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`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`
`TCT MOBILE (US) INC., TCT MOBILE (US) HOLDINGS INC., TCL
`COMMUNICATION TECHNOLOGY HOLDINGS LIMITED, TCT MOBILE
`INTERNATIONAL LIMITED, TCT MOBILE, INC., CRADLEPOINT, INC.,
`DELL INC., HONEYWELL INTERNATIONAL, INC., SIERRA WIRELESS,
`INC., THALES DIS AIS DEUTSCHLAND GMBH, ZTE CORPORATION, ZTE
`(USA) INC.,
`
`Petitioners
`v.
`SISVEL S.P.A.,
`
`Patent Owner
`__________
`U.S. Patent No. 8,971,279
`__________
`
`DECLARATION OF MARK R. LANNING IN SUPPORT OF PETITION
`FOR INTER PARTES REVIEW OF U.S. PATENT NO. 8,971,279
`CHALLENGING CLAIMS 1, 3-5, 11, and 13-15
`
`
`
`
`Ex. 1002 – TCT Mobile (US) Inc.
`TCT Mobile (US) Inc. v. Sisvel S.P.A., IPR2021-00678
`Page 1 of 243
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`

`

`Expert Declaration of Mark R. Lanning in Support of
`Inter Partes Review of U.S. Patent No. 8,971,279
`
`
`TABLE OF CONTENTS
`
`Page
`
`Introduction .................................................................................................... 1
`I.
`Background and Qualifications ...................................................................... 1
`II.
`III. Documents and Other Materials Relied Upon ................................................ 5
`IV. Relevant Patent Law and Legal Standards ..................................................... 6
`A. Date of Invention .................................................................................. 6
`B.
`Obviousness ......................................................................................... 6
`C.
`Standard of Proof ................................................................................. 9
`Level of Ordinary Skill in the Art .................................................................. 9
`V.
`VI. Relevant technology background ................................................................. 11
`A.
`The LTE Cellular Network ................................................................ 11
`1.
`LTE Overview ......................................................................... 11
`2.
`Physical Downlink Control CHannel (PDCCH). ..................... 24
`3.
`The RNTI and C-RNTI ............................................................ 27
`VII. Overview of the ’279 patent and Its Prosecution History ............................ 28
`A.
`Summary of the Prosecution History of the ’279 patent .................... 28
`B.
`Summary of the Disclosure of the ’279 patent ................................... 30
`C.
`The Priority Date of the ’279 Patent .................................................. 64
`VIII. Claim Construction ....................................................................................... 64
`IX. The Prior Art ................................................................................................. 65
`A. Dahlman, Erik et al., “3G Evolution: HSPA and LTE for Mobile
`Broadband,” 2nd edition, Elsevier Ltd., October 2008 (“Dahlman”, Ex.
`1003) .................................................................................................. 65
`3GPP Technical Specification Group for Radio Access Network
`published the “Missing details of semi-persistent scheduling”
`Technical Revision Specification R1-083718, 3GPP TSG-RAN WG1
`
`B.
`
`
`
`i
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`Expert Declaration of Mark R. Lanning in Support of
`Inter Partes Review of U.S. Patent No. 8,971,279
`
`
`X.
`
`C.
`
`B.
`
`C.
`D.
`
`Meeting #54bis, Prague, Czech Republic, September 29-October 3,
`2008 (“Nokia,” Exhibit 1004) ............................................................ 71
`3GPP Technical Specification Group for Radio Access Network
`published the “SPS resource release” Technical Revision
`Specification R2-084455, 3GPP TSG-RAN2#63 Meeting, Jeju, South
`Korea, August 18th-22nd (“Samsung,” Exhibit 1005) ....................... 72
`Invalidity of the ’279 CHALLENGED Claims ............................................ 74
`A. An Obvious Dahlman-Samsung Combination ................................... 76
`1.
`Technical Description of Dahlman-Samsung Combination .... 77
`2.
`Reasons for Constructing Dahlman-Samsung Combination ... 80
`An Obvious Nokia-Samsung Combination ........................................ 87
`1.
`Technical Description of Nokia-Samsung Combination ......... 87
`2.
`Reasons for Constructing the Nokia-Samsung Combination .. 88
`An Obvious Dahlman-Nokia-Samsung Combination ........................ 95
`The ’279 patent Claim Elements ........................................................ 97
`A method for deactivating Semi-Persistent Scheduling (SPS)
`1.
`transmission in a wireless mobile communication system, the
`method comprising: ................................................................. 97
`A User Equipment (UE) used for in a wireless mobile
`communication system, the UE configured to: ...................... 104
`“performing, by a User Equipment (UE), a SPS transmission at
`an interval of a subframe period configured by a radio resource
`control (RRC) signal” and “perform a Semi-Persistent
`Scheduling (SPS) transmission at an interval of a subframe
`period configured by a radio resource control (RRC) signal.”
`................................................................................................ 108
`“receiving, by the UE, a Physical Downlink Control Channel
`(PDCCH) signal with a Radio Network Temporary Identifier
`(RNTI), wherein the PDCCH signal includes a first field related
`to a resource allocation; and” and “receive a Physical Downlink
`
`2.
`
`3.
`
`4.
`
`
`
`ii
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`Expert Declaration of Mark R. Lanning in Support of
`Inter Partes Review of U.S. Patent No. 8,971,279
`
`
`5.
`
`6.
`
`Control Channel (PDCCH) signal with a Radio Network
`Temporary Identifier (RNTI), wherein the PDCCH signal
`includes a first field related to a resource allocation; and” .... 113
`performing a procedure for deactivating the SPS transmission if
`the PDCCH signal satisfies conditions for SPS deactivation 117
`wherein the conditions for SPS deactivation include: the RNTI
`is a SPS Cell RNTI (SPS C-RNTI) ........................................ 120
`the first field is entirely filled with ‘1’ ................................... 122
`wherein the PDCCH signal carries a Downlink Control
`Information (DCI) format ‘0’ ................................................. 128
`wherein the first field indicates a Resource Indication Value
`(RIV) ...................................................................................... 131
`“further comprising: continuing, by the UE, the SPS
`transmission if the PDCCH signal does not satisfy the
`conditions for SPS deactivation” and “wherein the UE is further
`configured to continue the SPS transmission if the PDCCH
`signal does not satisfy the conditions for SPS deactivation.” 137
`XI. Concluding Statements ............................................................................... 141
`Appendix A ............................................................................................................... 1
`Appendix B ............................................................................................................... 1
`Appendix C ............................................................................................................... 1
`
`Introduction .................................................................................................... 1
`I.
`Background and Qualifications ...................................................................... 1
`II.
`III. Documents and Other Materials Relied Upon ................................................ 5
`IV. Relevant Patent Law and Legal Standards ..................................................... 6
`A. Date of Invention .................................................................................. 6
`B.
`Obviousness ......................................................................................... 6
`C.
`Standard of Proof ................................................................................. 9
`
`7.
`8.
`
`9.
`
`10.
`
`
`
`iii
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`Expert Declaration of Mark R. Lanning in Support of
`Inter Partes Review of U.S. Patent No. 8,971,279
`
`Level of Ordinary Skill in the Art .................................................................. 9
`V.
`VI. Relevant technology background ................................................................. 11
`A.
`The LTE Cellular Network ................................................................ 11
`VII. Overview of the ’279 patent and Its Prosecution History ............................ 28
`A.
`Summary of the Prosecution History of the ’279 patent .................... 28
`B.
`Summary of the Disclosure of the ’279 patent ................................... 30
`C.
`The Priority Date of the ’279 Patent .................................................. 64
`VIII. Claim Construction ....................................................................................... 64
`IX. The Prior Art ................................................................................................. 65
`A. Dahlman, Erik et al., “3G Evolution: HSPA and LTE for Mobile
`Broadband,” 2nd edition, Elsevier Ltd., October 2008 (“Dahlman”, Ex.
`1003) .................................................................................................. 65
`3GPP Technical Specification Group for Radio Access Network
`published the “Missing details of semi-persistent scheduling”
`Technical Revision Specification R1-083718, 3GPP TSG-RAN WG1
`Meeting #54bis, Prague, Czech Republic, September 29-October 3,
`2008 (“Nokia,” Exhibit 1004) ............................................................ 71
`3GPP Technical Specification Group for Radio Access Network
`published the “SPS resource release” Technical Revision
`Specification R2-084455, 3GPP TSG-RAN2#63 Meeting, Jeju, South
`Korea, August 18th-22nd (“Samsung,” Exhibit 1005) ....................... 72
`Invalidity of the ’279 CHALLENGED Claims ............................................ 74
`A. An Obvious Dahlman-Samsung Combination ................................... 76
`B.
`An Obvious Nokia-Samsung Combination ........................................ 87
`C.
`An Obvious Dahlman-Nokia-Samsung Combination ........................ 95
`D.
`The ’279 patent Claim Elements ........................................................ 97
`XI. Concluding Statements ............................................................................... 141
`Appendix A ............................................................................................................... 1
`Appendix B ............................................................................................................... 1
`iv
`
`X.
`
`
`
`B.
`
`C.
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`Expert Declaration of Mark R. Lanning in Support of
`Inter Partes Review of U.S. Patent No. 8,971,279
`
`Appendix C ............................................................................................................... 1
`
`
`
`v
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`I.
`
`Expert Declaration of Mark R. Lanning in Support of
`Inter Partes Review of U.S. Patent No. 8,971,279
`
`
`INTRODUCTION
`I, Mark R. Lanning, declare as follows:
`1. My name is Mark R. Lanning. I have been asked by Petitioners to
`
`provide my expert opinions in support of the above-identified petition for inter
`
`partes review of U.S. Patent No. 8,971,279 (“the ’279 patent”), challenging the
`
`validity of claims 1, 3-5, 11, and 13-15 (the “Challenged Claims”).
`
`2.
`
`3.
`
`I currently hold the opinions set forth in this declaration.
`
`In summary, it is my opinion that the references cited below render
`
`obvious claims 1, 3-5, 11, and 13-15 of the ’279 patent. My detailed opinions on
`
`the claims are set forth below and further detailed in Appendix A (Ground I claim
`
`charts) and Appendix B Grounds II and III claim charts. My detailed analysis for
`
`Ground IV uses Appendix A and claims [1.5] and [11.4] from Appendix B).
`
`4.
`
`I am being compensated for my time at the rate of $550 per hour.
`
`This compensation is not contingent upon my performance, the outcome of this
`
`matter, or any issues involved in or related to this matter.
`
`II. BACKGROUND AND QUALIFICATIONS
`5.
`I have extensive experience in the field of telecommunications
`
`including: circuit-switched networks; multiple generations of cellular networks;
`
`and packet-switched networks.
`
`Lanning Declaration
`
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`Page 1 of 142
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`Expert Declaration of Mark R. Lanning in Support of
`Inter Partes Review of U.S. Patent No. 8,971,279
`
`
`Further details on my education, work experience, and the cases in
`
`6.
`
`which I have previously given testimony in the past four years are contained in my
`
`curriculum vitae (CV). See Appendix C.
`
`7.
`
`I am currently the president of two consulting companies: Telecom
`
`Architects, Inc. and Reticle Consulting, LLC. Telecom Architects provides
`
`consulting services to fixed and wireless telecom service providers and their
`
`equipment suppliers. I have been President of Telecom Architects since 1999.
`
`8.
`
`I have over 38 years of experience working in the telecommunications
`
`industry that began in the U.S. Army Signal Corp. My experience relevant to this
`
`case includes my work as an architect of various telecommunications systems and
`
`my work developing equipment used in telecommunications systems. This
`
`experience includes extensive design, implementation and testing work on the
`
`wireless interface functionality (between the base station and mobile phones) for
`
`multiple generations of cellular standards.
`
`9.
`
`I received a B.S. in Computer Science from Southern Methodist
`
`University (SMU) in 1983.
`
`10. DSC, now a part of Alcatel, hired me in 1983 where I was a software
`
`development manager on the team responsible for converting DSC’s PSTN
`
`telephone switch into a Mobile Switching Center (MSC) for Motorola to sell as a
`
`part of their cellular product offering in the U.S. and many other countries.
`Lanning Declaration
`Page 2 of 142
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`Expert Declaration of Mark R. Lanning in Support of
`Inter Partes Review of U.S. Patent No. 8,971,279
`
`
`In 1991, I began working as a consultant to Motorola for its
`
`11.
`
`“SuperCell” base station product and as a consultant to British Telecom to upgrade
`
`its current analog cellular network and I was one of the network architects
`
`responsible for the design and rollout of its Global System for Mobile
`
`Communications (“GSM”) network known as Cellnet. Beginning in the early
`
`1990s, I was responsible for implementation of the SMS service, including
`
`working with suppliers of the SMS Center (SMSC), Mobile Switching Centers
`
`(MSCs) and cellular phones to define and roll out the functionality that was to be
`
`provided.
`
`12.
`
`I was personally involved with Nokia, Ericsson, Motorola and other
`
`equipment suppliers in this effort.
`
`13. Since 1995, I have also provided second generation (2G) and third
`
`generation (3G) Code Division Multiple Access (“CDMA”) network architecture
`
`and equipment design and implementation consulting services to companies such
`
`as Sprint, Nextel, Nokia, and Ericsson. While consulting to Nextel, which has
`
`since become part of Sprint, as one of the network architects for its iDEN network,
`
`one of my responsibilities was to define the network and mobile phone
`
`functionality required to support MMS and advanced data communications
`
`capability.
`
`Lanning Declaration
`
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`Page 3 of 142
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`Expert Declaration of Mark R. Lanning in Support of
`Inter Partes Review of U.S. Patent No. 8,971,279
`
`
`In addition to my cellular experience listed above, for at least the past
`
`14.
`
`ten years, I have kept up-to-date my knowledge of the present-day 3G, 4G, and 5G
`
`cellular network and wireless standards and their associated equipment and
`
`protocols. I have done this through my study of each new release of these
`
`standards, technical books and trade publications as well as my expert work in
`
`legal cases, which has involved evaluating the functionality of many different
`
`types of network equipment, mobile devices, and baseband chipsets. I have also
`
`evaluated thousands of cellular technology patents and most of these were for
`
`cellular phone and/or base station functionality.
`
`15.
`
`I am a member of the Institute of Electrical and Electronics Engineers
`
`(IEEE), including the IEEE Standards Association. I am also a member of the
`
`Association for Computing Machinery (ACM). While employed at DSC, I was a
`
`member of the ANSI T1 and T1X1 standard groups responsible for the definition
`
`and standardization of the Advanced Intelligent Network (AIN) and Signaling
`
`System 7 (SS7) protocol.
`
`16.
`
`I was retained as a technical expert by defendants, TCT Mobile (US)
`
`Inc., TCT Mobile (US) Holdings Inc. TCL Communication Technology Holdings
`
`Limited, TCT Mobile International Limited, and TCT Mobile, Inc.
`
`Lanning Declaration
`
`
`Page 4 of 142
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`Expert Declaration of Mark R. Lanning in Support of
`Inter Partes Review of U.S. Patent No. 8,971,279
`
`
`III. DOCUMENTS AND OTHER MATERIALS RELIED UPON
`17.
`In forming the opinions set forth in this declaration, I have reviewed
`
`the documents in the below table.
`
`Exhibit
`Number
`1001
`1002
`
`1003
`
`1004
`
`1005
`
`1006
`1007
`
`1008
`1009
`1010
`
`1011
`1012
`
`1013
`
`1014
`1015
`1016
`
`
`
`Description
`U.S. Patent No. 8,971,279 to Dong Youn Seo et al. (“the ’279 patent”)
`Declaration of Mark Lanning Ph.D. in Support of Petition for Inter Partes
`Review of U.S. Patent No. 8,971,279 (“Lanning”)
`Dahlman, Erik et al., “3G Evolution: HSPA and LTE for Mobile Broadband,”
`2nd edition, Elsevier Ltd., October 2008 (“Dahlman”).
`3GPP Technical Specification Group for Radio Access Network published the
`“Missing details of semi-persistent scheduling” Technical Revision
`Specification R1-083718, 3GPP TSG-RAN WG1 Meeting #54bis, Prague,
`Czech Republic, September 29-October 3, 2008 (“Nokia”).
`3GPP Technical Specification Group for Radio Access Network published the
`“SPS resource release” Technical Revision Specification R2-084455, 3GPP
`TSG-RAN2#63 Meeting, Jeju, South Korea, August 18th-22nd (“Samsung”).
`Declaration of James L. Mullins, Ph.D.
`Declaration of Craig Bishop in Support of Petition for Inter Partes Review of
`U.S. Patent No. 8,971,279 (“Bishop”)
`’279 patent Notice of Allowance
`11/10/2010 Office Action in U.S. Patent Application No. 12/581,584
`2/10/2011 Response to Office Action in U.S. Patent Application No.
`12/581,584
`https://www.3gpp.org/technologies/keywords-acronyms/98-lte.
`LTE in a nutshell.
`https://home.zhaw.ch/kunr/NTM1/literatur/LTE%20in%20a%20Nutshell%20-
`%20Physical%20Layer.pdf
`How LTE Stuff Works?: RNTIs in LTE.
`http://howltestuffworks.blogspot.com/2014/10/rntis-in-lte.html
`3GPP TS 36.321 (2008-September)
`3GPP TS 36.213 V8.4.0 (2008-September)
`3GPP LTE: Introducing Single-Carrier FDMA by Agilent Technologies
`
`Lanning Declaration
`
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`Page 5 of 142
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`Expert Declaration of Mark R. Lanning in Support of
`Inter Partes Review of U.S. Patent No. 8,971,279
`
`
`18. Additionally, I have utilized my own experience and expertise,
`
`including that regarding the knowledge and capabilities of a person of ordinary
`
`skill in the relevant art in the timeframe of the claimed priority date of the ’279
`
`patent.
`
`IV. RELEVANT PATENT LAW AND LEGAL STANDARDS
`A. Date of Invention
`19.
`I have been asked to use the date of the filing of the earliest
`
`application to which priority is claimed (i.e., November 13, 2008) as the date of
`
`invention for purposes of my analysis.
`
`B. Obviousness
`20.
`I am informed and understand that a patent claim is invalid under 35
`
`U.S.C. § 103 if the differences between the invention and the prior art are such that
`
`the subject matter as a whole would have been obvious at the time of the invention
`
`to a person having ordinary skill in the art to which the subject matter pertains.
`
`Obviousness, as has been explained to me, is based on (i) the scope and content of
`
`the prior art, (ii) the differences between the prior art and the claim, (iii) the level
`
`of ordinary skill in the art, and, (iv) any secondary indicia of non-obviousness
`
`(e.g., “secondary considerations” such as commercial success in the market place
`
`of the claimed invention), to the extent that they exist.
`
`Lanning Declaration
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`Page 6 of 142
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`Expert Declaration of Mark R. Lanning in Support of
`Inter Partes Review of U.S. Patent No. 8,971,279
`
`
`I further understand that obviousness may be shown by showing that
`
`21.
`
`it would have been obvious to combine the teachings of more than one item of
`
`prior art. In determining whether a piece of prior art could have been combined
`
`with other prior art or with other information within the knowledge of a person
`
`having ordinary skill in the art, the following are examples of approaches and
`
`rationales that may be considered:
`
`• Combining prior art elements according to known methods to yield
`
`predictable results;
`
`• Simple substitution of one known element for another to obtain
`
`predictable results;
`
`• Use of a known technique to improve similar devices (methods, or
`
`products) in the same way;
`
`• Applying a known technique to a known device (method, or product)
`
`ready for improvement to yield predictable results;
`
`• Applying a technique or approach that would have been obvious to try
`
`(choosing from a finite number of identified, predictable solutions,
`
`with a reasonable expectation of success);
`
`• 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
`
`Lanning Declaration
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`Expert Declaration of Mark R. Lanning in Support of
`Inter Partes Review of U.S. Patent No. 8,971,279
`
`
`incentives or other market forces if the variations would have been
`
`predictable to a person having ordinary skill in the art; and
`
`• 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.
`
`22.
`
`I further understand that an invention may be obvious if one of
`
`ordinary skill in the art, facing a wide range of needs created by developments in
`
`the field, would have seen an obvious benefit to the solutions tried by the
`
`applicant. When there is a design need or market pressure to solve a problem and
`
`there are a finite number of identified, predictable solutions, it may be obvious to a
`
`person of ordinary skill to try the known options. If a technique has been used to
`
`improve one device, and a person of ordinary skill in the art would recognize that it
`
`would improve similar devices in the same way, using the technique would have
`
`been obvious.
`
`23.
`
`I further understand that a person of ordinary skill in the art is a
`
`hypothetical person who is presumed to be aware of all of the relevant art at the
`
`time of the invention. The person of ordinary skill is not an automaton, and may
`
`be able to fit together the teachings of multiple patents and/or printed publications
`
`Lanning Declaration
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`Expert Declaration of Mark R. Lanning in Support of
`Inter Partes Review of U.S. Patent No. 8,971,279
`
`
`employing ordinary creativity and the common sense that familiar items may have
`
`uses in another context or beyond their primary purposes.
`
`24.
`
`I also understand that when considering the obviousness of a patent
`
`claim, one should consider whether a teaching, suggestion, or motivation to
`
`combine the references exists so as to avoid impermissibly applying hindsight
`
`when combining or modifying the prior art. I understand this test should not be
`
`applied rigidly, but that the test can be important to avoid such hindsight.
`
`25.
`
`I also understand that one of ordinary skill in the art must have a
`
`reasonable expectation of success in combining or modifying prior art references.
`
`26.
`
`I also understand that all elements of a claim must be considered in an
`
`obviousness analysis.
`
`C. Standard of Proof
`27.
`I understand that the standard to prove unpatentability in an inter
`
`partes review proceeding is by a preponderance of the evidence, which means
`
`more likely than not.
`
`V. LEVEL OF ORDINARY SKILL IN THE ART
`28.
`I have considered the level of ordinary skill in the art relevant to the
`
`’279 patent. I understand that factors such as the education level of those working
`
`in the field, the sophistication of the technology, the types of problems encountered
`
`Lanning Declaration
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`Expert Declaration of Mark R. Lanning in Support of
`Inter Partes Review of U.S. Patent No. 8,971,279
`
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`in the art, the prior art solutions to those problems, and the speed at which
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`innovations are made may help establish the level of skill in the art.
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`29. After reviewing the ’279 patent, the relevant portions of the
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`prosecution history of the ’279 patent, and cited references, it is my opinion that
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`the relevant art of the ’279 patent is in the general field of wireless mobile
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`communication systems. See Ex. 1001, Abstract, 1:22-23.1
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`30. Specifically, the ’279 patent relates to techniques for scheduling semi-
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`persistent scheduling (SPS) of uplink and downlink data transmissions. Ex. 1001
`
`at 1:22-29. The ’279 patent allegedly reduces the signaling message overhead for
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`deactivating the SPS resources by using certain code points (values in a specific
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`portion of a signaling message) that are unused in an existing prior art signaling
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`message and filling those codepoints with a binary ‘1’ value. Ex. 1001 at 3:56-
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`4:11, 21:25-32, 21:61-67. Certain of the code points in the bitfield are used for
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`allocations, it is only the unused codepoints that are used for deallocation. Id.
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`31. Based upon my knowledge of this field, I conclude that a person of
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`ordinary skill in the art (“POSITA”) at the time of the alleged invention of the ’279
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`patent (i.e., around November 13, 2008), and for that matter, at all subsequent
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`times through the present, would have held at least a degree in electrical
`
`
`1 All cites to the exhibits are to the original exhibit page numbers.
`Lanning Declaration
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`Page 10 of 142
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`Ex. 1002 – TCT Mobile (US) Inc.
`TCT Mobile (US) Inc. v. Sisvel S.P.A., IPR2021-00678
`Page 16 of 243
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`Expert Declaration of Mark R. Lanning in Support of
`Inter Partes Review of U.S. Patent No. 8,971,279
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`engineering, computer engineering, computer science or a similar discipline, with
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`at least three years of relevant industry or research experience, including
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`experience designing or implementing wireless radio systems for data transmission
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`and retransmission. Additional work or research experience can substitute for less
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`or different education, and vice-versa. A person of ordinary skill in the art would
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`also have had familiarity with the 3GPP technical specifications at the time,
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`including LTE. Ex. 1001, 1:31-35.
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`32.
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`I am and was at the time of the alleged invention at least a person of
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`skill in the relevant art, of a level at least as high as or more than ordinarily skilled
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`persons, and I am able to provide insight and opinions into the understandings of
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`such persons at all relevant times by virtue of my education, training and
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`experience.
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`VI. RELEVANT TECHNOLOGY BACKGROUND
`A. The LTE Cellular Network
`1.
`LTE Overview
`33. The ’279 patent discloses that its alleged invention is for use in the
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`Third Generation Partnership Project Long Term Evolution (3GPP “LTE”) 4G
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`cellular standard. Ex. 1001, ’279 patent at 1:31-35. The ’279 patent claims a
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`particular method for deactivating the Semi-Persistent Scheduling (SPS)
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`functionality based on information the UE may receive from the base station
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`Lanning Declaration
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`Page 11 of 142
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`Ex. 1002 – TCT Mobile (US) Inc.
`TCT Mobile (US) Inc. v. Sisvel S.P.A., IPR2021-00678
`Page 17 of 243
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`Expert Declaration of Mark R. Lanning in Support of
`Inter Partes Review of U.S. Patent No. 8,971,279
`
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`(eNodeB) on one of the LTE control channels called the Physical Downlink
`
`Control Channel (PDCCH):
`
`2. Discussion of the Related Art
`A 3rd Generation Partnership Project Long Term
`Evolution
`(3GPP LTE)
`communication
`system
`(hereinafter referred
`to as an "LTE system" for
`convenience of description) will hereinafter be described
`as an example of a mobile communication system
`applicable to the present invention.
`Ex. 1001, ’279 patent at 1:30-35.
`
`In another aspect of the present invention, there is
`provided a wireless communication apparatus including a
`radio frequency (RF) unit, and a processor electrically
`connected to the RF unit, wherein the processor is
`configured to fill the entirety of a binary field indicating
`resource allocation information contained in a downlink
`control channel with '1 ', and to transmit the downlink
`control channel to a user equipment (UE), the binary field
`being entirely filled with the value of' 1' indicates a release
`of resources allocated to the UE.
`The downlink control channel may be a physical
`downlink control channel (PDCCH).
`Id. at ’279 patent at 4:66-5:9; emphases added.
`
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`34. The ’279 patent also discloses the UE sending information to the base
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`station (eNodeB) using the LTE Physical Uplink Control Channel (PUCCH) with
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`at least:
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`a Physical Uplink Control Channel (PUCCH) for
`transmitting control information, such as HARQ ACK or
`NACK Scheduling Request (SR) and Channel Quality
`
`Lanning Declaration
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`Page 12 of 142
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`Ex. 1002 – TCT Mobile (US) Inc.
`TCT Mobile (US) Inc. v. Sisvel S.P.A., IPR2021-00678
`Page 18 of 243
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`Expert Declaration of Mark R. Lanning in Support of
`Inter Partes Review of U.S. Patent No. 8,971,279
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`Indicator (CQI) report information, received from first and
`second layers (Ll and L2).
`FIG. 8 shows physical channels used for a 3GPP LTE
`system serving as an example of a mobile communication
`system and a general signal transmission method capable
`of using the physical channels.
`Id. at ’279 patent at 9:23-31 and Fig. 8; emphases added.
`
`35. Based on my personal experience, the LTE 4G standard was the most
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`complex cellular standard that had been defined by the 2008-2009 timeframe.
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`However, the 4G cellular standard was not created from scratch. Instead, as shown
`
`by the figure below published on the 3GPP website, it was built on many of the
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`concepts and methods that were defined and proven by the 2G GSM and 3G
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`UMTS standards that were defined before it. The UMTS standard had been used
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`by millions of users worldwide for at least 5 years before the ’279 patent.
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`Lanning Declaration
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`Page 13 of 142
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`Ex. 1002 – TCT Mobile (US) Inc.
`TCT Mobile (US) Inc. v. Sisvel S.P.A., IPR2021-00678
`Page 19 of 243
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`Expert Declaration of Mark R. Lanning in Support of
`Inter Partes Review of U.S. Patent No. 8,971,279
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`Ex. 1011 at Figure 1 (https://www.3gpp.org/technologies/keywords-acronyms/98-
`
`
`
`lte).
`
`36.
`
`I describe here the evolution from earlier standards to LTE to show
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`the extent of the existing technical foundation on which LTE was built. I also
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`discuss later in Sections VII.B and IX the extent of what was already known in the
`
`LTE sta