IPR2022-00367
`(’235 Patent)
`
`Apple Inc. and HP Inc.
`Petitioners
`v.
`XR Communications, LLC, d/b/a Vivato Technologies,
`Patent Owner
`Patent Owner’s Demonstratives
`
`Filing Date: May 2, 2023
`Oral Argument Date: May 5, 2023
`
`Exhibit 2014
`IPR2022-00367
`Page 1 of 41
`
`
`(’235 Patent)
`
`Apple Inc. and HP Inc.
`Petitioners
`v.
`XR Communications, LLC, d/b/a Vivato Technologies,
`Patent Owner
`Patent Owner’s Demonstratives
`
`Filing Date: May 2, 2023
`Oral Argument Date: May 5, 2023
`
`Exhibit 2014
`IPR2022-00367
`Page 1 of 41
`
`
`
`’235 Patent
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`2
`
`Exhibit 2014
`IPR2022-00367
`Page 2 of 41
`
`
`
`Overview of ’235 Patent
`
`-’235 Patent (Ex. 1001) at Figs 2-3
`
`POR 4-5, 21; SR 17
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`3
`
`Exhibit 2014
`IPR2022-00367
`Page 3 of 41
`
`
`
`Overview of ’235 Patent
`
`-’235 Patent (Ex. 1001) at 24:25-41
`
`POR 5-7
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`4
`
`Exhibit 2014
`IPR2022-00367
`Page 4 of 41
`
`
`
`Overview of ’235 Patent
`
`-’235 Patent (Ex. 1001) at Figs. 3, 8A
`
`POR 4-5, SR 17
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`5
`
`Exhibit 2014
`IPR2022-00367
`Page 5 of 41
`
`
`
`Overview of ’235 Patent
`
`POR 5, 21-22
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`6
`
`-’235 Patent (Ex. 1001) at Fig. 6
`
`Exhibit 2014
`IPR2022-00367
`Page 6 of 41
`
`
`
`Overview of ’235 Patent
`
`POR 5, 21-22
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`7
`
`-’235 Patent (Ex. 1001) at 9:11-22
`
`Exhibit 2014
`IPR2022-00367
`Page 7 of 41
`
`
`
`’235 Patent Claim 8[a]
`
`8[a]: receiving a first signal transmission from a remote station
`via a first antenna element of an antenna and a second signal
`transmission from the remote station via a second antenna
`element of the antenna simultaneously
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`8
`
`Exhibit 2014
`IPR2022-00367
`Page 8 of 41
`
`
`
`’235 Patent Claim 8[c]-[d]
`
`8[c]: determining first signal information for the first signal
`transmission;
`8[d]: determining second signal information for the second
`signal transmission, wherein the second signal information is
`different than the first signal information;
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`9
`
`Exhibit 2014
`IPR2022-00367
`Page 9 of 41
`
`
`
`’235 Patent Claim 8[e]
`
`8[e]: determining a set of weighting values based on the first
`signal information and the second signal information, wherein
`the set of weighting values is configured to be used by the
`remote station to construct one or more beam-formed
`transmission signals
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`10
`
`Exhibit 2014
`IPR2022-00367
`Page 10 of 41
`
`
`
`Burke
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`11
`
`Exhibit 2014
`IPR2022-00367
`Page 11 of 41
`
`
`
`Burke Fig. 2
`
`POR 12, 19; SR 10-11, 16-18
`
`-Burke (Ex. 1006) Fig. 2
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`12
`
`Exhibit 2014
`IPR2022-00367
`Page 12 of 41
`
`
`
`Burke Fig. 2
`
`POR 12; SR 16-17
`
`-Burke (Ex. 1006) at 4:6-15
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`13
`
`Exhibit 2014
`IPR2022-00367
`Page 13 of 41
`
`
`
`Burke Fig. 2
`
`POR 12, 19; SR 10-11, 16-18
`
`-Burke (Ex. 1006) Fig. 2
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`14
`
`Exhibit 2014
`IPR2022-00367
`Page 14 of 41
`
`
`
`Burke Fig. 12: Mobile Station 106
`
`POR 19-20, 25
`SR 1-3, 5, 9-14
`
`-Burke (Ex. 1006) Fig. 12
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`15
`
`Exhibit 2014
`IPR2022-00367
`Page 15 of 41
`
`
`
`Burke Fig. 12: Mobile Station 106
`
`POR 12, 14, 23-29, 33
`SR 2, 6-7, 9
`
`-Burke (Ex. 1006) at 25:56-64
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`16
`
`Exhibit 2014
`IPR2022-00367
`Page 16 of 41
`
`
`
`Burke Fig. 12: Mobile Station 106
`
`POR 19-20, 25
`SR 1-3, 5, 9-14
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`17
`
`Exhibit 2014
`IPR2022-00367
`Page 17 of 41
`
`
`
`Ground 1: Single-Reference
`Obviousness Based on Burke
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`18
`
`Exhibit 2014
`IPR2022-00367
`Page 18 of 41
`
`
`
`Petition’s Theory for Obviousness
`
`Petition at 28
`
`Burke (Ex. 1006) at 25:58-61
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`19
`
`Exhibit 2014
`IPR2022-00367
`Page 19 of 41
`
`
`
`“Array of Diversity Antennas”
`
`Petitioners’ Expert Dr. Akl
`
`SR 4
`
`-Akl Dep. (Ex. 2013) at 34:14-25
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`20
`
`Exhibit 2014
`IPR2022-00367
`Page 20 of 41
`
`
`
`“Array of Diversity Antennas”
`
`Petitioners’ Expert Dr. Akl
`
`SR 8
`
`-Akl Dep. (Ex. 2013) at 35:12-36:1
`21
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Exhibit 2014
`IPR2022-00367
`Page 21 of 41
`
`
`
`“Array of Diversity Antennas”
`
`Petitioners’ Expert Dr. Akl
`
`SR 8
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`22
`
`-Akl Dep. (Ex. 2013) at 36:2-8
`
`Exhibit 2014
`IPR2022-00367
`Page 22 of 41
`
`
`
`“Array of Diversity Antennas”
`
`Petitioners’ Expert Dr. Akl
`
`SR 8
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`23
`
`-Akl Dep. (Ex. 2013) at 36:13-19
`
`Exhibit 2014
`IPR2022-00367
`Page 23 of 41
`
`
`
`“Array of Diversity Antennas”
`
`Goldsmith Textbook (from 2005)
`
`SR 4-5
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`24
`
`-Goldsmith (Ex. 1017) at 202
`
`Exhibit 2014
`IPR2022-00367
`Page 24 of 41
`
`
`
`“Array of Diversity Antennas”
`
`Goldsmith Textbook (from 2005)
`
`“One of the most powerful techniques to mitigate the
`effects of fading is to use diversity-combining of
`independently fading signal paths. Diversity-combining
`uses the fact that independent signal paths have a low
`probability of experiencing deep fades simultaneously.
`Thus, the idea behind diversity is to send the same data
`over independent fading paths. These independent
`paths are combined in some way such that the fading
`of the resultant signal is reduced. . .”
`
`SR 4-5
`
`-Goldsmith (Ex. 1017) at 202
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`25
`
`Exhibit 2014
`IPR2022-00367
`Page 25 of 41
`
`
`
`“Array of Diversity Antennas”
`
`Goldsmith Textbook (from 2005)
`
`“. . . . For example, consider a system with two
`antennas at either the transmitter or receiver that
`experience independent fading. If the antennas are
`spaced sufficiently far apart, it is unlikely that they
`both experience deep fades at the same time. By
`selecting the antenna with the strongest signal,
`called selection combining, we obtain a much better
`signal than if we just had one antenna.”
`
`SR 4-5
`
`-Goldsmith (Ex. 1017) at 202
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`26
`
`Exhibit 2014
`IPR2022-00367
`Page 26 of 41
`
`
`
`Failure to Show Claims 8[a], 8[d], 8[e]
`
`Patent Owner’s Expert Dr. Vojcic
`
`POR 19, 23, 25
`SR 3, 14
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`27
`
`- Vojcic Decl. (Ex. 2010) ¶ 38
`
`Exhibit 2014
`IPR2022-00367
`Page 27 of 41
`
`
`
`Failure to Show Claims 8[a], 8[d], 8[e]
`
`Patent Owner’s Expert Dr. Vojcic
`
`POR 19, 23, 25
`SR 3, 14
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`28
`
`- Vojcic Decl. (Ex. 2010) ¶ 38
`
`Exhibit 2014
`IPR2022-00367
`Page 28 of 41
`
`
`
`Failure to Show Claims 8[a], 8[d], 8[e]
`
`Patent Owner’s Expert Dr. Vojcic
`
`POR 23-27; SR 5-6
`
`-Vojcic Decl. (Ex. 2010) ¶ 39
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`29
`
`Exhibit 2014
`IPR2022-00367
`Page 29 of 41
`
`
`
`Failure to Show Claims 8[a], 8[d], 8[e]
`
`Patent Owner’s Expert Dr. Vojcic
`
`POR 29; SR 8
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`30
`
`- Vojcic Decl. (Ex. 2010) ¶¶ 42-43
`
`Exhibit 2014
`IPR2022-00367
`Page 30 of 41
`
`
`
`Failure to Show Claims 8[a], 8[d], 8[e]
`
`Patent Owner’s Expert Dr. Vojcic
`
`POR 32; SR 12-13, 18-19
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`31
`
`-Vojcic Decl. (Ex. 2010) ¶¶ 46
`
`Exhibit 2014
`IPR2022-00367
`Page 31 of 41
`
`
`
`Failure to Show Claims 8[a], 8[d], 8[e]
`
`Patent Owner’s Expert Dr. Vojcic
`
`POR 32-33; SR 13, 19
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`32
`
`-Vojcic Decl. (Ex. 2010) ¶¶ 47
`
`Exhibit 2014
`IPR2022-00367
`Page 32 of 41
`
`
`
`Petitioners Add New Theory in Reply
`
`Petitioners’ Expert Dr. Akl Reply Declaration
`
`-Second Akl Decl. (Ex. 1044) ¶ 9
`
`SR 9-11
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`33
`
`Exhibit 2014
`IPR2022-00367
`Page 33 of 41
`
`
`
`Petitioners Add New Theory in Reply
`
`Petitioners’ Expert Dr. Akl Reply Declaration
`
`SR 9-11
`
`-Second Akl Decl. (Ex. 1044) ¶ 9
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`34
`
`Exhibit 2014
`IPR2022-00367
`Page 34 of 41
`
`
`
`Petitioners Add New Theory in Reply
`
`Petition’s Theory
`
`-Pet. at 27
`
`POR 19-20
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`35
`
`Exhibit 2014
`IPR2022-00367
`Page 35 of 41
`
`
`
`Petitioners Add New Theory in Reply
`
`Petition’s Theory
`
`Pet. at 33
`
`SR 2, 3
`
`Pet. at 34
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`36
`
`Exhibit 2014
`IPR2022-00367
`Page 36 of 41
`
`
`
`Caselaw
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`37
`
`Exhibit 2014
`IPR2022-00367
`Page 37 of 41
`
`
`
`Requirement to Prove Obviousness
`
`“In cases in which ‘common sense’ is used to
`supply a missing limitation, as distinct from a
`motivation to combine, moreover, our search for
`a reasoned basis for resort to common sense
`must be searching.”
`
`-Arendi S.A.R.L. v. Apple Inc., 832 F.3d 1355, 1363 (Fed. Cir. 2016)
`
`POR 16
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`38
`
`Exhibit 2014
`IPR2022-00367
`Page 38 of 41
`
`
`
`Requirement to Prove Obviousness
`
`“[W]e conclude that there is not substantial evidence to
`support the Board’s finding of fact that Evans expressly
`teaches that ‘one sensor’ may be used to control a
`plurality of valves, and there is not substantial evidence
`of record, either expressly or implicitly, to modify the
`teachings of Evans to obtain a system in which one
`sensor controls a plurality of valves.”
`
`-In re Kotzab, 217 F.3d 1365, 1371–72 (Fed. Cir. 2000)
`
`POR 15
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`39
`
`Exhibit 2014
`IPR2022-00367
`Page 39 of 41
`
`
`
`Requirement to Prove Obviousness
`
`“[I]n an obviousness analysis, conclusory assertions
`from a third party about general knowledge in the
`art cannot, without supporting evidence of record,
`supply a limitation that is not evidently and
`indisputably within the common knowledge of those
`skilled in the art.”
`
`-PTAB Consolidated Trial Practice (Nov. 2019) at 36 (citing K/S Himpp
`v. Hear-Wear Techs., LLC, 751 F.3d 1362, 1365 (Fed. Cir. 2014)).
`
`POR 18
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`40
`
`Exhibit 2014
`IPR2022-00367
`Page 40 of 41
`
`
`
`IPR2022-00367
`(’235 Patent)
`
`Apple Inc. and HP Inc.
`Petitioners
`v.
`XR Communications, LLC, d/b/a Vivato Technologies,
`Patent Owner
`Patent Owner’s Demonstratives
`
`Filing date: May 2, 2023
`Oral argument date: May 5, 2023
`
`Exhibit 2014
`IPR2022-00367
`Page 41 of 41
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
