ...................................................................................... 58
`7.
`Claim 7 ...................................................................................... 58
`8.
`Claim 8 ...................................................................................... 60
`9.
`Claim 10 .................................................................................... 63
`10. Claim 11 .................................................................................... 64
`11. Claim 12 .................................................................................... 66
`12. Claim 13 .................................................................................... 67
`13. Claim 14 .................................................................................... 67
`14. Claim 15 .................................................................................... 68
`15. Claim 16 .................................................................................... 68
`16. Claim 17 .................................................................................... 68
`17. Claim 18 .................................................................................... 69
`18. Claim 20 .................................................................................... 69
`19. Claim 21 .................................................................................... 69
`Ground II: Claims 1-8, 10-18, and 20-21 are obvious in view
`of Deenoo ............................................................................................ 71
`1.
`Claim 1 ...................................................................................... 71
`2.
`Claim 2 ...................................................................................... 79
`3.
`Claim 3 ...................................................................................... 81
`4.
`Claim 4 ...................................................................................... 82
`5.
`Claim 5 ...................................................................................... 82
`6.
`Claim 6 ...................................................................................... 85
`7.
`Claim 7 ...................................................................................... 85
`8.
`Claim 8 ...................................................................................... 86
`9.
`Claim 10 .................................................................................... 88
`10. Claim 11 .................................................................................... 88
`11. Claim 12 .................................................................................... 92
`12. Claim 13 .................................................................................... 93
`13. Claim 14 .................................................................................... 93
`14. Claim 15 .................................................................................... 93
`15. Claim 16 .................................................................................... 94
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`B.
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`Declaration of Dr. Wells for Inter Partes Review of U.S. Patent No. 10,512,027
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`C.
`
`16. Claim 17 .................................................................................... 94
`17. Claim 18 .................................................................................... 94
`18. Claim 20 .................................................................................... 95
`19. Claim 21 .................................................................................... 95
`Ground III: Claims 3, 4, 11-18, and 20 are obvious in view of
`Agiwal and Kubota .............................................................................. 97
`1.
`Claim 3 ...................................................................................... 97
`2.
`Claim 4 ....................................................................................101
`3.
`Claim 11 ..................................................................................101
`4.
`Claim 12 ..................................................................................105
`5.
`Claim 13 ..................................................................................105
`6.
`Claim 14 ..................................................................................105
`7.
`Claim 15 ..................................................................................106
`8.
`Claim 16 ..................................................................................106
`9.
`Claim 17 ..................................................................................107
`10. Claim 18 ..................................................................................107
`11. Claim 20 ..................................................................................107
`D. Ground IV: Claims 3, 4, 13, and 14 are obvious in view of
`Deenoo and Kubota ...........................................................................108
`1.
`Claim 3 ....................................................................................108
`2.
`Claim 4 ....................................................................................112
`3.
`Claim 13 ..................................................................................113
`4.
`Claim 14 ..................................................................................113
`SECONDARY CONSIDERATIONS .........................................................114
`X.
`XI. CONCLUSION ............................................................................................115
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`Declaration of Dr. Wells for Inter Partes Review of U.S. Patent No. 10,512,027
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`I, Jonathan Wells, do hereby declare as follows:
`INTRODUCTION
`I.
`1.
`I have been retained as an expert witness by Petitioner Samsung
`
`Electronics Co., Ltd. (“Samsung” or “Petitioner”) in connection with the above-
`
`captioned Petition for Inter Partes Review (“IPR”) of U.S. Patent No. 10,512,027
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`(“the ’027 patent”) (Ex. 1001).
`
`2.
`
`I have been asked to prepare this Declaration to provide my opinions
`
`regarding whether or not claims 1-8, 10-18, and 20-21 of the ’027 patent are valid
`
`in view of the prior art cited in the Petition. I refer to claims 1-8, 10-18, and 20-21
`
`of the ʼ027 patent as the “Challenged Claims.”
`
`3.
`
`In preparing my Declaration, I reviewed the ’027 patent, including its
`
`file history, prior art references, technical references, and other publications from
`
`the time of the alleged invention, which I discuss herein, including 3GPP meeting
`
`notes R2-166120 from October 10-14, 2016; LTE for UMTS, Evolution to LTE-
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`Advanced, Harri Holma and Antti Toskala (2d Ed., 2011) (“Holma”); and LTE - The
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`UMTS Long Term Evolution: From Theory to Practice, Stefania Sesia Baker and
`
`Issam Toufik (2nd ed., 2011) (“Sesia”).
`
`4.
`
`In forming the opinions expressed in my Declaration, I relied upon my
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`education and experience, and I considered the viewpoint of a person having
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`ordinary skill the art, as discussed in Section VII below, as of the priority date of the
`
`’027 patent.
`
`5.
`
`I am not currently, and never have been, an employee of Samsung. I
`
`received no compensation for this Declaration beyond my normal hourly
`
`compensation based on my time spent analyzing the ’027 patent, the prior art patents
`
`and publications cited below, and issues related thereto. My compensation is not
`
`affected by or dependent in any way on the outcome of this matter. I have no
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`financial interest in Samsung.
`
`II. QUALIFICATIONS
`6. My educational background, career history, publications, and other
`
`relevant qualifications provided here are only a summary. My full curriculum vitae,
`
`including cases in which I have previously given testimony, is attached as Exhibit
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`1006.
`
`7.
`
`I have over 30 years of academic and industry experience in wireless
`
`networks, including 2G, 3G, 4G and 5G networks, comprising GSM, WCDMA,
`
`LTE and NR technologies; cellular infrastructure equipment, including handsets,
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`base stations and backhaul; and wireless standards, rules and regulations (e.g., 3GPP,
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`ETSI and FCC). Over my career, I have developed and deployed radio frequency
`
`(RF) hardware for telecommunication infrastructure equipment for worldwide
`
`export, implemented marketing and product development strategies for cellular
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`wireless products, and participated in European Telecommunications Standards
`
`Institute (“ETSI”), Federal Communications Commission (“FCC”) and other
`
`technical body meetings. I have been a member of 3GPP, and have direct knowledge
`
`and experience with 3GPP and its operations and specifications. I have worked as
`
`an expert in matters related to the infringement and validity of patents on multiple
`
`occasions, including for patents related to wireless technologies and standards.
`
`8.
`
`In 1987, I received my Bachelor of Science (B.Sc.) degree in Physics
`
`with Physical Electronics, awarded with 1st Class Honours, from the University of
`
`Bath, Bath, United Kingdom. In 1991, I received my Doctor of Philosophy (Ph.D.)
`
`degree from the University of Bath. In 1998, I received my Master of Business
`
`Administration (M.B.A.) degree, awarded with distinction, from Massey University,
`
`New Zealand.
`
`9.
`
`I began my career in 1985, as an engineer for Plessey Research,
`
`Caswell, United Kingdom, developing high-speed fiber optic transmitter/receiver
`
`devices. In 1987, I worked at British Aerospace, Bristol, United Kingdom,
`
`designing and fabricating novel mixer devices to support my Ph.D. research. From
`
`1990 to 1992, I worked at the University of Bath as a Postdoctoral Research
`
`Officer. During
`
`this
`
`time, I researched and developed novel
`
`integrated
`
`semiconductor devices, including developing software models to predict the
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`Declaration of Dr. Wells for Inter Partes Review of U.S. Patent No. 10,512,027
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`performance of these and other devices. I also taught undergraduate classes and ran
`
`laboratory sessions.
`
`10. From 1993 to 1994, I was a Senior Design Engineer at Matra Marconi
`
`Space, where I developed integrated electronic components and space-qualified sub-
`
`systems for two satellite payloads.
`
`11. From 1994 to 1998 I was employed by MAS Technology (now Aviat
`
`Networks) in Wellington, New Zealand; first as a Senior Design Engineer before
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`being promoted to Engineering Group Manager. During this time, I was responsible
`
`for hardware development for three families of telecommunication equipment and
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`sustaining development for a family of satellite ground station terminals. I
`
`personally designed a wide range of RF devices, and was also responsible for the
`
`company’s European regulatory approvals.
`
`12. From 1998 to 2000, I was with Adaptive Broadband (now GE Digital
`
`Energy) in Rochester, NY; first as an Engineering Group Leader, and then as
`
`Director of Wideband Products. In this latter role, I had full profit and loss
`
`responsibility for the Terrestrial Infrastructure Group, where I also oversaw the
`
`development of a family of digital radios and associated switching and multiplexing
`
`equipment.
`
`13. From 2000 to 2004, I was Director of Product Development at Stratex
`
`Networks (now Aviat Networks) in San Jose, CA. At Stratex Networks I was
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`Declaration of Dr. Wells for Inter Partes Review of U.S. Patent No. 10,512,027
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`responsible for global product development of a portfolio of high-end digital
`
`microwave radios primarily for cellular applications. I led a development team of
`
`35 engineers, and provided technical leadership of Stratex’s flagship Eclipse
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`product.
`
`14.
`
` From 2005 to 2007, I was Director of Product Management and Global
`
`Regulatory Affairs at GigaBeam Corporation in Herndon, VA. At GigaBeam, I was
`
`responsible for overall product strategy for a novel, industry-transforming wireless
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`communication product. During this time, I had responsibility for establishing a
`
`global regulatory framework for this new product, which included developing FCC,
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`CEPT and ETSI standards to cover the specification and regulation of the system. I
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`participated in multiple FCC, CEPT and ETSI standard setting meetings, and met
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`multiple times with more than a dozen different international regulatory bodies to
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`help setup wireless regulations within their countries.
`
`15.
`
`I have been Managing Partner of AJIS Consulting since 2007. As an
`
`independent consultant, I provide expertise on various aspects of wireless
`
`communications, including, but not limited to, cellular technologies, wireless
`
`devices, network infrastructure, and wireless rules and regulations. In that capacity,
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`I have undertaken multiple projects consulting on these topics, as well as analyzing
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`patents and commercial equipment, for a variety of clients in the communications
`
`industry. This analysis of commercial equipment includes analysis and reverse
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`engineering of equipment including cellular base stations and user devices, and both
`
`Wi-Fi and Bluetooth equipment. I have conducted a number of technical workshops
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`on various aspects of wireless technology, including cellular networks, mm-wave
`
`radios, security sensors and short range radios. I have also helped public companies,
`
`private entities, and startups with product development and marketing strategies for
`
`wireless products.
`
`16.
`
`I have written multiple books, industry reports and journal and
`
`conference papers, most of which focus on wireless communications system. For
`
`example, I am the author of “Multi-Gigabit Microwave and Millimeter-Wave
`
`Wireless Communications” (Artech House, 2010). I have authored four
`
`comprehensive industry reports on cellular connectivity for Mobile Experts, which
`
`provides analysis and consulting services to mobile device manufacturers. I have
`
`lectured as part of undergraduate programs at UC Berkeley, Carnegie Mellon
`
`University and University of Bath, and have given over two dozen lectures and
`
`conference presentations on topics germane to wireless communications.
`
`17.
`
`I have been a member of the Institute of Electrical and Electronic
`
`Engineers (“IEEE”) since 1995 and a Senior Member of IEEE since 1999. I am also
`
`a Member of the IEEE Communications Society and the IEEE Microwave Theory
`
`and Techniques Society. I was a reviewer for the U.S. Government’s Broadband
`
`Technology Opportunity Program and the Broadband Initiatives Program, both part
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`of the American Recovery and Reinvestment Act of 2009. I have been a Chair or
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`Co-Chair of numerous technology workshops and symposia related to wireless
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`communications technology. In 2019 I was recognized by the IEEE Santa Clara
`
`Valley Section as their “Outstanding Engineer” of the year. The IEEE Santa Clara
`
`Valley Section encompasses Silicon Valley and is the largest IEEE Section in the
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`world. This was awarded “For his acknowledged expertise in the field of wireless
`
`communication and wireless technology, for his willingness to mentor others in the
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`field, and for his work in the development of the next generation of creative and
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`innovative technical products.”
`
`III. UNDERSTANDING OF PATENT LAW
`18.
`I understand that prior art to the ’027 patent includes patents and printed
`
`publications in the relevant art that predate the priority date of the ’027 patent.
`
`19.
`
`I understand that words of claims in an IPR are given their plain and
`
`ordinary meaning as understood by a person of ordinary skill in the art in view of
`
`the specification and prosecution history, unless those sources show an intent to
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`depart from such meaning.
`
`20.
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`I understand that a claim is invalid if it is anticipated or obvious.
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`Anticipation of a claim requires that every element of a claim be disclosed expressly
`
`or inherently in a single prior art reference, arranged in the prior art reference as
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`arranged in the claim. Obviousness of a claim requires that the claim be obvious
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`from the perspective of a person having ordinary skill in the relevant art at the time
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`of the alleged invention. I understand that a claim may be obvious in view of a
`
`combination of two or more prior art references.
`
`21.
`
`I understand that an obviousness analysis requires an understanding of
`
`the scope and content of the prior art, any differences between the alleged invention
`
`and the prior art, and the level of ordinary skill in evaluating the pertinent art.
`
`22.
`
`I further understand that a claim can be found obvious if it unites old
`
`elements with no change to their respective functions, or alters prior art by mere
`
`substitution of one element for another known in the field, with that combination
`
`yielding predictable results. While it may be helpful to identify a reason for this
`
`combination, I understand common sense should guide, and there is no rigid
`
`requirement for a teaching, suggestion, or motivation to combine. When a product
`
`is available, design incentives and other market forces can prompt variations of it,
`
`either in the same field or different one. It is my understanding that if a person
`
`having ordinary skill in the relevant art can implement a predictable variation,
`
`obviousness likely bars patentability. Similarly, if a technique has been used to
`
`improve one device, and a person having ordinary skill in the art would recognize
`
`that the technique would improve similar devices in the same way, use of the
`
`technique is obvious. I further understand that a claim may be obvious if common
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`sense directs one to combine multiple prior art references or add missing features to
`
`reproduce the alleged invention recited in the claims.
`
`23.
`
`I also understand that the following rationales may support a finding of
`
`obviousness, particularly where multiple references disclose the claimed subject
`
`matter:
`
`(i)
`
`(ii)
`
`Combining prior art elements according to known methods to yield
`predictable results;
`simple substitution of one known element for another to obtain
`predictable results;
`(iii) use of known technique to improve similar devices (methods, or
`products) in the same way;
`(iv) applying a known technique to a known device (method, or product)
`ready for improvement to yield predictable results;
`“obvious to try” – choosing from a finite number of identified,
`predictable solutions, with a reasonable expectation of success;
`(vi) known work in one field of endeavor may prompt variations of it for
`use in either the same field or a different one based on design incentives
`or other market forces if the variations are predictable to one of ordinary
`skill in the art; and
`(vii) some teaching, suggestion, or motivation in the prior art that would
`have led one of ordinary skill to modify the prior art reference or to
`combine prior art reference teachings to arrive at the claimed invention.
`IV. SUMMARY OF MY OPINIONS
`24.
`It is my opinion that claims 1-8, 10-18, and 20-21 of the ’027 patent are
`
`(v)
`
`obvious in view of Agiwal (Ground I below).
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`Declaration of Dr. Wells for Inter Partes Review of U.S. Patent No. 10,512,027
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`25.
`
`It is also my opinion that claims 1-8, 10-18, and 20-21 of the ’027 patent
`
`are obvious in view of Deenoo (Ground II below).
`
`26.
`
`It is also my opinion that claims 3, 4, 11-18, and 20 of the ’027 patent
`
`are obvious in view of Agiwal and Kubota (Ground III below).
`
`27.
`
`It is also my opinion that claims 3, 4, 13, and 14 of the ’027 patent are
`
`obvious in view of Deenoo and Kubota (Ground IV below).
`
`V. OVERVIEW OF THE TECHNOLOGY
`A. Cellular Networks
`28. A cellular wireless network typically includes a number of base stations
`
`(BS) that communicate with many user equipment (UE) wirelessly. Ex. 1004
`
`(Kubota) at ¶¶ 5-6 (“[A] wireless multiple-access communication system may
`
`include a number of base stations, each simultaneously supporting communication
`
`for multiple communication devices, otherwise known as user equipments (UEs).”).
`
`A base station is a network node in a cellular wireless system that may be known by
`
`various terminologies in different contexts, such as, for example, a nodeB (NB),
`
`evolved NodeB (eNodeB or eNB), or next generation NodeB (gNodeB or gNB) .
`
`Ex. 1008 (Sesia) at 2.2 (“[T]he access network is made up of essentially just one
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`node, the evolved NodeB (eNodeB), which connects to the UEs.”); Ex. 1002
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`(Agiwal) at 2:33-34 (“In the fourth generation wireless communication system,
`
`enhanced node B (eNB) or base station (BS) in cell broadcast system information.”)
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`A user equipment (UE) may be, for example, a handset, mobile cell phone,
`
`smartphone, laptop computer or any related wireless transmit/receive unit (WTRU).
`
`Ex.
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`1003
`
`(Deenoo)
`
`at
`
`¶ 25
`
`(“By way
`
`of
`
`example,
`
`the
`
`WTRUs 102 a, 102 b, 102 c, 102 d may be configured to transmit and/or receive
`
`wireless signals and may include user equipment (UE), a mobile station, a fixed or
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`mobile subscriber unit, a pager, a cellular telephone, a personal digital assistant
`
`(PDA), a smartphone, a laptop, a netbook, a personal computer, a wireless sensor,
`
`consumer electronics, and the like.”).
`
`29. A UE and base station will communicate with one another wirelessly,
`
`using radio waves. Communication is sent on a channel, which can comprise a band
`
`of frequency within the frequency spectrum. When a UE sends a communication to
`
`a base station, this may be referred to as sending a message on an “uplink.” Ex.
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`1004 (Kubota) at ¶ 5 (“A base station may communicate with UEs on downlink
`
`channels (e.g., for transmissions from a base station to a UE) and uplink channels
`
`(e.g., for transmissions from a UE to a base station).”). When a base station sends a
`
`communication to a UE, this may be referred to as sending a message on a
`
`“downlink.” Id.
`
`Long-Term Evolution (LTE) and New Radio (NR)
`B.
`30. Development of the 4th generation (4G) of the wireless technology,
`
`also known as Long-Term Evolution (LTE), standard started in 2004. Ex. 1007
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`(Holma) at 4. LTE was developed by the 3rd Generation Partnership Project
`
`(3GPP), which is the dominant standards development group for mobile radio
`
`systems. Ex. 1008 (Sesia) at 1.1.2. According to the LTE scheme, information is
`
`transmitted from one or more user equipments (UEs) on uplink channels to a base
`
`station (BS or eNodeB). Information can also be transmitted in the other direction,
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`from the base station to the UEs on downlink channels. Ex. 1007 (Holma) at 5.
`
`Whereas the uplink uses a Single Carrier Frequency Division Multiple Access (SC-
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`FDMA) scheme, the downlink uses a multiple-access scheme using Orthogonal
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`Frequency Division Multiplexing (OFDMA). Ex. 1007 (Holma) at 5. By the mid-
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`2010s, development was underway on the 5th generation of wireless technology,
`
`known as 5G or NR (“new radio”). In 5G, a UE communicates with a base station
`
`known as a gNodeB. 5G wireless devices typically accommodate higher bandwidth
`
`and provide higher data rates to more users in a fixed area in comparison to 4G.
`
`C.
`31.
`
`System Information (SI) and System Information Blocks (SIBs)
`In a wireless communication network, like a cellular network, a base
`
`station (BS) and a user device or user equipment (UE) communicate through
`
`channels, which are signals transmitted between the base station and the UE over an
`
`air-interface. In cellular systems, the basic System Information (SI), which allows
`
`the other channels in the cell to be configured and operated, is usually carried by a
`
`Broadcast Channel (BCH). Ex. 1008 (Sesia) at 9.2.1.
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`32. Sesia is a well-known textbook on LTE and provides an overview of
`
`system information. System information is structured by System Information
`
`Blocks (SIBs). Ex. 1008 (Sesia) at 3.2.2. Each SIB contains a set of functionally-
`
`related parameters. Id. For example, Sesia describes that SIB types have included:
`
`The Master Information Block (MIB),
`•
`which includes a limited number of the most
`frequently
`transmitted parameters which are
`essential for a UE’s initial access to the network.
`System Information Block Type 1 (SIB1),
`•
`which contains parameters needed to determine if a
`cell is suitable for cell selection, as well as
`information about the time-domain scheduling of
`the other SIBs.
`System Information Block Type 2 (SIB2),
`•
`which
`includes common and shared channel
`information.
`SIB3–SIB8, which include parameters used
`•
`to control intra-frequency, inter-frequency and
`inter-RAT cell reselection.
`SIB9, which is used to signal the name of a
`•
`Home eNodeB (HeNBs).
`SIB10–SIB12, which include the Earthquake
`•
`and Tsunami Warning
`Service
`(ETWS)
`notifications and Commercial Mobile Alert System
`(CMAS) warning messages (See Section 13.7).
`SIB13, which
`includes MBMS related
`•
`control information (See Section 13.6.3.2.)
`
`
`Id. There may be several SI messages, and each SI message includes one or more
`
`SIBs that have the same scheduling requirements, for example, the same
`
`transmission periodicity. Id. Sesia further provides an example of possible SI
`
`scheduling configuration:
`
`13
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`Samsung Ex. 1005
`
`

`

`Declaration of Dr. Wells for Inter Partes Review of U.S. Patent No. 10,512,027
`
`
`
`
`Id. at Table 3.1.
`
`D. Using Preambles to Request System Information
`33. System Information (SI) can either be continuously broadcast from the
`
`base station (i.e., “always on”) or delivered to a UE on demand. Ex. 1009 (R2-
`
`166120, Oct. 10-14, 2016) at 1. In order to increase network efficiency, for example,
`
`by reducing signaling overhead, companies have long tried to reduce the amount of
`
`continuously broadcast system information and replacing it with on-demand system
`
`information. Id. at 1-2.
`
`34. A known implementation of such on-demand SI delivery, which was
`
`discussed by 3GPP at least as early as October 2016, is requesting SI using preamble
`
`transmission associated with the requested SI. Id. at 3. A preamble is a message
`
`sent by a UE to a base station, the content and characteristics of which are known in
`
`advance, and which can indicate a request for SI. Id. at 3. Under this
`
`14
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`

`Declaration of Dr. Wells for Inter Partes Review of U.S. Patent No. 10,512,027
`
`implementation, each preamble can be mapped to an individual SI or to a set of SI.
`
`Id. (“each reserved preamble is mapped to a set of system information.”). When the
`
`UE wants to acquire specific SI, it sends the corresponding preamble to the base
`
`station (e.g., gNodeB or gNB) to request the specific SI. In addition to requesting
`
`one specific SI, this approach also includes the UE requesting “system information
`
`in more than one group.” Id.
`
`
`
`Id. at Fig. 4.
`
`VI. OVERVIEW OF THE ’027 PATENT
`35.
`I understand that the ’027 patent issued on December 17, 2019 from
`
`U.S. Application No. 15/568,431, filed September 13, 2017. I understand that the
`
`ʼ027 patent purports to claim priority to PCT Application No. PCT/CN2017/070130,
`
`filed on January 4, 2017.
`
`36. The ’027 patent describes requesting and transmitting SI using a
`
`preamble, which indicates at least one system information block (SIB) group that
`
`are grouped based on feature. The ’027 patent states that prior art systems used one
`
`preamble to request all other SI which may lead to transmitting some undesired other
`
`15
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`

`Declaration of Dr. Wells for Inter Partes Review of U.S. Patent No. 10,512,027
`
`SI. Ex. 1001 (’027 patent) at 4:46-48. This is because there are other SI in the
`
`system, all of which the network may broadcast in response to receiving such
`
`preamble. This is inefficient because the requesting UE may not need all of the other
`
`SI. Id. at 4:48-52. As a solution to this inefficiency, the ’027 patent proposes “on-
`
`demand request for SI.” Id. at 4:58-59. In particular, the ’027 patent