UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE, INC.,
`Petitioner,
`v.
`Ericsson Inc.,
`Patent Owner
`
`Case IPR2022-00337
`U.S. Patent 10,454,655
`
`DECLARATION OF DR. ZYGMUNT HAAS,
`IN SUPPORT OF PATENT OWNER’S PRELIMINARY RESPONSE
`
`1
`
`ERICSSON EXHIBIT 2001
`Apple, Inc. v. Telefonaktiebolaget LM Ericsson
`IPR2022-00337, Page 1
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`Haas Declaration for Patent Owner’s Preliminary Response
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`IPR2022-00337
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`a)
`
`b)
`
`TABLE OF CONTENTS
`Introduction ...................................................................................................... 5
`I.
`Qualifications and Professional Experience .................................................... 6
`II.
`Level of Ordinary Skill in the Art ................................................................. 10
`III.
`IV. Relevant Legal Standards .............................................................................. 12
`V.
`SUMMARY of the ’655 Patent ..................................................................... 13
`VI. Claim Construction ........................................................................................ 20
`VII. Bao and Feuersanger Do Not render the Claims Obvious ............................ 21
`A.
`Summary of Bao (Grounds 1A and 1B) .............................................. 21
`B.
`Summary of Feuersanger (Ground 1B) ............................................... 23
`C.
`Bao and Feuersanger Do Not Render Obvious Claims 21-40. ........... 25
`1.
`Bao alone does not render obvious the claimed
`requirement for first and second LCIDs associated with
`first and second MAC CE formats with first and second
`bit map sizes, respectively (claim elements [21b], [26d],
`[31b], and [36d]) . .......................................................... 25
`Bao is consistent across all embodiments that
`there is one specific LCID associated with the
`activation/deactivation MAC CE. .................................. 26
`The cited portion of Bao already teaches a
`solution to indicate the length of a MAC CE – that
`does not involve using different LCIDs. ....................... 28
`It would not have been obvious to use different
`LCIDs for different length MAC CEs of the
`component carrier “activation/deactivation” MAC
`CE. ................................................................................. 30
`The cited portion of Bao does not disclose using
`“activation/deactivation” MAC CEs of different
`lengths. ........................................................................... 32
`
`c)
`
`d)
`
`2
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`ERICSSON EXHIBIT 2001
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`IPR2022-00337, Page 2
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`2.
`
`3.
`
`Feuersanger does not overcome the deficiencies of Bao
`with respect to rendering obvious first and second LCIDs
`associated with first and second MAC CE formats with
`first and second bit map sizes, respectively (claim
`elements [21b], [26d], [31b], and [36d]). ...................... 34
`For similar reasons, neither Bao alone, nor Bao
`combined with Feuersanger, renders obvious claim
`elements [21e] and [26g]. .............................................. 36
`Petitioner’s alleged motivation to combine Bao and
`Feuersanger is misleading and irrelevant to any claim
`limitation. ............................................................................................ 38
`Petitioner’s Analysis of Independent Claims 1, 7, 13, and 17 is
`Defective. ............................................................................................ 39
`Summary ............................................................................................. 41
`F.
`VIII. Petitioner’s Ground 2 Fails Because Kwon Does Not Render the
`Claims Obvious ............................................................................................. 41
`A.
`Summary of Kwon .............................................................................. 41
`B.
`Kwon Fails to Render Obvious Claims 21-40. ................................... 45
`1.
`Kwon does not disclose or render obvious the claimed
`requirement for first and second LCIDs associated with
`first and second MAC CE formats with first and second
`bit map sizes, respectively (claim elements [21b], [26d],
`[31b], and [36d]). ........................................................... 45
`a. LCID is used in Kwon only to identify a MAC
`CE as an activation/deactivation indicator MAC
`CE, not to indicate a bitmap length. .............................. 47
`Petitioner’s focus on other types of LCIDs
`contradicts its position. .................................................. 50
`Kwon consistently teaches that a wireless
`communication system uses a fixed-size bit map
`based on a maximum number of component
`carriers. ........................................................................... 52
`
`D.
`
`E.
`
`a)
`
`b)
`
`c)
`
`3
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`ERICSSON EXHIBIT 2001
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`d)
`
`Summary – Kwon neither discloses nor render
`obvious first and second LCIDs associated with
`first and second MAC CE formats with first and
`second bit map sizes, respectively. ................................ 55
`For similar reasons, Kwon does not render obvious claim
`elements [21e], [26g] ..................................................... 56
`Petitioner’s analysis of claims 1, 7, 13, and 17 is defective. .............. 59
`C.
`IX. Conclusion ..................................................................................................... 61
`
`2.
`
`4
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`ERICSSON EXHIBIT 2001
`Apple, Inc. v. Telefonaktiebolaget LM Ericsson
`IPR2022-00337, Page 4
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`Haas Declaration for Patent Owner’s Preliminary Response
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`I, Zygmunt Haas, do hereby declare as follows:
`
`I.
`
`INTRODUCTION
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`5
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`d.
`
`U.S. Patent Pub. No. 2013/0039202 to Feuersanger et al.
`
`(“Feuersanger”), Ex.1005;
`
`e.
`
`f.
`
`g.
`
`U.S. Patent No. 8,538,411 to Kwon et al. (“Kwon”), Ex. 1006;
`
`IPR2022-00337, Petition for Inter Partes Review;
`
`Expert Declaration of Dr. Michael Buehrer, Ex. 1003.
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`University of Texas in Dallas. I am also Professor Emeritus at the School of
`
`Electrical and Computer Engineering at Cornell University. In addition, I have
`
`provided technical consulting services in intellectual property matters, during which
`
`I have written expert reports and provided deposition and trial testimony involving
`
`wireless communication technologies.
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`IPR2022-00337
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`and co-authored numerous technical papers and book chapters related to wireless
`
`communication networks. I hold over twenty patents in the fields of high-speed
`
`networking, wireless networks, and optical switching. My employment history
`
`following my graduation from Stanford University began at the Network Research
`
`Department of AT&T Bell Laboratories in 1988. At AT&T Bell Laboratories, I
`
`pursued research on wireless communications, mobility management, fast protocols,
`
`optical networks, and optical switching. During my tenure at AT&T, I also worked
`
`for the AT&T Wireless Center of Excellence, where I investigated various aspects
`
`of wireless and mobile networks.
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`Institute of Electrical and Electronic Engineers (IEEE) and the Association for
`
`Computing Machinery (ACM). In 2007, I was elevated to an IEEE Fellow, and in
`
`2022, I was elevated to an ACM Fellow. I have been responsible for organizing
`
`several workshops, and delivering numerous tutorials at major IEEE and ACM
`
`conferences. I have served as editor of several publications including the IEEE
`
`Transactions on Networking, the IEEE Transactions on Wireless Communications,
`
`the IEEE Communications Magazine, the Springer “Wireless Networks” journal, the
`
`Elsevier “Ad Hoc Networks” journal, the “Journal of High Speed Networks,” and
`
`the Wiley “Wireless Communications and Mobile Computing” journal. I have also
`
`been a guest editor of IEEE Journal on Selected Areas in Communications issues on
`
`“Gigabit Networks,” “Mobile Computing Networks,” and “Ad-Hoc Networks.”
`
`Finally, I have served as the Chair of the IEEE Technical Committee on Personal
`
`Communications (TCPC), today known as Wireless Communications Technical
`
`Committee (WTC).
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`authoring the paper “Engineering a Network in the Sky” from thehe 35th
`
`International Conference on Information Networking, (ICOIN21). In 2012, I
`
`received the “Best Paper Award for co-authoring “Collaborating with Correlation
`
`for Energy Efficient WSN” directed at Wireless Sensor Networking. I previously
`
`received the “Best Paper Award” for co-authoring “Optimal Resource Allocation for
`
`UWB Wireless Ad Hoc Networks” directed at personal indoor and mobile radio
`
`communications. Finally, in 2003, I received the “Highly Commended Paper
`
`Award” for co-authoring “Performance Evaluation of the Modified IEEE 802.11
`
`MAC for Multi-Channel Multi-Hop Ad Hoc Network,” directed at advanced
`
`information networking and applications.
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`IV. RELEVANT LEGAL STANDARDS
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`spectral bandwidth can be allocated to an LTE terminal (also known as a User
`
`Equipment or UE, Ex. 1001, 2:19-21), yielding higher data rates. In other words, the
`
`maximum supportable data rate (or throughput) scales with the spectral bandwidth,
`
`such that increasing spectral bandwidth to a terminal increases the maximum data
`
`rate to the terminal.
`
`24. Referring to a particular prior art 3GPP wireless standards document
`
`(TS 36.321 v12.3.0, dated September 2014), the ’655 explains that a base station and
`
`a mobile station use Medium Access Control (MAC) Control Elements (CE) to
`
`exchange control information, and a Logical Channel Identity (LCID) is used to
`
`identify the MAC CE:
`
`In LTE, the eNodeB (also referred to as a base station) and the UE
`use Medium Access (MAC) Control Elements (CE) to exchange
`information such as buffer status reports, power headroom reports, etc.
`A comprehensive list of MAC CEs is provided in section 6.1.3 of
`3GPP TS 36.321 v12.3.0 (2014-09), “LTE; Evolved Universal
`Terrestrial Radio Access (E-UTRA); Medium Access Control (MAC)
`protocol specification.” Moreover, each MAC CE may be identified
`by a LCID (Logical Channel Identity) which is used as an identifier
`for the MAC CE so that the receiver interprets the MAC CE
`correctly. With the existing LTE specification, however, a number of
`component carriers may be limited.
`
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`ERICSSON EXHIBIT 2001
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`Id., 2:22-331. The then-existing 3GPP standard included a specific MAC CE, called
`
`an “Activation/Deactivation” MAC CE, whose purpose was to indicate the carriers
`
`assigned to the UE. In other words, it was known in the 3GPP standards that an
`
`LCID is used to identify the MAC CE. The ’655 Patent points out the limitation with
`
`the then-existing 3GPP standard that “a number of component carriers may be
`
`limited,” ’655 Patent, 2:33, such that only “up to 5 aggregated carriers” may be
`
`supported. Id., 1:43.
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`Id., 7:52-58. In one embodiment, “different versions of the MAC CEs may have
`
`different LCIDs.” ’655 Patent, 7:61-63. By using two different versions of a MAC
`
`CE corresponding to different numbers of carriers, the ’655 beneficially allows for
`
`a greater number of component carriers to be supported, without using the larger
`
`bitmap size when a smaller number of carriers is supported:
`
`By only using the second version of the Activation/Deactivation MAC
`CE of FIG. 7 when a highest secondary component carrier index for a
`configured secondary component carrier exceeds a threshold (e.g., a
`highest secondary component carrier for a configured secondary
`component
`carrier
`is
`greater
`than
`7),
`the
`smaller
`Activation/Deactivation MAC CE can be used when the highest
`configured component carrier index does not exceed the threshold,
`thereby reducing signaling overhead.
`’655 Patent, 12:25-33.
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`Id., Figure 2B (annotated; prior art from 3GPP standard). By contrast, one solution
`
`proposed by the ’655 Patent was to modify the standardized methodology so that
`
`“different Logical Channel Identities (LCID) may be used for different MAC
`
`CEs of the same type having different bit map sizes (e.g., … different
`
`Activation/Deactivation MAC CEs having different bit map sizes).” ’655 Patent,
`
`17:36-41. In other words, unlike what appeared in the 3GPP standard at the time, the
`
`’655 Patent proposes the use of different LCIDs for different MAC CEs of the same
`
`type (namely, the Activation/Deactivation MAC CE type) to indicate different bit
`
`map sizes for this type of MAC CE.
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`21. A method of operating a wireless terminal in communication
`with a wireless communication network, the method comprising:
`receiving a medium access control, MAC, control element, CE,
`from the wireless communication network, wherein the MAC CE has
`one of a plurality of formats, wherein a first format of the plurality of
`formats has a first bit map size and the first format is associated with a
`first Logical Channel Identity (LCID), wherein a second format of the
`plurality of formats has a second bit map size and the second format is
`associated with a second LCID, wherein the first and second bit map
`sizes are different, and wherein the first and second LCIDs are
`different; and
`responsive to receiving one of the first and second LCIDs
`together with the MAC CE, applying a bit map of the MAC CE using
`one of the first and second bit map sizes to activate/deactivate
`component carriers of a group of component carriers based on the one
`of the first and second LCIDs received together with the MAC CE.
`
`Id., 54:46-51. As shown, claim 21 relates to a “first format” of a “MAC CE” having
`
`a “first bit map size” and associated with a “first LCID,” and a “second format” of
`
`the “MAC CE” having a “second bit map size” and associated with a “second LCID.”
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`Claim 21 also relates to a “wireless terminal” “using one of the first and second bit
`
`map sizes to activate/deactivate component carriers.”
`
`28. An example operation of a “wireless terminal UE” in a wireless
`
`network is illustrated in Figures 15A-15C. Id., 15:41-43.
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`Id., Figure 15A. Referring to Figure 15A, in a specific example illustrating the use
`
`of different LCIDs to indicate different bit map sizes to a given UE, the ’655 Patent
`
`explains:
`
`For example, communicating a first MAC CE at block 1505 may
`include receiving the first MAC CE and applying bits of the first bit
`map to respective component carriers of a first group of component
`carriers responsive to a first LCID, and communicating a second MAC
`CE may include receiving the second MAC CE and applying bits of the
`second bit map to respective component carriers of a second group of
`component carriers responsive to a second LCID (different than the
`first LCID).
`Id., 17:41-49. Thus, the ’655 discloses a UE in a wireless network is provided the
`
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`ability to receive two different bit map sizes, depending on the number of component
`
`carriers in use.
`
`VI. CLAIM CONSTRUCTION
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`meaning as would have been understood by one of ordinary skill in the art.
`
`VII. BAO AND FEUERSANGER DO NOT RENDER THE CLAIMS
`OBVIOUS2
`
`A.
`
`Summary of Bao (Grounds 1A and 1B)
`
`21
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`[T]he LCID in the MAC subheaders is the identifier for indicating the
`existence of the component carrier indication MAC CE. In particular,
`after the component carrier indication MAC CE has been introduced,
`an independent LCID, which may be a reserved LCID value, is
`defined to indicate the corresponding MAC CE as the component
`carrier indication MAC CE. … In this embodiment, the reserved
`LCID value corresponds to the component carrier indication MAC
`CE in the present invention so as to indicate the existence of the
`component carrier indication MAC CE.
`
`Bao, ¶ [0032]. A value that is “reserved” is a value that has not yet been assigned in
`
`the protocol. (For example, in Kwon, several values of LCID are designated as
`
`“Reserved,” or not previously used, in Tables 1 and 2. Kwon, 23:12-51). Thus, Bao
`
`describes using only one LCID value and selecting the value of the LCID from a set
`
`of “reserved” (or previously unused) value(s), with the specifically selected LCID
`
`value indicating the “type” of MAC CE as a “component carrier indication MAC
`
`CE,” thereby indicating the “existence” of a MAC CE as this type.
`
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`These tables and the associated disclosure in Feuersanger confirm that LCID values
`
`were used to indicate different MAC CEs. Feuersanger, ¶ [0072] (“MAC Control
`
`Elements can be … identified by a specific Logical Channel ID (LCID) in the MAC
`
`header.”). Note
`
`that
`
`in Tables 2 and 3 of Feuersanger,
`
`there
`
`is no
`
`“Activation/Deactivation” CC MAC CE, unlike Figure 2B of the ’655 Patent.
`
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`(de)activation message is provided as a bitmap.” Feuersanger, ¶ [0213]. And the size
`
`of the bitmap is based on an “assumed…maximum of five component carriers in the
`
`downlink,” Feuersanger, [0215], which is equivalent to what is stated in the
`
`Background of the ’655 Patent (i.e., at 1:43). There is no disclosure in Feuersanger
`
`that a UE may receive more than one bit map size while communicating in a wireless
`
`communication system, nor has Petitioner shown any.
`
`C.
`
`Bao and Feuersanger Do Not Render Obvious Claims 21-40.
`
`Bao alone does not render obvious the claimed requirement
`1.
`for first and second LCIDs associated with first and second MAC
`CE formats with first and second bit map sizes, respectively
`(claim elements [21b], [26d], [31b], and [36d]) 3.
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`formats, wherein a first format of the plurality of formats has a first bit map size
`and the first format is associated with a first Logical Channel Identity (LCID),
`wherein a second format of the plurality of formats has a second bit map size and
`the second format is associated with a second LCID,
`[26d] wherein the MAC CE has one of a plurality of formats, wherein a first
`format of the plurality of formats has a first bit map size and the first format is
`associated with a first Logical Channel Identity (LCID), wherein a second format
`of the plurality of formats has a second bit map size and the second format is
`associated with a second LCID
`[31b] wherein the first format [of a MAC CE]4 has a first bit map size and the
`first format is associated with a first Logical Channel Identity (LCID), wherein
`the second format [of the MAC CE] has a second bit map size and the second
`format is associated with a second LCID
`[36d] wherein the first format [of a MAC CE]5 has a first bit map size and the
`first format is associated with a first Logical Channel Identity (LCID), wherein
`the second format [of the MAC CE] has a second bit map size and the second
`format is associated with a second LCID
`
`Bao is consistent across all embodiments that there is
`a)
`one specific LCID associated with the activation/deactivation
`MAC CE.
`
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`embodiments and bears the instruction and the corresponding CC, into the MAC
`
`PDU, and adds an identifier indicating existence of the MAC CE in a MAC head
`
`of the MAC PDU.” Bao, ¶ [0031].
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`following correctly annotated figure of Bao:
`
`Ex. 1003, ¶ 63.
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`distinct field, the “L” field, that indicates the length of the MAC CE:
`
`An LCID (Logical Channel ID) field is configured for identifying
`the type of the MAC CE and the logical channel to which a MAC SDU
`belongs. An L field is configured for indicating the length of the
`corresponding MAC CE or MAC SDU. MAC CE is configured for
`bearing a control message.
`Bao, ¶ [0028]. An LCID field and an L field are identified above as different fields,
`
`reinforcing that LCID indicates the MAC CE, and the “L field” can indicate length.
`
`Similarly, the LCID and L fields are illustrated separately in Figure 4, reinforcing
`
`that these are different fields.
`
`Bao, Figure 4.
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`It would not have been obvious to use different LCIDs
`c)
`for different length MAC CEs of the component carrier
`“activation/deactivation” MAC CE.
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`Petitioner omits the first part of the sentence in Bao, which states that the MAC CE
`
`length is “fixed”:
`
`As shown in FIG. 7, the component carrier indication MAC CE may
`have fixed length, which depends upon the maximum number N of the
`aggregated carriers allowable to be supported by the current cell or the
`LTE-A system.
`Bao, ¶ [0037]. Petitioner does not reconcile this teaching of Bao with its claim
`
`mapping, merely stating in a conclusory manner that “the group of CCs can vary
`
`based on the current cell, or base station, to which the UE is connected.” Petition,
`
`19. And Petitioner’s expert does not attempt to explain this inconsistency with
`
`respect to Bao’s teaching of a MAC CE with a fixed length when he makes the
`
`unsupported statement that “[t]hus, Bao discloses a MAC CE having a particular
`
`size, and that a MAC CE of a first format can have a first bitmap size and a MAC
`
`CE of a second format can have a second bitmap size.” Ex. 1003, ¶ 98.
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`Accordingly, Petitioner, and Petitioner’s expert, seem to mischaracterize the
`
`teachings of Bao and ignore teachings that are relevant to sizes of MAC CEs.
`
`Feuersanger does not overcome the deficiencies of Bao with
`2.
`respect to rendering obvious first and second LCIDs associated
`with first and second MAC CE formats with first and second bit
`map sizes, respectively (claim elements [21b], [26d], [31b], and
`[36d]).
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`associated with different BSR MAC CE sizes as Petitioner alleges, Petitioner’s
`
`position
`
`confirms
`
`that Feuersanger
`
`teaches
`
`a
`
`fixed-sized downlink
`
`“activation/deactivation” MAC CE by specifically choosing to use only one LCID
`
`value for the activation/deactivation MAC CE. Feuersanger, ¶ [0211] (“[T]he
`
`component carrier (de)activation message is provided in the form of a new MAC
`
`control element identified by a specific LCID. This new MAC control element
`
`carries the (de)activation information.”). There is no disclosure in Feuersanger that
`
`a UE may receive more than one component carrier (de)activation bit map size while
`
`communicating in a wireless communication system, nor has Petitioner shown any.
`
`For similar reasons, neither Bao alone, nor Bao combined
`3.
`with Feuersanger, renders obvious claim elements [21e] and [26g].
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`Petitioner also correctly acknowledges that Bao discloses that “each type of the
`
`MAC CE corresponds to one possible value in LCID field.” Petition, 26 (quoting
`
`Bao). Citing to the analysis of claim element [21b], Petitioner then incorrectly
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`concludes that Bao discloses “applying a CC indication MAC CE responsive to an
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`LCID, which can provide information such as the presence [i.e., existence] of the
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`CC indication MAC CE and its format, including the bitmap size of the MAC
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`CE.” Petition, 28 (brackets added). This statement is not only unsupported by any
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`evidence, it is, indeed, contradicted by the evidence. As explained previously, Bao
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`clearly explains that the LCID indeed indicates the “existence” of the CC indication
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`MAC CE, but Bao does not teach that the LCID indicates the bit map size of the
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`MAC CE. Quite the opposite – to the extent a MAC CE size is not fixed, Bao
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`presents a different field for indicating the size of the MAC CE – an “L field” (Bao,
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`¶ [0028]), as explained earlier. Petitioner conspicuously ignores these teachings of
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`Bao. Because Bao already provides a solution for indicating the size of the MAC CE
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`(if needed), there is no reason to introduce yet another solution for the same feature,
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`i.e., indicating the size of the MAC CE.
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`Petitioner’s alleged motivation to combine Bao and Feuersanger is
`D.
`misleading and irrelevant to any claim limitation.
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`an “activation/deactivation” MAC CE (see ’655 Patent, Figure 2B), and this single
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`MAC CE has a fixed length, just like Feuersanger.
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`Petition, 46. Dr. Buehrer’s cited analysis (at Ex. 1003, ¶¶ 225, 250) is identical. To
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`the extent that Petitioner’s argument can be understood, as discussed above,
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`Petitioner’s analysis of claim element [21e] is deficient.
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`discussed above, Petitioner’s analysis of claim element [21e] is deficient.
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`F.
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`Summary
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`Kwon, 23:12-24, Table 1 (annotated).
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`Kwon, 23:40-51, Table 2 (annotated).
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`control element. In Table 1, one value indicates “CC activation/deactivation” for an
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`uplink (UL), and another value of LCID indicates “CC activation/deactivation” for
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`a downlink (DL). Kwon, 23:25-33. In Table 2, there is a single LCID value that
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`indicates “CC activation/deactivation” for both uplink and downlink. Kwon, 23:53-
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`57.
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`communication system. For example, Kwon discloses:
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`Herein, the wireless communication system is a system that may
`simultaneously use up to 5 CCs. In addition, if the wireless
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`communication system is a system supporting M CCs (where M≧5),
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`the activation indicator corresponding to the CC may be configured
`with m bits…[such as] 8 bits.
`Kwon, 15:64-16:6. Thus, Kwon teaches that a “wireless communication system” is
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`designed to support M CCs. Importantly, Kwon does not disclose that the number of
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`bits in the CC “activation indicator” MAC CE varies in communication with a UE
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`in the wireless communication system. There is no reason for the number of bits (“m
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`bits”) of the activation indictor to vary within the system, because the system is
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`designed to accommodate a specific number of subcarriers. Similarly, Kwon
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`discloses that “[t]he activation indicator may be constructed in a format of a bitmap
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`having a specific length. The length of the bitmap may be determined variously, for
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`example, 4 bits, 8 bits, etc.” Kwon, 19:22-29. Thus, the “length of the bitmap” is a
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`“specific length” within Kwon’s wireless communication system. Kwon does not
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`describe the bit map as changing within the wireless communication system.
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`Furthermore, the LCID is not used in Kwon to indicate bit map size.
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`44
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`ERICSSON EXHIBIT 2001
`Apple, Inc. v. Telefonaktiebolaget LM Ericsson
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`B.
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`Kwon Fails to Render Obvious Claims 21-40.
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`Kwon does not disclose or render obvious the claimed
`1.
`requirement for first and second LCIDs associated with first and
`second MAC CE formats with first and second bit map sizes,
`respectively (claim elements [21b], [26d], [31b], and [36d]).
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`[36d] wherein the first format [of a MAC CE]7 has a first bit map size and the
`first format is associated with a first Logical Channel Identity (LCID), wherein
`the second format [of the MAC CE] has a second bit map size and the second
`format is associated with a second LCID
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`so because the length of the bit map is fixed in the system—there are not different
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`sizes of activation indication MAC CEs. Thus, Petitioner’s arguments are
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`contradicted by the teachings of Kwon, as explained more fully below.
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`LCID is used in Kwon only to identify a MAC
`a.
`a)
`CE as an activation/deactivation indicator MAC CE, not to
`indicate a bitmap length.
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`the alternatives that Kwon presents.
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`Kwon, 23:12-24, Table 1 (annotated).
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`Kwon, 23:40-51, Table 2 (annotated).
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`(“Referring to Table 2, an LCID field value of ‘11001’ indicates that the
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`corresponding MAC control element is a MAC control element including the
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`activation indicator, and this concurrently indicates activation/deactivation of the DL
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`CC and the UL CC.”). Thus, as an example, if Table 2 is used and a wireless terminal
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`receives an LCID value of ‘11001’, the wireless terminal determines that the
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`corresponding MAC CE is an activation indicator MAC CE for both uplink and
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`downlink. In other words, “activation/deactivation of the UL CC may be determined
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`depending on activation/deactivation of the DL CC.” Kwon, 23:34-36. Since there
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`is only one value of LCID presented for downlink (and/or uplink) in each scenario,
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`the LCID field is not used in Kwon to indicate two different bit map lengths for the
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`downlink (and/or uplink).
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`similarities.
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`BSR,” “Short BSR,” and “Long BSR” that each have distinct LCIDs.
`APPLE-1006, 23:4-56. A POSITA would have recognized that each of
`the Truncated BSR, Short BSR, and Long BSR represents a buffer
`status report (BSR) of a particular size. APPLE-1003, [318].
`Thus, to a POSITA, Kwon discloses, or at least renders obvious,
`that a first LCID is associated with a MAC CE of a first format, a second
`LCID is associated with a MAC CE of a second format, and that the
`LCIDs can be different. APPLE-1003, [312]-[319], [373], [395], [425].
`Petition, 56-57. However, Petitioner’s arguments for Kwon fail for similar reasons
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`as they failed for Feuersanger.
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