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. 9,300,432
`
`Case IPR2021-00645
`
`DECLARATION OF FRIEDHELM RODERMUND
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW OF U.S.
`PATENT NO. 9,300,432
`
`Page 1
`
`1
`
`SAMSUNG 1015
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner,
`
`v.
`
`TELEFONAKTIEBOLAGET LM ERICSSON,
`Patent Owner
`
`U.S. PATENT NO. 9,300,432
`
`Case IPR2021-00645
`
`DECLARATION OF FRIEDHELM RODERMUND
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW OF U.S.
`PATENT NO. 9,300,432
`
`Page 1
`
`1
`
`SAMSUNG 1015
`
`
`
`TABLE OF CONTENTS
`
`
`
`Page
`
`I.
`
`II.
`
`III.
`
`IV.
`
`
`INTRODUCTION AND ENGAGEMENT ............................................................ 3
`
`BACKGROUND AND QUALIFICATIONS ........................................................ 5
`
`SUMMARY OF MY OPINIONS ........................................................................... 9
`
`PUBLICATION OF 3GPP SPECIFICATIONS AND RELATED DOCUMENTS
`10
`
`A.
`
`B.
`
`General Practices .................................................................................................. 11
`
`Specific Documents .............................................................................................. 20
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`R1-074426................................................................................................. 20
`
`TR 21.905 v7.4.0 ...................................................................................... 24
`
`TS 25.211 V7.4.0 ...................................................................................... 27
`
`TS 25.214 V7.4.0 ...................................................................................... 30
`
`TS 25.302 V7.4.0 ...................................................................................... 33
`
`TS 25.331 V7.4.0 ...................................................................................... 36
`
`V.
`
`AVAILABILITY FOR CROSS-EXAMINATION .............................................. 38
`
`A.
`
`B.
`
`
`
`Right To Supplement ............................................................................................ 39
`
`Signature ............................................................................................................... 39
`
`
`DECLARATION OF FRIEDHELM RODERMUND
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`Page 2
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`2
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`I, Friedhelm Rodermund, do hereby declare as follows:
`
`I.
`
`INTRODUCTION AND ENGAGEMENT
`
`1.
`
`I have been retained in this matter by Samsung Electronics Co., Ltd
`
`(“Petitioner” or “Samsung”) to provide testimony regarding 3GPP’s standard
`
`business practices for record keeping and publishing technical specifications,
`
`change request proposals, reports, and other documents developed during the
`
`course of standards activities carried out by the 3rd Generation Partnership Project
`
`(“3GPP”) and the European Telecommunications Standards Institute (“ETSI”).
`
`2.
`
`I have been asked to provide my opinions regarding the authenticity
`
`and dates of public accessibility of the following 3GPP documents:
`
`• T-doc R1-074426, which represents a document with the title “Rank
`
`feedback in downlink MIMO” (hereinafter “R1-074426”,
`
`SAMSUNG-1006)
`
`• Version 7.4.0 of technical report 3GPP TR 21.905 (“Technical
`
`Specification Group Services and System Aspects; Vocabulary for
`
`3GPP Specifications (Release 7)”) (hereinafter “TR 21.905 v7.4.0”,
`
`SAMSUNG-1010)
`
`• Version 7.4.0 of technical specification 3GPP TS 25.211 (“Technical
`
`Specification Group Radio Access Network; Physical channels and
`
`DECLARATION OF FRIEDHELM RODERMUND
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`3
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`
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`
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`mapping of transport channels onto physical channels (FDD) (Release
`
`7)”) (hereinafter “TS 25.211 v7.4.0”) (SAMSUNG-1013)
`
`• Version 7.4.0 of technical specification 3GPP TS 25.214 (“Technical
`
`Specification Group Radio Access Network; Physical layer procedures
`
`(Release 7)”) (hereinafter “TS 25.214 v7.4.0”) (SAMSUNG-1005)
`
`• Version 7.4.0 of technical specification 3GPP TS 25.302 (“Technical
`
`Specification Group Radio Access Network; Services provided by the
`
`physical layer (Release 7)”) (hereinafter “TS 25.302 v7.4.0”)
`
`(SAMSUNG-1014)
`
`• Version 7.4.0 of technical specification 3GPP TS 25.331 (“Technical
`
`Specification Group Radio Access Network; Radio Resource Control
`
`(RRC); Protocol specification (Release 7)”) (hereinafter “TS 25.331
`
`v7.4.0”, SAMSUNG-1004)
`
`3.
`
`As an ETSI Project Manager and Secretary, from June 1998 to
`
`December 2004, I have personal knowledge of 3GPP’s standard business and
`
`records keeping practices. I continued following 3GPP’s work ever since. Thus,
`
`based on my experience, personal knowledge, and review of 3GPP’s business
`
`records, I am able to testify regarding the authenticity of certain documents
`
`published by 3GPP and the timing of their publication.
`
`DECLARATION OF FRIEDHELM RODERMUND
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`4.
`
`I am being compensated for my time spent on this matter at my usual
`
`rate of €450 per hour. My fee is not contingent on the outcome of this or any
`
`matter, or on the content of any of the testimony I give in this declaration. I have
`
`no financial interest in Petitioner.
`
`5.
`
`I have been informed that Ericsson (hereinafter referred to as “Patent
`
`Owner”) alleges ownership and is the current assignee of U.S. Patent No.
`
`9,300,432 (“the ’432 Patent”) (SAMSUNG-1001). I have no financial interest in
`
`the Patent Owner or the ’432 patent.
`
`II.
`
`BACKGROUND AND QUALIFICATIONS
`
`6.
`
`I have more than 20 years of experience working with standards
`
`development organizations including the Third Generation Partnership Project
`
`(“3GPP”), the European Telecommunications Standards Institute (“ETSI”), and the
`
`Open Mobile Alliance (“OMA”). I have particular experience with the
`
`development of standards related to cellular telecommunications, including the
`
`standards for the Universal Mobile Telecommunications System (“UMTS”), Long
`
`Term Evolution (“LTE”), and 5G, which are all standards developed by the 3GPP.
`
`A true and correct copy of my curriculum vitae (C.V.) is attached as Appendix A.
`
`7.
`
`I attended the University of Technology Aachen in Aachen, Germany,
`
`where I performed graduate studies in Electrical Engineering with a focus on
`
`telecommunications technologies (“Dipl.-Ing. TH” degree). I also attended the
`
`DECLARATION OF FRIEDHELM RODERMUND
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`University of Technology Trondheim in Trondheim, Norway, and completed my
`
`Diploma thesis, “Design of a dual processor computer for digital signal processing
`
`in power electronics,” in 1993.
`
`8.
`
`From December 1993 to June 1998, I worked at Mannesmann
`
`Mobilfunk as a System Engineer and Project Manager in Quality Assurance and
`
`Technical Standards. One of my responsibilities was to ensure by managing and
`
`performing related test activities that cellular network equipment was compatible
`
`with the Global System for Mobile Communications (“GSM”) standard developed
`
`by ETSI. During that time, I also started working as a standards delegate. I
`
`attended my first ETSI meeting in 1996 (although I was already following ETSI
`
`developments from 1992 during my studies).
`
`9.
`
`From June 1998 to December 2004, I worked at ETSI as a project
`
`manager for various ETSI Special Mobile Group (“SMG”) and 3GPP working
`
`groups. First, I served as a secretary of SMG4 “Data Services” and SMG8 “Base
`
`Stations Testing.” Then, as a project manager with the ETSI Mobile Competence
`
`Center (“MCC”), I supported establishing 3GPP as the new international standards
`
`development organization for cellular telecommunications. One of my roles was
`
`acting as Secretary for 3GPP’s Technical Specifications Group Terminals,
`
`Working Group (“T2”), the group which played a leading role in the creation of
`
`standards for Multimedia such as the Multimedia Messaging Service (“MMS”).
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`10. Later, I was a secretary of the highest-level Technical Specifications
`
`Group Terminals which was besides other things responsible for the development
`
`of test specifications including tests for the radio interface.
`
`11.
`
`I edited all technical specifications produced by my working groups
`
`and presented results to the parent body for approval. I attended all meetings (apart
`
`from some sub-working group meetings) and was also responsible for compiling
`
`meeting reports, for handling all the meeting documents, and managing the work
`
`plan. It was also my role to guide the groups and to advise the chairmen regarding
`
`3GPP working methods and procedures including document handling, and to make
`
`sure delegates were aware of their company’s obligations under the 3GPP
`
`Intellectual Property Right policy.
`
`12. As part of my responsibilities at ETSI, I acted as a 3GPP custodian of
`
`records by personally managing 3GPP’s public File Transfer Protocol (ftp) folders,
`
`which I used to make publicly accessible various 3GPP documents, including
`
`versions of 3GPP specifications, technical reports, liaison statements, change
`
`requests, contributions, agendas, meeting reports, and other 3GPP documents from
`
`my working groups. I am also knowledgeable about document management
`
`practices used in other working groups and within 3GPP in general with regard to
`
`making documents publicly accessible through the same, public ftp server of
`
`3GPP.
`
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`7
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`13. Since I left ETSI as a staff member in 2005, I have been continuously
`
`involved in standardization activities, including with Open Mobile Alliance, ETSI,
`
`and 3GPP. Since 2017, I also have been attending the ETSI IPR Special
`
`Committee, which is responsible for the maintenance of the ETSI IPR Policy.
`
`14. After I left ETSI, I worked from January 2005 to October 2014 at
`
`Vodafone, first as a Project Manager for Mobile Broadcast Standards, and then as
`
`Vice Chairman of the Device Management working group of the Open Mobile
`
`Alliance, and then as a Senior Standards Strategist, all with responsibilities as
`
`described on my C.V. At Vodafone, I was deeply involved in standards work with
`
`ETSI and 3GPP and other standards setting organizations, including as a delegate
`
`to 3GPP SA1 “Services.” As part of my responsibilities, I attended selected 3GPP
`
`meetings, submitted documents to 3GPP, used 3GPP resources (including 3GPP’s
`
`ftp server) extensively, and remained knowledgeable about 3GPP policies and
`
`procedures with regard to document management and public accessibility. I was
`
`also involved in the creation of patents, defense activities related to patent
`
`litigations, and patent evaluation, mostly in the context of standards development.
`
`15. Since leaving Vodafone in 2014, I have performed consulting work
`
`regarding Internet of Things (IoT) and Machine to Machine (M2M) technology
`
`and standards, first at Friedhelm Rodermund Consulting and then as the Founder
`
`and Director of IOTECC GmbH. In connection with my work, I regularly deal with
`
`DECLARATION OF FRIEDHELM RODERMUND
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`standards such as OMA’s Lightweight M2M, 3GPP’s LTE, Narrowband IoT (NB-
`
`IoT) and 5G standards. And I have extensively used 3GPP resources and have
`
`remained knowledgeable about 3GPP policies and procedures with regard to
`
`document management and public accessibility.
`
`16.
`
`I also provide consulting services related to patents, in particular
`
`around 3GPP Standard Essential Patents (“SEPs”), and I have been working as an
`
`expert witness on a number of occasions. I continue to closely follow the
`
`maintenance of the ETSI IPR Policy as a delegate to the ETSI IPR Special
`
`Committee. Furthermore, I’m conducting a seminar on SEPs and the Internet of
`
`Things at the Technical University of Ilmenau, Germany.
`
`17. At the time of writing this declaration, I am following – including
`
`attending selected meetings - the following standards committees: ETSI oneM2M,
`
`ETSI IPR Special Committee, Open Mobile Alliance, and 3GPP.
`
`18. A copy of my curriculum vitae, which includes a detailed description
`
`of my experience and education, is attached as Appendix A. A list of litigation
`
`matters on which I have worked over the last five years is also included in my
`
`curriculum vitae.
`
`III.
`
`SUMMARY OF MY OPINIONS
`
`DECLARATION OF FRIEDHELM RODERMUND
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`19.
`
`It is my opinion that R1-074426 (SAMSUNG-1006) is an authentic
`
`3GPP T-doc and would have been publicly accessible through ftp.3gpp.org no later
`
`than October 2, 2007.
`
`20.
`
`It is my opinion that TR 21.905 v7.4.0 (SAMSUNG-1010) is a
`
`technical report published by 3GPP and would have been publicly accessible
`
`through ftp.3gpp.org as of June 21, 2007.
`
`21.
`
`It is my opinion that TS 25.211 v7.4.0 (SAMSUNG-1013) is a technical
`
`specification published by 3GPP and would have been publicly accessible through
`
`ftp.3gpp.org as of December 1, 2007.
`
`22.
`
`It is my opinion that TS 25.214 v7.4.0 (SAMSUNG-1005) is a technical
`
`specification published by 3GPP and would have been publicly accessible through
`
`ftp.3gpp.org as of March 22, 2007.
`
`23.
`
`It is my opinion that TS 25.302 v7.4.0 (SAMSUNG-1014) is a technical
`
`specification published by 3GPP and would have been publicly accessible through
`
`ftp.3gpp.org as of July 16, 2007.
`
`24.
`
`It is my opinion that TS 25.331 v7.4.0 (SAMSUNG-1004) is a technical
`
`specification published by 3GPP and would have been publicly accessible through
`
`ftp.3gpp.org as of April 6, 2007.
`
`
`
`IV. PUBLICATION OF 3GPP
`SPECIFICATIONS AND RELATED DOCUMENTS
`
`DECLARATION OF FRIEDHELM RODERMUND
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`Page 10
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`
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`A. General Practices
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`25. Unless otherwise noted, the following is an accurate description of
`
`3GPP general practices from 1998 to the present, regardless of whether I use the
`
`present or past tense to describe those practices.
`
`26.
`
`3GPP was established in 1998 by a group of telecommunications
`
`standard development organizations from Japan, Korea, China, Europe, and the
`
`United States to jointly develop worldwide standards for mobile
`
`telecommunications. Today, 3GPP consists of seven partners: Association of Radio
`
`Industries and Businesses, Japan (“ARIB”), Alliance for Telecommunications
`
`Industry Solutions, USA (“ATIS”), China Communications Standards Association
`
`(“CCSA”), European Telecommunications Standards Institute (“ETSI”),
`
`Telecommunications Technology Association, Korea (“TTA”),
`
`Telecommunication Technology Committee, Japan (“TTC”). In addition to being
`
`one of the founding partners, ETSI hosts the Mobile Competence Centre (“MCC”),
`
`which provides administrative and technical support to the day-to-day work of
`
`3GPP. Furthermore, ETSI manages 3GPP’s IT services such as the 3GPP website,
`
`ftp server, and email exploders.
`
`27.
`
`3GPP is the world’s leading organization for developing and
`
`maintaining cellular telecommunications standards, which it has done since its
`
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`foundation in 1998. As noted above and in my C.V., I began working for 3GPP, as
`
`part of my work at ETSI, the European-based organizational partner of 3GPP.
`
`28.
`
`In the ordinary course of its regularly conducted business activities,
`
`and pursuant to its standard business practices, 3GPP publishes technical
`
`specifications, proposals, reports, and other documents related to the development
`
`of cellular telecommunications standards. Such documents are published for the
`
`purposes of discussion and establishment of industry standards for cellular
`
`telecommunications. This has been 3GPP’s ordinary course of business since when
`
`I began working at ETSI in 1998.
`
`29.
`
`In the ordinary course of 3GPP’s regularly conducted business
`
`activities, and pursuant to its standard business practices, all draft technical
`
`specifications, proposals, reports, and other temporary documents to be discussed
`
`or considered in relation to 3GPP’s telecommunications standards activities were,
`
`and continue to be, assigned a temporary document number and made publicly
`
`available, including on the ftp server associated with the 3GPP website, currently
`
`residing at ftp.3gpp.org. Such documents are referred to as “T-docs.” Final
`
`versions of the technical specifications also were, and continue to be, publicly
`
`available from that same ftp server.
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`30. The names and the structure of 3GPP working groups can be found
`
`below1:
`
`
`
`
`
`
`
`31. Each Technical Specification Group (TSG) or Working Group adopts
`
`a structured numbering system for the documents associated with their meetings,
`
`and those systems typically follow a consistent numbering system as shown in the
`
`
`1 See https://www.3gpp.org/specifications-groups
`
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`following example: xminnzzzz. The numbering system normally comprises five
`
`logical elements: (1) x: a single letter corresponding to the TSG; where in
`
`2007/2008 x was one of R (Radio Access Network), C (Core and Terminals), S
`
`(Service and System Aspects), or G (GSM/EDGE Radio Access Network); (2) m:
`
`A single character corresponding to the Working Group identity (typically 1, 2, 3,
`
`etc.) or, in the case of the TSG itself, the letter “P”; (3) i: Normally the hyphen
`
`character “-”; (4) nn: the calendar year of the meeting to which the document was
`
`submitted; (5) zzzz: a running number (some Working Groups use 5 digits).
`
`32.
`
`In the ordinary course of 3GPP’s regularly conducted business
`
`activities, and pursuant to its standard business practices, from December 1998
`
`onwards, 3GPP published all of its T-docs and all final versions of its technical
`
`specifications on its ftp server, which has always been easily and publicly
`
`accessible from its website and currently resides at ftp.3gpp.org.
`
`33. As early as December 1998, 3GPP’s ftp server was freely accessible
`
`to the general public with no login, password, or membership requirement.
`
`34. By 1999, at least 100 companies were members of 3GPP (by
`
`December 2020: 719 companies), ranging from Bosch to Ericsson to Nokia to
`
`Samsung and generally including those interested in the discussion, creation, and
`
`adoption of cellular telecommunications standards, including UMTS. Each of these
`
`companies typically delegated multiple individuals to regularly participate in 3GPP
`
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`meetings. Further, pursuant to 3GPP’s standard business practices, 3GPP working
`
`groups sent emails notifying these individuals as soon as new or additional
`
`documents had been uploaded to 3GPP’s ftp server. Thus, not only did the general
`
`public have access to the documents on the ftp server, but some of the most
`
`interested members of the public—those working to develop standards for cellular
`
`telecommunication or working to implement the standards—were personally
`
`informed of their availability by email. Based on my experience with 3GPP and the
`
`telecommunications industry, I would expect any person implementing a cellular
`
`network or device, e.g., an 5G network or device, to consult the corresponding
`
`specifications on the 3GPP ftp server, as well as other related documents. The
`
`whole purpose of 3GPP creating and making these specifications available was so
`
`that engineers and other individuals would have ready access to them when
`
`developing and implementing cellular networks and devices.
`
`35.
`
`3GPP specifications bear a specification number consisting of four or
`
`five digits, e.g., 09.02 or 29.002. The first two digits define the specification series
`
`which are defined to group the different aspects of the 3GPP system into e.g.
`
`requirements, service aspects, radio aspects codecs, security aspects, and test
`
`specifications. The series digits are followed by two additional digits for the 01 to
`
`13 series or three further digits for the 21 to 55 series. The subjects of the
`
`individual specification series are explained on 3GPP’s website at
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`
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`https://www.3gpp.org/specifications/specification-numbering, and reproduced
`
`below:
`
`
`
`
`
`36. For instance, the radio aspects of the 3GPP UMTS standard are covered
`
`in the “25 series” and are further subdivided into separate sections or specifications.
`
`The UMTS radio specification series starts at TS 25.053 and ends at TR 25.999.
`
`Excluding withdrawn specifications, the UMTS radio standard consists of more than
`
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`200 specifications. Each specification can span from a few pages to hundreds of
`
`pages. One full version of the UMTS standard is massive, spanning tens of thousands
`
`of pages.
`
`37.
`
`In the ordinary course of 3GPP’s regularly conducted business
`
`activities, and pursuant to its standard business practices, T-docs are usually
`
`uploaded to 3GPP’s ftp server and website before the meeting where they are to be
`
`discussed. Documents created or revised during the course of a meeting are normally
`
`uploaded at the latest during the week following the meeting (e.g., the meeting report
`
`of the meeting is usually published for review during the week following the
`
`meeting).
`
`38.
`
`In the ordinary course of 3GPP’s regularly conducted business
`
`activities, and pursuant to its standard business practices, 3GPP maintains archives
`
`that include different versions of the specifications, as well as email
`
`communications to its membership, including emails announcing the uploading of
`
`new or additional documents to 3GPP’s ftp server. These archives are created at
`
`the time the emails are initially sent.
`
`39. At least as early as July 1999, all of 3GPP’s email archives, including
`
`the dedicated email list for TSG RAN WG1 and TSG RAN WG2 were freely
`
`accessible to the general public with no login, password, or membership
`
`requirement. Each of 3GPP’s member companies typically assigned one or more
`
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`individuals to regularly participate in these email lists. Thus, not only did the
`
`general public have access to the emails in 3GPP’s email archives, but some of the
`
`most interested members of the public–those working to develop standards for
`
`cellular telecommunication–personally received copies of such emails through
`
`their participation in the email lists.
`
`40. By June 1999, 3GPP’s email archives were well-known to persons in
`
`the cellular telecommunications industry as a source of public information and of
`
`technical specifications, proposals, meeting announcements, technical discussions
`
`and reports regarding industry standards and technological advances.
`
`41. Based on my experience with 3GPP and the telecommunications
`
`industry, I would expect a person interested in the development of cellular
`
`standards, e.g., UMTS, to consult the emails archives of the working groups and
`
`TSGs that person is interested in, and/or, to be subscribed to the corresponding
`
`email reflectors to receive any email notifications in real-time.
`
`42.
`
`3GPP specifications almost always are duplicated in at least two and
`
`sometime more locations on the ftp server. One location corresponds to a
`
`“snapshot” of the specifications corresponding to a particular plenary meeting
`
`cycle, e.g., the 2018-12 snapshot contains a snapshot of numerous specifications
`
`after the December 2018 3GPP plenary meetings. The second location is an
`
`“archive” that contains all versions over time for a given specification. While
`
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`3GPP aims to upload the updated specifications to both locations at the same time,
`
`occasionally there may be a small difference in the upload date, and thus the date
`
`stamp, for the same specification uploaded to the two locations. Additionally,
`
`specifications which are not yet approved (so call “draft” specifications) are
`
`available as T-docs at working group and at plenary meetings (as soon the working
`
`group decides to submit the specification to the plenary meeting for information or
`
`approval).
`
`43. The timestamp on 3GPP’s ftp server shows the date when the
`
`document was uploaded the last time. Thus, the timestamp shows the latest
`
`possible date the document became publicly available and accessible on 3GPP’s
`
`ftp server. The given document might have been available earlier and the original
`
`timestamp might have been overwritten because the document was uploaded again.
`
`According to my experience, this is something which happened quite frequently.
`
`Thus, the ftp timestamp is reliable as the latest possible upload date but one cannot
`
`determine whether it represents the first upload of a document to the ftp server.
`
`44.
`
`3GPP’s working practice to store their documents on their ftp server,
`
`as described above, has not changed over time. Starting from the first 3GPP
`
`meetings in 1998 until present, all WGs and plenary meetings are represented by
`
`dedicated meeting folders on the ftp server. These meeting folders include the
`
`documents discussed at the meetings. Both the folders and the documents are
`
`DECLARATION OF FRIEDHELM RODERMUND
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`Page 19
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`19
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`
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`accessible to the public. Almost every week, a new meeting folder with the
`
`respective documents is added. In addition to the plenary and WG meeting folders,
`
`and some other folders, there is also the “Specs” folder, which holds all 3GPP
`
`specifications including the aforementioned “snapshot” and archive folders. Since
`
`the early days of 3GPP a new folder is added inside the “Specs” folder after each
`
`TSG plenary meeting to hold the latest versions of specifications approved at those
`
`TSG plenary meetings. This is still 3GPP’s working practice today; thus, this
`
`practice has not changed over time.
`
`B.
`
`Specific Documents
`
`1.
`
`R1-074426
`
`Based on my personal knowledge and my review of 3GPP’s business records, I
`
`recognize SAMSUNG-1006 as a true and correct copy of T-doc R1-074426, which
`
`represents a document submitted by Panasonic with the title “Rank feedback in
`
`downlink MIMO.” The document discusses rank feedback in downlink MIMO
`
`indicating the necessity for reliable rank suggestion with longer intervals. On its
`
`face, R1-074426 refers to the RAN WG1 meeting #50bis held on October 8-12,
`
`2007 in Shanghai, China. Thus, based on my personal knowledge and experience
`
`with ETSI’s and 3GPP’s standard business practices, this information tells me that
`
`R1-074426 was available either prior or during that meeting to at least all attending
`
`3GPP members. The availability of the document is confirmed by the date stamp,
`
`DECLARATION OF FRIEDHELM RODERMUND
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`Page 20
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`20
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`
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`October 2, 2007, shown on the historic 3GPP ftp server for the corresponding
`
`downloadable file (“R1-074426.zip”), as maintained by the Internet Archive at
`
`https://web.archive.org/web/20170318161927/http://www.3gpp.org:80/ftp/tsg_ran/
`
`WG1_RL1/TSGR1_83/Docs as well as the date stamp for the present-day listing of
`
`the same document on the 3GPP ftp server
`
`https://www.3gpp.org/ftp/tsg_ran/WG1_RL1/TSGR1_83/Docs as can be seen at
`
`the screen shot below:
`
`45.
`
`In addition, the information for the downloaded and extracted T-doc
`
`file states a last Modified date of “2. Oct 2007.” Here is a screenshot showing
`
`
`
`those file details:
`
`
`
`DECLARATION OF FRIEDHELM RODERMUND
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`Page 21
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`21
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`
`
`46. The official meeting report of the RAN WG1 meeting #50bis held on
`
`October 08-12, 2007 in Shanghai, China can be found in Appendix B. According to
`
`the 3GPP website at https://portal.3gpp.org/Meetings.aspx#/ which is shown by the
`
`screen shot below, that meeting was attended by 175 individuals (out of 236
`
`registered participants):
`
`
`
`DECLARATION OF FRIEDHELM RODERMUND
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`Page 22
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`22
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`
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`
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`
`
`47. The meeting report has a document list attached (Appendix C) which
`
`has T-doc R1-074426 marked as “available” which clearly indicates that the
`
`document was available at the meeting. The screen shot below shows the related
`
`excerpt of the document list:
`
`48. Furthermore,
`
`the
`
`document was
`
`distributed
`
`via
`
`the
`
`3GPP_TSG_RAN_WG1 email exploder on October 3, 2007 as shown in Appendix
`
`D. At that time this email exploder had around 1000 subscribers as can be seen by
`
`
`
`DECLARATION OF FRIEDHELM RODERMUND
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`Page 23
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`23
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`
`
`the
`
`Internet
`
`Archive
`
`https://web.archive.org/web/20070827091800/http://list.3gpp.org/.
`
`
`
`at
`
`49. Thus, based on my personal knowledge and experience with ETSI’s
`
`and 3GPP’s standard business practices, this information tells me that this document
`
`was available to all 3GPP members and the general public by October 2, 2007, at
`
`the latest.
`
`
`
`2.
`
`TR 21.905 v7.4.0
`
`50.
`
` Based on my personal knowledge and my review of 3GPP’s business
`
`records, I recognize SAMSUNG-1010 as a true and correct copy of version 7.4.0
`
`of technical report 3GPP TR 21.905 (“Technical Specification Group Services and
`
`System Aspects; Vocabulary for 3GPP Specifications (Release 7)”) which shows
`
`on its cover page “2007-06” as the year (2007) and month (June) during which this
`
`document was released by 3GPP. The document was published and freely
`
`available on 3GPP’s ftp server by June 21, 2007. This is confirmed by the date
`
`stamp shown on the historic 3GPP ftp server for the corresponding downloadable
`
`file (“21905-740.zip”), as maintained by the Internet Archive at
`
`https://web.archive.org/web/20070822172534/http://www.3gpp.org:80/ftp/specs/ar
`
`chive/21_series/21.905, as well as the date stamp for the present-day listing of the
`
`same document on the 3GPP ftp server at
`
`DECLARATION OF FRIEDHELM RODERMUND
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`Page 24
`
`24
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`
`
`https://www.3gpp.org/ftp/Specs/archive/21_series/21.905/ as shown by the
`
`screenshot below:
`
`
`
`51.
`
`In addition, the information for the downloaded and extracted
`
`specification file states a last Modified date of “21. June 2007.” Here is a
`
`screenshot showing those file details:
`
`
`
`
`
`
`
`
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 25
`
`25
`
`
`
`
`
`
`
`
`
`52. Thus, based on my personal knowledge and experience with ETSI’s
`
`and 3GPP’s standard business practices, this information tells me that this document
`
`was available to all 3GPP members and the general public by June 21, 2007, at the
`
`latest.
`
`
`
`DECLARATION OF FRIEDHELM RODERMUND
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`Page 26
`
`
`
`26
`
`
`
`
`
`3.
`
`TS 25.211 V7.4.0
`
`53. Based on my personal knowledge and my review of 3GPP’s business
`
`records, I recognize SAMSUNG-1013 as a true and correct copy of version 7.4.0 of
`
`technical specification 3GPP TS 25.211 (“Technical Specification Group Radio
`
`Access Network; Physical channels and mapping of transport channels onto physical
`
`channels (FDD) (Release 7)”), which shows on its cover page “2007-11” as the year
`
`(2007) and month (November) during which this document was released by 3GPP.
`
`The document was published and freely available on 3GPP’s ftp server by December
`
`1, 2007. This is confirmed by the date stamp shown on the historic 3GPP ftp server
`
`for the corresponding downloadable file (“25211-740.zip”), as maintained by the
`
`Internet Archive at
`
`https://web.archive.org/web/20080103160023/http://www.3gpp.org:80/ftp/Specs/a
`
`rchive/25_series/25.211. This information is also shown on the date stamp for the
`
`present-day listing of the same document on the 3GPP ftp server at
`
`
`
`https://www.3gpp.org/ftp/Specs/archive/25_series/25.211, as shown by the screen
`
`shot below:
`
`
`
`
`
`
`
`
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 27
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`27
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`
`
`
`
`54.
`
`In addition, metadata information for the downloaded and extracted
`
`specification file states a last Modified date of “1. Dec 2007”, as shown in the screen
`
`
`
`shot below:
`
`
`
`
`
`
`
`
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 28
`
`28
`
`
`
`
`
`
`
`55. Thus, based on my personal knowledge and experience with ETSI’s
`
`and 3GPP’s standard business practices, this information tells me that this document
`
`was available to all 3GPP members and the general public by December 1, 2007, at
`
`the latest.
`
`
`
`
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 29
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`29
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`
`
`
`
`4.
`
`TS 25.214 V7.4.0
`
`56. Based on my personal knowledge and my review of 3GPP’s business
`
`records, I recognize SAMSUNG-1005 as a true and correct copy of version 7.4.0 of
`
`technical specification 3GPP TS 25.214 (“Technical Specification Group Radio
`
`Access Network; Physical layer procedures (FDD) (Release 7)”), which shows on
`
`its cover page “2007-03” as the year (2007) and month (March) during which this
`
`document was released by 3GPP. The document was published and freely available
`
`on 3GPP’s ftp server by March 22, 2007. This is confirmed by the date stamp shown
`
`on the historic 3GPP ftp server for the corresponding downloadable file (“25214-
`
`740.zip”), as maintained by th
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