`
`
`
`
`
`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, AND
`ZTE (USA) INC.,
`
`Petitioners
`
`v.
`
`SISVEL S.P.A.,
`
`Patent Owner
`
`__________
`
`U.S. Patent No. 7,319,718
`__________
`
`
`DECLARATION OF CRAIG BISHOP IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW OF U.S. PATENT NO. 7,319,718
`
`
`
`IPR2021-00908 Honeywell Exh. 1015
`(Honeywell International, Inc., et al. v. 3G Licensing S.A.)
`
`

`

`Expert Declaration of Craig Bishop in Support of
`Inter Partes Review of U.S. Patent No. 7,319,718
`
`
`TABLE OF CONTENTS
`
`Page
`
`I.
`
`Introduction ............................................................................................... 1
`
`II. Qualifications ............................................................................................. 2
`
`III. Public Availability of 3GPP Technical Specifications and Other
`Documents .................................................................................................. 7
`
`A.
`
`B.
`
`C.
`
`D.
`
`E.
`
`F.
`
`Prominence and Purpose of 3GPP ...................................................... 7
`
`3GPP’s Policy and Practice of Making Documents Public ................11
`
`3GPP Structure and Standards Development Process........................12
`
`3GPP Temporary Documents............................................................16
`
`The 3GPP Listserv ............................................................................18
`
`The 3GPP Public File Repository .....................................................22
`
`IV. Exhibit 1004 (R1-02-0046) ........................................................................25
`
`V.
`
`Exhibit 1005 (R1-02-0654) ........................................................................28
`
`VI. Exhibit 1006 (R1-02-0356) ........................................................................29
`
`VII. Exhibit 1007 (R1-02-0628) ........................................................................32
`
`VIII. Exhibit 1008 (R1-02-0791) ........................................................................35
`
`IX. Exhibit 1009 (R1-02-0927) ........................................................................37
`
`X.
`
`Exhibit 1010 (R1-02-0354) ........................................................................40
`
`XI. Exhibit 1021 (R1-02-0019) ........................................................................42
`
`XII. Exhibit 1022 (R1-01-1144) ........................................................................45
`
`XIII. Conclusion .................................................................................................46
`
`XIV. Declaration ................................................................................................50
`
`
`
`309324407.7
`
`
`
`i
`
`IPR2021-00908 Honeywell Exh. 1015
`(Honeywell International, Inc., et al. v. 3G Licensing S.A.)
`
`

`

`Expert Declaration of Craig Bishop in Support of
`Inter Partes Review of U.S. Patent No. 7,319,718
`
`
`I.
`
`INTRODUCTION
`
`I, Craig Bishop, declare as follows:
`
`1.
`
`I have been retained as an independent expert witness on behalf of
`
`Petitioners related to Inter Partes Review (“IPR”) of U.S. Patent No. 7,319,718
`
`(“the ’718 patent”).
`
`2.
`
`I am being compensated for my work in this matter at my accustomed
`
`hourly rate. I am also being reimbursed for reasonable and customary expenses
`
`associated with my work and testimony in this investigation. My compensation is
`
`not contingent on the results of my study, the substance of my opinions, or the
`
`outcome of this matter.
`
`3.
`
`In forming the opinions expressed within this Declaration I have
`
`reviewed and considered the following exhibits, each of which is a type of material
`
`that experts in my field would reasonably rely upon when forming opinions:
`
`Exhibits 1004 1005, 1006, 1007, 1008, 1009, 1010, 1021, and 1022. I have also
`
`relied on my own academic background, knowledge, and professional experiences
`
`in the field of wireless communications and 3GPP standards-development, as
`
`described below.
`
`4.
`
`Although I have attempted to organize the information presented in
`
`this Declaration into helpful sections and/or divisions, my opinions are supported
`
`by the information in the Declaration in its entirety.
`
`Bishop Declaration
`309324407.7
`
`
`
`Page 1 of 51
`
`IPR2021-00908 Honeywell Exh. 1015
`(Honeywell International, Inc., et al. v. 3G Licensing S.A.)
`
`

`

`Expert Declaration of Craig Bishop in Support of
`Inter Partes Review of U.S. Patent No. 7,319,718
`
`
`II. QUALIFICATIONS
`
`5. My complete qualifications and professional experience are described
`
`in my curriculum vitae, a copy of which has been attached as Exhibit 1017. The
`
`following is a summary of my relevant qualifications and professional experience.
`
`6.
`
`I earned my Bachelor of Electronic Engineering degree with Honors
`
`from Polytechnic of Central London in 1989. In 2005, I earned my MSC in
`
`Computer Science with Distinction from the University of Kent.
`
`7.
`
`After graduating with my first degree, I worked as an operations
`
`engineer at the British Broadcasting Corporation (BBC) for 4 years, then as a civil
`
`servant at the UK Radiocommunications Agency until 1996, during which time I
`
`became involved in telecommunications standardization in the European
`
`Telecommunication Standards Institute (“ETSI”), working in particular in
`
`Technical Committee Radio Equipment and Systems (TC RES2) concerned with
`
`the standardization of Private Mobile Radio (PMR). From 1994 through 1996, I
`
`acted as Rapporteur for voice and data related PMR standards ETS 300 113, ETS
`
`300 219 and ETS 300 390. I participated as the only TC RES2 delegate on behalf
`
`of the UK Radiocommunications Agency, generating proposals in support of UK
`
`administration and business requirements, downloading and reviewing other
`
`meeting input documents, and proposing changes as necessary to ensure input
`
`documents and the resulting specifications were in line with said requirements.
`
`Bishop Declaration
`309324407.7
`
`
`
`Page 2 of 51
`
`IPR2021-00908 Honeywell Exh. 1015
`(Honeywell International, Inc., et al. v. 3G Licensing S.A.)
`
`

`

`Expert Declaration of Craig Bishop in Support of
`Inter Partes Review of U.S. Patent No. 7,319,718
`
`
`8.
`
`In 1996, I joined Samsung Electronic Research Institute as a Senior
`
`Standards Engineer where I worked for 16 years, eventually becoming Director of
`
`Standards and Industry Affairs in 2011. My work at Samsung mainly focused on
`
`the standardization of GSM/GPRS, UMTS, and LTE/EPS systems. Initially, I
`
`participated in ETSI Special Mobile Group (SMG) committees SMG1, SMG2,
`
`SMG4, SMG5, SMG9 and relevant UMTS related sub-committees working on the
`
`air interface radio access network protocols, service, and terminal aspects of
`
`UMTS and GSM/GPRS until 1999. I was specifically involved in the ETSI SMG2
`
`meetings leading up to selection of WCDMA as the radio access technology for the
`
`Frequency Division Duplex mode of UMTS.
`
`9.
`
`Beginning in 1998, I worked as a Principal Standards Engineer on the
`
`3rd Generation Partnership Project (3GPP) on UMTS. I have been involved with
`
`3GPP since its inception. I attended the inaugural 3GPP TSG meetings held in
`
`December 1998, and I began attending Working Group meetings in 1999.
`
`Specifically, I regularly attended Radio Access Network (RAN) WG1, Services &
`
`System Aspects (SA) WG1, Terminals (T) WG2, but also other Working Groups
`
`and Technical Specification Group (TSG) plenary meetings covering similar
`
`technical aspects as in my previous work in ETSI. As examples, RAN WG1 was,
`
`and is, a Working Group responsible for the specification of the physical layer of
`
`the latest wireless cellular standards, and RAN WG2 was, and is, a Working Group
`
`Bishop Declaration
`309324407.7
`
`
`
`Page 3 of 51
`
`IPR2021-00908 Honeywell Exh. 1015
`(Honeywell International, Inc., et al. v. 3G Licensing S.A.)
`
`

`

`Expert Declaration of Craig Bishop in Support of
`Inter Partes Review of U.S. Patent No. 7,319,718
`
`
`responsible for signaling protocol layers 2 and 3 residing just above the physical
`
`layer. As part of this work, I would prepare meeting contributions in support of
`
`Samsung’s research and development activities. Also, by way of preparation for
`
`each meeting, I would download all contributions and review those of interest to
`
`Samsung, and where necessary, prepare additional input to the meeting based on
`
`said review.
`
`10. Beginning in 2000, I acted as project manager and then as system
`
`engineering manager at Samsung, providing technical requirements for the team
`
`working on Samsung’s UMTS modem development. This involved scrutiny of
`
`ongoing standardization work, particularly in RAN WG1, RAN WG2, and TSG
`
`Core Network (CN) WG1, from which I would download, and assess the impact
`
`of, contributions on Samsung’s development project, ensuring that Samsung’s
`
`development team was kept informed about the latest developments as layers 1, 2
`
`and 3 of the UMTS standard were stabilized.
`
`11. During this period, in addition to authoring and presenting technical
`
`contributions for the 3GPP standard, and producing technical requirements for the
`
`radio modem, I acted as Rapporteur for 3GPP Technical Reports covering User
`
`Equipment (“UE”) capability requirements (3GPP TR 21.904) from 1999–2000,
`
`and the Evolution of the 3GPP System (3GPP TR 21.902) in 2003 (the first Study
`
`Item to consider the 3GPP system beyond UMTS towards LTE/EPS).
`
`Bishop Declaration
`309324407.7
`
`
`
`Page 4 of 51
`
`IPR2021-00908 Honeywell Exh. 1015
`(Honeywell International, Inc., et al. v. 3G Licensing S.A.)
`
`

`

`Expert Declaration of Craig Bishop in Support of
`Inter Partes Review of U.S. Patent No. 7,319,718
`
`
`12.
`
`In 2005, I became Head of Advanced Technologies, Standards and
`
`Regulation (ATSR) at Samsung. In addition to my managerial duties which
`
`included responsibility for standards, research, and regulatory engineers including
`
`three standards engineers who were regularly attending 3GPP RAN WG2 and Core
`
`Network and Terminals (CT) WG1 Working Groups, I personally continued to
`
`work on 3GPP standardization issues. From 2005 until 2008, I regularly attended
`
`and participated in SA WG2 meetings, mainly focusing on IP Multimedia
`
`Subsystem (IMS) including voice over IMS but also looking at wider Evolved
`
`Packet System (EPS) related issues. From 2008 until 2011, I regularly attended
`
`and participated in SA WG1 meetings. I also attended SA plenary meetings from
`
`2008 until I left Samsung in 2013. As well as generating contributions in support
`
`of Samsung’s research and development as preparation for each meeting, I would
`
`download and review documents from other 3GPP members, identifying those of
`
`interest to Samsung and, where necessary, preparing additional contributions on
`
`behalf of Samsung. The work required a sound working knowledge of the broader
`
`3GPP system to ensure effective management of the ATSR team, effective
`
`participation in meeting discussions, expert assessment of third-party standards
`
`contributions, and provision of implementation guidance to Samsung developers.
`
`13. From 2006 until I stopped attending SA WG1 meetings in 2011, I
`
`authored and presented over 100 contributions to SA WG2 and SA WG1 meetings
`
`Bishop Declaration
`309324407.7
`
`
`
`Page 5 of 51
`
`IPR2021-00908 Honeywell Exh. 1015
`(Honeywell International, Inc., et al. v. 3G Licensing S.A.)
`
`

`

`at 3GPP and appeared as an author/co-author on 18 patent applications related to
`
`Expert Declaration of Craig Bishop in Support of
`Inter Partes Review of U.S. Patent No. 7,319,718
`
`
`User Equipment operation in the IMS and the 3GPP Core Network.
`
`14.
`
`In 2011, I became Director of Standards and Industry Affairs at
`
`Samsung, and in November of that year I was elected to the Board of ETSI on
`
`which I served for a term of 3 years until November 2014.
`
`15. Since leaving Samsung in January 2013, I have become a member of
`
`ETSI, and as part of various projects undertaken, I have continued to regularly
`
`access the 3GPP and ETSI document servers, and to keep abreast of 3GPP and
`
`ETSI document handling and publication practices.
`
`16. Through my extensive work on 3GPP standardization issues, I have
`
`become very familiar with 3GPP’s practices relating to making final specifications,
`
`draft standards, and standards-related contributions publicly available, including in
`
`the 1999–2011 timeframe when I was attending or monitoring various 3GPP
`
`Working Groups including RAN WG1 and RAN WG2.
`
`17. For the purposes of my analysis in this Declaration, I have been
`
`informed by counsel that a person of ordinary skill in the art (“POSITA”) in the
`
`field of the ’718 patent in approximately 2003 would have had a degree in
`
`electrical engineering or a similar discipline, with at least three years of relevant
`
`industry or research experience (or additional education). The relevant experience
`
`Bishop Declaration
`309324407.7
`
`
`
`Page 6 of 51
`
`IPR2021-00908 Honeywell Exh. 1015
`(Honeywell International, Inc., et al. v. 3G Licensing S.A.)
`
`

`

`would include a working understanding of the then-existing wireless cellular
`
`Expert Declaration of Craig Bishop in Support of
`Inter Partes Review of U.S. Patent No. 7,319,718
`
`
`communications standards.
`
`III. PUBLIC AVAILABILITY OF 3GPP TECHNICAL
`SPECIFICATIONS AND OTHER DOCUMENTS
`
`18. Based on my years of experience working in various capacities in
`
`3GPP and on 3GPP technical specifications issues, I am familiar with the regular
`
`business practices of the 3rd Generation Partnership Project (“3GPP”) relating to
`
`technical documents including specifications, draft standards and proposals, and
`
`standards-related technical contributions—including the business practices through
`
`which 3GPP makes these documents public.
`
`A.
`
`Prominence and Purpose of 3GPP
`
`19.
`
`3GPP was inaugurated in December 1998 to produce Technical
`
`Specifications and Technical Reports for the 3G mobile system called Universal
`
`Mobile Telecommunications System (“UMTS”). Ex. 1026, at 2–3 (3GPP
`
`Partnership Project Description). A number of standards organizations agreed to
`
`cooperate to produce a “complete set of globally applicable Technical
`
`Specifications” that would then be transposed into standards by the relevant
`
`standardization bodies (also known as “Organizational Partners”). Id. at 3, 5.
`
`20.
`
`3GPP is a global initiative partnership made up of the aforementioned
`
`Organizational Partners, as well as market representation partners, and individual
`
`members. Ex. 1027, at 7−8 (3GPP Working Procedures). Today, 3GPP unites
`
`Bishop Declaration
`309324407.7
`
`
`
`Page 7 of 51
`
`IPR2021-00908 Honeywell Exh. 1015
`(Honeywell International, Inc., et al. v. 3G Licensing S.A.)
`
`

`

`Expert Declaration of Craig Bishop in Support of
`Inter Partes Review of U.S. Patent No. 7,319,718
`
`
`seven telecommunications standard development organizations (“Organizational
`
`Partners”) from around the world: the Association of Radio Industries and
`
`Businesses (ARIB) and the Telecommunication Technology Committee (TTC)
`
`from Japan, the China Communications Standards Association (CCSA) from
`
`China, the Telecommunications Standards Development Society, India (TSDSI)
`
`from India, the Telecommunications Technology Association (TTA) from Korea,
`
`the European Telecommunications Standards Institute (ETSI), and the Alliance for
`
`Telecommunications Industry Solutions (ATIS) from the United States.1 These
`
`Organizational Partners are regional standards organizations that have the authority
`
`to define, publish, and set standards for their respective regions. Ex. 1026, at 12.
`
`3GPP also includes “Market Representation Partners” that represent various
`
`industry perspectives and offer market advice. Ex. 1027, at 9. Additionally, 3GPP
`
`includes individual member companies (“Individual Members”) that are permitted
`
`to participate in 3GPP through their membership of a 3GPP Organizational
`
`Partner. Id. at 8, 10. As an example of how prominent 3GPP was in the industry,
`
`350 delegates attended the first 3GPP Technical Meeting in December 1998. Ex.
`
`1028, at 6 (GSM and UMTS: The Creation of Global Mobile Communication; See
`
`page 217 on success of 3GPP).
`
`
`1 The specific organizational partners that make up 3GPP have changed over time.
`
`Bishop Declaration
`309324407.7
`
`
`
`Page 8 of 51
`
`IPR2021-00908 Honeywell Exh. 1015
`(Honeywell International, Inc., et al. v. 3G Licensing S.A.)
`
`

`

`Expert Declaration of Craig Bishop in Support of
`Inter Partes Review of U.S. Patent No. 7,319,718
`
`
`21. As noted in paragraph 19, a primary goal of 3GPP is to provide an
`
`environment to produce technical specifications and technical reports that define
`
`and standardize technologies covering cellular telecommunications networks,
`
`including User Equipment or Mobile Device (UE) technologies, Radio Access
`
`Network (RAN) technologies, Core Network (CN) technologies, and service and
`
`system capabilities—including work on codecs, security, and quality of service.
`
`The specifications also provide hooks for interworking with non-3GPP networks
`
`including but not limited to Wi-Fi networks.
`
`22. Given the prominence of 3GPP in the wireless communication
`
`industry, beginning in 1998 and continuing through today, interested POSITAs
`
`were tracking the developments of the latest 3GPP specifications and other
`
`submissions to ensure timely development of products and services developed by
`
`their companies that were consistent with the standards being developed. In other
`
`words, it is my opinion that a POSITA in cellular communications would have to
`
`be familiar with 3GPP and the specification-related documents produced as part of
`
`the 3GPP process in order to properly perform his or her job. Without access to
`
`and knowledge of the 3GPP documentation, including for example the substantive
`
`contents of 3GPP technical specifications, an engineer could not develop products
`
`that were interoperable with the worldwide 3G (and later 4G) standards. Because
`
`3GPP documents were an important aspect of a POSITA’s professional experience,
`
`Bishop Declaration
`309324407.7
`
`
`
`Page 9 of 51
`
`IPR2021-00908 Honeywell Exh. 1015
`(Honeywell International, Inc., et al. v. 3G Licensing S.A.)
`
`

`

`Expert Declaration of Craig Bishop in Support of
`Inter Partes Review of U.S. Patent No. 7,319,718
`
`
`textbooks and articles about cellular communications commonly directed readers
`
`to the 3GPP website for information regarding standards development. Ex. 1028,
`
`at 23 (See page 246 directing readers to the 3GPP website at the conclusion of the
`
`chapter on the success of 3GPP in the standards development process). As a
`
`POSITA in cellular communications myself, I would regularly visit the 3GPP
`
`website for the latest developments in 3G standards setting and refer colleagues
`
`involved in the development of 3G devices to the 3GPP website as a valuable
`
`reference.
`
`23. My personal experience at Samsung confirms 3GPP’s prominence in
`
`the wireless industry. Engineers and managers at Samsung who were responsible
`
`for developing 3G modem software (and who were not attending 3GPP meetings
`
`or involved with 3GPP in any direct way) regularly asked me to which version of a
`
`given 3GPP specification they should be developing their products as well as how
`
`various passages of the specifications should be interpreted. Similarly, managers
`
`at Samsung would ask me when specific 3GPP releases would be ready and what
`
`would be included in those releases. A significant part of my role at Samsung was
`
`to ensure that Samsung’s development engineers were made aware of changes and
`
`proposals made in the 3GPP development process that would likely impact their
`
`work—and to discuss the implications of those changes or proposals with them.
`
`Such communication became so regular that around 2003 we began holding regular
`
`Bishop Declaration
`309324407.7
`
`
`
`Page 10 of 51
`
`IPR2021-00908 Honeywell Exh. 1015
`(Honeywell International, Inc., et al. v. 3G Licensing S.A.)
`
`

`

`Expert Declaration of Craig Bishop in Support of
`Inter Partes Review of U.S. Patent No. 7,319,718
`
`
`feedback sessions between those of us involved with 3GPP and the development
`
`engineers who were not directly involved in the 3GPP work. I also maintained an
`
`internal company database at that time, which tracked changes that had been
`
`approved by 3GPP, to help the various development groups at Samsung stay
`
`informed as to changes that would impact their development work. The database
`
`contained summaries of changes introduced (and by whom), a brief assessment on
`
`the potential impact of the change, and the time and date information, including from
`
`which version the change was introduced. The database also included links to
`
`relevant 3GPP documents so that engineers could access the documents directly. In
`
`short, the technical work of 3GPP was at the forefront of development at Samsung,
`
`even for engineers who were not involved with creating specifications or contributing
`
`to the 3GPP process.
`
`B.
`
`3GPP’s Policy and Practice of Making Documents Public
`
`24.
`
`3GPP’s policy was to make 3GPP documents available to the public,
`
`including to interested POSITAs. The free availability of 3GPP documents to any
`
`interested member of the public was widely recognized in the industry. For
`
`example, textbooks and other sources directed readers to the 3GPP website for
`
`information about relevant standards. Making the documents available to the
`
`public was intended to help foster discussion and collaboration among 3GPP
`
`Working Group members, as well as among other interested POSITA.
`
`Bishop Declaration
`309324407.7
`
`
`
`Page 11 of 51
`
`IPR2021-00908 Honeywell Exh. 1015
`(Honeywell International, Inc., et al. v. 3G Licensing S.A.)
`
`

`

`Expert Declaration of Craig Bishop in Support of
`Inter Partes Review of U.S. Patent No. 7,319,718
`
`
`25. Because the purpose of 3GPP was worldwide adoption of a common
`
`standard, no restrictions on distribution or discussion were placed on 3GPP
`
`documents. For example, I personally recall sharing some documents with a
`
`colleague who was not involved in the 3GPP process. As another example, the
`
`internal company database I created at Samsung, discussed in paragraph 24,
`
`included links to 3GPP documents so that others (including individuals not
`
`involved with 3GPP) could access those documents directly. This type of
`
`document sharing—providing documents to those outside 3GPP to foster technical
`
`development—has always been accepted and encouraged by 3GPP. Ex. 1029, at
`
`¶3.3 (3GPP Frequently Asked Questions, “No password is needed to access any
`
`information on the 3GPP Web site, all information is openly published.”).
`
`C.
`
`3GPP Structure and Standards Development Process
`
`26. Within 3GPP, responsibility for producing specifications was
`
`delegated to the Technical Specification Groups (“TSGs”). Ex. 1027, at 14−15
`
`(“TSG tasks”). Each TSG is further divided into a number of Working Groups
`
`(“WGs”). Id. at 11. Two of the TSGs were (and still are) called: TSG Radio Access
`
`Networks (“RAN”) and TSG Service & Systems Aspects (“SA”). Two other TSGs,
`
`TSG Core Networks (“CN”) and TSG Terminals (“T”), were amalgamated under
`
`Core Network and Terminals (“CT”) following the closure of TSG T in 2005, with
`
`responsibility for terminal test specifications being moved to a RAN working group
`
`Bishop Declaration
`309324407.7
`
`
`
`Page 12 of 51
`
`IPR2021-00908 Honeywell Exh. 1015
`(Honeywell International, Inc., et al. v. 3G Licensing S.A.)
`
`

`

`Expert Declaration of Craig Bishop in Support of
`Inter Partes Review of U.S. Patent No. 7,319,718
`
`
`(RAN WG5). A fifth TSG, GSM EDGE Radio Access Networks (GERAN), was
`
`responsible for evolution of the GSM radio technology until it closed in 2016 and its
`
`work was transferred to a RAN working group responsible for legacy systems (RAN
`
`WG6) which itself closed in July 2020. POSITAs would have been aware of the
`
`division of work by subject matter among the TSGs and among the Working Groups
`
`within each TSG. Ex. 1026, at 32–35 (3GPP Partnership Project Description, listing
`
`subject matter covered by each TSG). This division of work among the TSGs
`
`“result[ed] in a process that is able to rapidly produce and approve specifications and
`
`reports in response to the needs of the market.” Ex. 1028, at 16 (See page 239).
`
`Within each TSG, each Working Group also focused on particular subject matter. A
`
`brief description of each Working Group’s technology area could be found on the
`
`Working Group home pages on the 3GPP website. With such guidance, POSITAs
`
`would have been aware of the division of work among TSG Working Groups,
`
`including what subject matter each Working Group was responsible for.
`
`27. The TSGs held quarterly plenary meetings where members’
`
`contributions, draft specifications/reports, and other documents that had been
`
`agreed upon by the Working Groups were presented for discussion and approval.
`
`Ex. 1027, at 26 (“Deliverable types,” stating that Technical Specifications and
`
`Technical Reports are “drawn up by the TSGs” and are approved by TSGs). Once
`
`a Technical Specification was, or Change Requests creating a new version of a
`
`Bishop Declaration
`309324407.7
`
`
`
`Page 13 of 51
`
`IPR2021-00908 Honeywell Exh. 1015
`(Honeywell International, Inc., et al. v. 3G Licensing S.A.)
`
`

`

`Expert Declaration of Craig Bishop in Support of
`Inter Partes Review of U.S. Patent No. 7,319,718
`
`
`Technical Specification were, formally approved by TSG plenary, the latest
`
`version of said Technical Specification would be created by the Mobile
`
`Competence Centre (MCC2) and uploaded to the file server. Ex. 1029, at ¶5.16. In
`
`that way, the conclusion of 3GPP TSG plenary meetings serves as notice that new
`
`versions of specifications incorporating Change Requests approved by the TSG
`
`meeting will shortly be made available on the public 3GPP server. The Working
`
`Groups also met regularly. The attendees (also called “delegates”) at these
`
`meetings were engineers representing telecommunications organizations from
`
`around the world such as equipment manufacturers, mobile network operators, and
`
`services providers, including for example AT&T, Ericsson, Nokia, Qualcomm, and
`
`Samsung, among many others. The Working Groups were not exclusive groups of
`
`specialists. Instead, most, if not all, of the major 3GPP members sent delegates to
`
`these meetings and Working Group meetings often had over a hundred delegates in
`
`attendance. Ex. 1030 (RAN1 #25 Meeting Information, list of participants). Most,
`
`if not all, of those delegates would have been POSITAs at the time of their
`
`attendance at these Working Group meetings.
`
`28. As discussed below, as part of the standards development process,
`
`delegates could submit contributions (“TDocs” − see below) on behalf of the
`
`
`2 Part of the ETSI secretariat supporting 3GPP activities.
`
`Bishop Declaration
`309324407.7
`
`
`
`Page 14 of 51
`
`IPR2021-00908 Honeywell Exh. 1015
`(Honeywell International, Inc., et al. v. 3G Licensing S.A.)
`
`

`

`Expert Declaration of Craig Bishop in Support of
`Inter Partes Review of U.S. Patent No. 7,319,718
`
`
`Individual Members. Members had an incentive to stay updated on 3GPP
`
`developments because the members usually wanted to contribute to the standard
`
`and to make suggestions as to what technologies and/or features should (or should
`
`not) be included. Delegates also attended 3GPP meetings to keep their employers
`
`abreast of developments related to the standards that would ultimately apply to
`
`those companies and the products those companies produced. 3GPP members
`
`around the world—and the interested POSITAs employed by them—would have
`
`been motivated to stay up to date regarding 3GPP developments to ensure their
`
`products, networks, and research programs remained consistent with and relevant
`
`to the specifications being developed. In light of this need to follow the standards
`
`development process, delegates often distributed 3GPP-related documents far
`
`beyond the attendees at 3GPP meetings. This was certainly my experience at
`
`Samsung, as I described in paragraph 26.
`
`29. Although attendance at 3GPP meetings was generally limited to 3GPP
`
`members, the public, including interested POSITAs, would have been made aware
`
`of Working Group meeting dates and times on 3GPP’s website and via 3GPP
`
`Working Group email lists. For example, POSITAs would have been aware of the
`
`meeting information pages for each TSG Working Group. E.g., Ex. 1027, at 21
`
`(“TSG and WG meeting invitation” and “TSG and WG meeting agenda”).
`
`Bishop Declaration
`309324407.7
`
`
`
`Page 15 of 51
`
`IPR2021-00908 Honeywell Exh. 1015
`(Honeywell International, Inc., et al. v. 3G Licensing S.A.)
`
`

`

`Expert Declaration of Craig Bishop in Support of
`Inter Partes Review of U.S. Patent No. 7,319,718
`
`
`D.
`
`3GPP Temporary Documents
`
`30. The technical specifications and reports developed by 3GPP were, and
`
`are, driven by the technical contributions of 3GPP members. As part of that
`
`development process, various types of documents were produced. As relevant to
`
`this proceeding, the 3GPP process involved the consideration of temporary
`
`documents3 (“TDocs,” also referred to as “technical contributions,” or “member
`
`contributions,”), resulting in the production of technical specifications.
`
`31. Prior to each Working Group meeting, members of the Working
`
`Group could prepare TDocs to identify, discuss, and/or propose a new feature or
`
`change(s) to an existing feature or to identify a technical issue for discussion.
`
`32. POSITAs would have known that TDocs could be a helpful source of
`
`technical information regarding the 3GPP specifications. Each TDoc was assigned
`
`a TDoc number, according to a standard format set by 3GPP. (Some documents,
`
`
`3 The term “temporary” is used to designate documents that are submitted to
`
`and dealt with by 3GPP TSGs and WGs in the process of elaborating the
`
`standards, but do not constitute permanent 3GPP deliverables such as
`
`Technical Specifications and Reports. Temporary documents are
`
`permanently archived by and freely available from 3GPP once they have
`
`been submitted.
`
`Bishop Declaration
`309324407.7
`
`
`
`Page 16 of 51
`
`IPR2021-00908 Honeywell Exh. 1015
`(Honeywell International, Inc., et al. v. 3G Licensing S.A.)
`
`

`

`Expert Declaration of Craig Bishop in Support of
`Inter Partes Review of U.S. Patent No. 7,319,718
`
`
`other than technical contributions, such as meeting reports, were also assigned
`
`TDoc numbers, for ease of reference.) As described in the 3GPP Working
`
`Procedures, the numbering system followed the format: xminnzzzz.ext. Ex. 1027,
`
`at 22. Within that format, “x” referred to the relevant TSG. Id. For example, “R”
`
`was used for TSG RAN. Id. Likewise, “m” referred to the relevant Working
`
`Group. Id. A document for RAN WG1 would therefore begin with “R1,” and a
`
`document for the TSG RAN plenary would use the letter “P” instead of a number.
`
`Id. The digit “i” is normally a hyphen character but may take on other values. Id.
`
`The two digits “nn” represented the year (e.g., 03), and the digits “zzzz”
`
`represented the unique document number. Id. This general naming convention has
`
`been in use since at least 1999 with only minor variations.4 Id. at 22, 47 (Annex J:
`
`Change History). Specifically, the allocated document number was used as the
`
`TDoc’s filename. Id. at 22. Documents were compressed to “.zip” files, such that
`
`a TDoc with number, “R1-030001,” would be contained in the file “R1-
`
`030001.zip.”
`
`
`4 E.g. in RAN WG1 during 2000, 2001, and 2002, it became the convention to
`
`include an additional hyphen between the year characters “nn” and the digits
`
`representing the unique document number “zzzz.”
`
`Bishop Declaration
`309324407.7
`
`
`
`Page 17 of 51
`
`IPR2021-00908 Honeywell Exh. 1015
`(Honeywell International, Inc., et al. v. 3G Licensing S.A.)
`
`

`

`Expert Declaration of Craig Bishop in Support of
`Inter Parte