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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`XIAOMI COMMUNICATIONS CO., LTD.,
`Petitioner
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`v.
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`KONINKLIJKE KPN N.V.,
`Patent Owner
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`Case IPR2022-00025
`Patent No. 8,886,772
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`DECLARATION OF DR. ROBERT AKL, D.Sc.
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`TABLE OF CONTENTS
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`Introduction ....................................................................................................... 5
`I.
`II. Background and Qualifications ........................................................................ 6
`III. Level of Ordinary Skill in the Art ...................................................................12
`IV. Materials Considered and Relied Upon ..........................................................13
`V. Legal Standards ...............................................................................................14
`A.
`Legal Standards for Prior Art ..............................................................14
`B.
`Legal Standard for Obviousness .........................................................15
`VI. Overview of the ’772 Patent ...........................................................................19
`A.
`Subject Matter Overview ....................................................................19
`B.
`File History of the ’772 Patent ............................................................25
`C.
`Interpretation of the ’772 Patent Claims at Issue ................................26
`VII. GROUND 1 — Chatrath Renders Obvious Claims 1-6 and 8-16 .................26
`A. Overview of Chatrath .........................................................................27
`B.
`Claim 1 ................................................................................................31
`C.
`Claim 2 ................................................................................................50
`D.
`Claim 3 ................................................................................................52
`E.
`Claim 4 ................................................................................................54
`F.
`Claim 5 ................................................................................................56
`G.
`Claim 6 ................................................................................................57
`H.
`Claim 8 ................................................................................................58
`I.
`Claim 9 ................................................................................................60
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`Claim 10 ..............................................................................................60
`J.
`Claim 11 ..............................................................................................62
`K.
`Claim 12 ..............................................................................................63
`L.
`M. Claim 13 ..............................................................................................65
`N.
`Claim 14 ..............................................................................................66
`O.
`Claim 15 ..............................................................................................66
`P.
`Claim 16 ..............................................................................................68
`VIII. GROUND 2 — Chatrath in view of Oh Renders Obvious Claim 7 ..............68
`A. Overview of Oh ...................................................................................68
`B.
`Claim 7 ................................................................................................70
`IX. GROUND 3 — Schliserman in view of Tullberg Renders Obvious
`Claims 1-6 and 8-16.......................................................................................74
`A. Overview of Schliserman ....................................................................74
`B.
`Overview of Tullberg ..........................................................................79
`C.
`Obviousness to Combine Schliserman and Tullberg ..........................83
`D.
`Claim 1 ................................................................................................86
`E.
`Claim 2 ..............................................................................................105
`F.
`Claim 3 ..............................................................................................106
`G.
`Claim 4 ..............................................................................................109
`H.
`Claim 5 ..............................................................................................111
`I.
`Claim 6 ..............................................................................................112
`J.
`Claim 8 ..............................................................................................114
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`Claim 9 ..............................................................................................116
`K.
`Claim 10 ............................................................................................118
`L.
`M. Claim 11 ............................................................................................119
`N.
`Claim 12 ............................................................................................120
`O.
`Claim 13 ............................................................................................122
`P.
`Claim 14 ............................................................................................123
`Q.
`Claim 15 ............................................................................................123
`R.
`Claim 16 ............................................................................................125
`X. Additional Remarks ......................................................................................126
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`I, Robert Akl, D.Sc. of Dallas, Texas, declare that:
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`I.
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`Introduction
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`1. My name is Robert Akl, and I have been retained by counsel for Xiaomi
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`Communications Co., Ltd. (“Petitioner”) as an expert witness to provide assistance
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`regarding U.S. Patent No. 8,886,772 (“the ’772 patent”). Specifically, I have been
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`asked to consider the validity of claims 1-16 of the ’772 patent (the “Challenged
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`Claims”) in view of prior art, anticipation and obviousness considerations, and
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`understanding of a person of ordinary skill in the art (“POSITA”) at the time of the
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`invention as it relates to the ’772 patent. I have personal knowledge of the facts and
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`opinions set forth in this declaration and believe them to be true. If called upon to do
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`so, I would testify competently thereto.
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`2.
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`I am being compensated for my time at my standard consulting rate. I
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`am also being reimbursed for expenses that I incur during the course of this work.
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`My compensation is not contingent upon the results of my study, the substance of
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`my opinions, or the outcome of any proceeding involving the challenged claims. I
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`have no financial interest in the outcome of this matter or on the pending litigation
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`between Petitioner and Patent Owner.
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`3. My analysis here is based on my years of education, research and
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`experience, as well as my investigation and study of relevant materials, including
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`those cited herein.
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`4.
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`I may rely upon these materials, my knowledge and experience, and/or
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`additional materials to rebut arguments raised by the Patent Owner. Further, I may
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`also consider additional documents and information in forming any necessary
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`opinions, including documents that may not yet have been provided to me.
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`5. My analysis of the materials produced in this proceeding is ongoing and
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`I will continue to review any new material as it is provided. This declaration
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`represents only those opinions I have formed to date. I reserve the right to revise,
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`supplement, and/or amend my opinions stated herein based on new information and
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`on my continuing analysis of the materials already provided.
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`II. Background and Qualifications
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`6.
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`I am an expert
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`in
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`the field of computer networking and
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`telecommunication systems. I have studied, taught, practiced, and researched this
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`field for over 25 years. I have summarized in this section my educational background,
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`work experience, and other relevant qualifications. Attached hereto as Appendix A,
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`is a true and correct copy of my curriculum vitae describing my background and
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`experience.
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`7.
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`I earned my Bachelor of Science degrees in Electrical Engineering and
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`Computer Science summa cum laude with a grade point average of 4.0/4.0 and a
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`ranking of first in my undergraduate class from Washington University in St. Louis
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`in 1994. In 1996, I earned my Master of Science degree in Electrical Engineering
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`from Washington University in St. Louis with a grade point average of 4.0/4.0. I
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`earned my Doctor of Science in Electrical Engineering from Washington University
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`in St. Louis in 2000, again with a grade point average of 4.0/4.0, with my dissertation
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`being on “Cell Design to Maximize Capacity in Cellular Code Division Multiple
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`Access (CDMA) Networks.”
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`8. While a graduate student, from 1996 through 2000, I worked at
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`MinMax Corporation in St. Louis, where I designed software packages that provided
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`tools to flexibly allocate capacity in a CDMA communications network and
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`maximize the number of subscribers. I also analyzed and simulated different audio
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`compression schemes. I also validated
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`the hardware architecture for an
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`Asynchronous Transfer Mode (ATM) switch capable of channel group switching, as
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`well as performed logical and timing simulations, and developed the hardware
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`architecture for the ATM switch. I also worked with Teleware Corporation in Seoul,
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`South Korea, where I designed and developed algorithms that were commercially
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`deployed in a software package suite for analyzing the capacity in a CDMA network
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`implementing the IS-95 standard to maximize the number of subscribers.
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`9.
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`After obtaining my Doctor of Science degree, I worked as a Senior
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`Systems Engineer at Comspace Corporation from October of 2000 to December of
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`2001. At Comspace, I designed and developed advanced data coding and modulation
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`methods for improving the reliability and increasing the available data rates for
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`cellular communications. I coded and simulated different encoding schemes
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`(including Turbo coding, Viterbi decoding, trellis coded modulation, and Reed-
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`Muller codes) and modulation techniques using amplitude and phase characteristics
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`and multi-level star constellations. This work further entailed the optimization of
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`soft decision parameters and interleavers for additive white Gaussian and Rayleigh
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`faded channels. In addition, I also extended the control and trunking of Logic
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`Trunked Radio (LTR) to include one-to-one and one-to-many voice and data
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`messaging.
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`10.
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`In January of 2002, I joined the faculty of the University of New
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`Orleans in Louisiana as an Assistant Professor in the Department of Electrical
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`Engineering. While in this position, I designed and taught two new courses called
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`“Computer Systems Design I and II.” I also developed a Computer Engineering
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`Curriculum with a strong hardware-design emphasis, formed a wireless research
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`group, and advised graduate and undergraduate students.
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`11.
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`In September of 2002, I received an appointment as an Assistant
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`Professor in the Department of Computer Science and Engineering at the University
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`of North Texas (UNT), in Denton, Texas. In May of 2008, I became a tenured
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`Associate Professor in the Department of Computer Science and Engineering. As a
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`faculty member, I have taught courses and directed research in networking and
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`telecommunications, including 2G, 3G, 4G, 5G, CDMA/WCDMA, GPS, GSM,
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`UMTS, LTE, ad-hoc networks, Bluetooth, call admission control, channel coding,
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`communication interfaces and standards, compression, computer architecture,
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`databases, MIMO systems, multi-cell network optimization, network security,
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`packet-networks, telephony, VoIP, Wi-Fi (802.11), 802.15.4, Zigbee, wireless
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`communication, and wireless sensors. I am also the director of the Wireless Sensor
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`Lab (“WiSL”) at UNT. I am a member of the Center for Information and Cyber
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`Security (CICS). It is the only program in the U.S. to be federally certified by the
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`National Security Agency as a Center of Academic Excellence in Information
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`Assurance Education and Research and Cyber Defense Research. I am also a
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`member of the NSF Net-Centric & Cloud Software & Systems: Industry-University
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`Cooperative Research Center (I/UCRC). Several of my research projects are funded
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`by industry. In January of 2015, I was promoted to Associate Chair of Graduate
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`Studies in the Department of Computer Science and Engineering.
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`12.
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`In addition to advising and mentoring students at UNT, I was asked to
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`join the faculty of the University of Arkansas in Little Rock as an Adjunct Assistant
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`Professor from 2004 to 2008 in order to supervise the research of two Ph.D. graduate
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`students who were doing research in wireless communications. At UNT, I have
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`advised and supervised more than 250 undergraduate and graduate students, several
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`of whom received a master’s or doctorate degree under my guidance.
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`13. Further, since 2005, I have received over a million dollars in funding
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`from the State of Texas, Texas Higher Education Coordination Board, the National
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`Science Foundation, and industry to design and conduct robotics, video, and mobile
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`gaming (e.g., Xbox, PC, mobile device) programming summer camps for middle
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`and high school students at UNT. By using video and mobile gaming as the backdrop,
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`participants have learned coding and programming principles and developed an
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`understanding of the role of physics and mathematics in video game design.
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`14.
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`In addition to my academic work, I have remained active in the
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`communication industry through my consulting work. In 2002, I consulted for
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`Input/Output Inc. and designed and implemented algorithms for optimizing the
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`frequency selection process used by sonar for scanning the bottom of the ocean. In
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`2004, I worked with Allegiant Integrated Solutions in Ft. Worth, Texas, to design
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`and develop an integrated set of tools for fast deployment of wireless networks, using
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`the 802.11 standard. Among other features, these tools optimize the placement of
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`Access Points and determine their respective channel allocations to minimize
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`interference and maximize capacity. I also assisted the Collin County Sheriff’s
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`Office (Texas) in a double homicide investigation, analyzing cellular record data to
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`determine user location.
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`15.
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`I have authored and co-authored over 90 journal publications,
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`conference proceedings, technical papers, book chapters, and technical presentations
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`in a broad array of communications-related technologies, including networking and
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`wireless communication. I have also developed and taught over 100 courses related
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`to communications and computer systems, including several courses on signals and
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`systems, 4G/LTE and 5G/NR, OFDM, VoIP, Wi-Fi (802.11), 802.15.4, Zigbee,
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`wireless communication, communications systems, communication interfaces and
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`standards, databases, sensor networks, source coding and compression, network
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`security, computer systems design, game and app design, and computer architecture.
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`These courses have included introductory courses on communication networks and
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`signals and systems, as well as more advanced courses on wireless communications.
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`A complete list of my publications and the courses I have developed and/or taught
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`is also contained in my curriculum vitae.
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`16. My professional affiliations include services in various professional
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`organizations and serving as a reviewer for a number of technical publications,
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`journals, and conferences. I have also received a number of awards and recognitions,
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`including the IEEE Professionalism Award (2008), UNT College of Engineering
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`Outstanding Teacher Award (2008), and Tech Titan of the Future (2010) among
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`others, which are listed in my curriculum vitae.
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`17.
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`I have also served as an expert in certain legal proceedings. A list of
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`cases in which I have testified at trial, hearing, or by deposition (including those
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`during the past five years) is provided in my curriculum vitae. Over the years, I have
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`been retained by both patent owners and petitioners.
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`III. Level of Ordinary Skill in the Art
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`18.
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`In rendering the opinions set forth in this declaration, I was asked to
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`consider the patent claims and the prior art through the eyes of a POSITA at the time
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`of the alleged invention, which I understand is asserted to be July 31, 2008—the
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`earliest proclaimed priority date. I understand that the factors considered in
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`determining the ordinary level of skill in a field of art include the level of education
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`and experience of persons working in the field; the types of problems encountered
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`in the field; the teachings of the prior art, and the sophistication of the technology at
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`the time of the alleged invention. I understand that a POSITA is not a specific real
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`individual, but rather is a hypothetical individual having the qualities reflected by
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`the factors above. I understand that a POSITA would also have knowledge from the
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`teachings of the prior art, including the art cited below.
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`19. Taking these factors into consideration, on or before July 31, 2008, a
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`POSITA relating to the technology of the ’772 patent would have had a Bachelor’s
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`degree in electrical engineering, computer engineering, computer science, or a
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`related field, and at least 2 years of experience in the field of computer networking
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`or development of
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`telecommunication systems,
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`including remote device
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`management systems, or the equivalent. Additional graduate education could
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`substitute for professional experience, or significant experience in the field could
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`substitute for formal education.
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`20. Before July 31, 2008, my level of skill in the art was at least that of a
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`POSITA. I am qualified to provide opinions concerning what a POSITA would have
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`known and understood at that time, and my analysis and conclusions herein are from
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`the perspective of a POSITA as of that date.
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`IV. Materials Considered and Relied Upon
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`21.
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`In reaching the conclusions described in this declaration, I have relied
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`on the documents and materials cited herein as well as those identified in this
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`declaration, including the ’772 patent, the prosecution history of the ’772 patent, and
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`prior art references cited herein. These materials comprise patents, related
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`documents, and printed publications. Each of these materials is a type of document
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`that experts in my field would have reasonably relied upon when forming their
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`opinions. When quoting from these materials, all emphasis is added unless otherwise
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`noted.
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`22.
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`I have also relied on my education, training, research, knowledge, and
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`personal and professional experience in the relevant technologies and systems that
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`were already in use prior to, and within the timeframe of the earliest priority date of
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`the claimed subject matter in the ’772 patent, which is July 31, 2008.
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`• Ex. 1001: U.S. Patent No. 8,886,772 (“the ’772 patent”)
`• Ex. 1002: Prosecution History of the ’772 patent
`• Ex. 1004: U.S. Patent Application Publication No. 2005/0060361
`(“Chatrath”)
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`• Ex. 1005: U.S. Patent Application Publication No. 2006/0172769 (“Oh”)
`• Ex. 1006: International Publication No. WO 2007/066318 (“Schliserman”)
`• Ex. 1007: U.S. Patent Application Publication No. 2007/0192464
`(“Tullberg”)
`• Ex. 1008: Excerpts from Wireless Communications and Networking, by
`Vijay K. Garg, Morgan Kaufmann Publishers, 2007
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`V. Legal Standards
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`23.
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`I am not a lawyer and do not provide any legal opinions, but I have been
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`advised that certain legal standards are to be applied by technical experts in forming
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`opinions regarding meaning and validity of patent claims. I have applied the legal
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`standards described below, which were provided to me by counsel for Petitioner.
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`24.
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`I have been informed that assessing the validity of a U.S. patent based
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`on a prior art analysis requires two steps. First, one must construe the terms of the
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`patent claims to understand what meaning a POSITA would have given the terms.
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`Second, after the claim terms have been construed, one may then assess validity by
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`comparing a patent claim to the “prior art.” I have been informed that the teaching
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`of the prior art is viewed through the eyes of a POSITA at the time the invention was
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`made. My analysis as to what constitutes a relevant POSITA is set forth above.
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`A. Legal Standards for Prior Art
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`25.
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`I have been informed that a patent or other publication must first qualify
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`as prior art before it can be used to invalidate a patent claim. I was informed by
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`counsel for Petitioner that each of the references (Ex. 1004-1007) is prior art to
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`the ’772 patent under pre-AIA 35 U.S.C. § 102(b) because it was published more
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`than one year before the US filing date, July 30, 2009, of the ’772 patent application.
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`26.
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`I have been informed that documents and materials that qualify as prior
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`art can be used to invalidate a patent claim as anticipated or as obvious.
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`B.
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`Legal Standard for Obviousness
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`27.
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`I have been informed that a patent claim is invalid as obvious under 35
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`U.S.C. §103(a) if the subject matter of the claimed invention “as a whole” would
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`have been obvious to a POSITA at the time the invention was made. To determine
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`the differences between a prior art reference (or a proposed combination of prior art
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`references) and the claims, the question of obviousness is not whether the differences
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`themselves would have been obvious, but whether the claimed invention as a whole
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`would have been obvious. Also, obviousness grounds cannot be sustained by mere
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`conclusory statements. Rather, it is necessary to provide some articulated reasoning
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`with rational underpinning to support the legal conclusion of obviousness.
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`28.
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`I have been informed that a POSITA is assumed to know and to have
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`all relevant prior art in the field of endeavor covered by the patent in suit, and would
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`thus have been familiar with each of the references cited herein, as well as the
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`background knowledge in the art and the full range of teachings they contain.
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`29.
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`I have been informed that there are two criteria for determining whether
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`prior art is analogous and thus can be considered prior art under 35 U.S.C. §103(a):
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`(1) whether the art is from the same field of endeavor, regardless of the problem
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`addressed, and (2) if the reference is not within the field of the patentee’s endeavor,
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`whether the reference still is reasonably pertinent to the particular problem with
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`which the patentee is involved. I have also been informed that the field of endeavor
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`of a patent is not limited to the specific point of novelty, the narrowest possible
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`conception of the field, or the particular focus within a given field. I have also been
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`informed that a reference is reasonably pertinent if, even though it may be in a
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`different field from that of the patentee’s endeavor, it is one which, because of the
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`matter with which it deals, logically would have commended itself to a patentee’s
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`attention in considering his problem.
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`30.
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`I have also been informed that in considering whether an invention for
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`a claimed combination would have been obvious, I may assess whether there are
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`apparent reasons to combine known elements in the prior art in the manner claimed
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`in view of interrelated teachings of multiple prior art references, the effects of
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`demands known to the design community or present in the market place, and/or the
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`background knowledge possessed by a POSITA. I have been informed that other
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`principles may be relied on in evaluating whether an alleged invention would have
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`been obvious, and that these principles include the following:
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`31. A combination of familiar elements according to known methods is
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`likely to be obvious when it does no more than yield predictable results;
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`32. When a device or technology is available in one field of endeavor,
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`design incentives and other market forces can prompt variations of it, either in the
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`same field or in a different one, so that if a person of ordinary skill can implement a
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`predictable variation, the variation is likely obvious;
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`33. An explicit or implicit teaching, suggestion, or motivation to combine
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`two prior art references to form the claimed combination may demonstrate
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`obviousness, but proof of obviousness does not depend on or require showing an
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`explicit teaching, suggestion, or motivation to combine;
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`34.
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`In determining whether the subject matter of a patent claim would have
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`been obvious, neither the particular motivation nor the avowed purpose of the named
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`inventor controls;
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`35. One of the ways in which a patent’s subject can be proved obvious is
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`by noting that there existed at the time of invention a known problem for which there
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`was an obvious solution encompassed by the patent’s claims;
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`36. Any need or problem known in the field of endeavor at the time of
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`invention and addressed by the patent can provide a reason for combining the
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`elements in the manner claimed;
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`37.
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`“Common sense” teaches that familiar items may have obvious uses
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`beyond their primary purposes, and in many cases a POSITA will be able to fit the
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`teachings of multiple patents together like pieces of a puzzle;
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`38. A patent claim can be proved obvious by showing that the claimed
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`combination of elements was “obvious to try,” particularly when there is a design
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`need or market pressure to solve a problem and there are a finite number of identified,
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`predictable solutions such that a person of ordinary skill in the art would have had
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`good reason to pursue the known options within his or her technical grasp.
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`39.
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`I have been informed that for inter partes reviews, unpatentability must
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`be shown under a preponderance of the evidence standard. I have been informed that
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`to establish something by a preponderance of the evidence one needs to prove it is
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`more likely true than not true.
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`40.
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`I have been informed that in order to determine whether a patent claim
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`is obvious, one must make certain factual findings regarding the claimed invention
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`and the prior art. Specifically, I have been informed that the following factors must
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`be evaluated to determine whether a claim is obvious: the scope and content of the
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`prior art; the difference or differences, if any, between the claim of the patent and
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`the prior art; the level of ordinary skill in the art at the time the claimed invention
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`was made; and, if available, the objective indicia of non-obviousness, also known as
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`“secondary considerations.”
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`41.
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`I have been informed that the secondary considerations include:
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`commercial success of a product due to the merits of the claimed invention; a long
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`felt need for the solution provided by the claimed invention; unsuccessful attempts
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`by others to find the solution provided by the claimed invention; copying of the
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`claimed invention by others; unexpected and superior results from the claimed
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`invention; acceptance by others of the claimed invention as shown by praise from
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`others in the field or from the licensing of the claimed invention; teaching away from
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`the conventional wisdom in the art at the time of the invention; independent
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`invention of the claimed invention by others before or at about the same time as the
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`named inventor thought of it; and other evidence tending to show obviousness.
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`42.
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`I have been informed that, to establish a secondary consideration, the
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`evidence must demonstrate a nexus between that secondary consideration and the
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`claimed invention.
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`VI. Overview of the ’772 Patent
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`A.
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`Subject Matter Overview
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`43. The ’772 patent is titled “METHOD AND SYSTEM FOR REMOTE
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`DEVICE MANAGEMENT.” ’772 patent (Ex. 1001), Title. The patent describes the
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`technical problem it tried to solve in the Background. Traditionally, manageable
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`electronic devices, also known as Customer Premises Equipment (CPE) devices, in
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`a local area network (LAN) are coupled to a wide area network (WAN) to allow
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`remote management over the network. Id., 1:26-35. In this arrangement, a CPE
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`device in a local network connects to an auto-configuration server (ACS) that is
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`capable of providing service level settings for services available to the CPE. Id.,
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`1:42-45. The patent states the ACS is dedicated either to a certain level of services
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`(e.g., premium, best effort), a type of device (e.g., Home Gateway, Voice over IP
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`telephone, Set TopBox) or a specific customer group (e.g., business or residential)
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`and for that reason, each CPE device “must be preconfigured to specifically address
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`the proper ACS.” Id., 1:46-53. This pre-configuration in prior art “may be time-
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`consuming and/or may be sensitive to errors and mistakes.” Id., 1:54-60.
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`44. The ’772 patent provides a remote device management method “that
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`overcomes or reduces the problems of the prior art.” Id., 1:64-65. The method “will
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`determine which specific auto-configuration server (ACS) is available for a given
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`manageable electronic device, which allows to reduce the complexity of pre-
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`installation and installation of devices.” Id., 2:26-29.
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`45. FIG. 2 schematically shows an architecture for remote device
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`management:
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`46. The ’772 patent describes an auto-configuration server manager 25,
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`databases 26, 27, 28, and a plurality of auto-configuration servers ACS1, ACS2,
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`ACS3 are located in the WAN, and the auto-configuration server manager 25 is
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`arranged for controlling access to the auto-configuration servers ACS1, ACS2,
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`ACS3 by manageable electronic devices (CPE devices) in the LAN. Id., 4:66-5:14.
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`47. FIGS. 3a and 3b illustrate alternative flow diagrams for remote device
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`management. The claims of the ’772 patent correspond to FIG. 3b reproduced below,
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`which includes relaying a request to the ACS and relaying a reply from the ACS to
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`the manageable electronic device at action 106a. The only difference between FIGS.
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`3a and 3b is that action 106a in FIG. 3b replaces action 106 in FIG. 3a.
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`In action 101, the auto-configuration server manager 25 receives a
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`48.
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`request from a manageable electronic device. The request includes an IP address and
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`type or function information of the manageable electronic device. The request may
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`also include manufacturer or supplier information of the manageable electronic
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`device. Id., 6:3-9.
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`49.
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`In action 102, the auto-configuration server manager 25 compares the
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`received IP address of the manageable electronic device, which is included in the
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`received request, with a first database 26 that includes IP address information on IP
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`addresses that are valid for allowing access to the auto-configuration server manager
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`25. Id., 6:10-15.
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`50.
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`In action 103, the auto-configuration server manager 25 checks if the
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`received IP address is a valid address in the first database 26. If the received IP
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`address is a valid address, in action 104, the auto-configuration server manager 25
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`resolves an identity of a service provider ISPID from the IP address by means of a
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`second database 27, which includes information that associates the identity of the
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`service provider ISPID with the IP address of the manageable electronic device. Id.,
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`6:19-34.
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`51.
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`In action 105, the auto-configuration server manager 25 resolves an IP
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`address ACSID of the dedicated auto-configuration server from at least one of the
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`identity of the service provider ISPID and the received IP address of the manageable
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`electronic device by means of a third database 28, which includes information that
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`associates the IP address of the dedicated auto-configuration server with at least one
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`of the identity of the service provider ISPID and the IP address of the manageable
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`electronic device. Id., 6:35-51.
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`52.
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`In step 106a, the auto-configuration server manager 25