Petitioners’ Oral Hearing Demonstratives
`
`Apple Inc. and HP Inc. (Petitioners)
`v.
`XR Communications LLC (Patent Owner)
`
`Case No. IPR2022-00367
`U.S. Patent No. 10,715,235
`
`Before Hon. James Mayberry, Miriam Quinn, and Barbara Parvis
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`1
`
`APPLE 1045
`Apple et al. v. XR Commc'ns
`IPR2022-00367
`
`1
`
`
`
`Apple Inc. and HP Inc. (Petitioners)
`v.
`XR Communications LLC (Patent Owner)
`
`Case No. IPR2022-00367
`U.S. Patent No. 10,715,235
`
`Before Hon. James Mayberry, Miriam Quinn, and Barbara Parvis
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`1
`
`APPLE 1045
`Apple et al. v. XR Commc'ns
`IPR2022-00367
`
`1
`
`
`
`Instituted Grounds
`
`35 USC 103(a) Ground
`
`Claim(s) Challenged
`
`Burke
`
`Burke and Shull
`* Independent claim noted in green
`
`8-12
`13, 14
`
`Petition (Pet.), 2; Institution Decision (ID), 7.
`
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`2
`
`2
`
`
`
`Table Of Contents
`
`The ’235 Patent
`Overview of Burke
`Issues/Discussion Topics
`Burke’s mobile station has a plurality of antenna elements (feature
`[8a])
`Burke’s disclosure renders obvious a mobile station having two
`antenna elements receiving two signals simultaneously (feature [8a])
`Burke discloses sending two signal transmissions with different
`signal information (feature [8d])
`Burke’s pre-correction processor can be similarly implemented in
`Burke’s mobile station and base station (feature [8e])
`
`4
`6
`
`10
`
`14
`
`26
`
`30
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`3
`
`3
`
`
`
`The ’235 Patent
`
`“The ’235 Patent discloses “a
`multi-beam directed signal system
`[that] coordinates directed wireless
`communication with [a] client.”
`
`Pet., 4 (citing EX1001 (’235 patent), 2:7-16).
`
`“[S]ignals … are received via
`antenna array [ ] and are provided
`to the signal control and
`coordination logic 304” for further
`processing (e.g., routing, applying
`weights).
`
`EX1001, 24:34-60; Pet., 5-6.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX1001, FIG. 2.
`
`4
`
`4
`
`
`
`The ’235 Patent – Independent Claim 8
`
`[8pre] A method in a wireless communications system, the method
`comprising:
`[8a] 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,
`[8b] wherein the first signal transmission and the second signal
`transmission comprise electromagnetic signals comprising one or more
`transmission peaks and one or more transmission nulls;
`[8c] determining first signal information for the first signal transmission;
`[8d] determining second signal information for the second signal
`transmission, wherein the second signal information is different than the
`first signal information;
`[8e] 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; and
`[8f] transmitting to the remote station a third signal comprising content
`based on the set of weighting values.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX-1001, 32:33-58.
`
`5
`
`5
`
`
`
`Overview of Burke
`
`Burke (EX1006), FIG. 2; Pet., 22.
`
`“pre-correction processor 310 produces weights and delays that cause the signals received
`along the various M multipaths to arrive simultaneously and in-phase.”
`
`EX1006, 7:66-8:2; Pet., 23.
`“delays are applied to the signals transmitted along the different signal paths such that they
`arrive at the antenna 112 of the receiving mobile station 106 at the same time.”
`EX1006, 4:42-45; Pet., 23.
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`6
`
`6
`
`
`
`Overview of Burke
`
`EX1006, FIG. 2; Pet., 22.
`
`“Signals are received at antenna 112 (which may be a single antenna, or an array of diversity antennas for deploying
`diversity techniques known in the art). The received signal is conditioned in receiver 1210, using techniques appropriate
`for one or more communication systems compatible with mobile station 106, such as those described above.”
`EX1006, 7:66-8:2; Pet., 22.
`“Received signals arrive at antenna 360 and are processed in receiver 370, in accordance with one or more systems or
`standards, such as those referenced above. Alternative embodiments may deploy an array of antennas for antenna 360, or
`one or more antennas 110 may be shared for receive and transmit.”
`
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`EX1006, 5:15-20; Pet., 22.
`
`7
`
`7
`
`
`
`Overview of Burke
`
`“Burke’s FIG. 12 illustrates the components of a mobile station 106 that receive signals from the base
`station 104. EX-1006, 25:56-67. “Signals are received at antenna 112” and “conditioned in receiver 1210.”
`Id. “Examples of conditioning include amplification, filtering, down conversion, analog to digital conversion,
`and other techniques known in the art.” Id.; EX-1003, ¶[73].”
`
`EX1006, FIG. 12; Pet., 24.
`
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`Pet., 23.
`
`8
`
`8
`
`
`
`Burke’s base station and mobile station have similar
`features and components
`Burke (EX1006)
`“Signals are received at antenna 112 (which may be a single antenna, or an array of
`diversity antennas for deploying diversity techniques known in the art). The received
`signal is conditioned in receiver 1210, using techniques appropriate for one or
`more communication systems compatible with mobile station 106, such as
`those described above.”
`
`EX1006, 25:58-61; Pet. Rep., 8.
`“a pre-correction processor, such as any pre-correction processor 310 described above,
`may be deployed within the mobile station instead of or in addition to one
`deployed in the base station 104.”
`
`EX1006, 27:22-35, Pet., 41.
`
`Dr. Akl’s second declaration (EX1044)
`Although antenna 110 refers to the antenna of the base station 104, a POSITA would
`have readily understood that Burke’s disclosure that an array of antennas can be
`shared for receiving data similarly applies on the mobile station 106 when the mobile
`station 106 uses an array of antennas to receive data. Indeed, space-time diversity
`(i.e., an example of a diversity technique) is one benefit of using diversity antennas,
`which are explicitly noted in Burke as being used by the mobile station 106.
`EX1006, 2:27-45, 25:56-67, Abstract.
`
`EX1044, footnote 1.
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`9
`
`9
`
`
`
`Five Topics For Discussion
`
`1. Burke’s mobile station has a plurality of antenna elements
`(feature [8a])
`2. Burke’s disclosure renders obvious a mobile station
`having two antenna elements receiving two signals
`simultaneously (feature [8a])
`3. Burke discloses sending two signal transmissions with
`different signal information (feature [8d])
`4. Burke’s pre-correction processor can be similarly
`implemented in Burke’s mobile station and base station
`(feature [8e])
`
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`10
`
`10
`
`
`
`The ’235 Patent – Independent Claim 8
`
`[8pre] A method in a wireless communications system, the method
`comprising:
`[8a] 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,
`[8b] wherein the first signal transmission and the second signal
`transmission comprise electromagnetic signals comprising one or more
`transmission peaks and one or more transmission nulls;
`[8c] determining first signal information for the first signal transmission;
`[8d] determining second signal information for the second signal
`transmission, wherein the second signal information is different than the
`first signal information;
`[8e] 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; and
`[8f] transmitting to the remote station a third signal comprising content
`based on the set of weighting values.
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`EX-1001, 32:33-58.
`
`11
`
`11
`
`
`
`Burke’s mobile station has an array of antenna elements
`
`XR argues:
`“But Burke’s mobile station uses an antenna with only a single antenna
`element.”
`
`Burke
`“Signals are received at antenna 112 (which may be a single antenna, or an
`array of diversity antennas for deploying diversity techniques known in the
`art).”
`
`EX1006, 25:58-61, 5:18-20; Pet., 22; EX1003, ¶[70].
`
`POR, 2, 12, 16-17, 19-22.
`
`EX1006, 25:58-61; Pet., 22, 27; EX1003, ¶[70].
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`12
`
`12
`
`
`
`XR’s expert, Dr. Vojcic, confirmed that antenna arrays
`were well-known in the art
`Petitioner Reply
`“during his deposition, Dr. Vojcic confirmed that antenna arrays were known
`for a long time. EX1043, 12:21-13:2 (“adaptive antenna arrays were known
`for a long time. And adaptive antennas for, say, beam steering and null
`steering were known in the art for some military applications, typically”).
`Given that antenna arrays were known for a long time and that multiple
`references corroborate the use of two antenna elements receiving two signals
`from a transmitter, the incorporation of an antenna array into Burke’s system
`would therefore have been well within the realm of a knowledge of a POSITA
`and therefore obvious.”
`
`Pet. Rep., 22.
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`13
`
`13
`
`
`
`Five Topics For Discussion
`
`1. Burke’s mobile station has a plurality of antenna elements
`(feature [8a])
`2. Burke’s disclosure renders obvious a mobile station
`having two antenna elements receiving two signals
`simultaneously (feature [8a])
`3. Burke discloses sending two signal transmissions with
`different signal information (feature [8d])
`4. Burke’s pre-correction processor can be similarly
`implemented in Burke’s mobile station and base station
`(feature [8e])
`
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`14
`
`14
`
`
`
`Burke’s renders obvious a mobile station having two
`antenna elements receiving two signals simultaneously
`’235 Patent, Feature [8a]
`“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,”
`
`Burke
`
`EX1001, 33:50-53.
`
`“pre-correction processor 310
`produces weights and delays that
`cause the signals received along the
`various M multipaths to arrive
`simultaneously and in-phase.”
`EX1006, 7:66-8:2; Pet., 23, 29.
`“Signals are received at antenna 112
`(which may be a single antenna, or
`an array of diversity antennas for
`deploying diversity techniques
`known in the art).”
`EX1006, 25:58-61, 5:18-20; Pet., 22;
`EX1003, ¶[70].
`
`EX1006, 25:58-61; Pet., 22, 27; EX1003, ¶[70].
`
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`15
`
`15
`
`
`
`Corroborating references confirm the obviousness of receiving two
`signals using two antenna elements in Burke
`
`Petition
`“it would have been obvious to a POSITA that the first signal transmission transmitted over a signal
`path 150 (“first signal transmission”) would have been received via one of the antennas, e.g., a first
`antenna (“first antenna element”) of the array of antennas in antenna 112, and a second signal
`transmission transmitted over signal path 160 would have been received via a second antenna
`(“second antenna element”) of the array of antennas in antenna 112 (“antenna”). EX-1003, ¶[85].
`Prior art from the same time period further demonstrates that a POSITA would have been
`motivated to implement Burke’s disclosure (EX-1006, 25:58-61) for its technological benefits
`like improved short term channel estimation and receiver performance gain with a reasonable
`expectation of success because it was implemented in similar wireless communications systems.”
`Pet., 28; EX1003, ¶[85].
`
`Hottinen, Walton, and Goldsmith are examples of the well-known understanding a
`POSITA would have had that different receiving antennas in an antenna array would have
`been used to receive two signal transmissions transmitted from two antennas in an
`antenna array of a transmitting device. EX-1003, ¶[85].
`
`Pet., 29; EX1003, ¶[85].
`
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`16
`
`16
`
`
`
`Goldsmith
`
`Goldsmith (EX1017)
`Directional antennas provide angle, or directional, diversity by restricting the receive antenna
`beamwidth to a given angle. In the extreme, if the angle is very small then at most one of the
`multipath rays will fall within the receive beamwidth, so there is no multipath fading from multiple
`rays. However, this diversity technique requires either a sufficient number of directional antennas
`to span all possible directions of arrival … Smart antennas are antenna arrays with adjustable
`phase at each antenna element: such arrays form directional antennas that can be steered to the
`incoming angle of the strongest multipath component [3].
`
`EX1017, 191; Pet., 29.
`In receiver diversity the independent fading paths associated with multiple receive antennas
`are combined to obtain a resultant signal that is then passed through a standard demodulator. The
`combining can be done in several ways which vary in complexity and overall performance.
`EX1017, 191; Pet., 29.
`
`“There are two types of performance gain associated with receiver space diversity: array gain and
`diversity gain. The array gain results from coherent combining of multiple receive signals. Even in
`the absence of fading, this can lead to an increase in average received SNR.”
`
`EX1017, 192; Pet., 29.
`XR’s expert, Dr. Vojcic, agreed that “Petitioner’s application of Burke would have resulted in
`improved performance gain. EX1043, 68:1-2 (‘the latter part is correct, yes, it could provide
`performance gain for the receiver’).”
`
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`EX1017, 192; Pet., 29; Pet. Rep., 16.
`
`17
`
`17
`
`
`
`Hottinen
`
`Hottinen (EX1011)
`
`“subsequent(cid:3)short(cid:882)term(cid:3)processing(cid:3)and(cid:3)
`an(cid:3)improved(cid:3)short(cid:882)term(cid:3)channel(cid:3)
`estimation(cid:3)at(cid:3)the(cid:3)user(cid:3)equipment(cid:3)
`enabled(cid:3)by(cid:3)an(cid:3)increase(cid:3)in(cid:3)diversity(cid:3)and(cid:3)
`antenna(cid:3)gain/interference(cid:3)
`suppression.”
`
`EX1011, 25; Pet., 28.
`
`EX1011, 24; Pet., 28.
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`18
`
`18
`
`
`
`Walton
`
`Walton (EX1012)
`
`“At each scheduled terminal 106, a number of receive antennas 552 receive the transmitted signals, and each receive
`antenna provides a received signal to a respective demodulator (DEMOD) 554. Each demodulator (or front end unit)
`554 performs processing complementary to that performed at modulator 522.”
`
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`EX1012, FIG. 5; Pet., 28-29;
`Pet. Rep., 11.
`
`19
`
`EX1012, FIG. 5;
`Pet., 28-29;
`Pet. Rep., 11.
`
`19
`
`
`
`One possible known configuration for antenna arrays
`
`Dr. Akl’s second declaration (EX1044)
`
`“one possible implementation is that a second set of components is added that is identical to the set of components
`shown in FIG. 12. In such a configuration, the antenna array includes two antenna elements 112. Realizing such a
`configuration is as simple and obvious as duplicating the components shown in FIG. 12 and adding them to Burke’s
`mobile station 106.”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
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`Pet. Rep., 12; EX1044, ¶[9].
`
`20
`
`EX1044, pg. 7;
`Pet. Rep., 12-13.
`
`20
`
`
`
`One possible known configuration for antenna arrays
`
`Petitioner Reply
`
`“Burke explicitly teaches that various suitable components can be used in processing
`the signals received by the antenna array including, for example, ‘RF downconverters,
`amplifiers, filters, analog-to-digital (AID) converters, demodulators, RAKE receivers,
`combiners, deinterleavers, decoders (Viterbi, turbo, block decoders such as those
`implementing Bode-Chaudhury-Hocquenghem (BCH) codes, etc.)’ EX1006, 5:13-32.
`Burke’s use of the plural form of the listed components is consistent with the
`duplication of components shown in FIG. 5 of Walton for an array of antennas,
`and is further corroboration that a POSITA would have known how to configure a
`receiver to accommodate an array of antennas.” EX1044, ¶¶[10]-[11].
`Pet. Rep., 14. EX1044, ¶¶[10]-[11].
`
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`
`21
`
`21
`
`
`
`It would have been obvious to a POSITA that two antenna elements
`in Burke’s antenna array would have received two signals
`
`Petitioner Reply
`the Petition explained that it would have been obvious when receiving two
`simultaneous signals from another device, the two signals would have been
`received at different antenna elements, namely a first antenna element and a
`second antenna element. Pet., 26-30. The obviousness of this is not based
`on hindsight or “common sense,” as XR alleges. POR, 2, 3. Rather, in
`disclosing that receiver antenna 112 can be implemented as “an array of
`diversity antennas for deploying diversity techniques” and similarly
`“one or more antennas 110 may be shared for receive,”[] Burke
`suggests to a POSITA that when an array of antenna elements is used
`to receive signals, two antenna elements in the array can be used for
`receiving two signal transmissions. EX1003, ¶¶[84]-[86]; Pet., 27-30;
`EX1044, ¶[7].
`
`Pet. Rep., 9-10.
`
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`
`22
`
`22
`
`
`
`Several possible configurations of antenna arrays would have been
`obvious to a POSITA
`
`Petitioner Reply
`As Dr. Akl explained in his first declaration (“Hottinen, Walton, and
`Goldsmith are examples of the well-known understanding a POSITA would
`have had that different receiving antennas in an antenna array would have
`been used to receive two signal transmissions transmitted from two antennas
`in an antenna array of a transmitting device”) and reiterates again now, the
`configuration depicted above would have been readily understood by a
`POSITA (e.g., as evidenced by Walton’s FIG. 5). EX1003, ¶[85], see also
`¶¶[84], [86]; EX1044, ¶[12]. However, a POSITA would have been able to
`implement several possible configurations to accommodate an array of
`antenna elements. EX1044, ¶[12]. Indeed, even XR’s expert conceded
`that “[i]t's possible to have different implementations.” EX1043, 76:1-19.
`
`Pet. Rep., 14-15.
`
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`23
`
`23
`
`
`
`XR’s reliance on Arendi is misplaced
`
`Petitioner Reply
`“the Federal Circuit has clarified that Arendi is distinguishable from circumstances, as
`here, where ‘the Board rel[y] on expert evidence, which [is] corroborated by’ the
`teachings in cited prior art. Koninklijke Philips NV v. Google LLC, 948 F. 3d 1330, 1338
`(Fed. Cir. 2020). Importantly, as noted below, the Federal Circuit recognized that a
`POSITA’s knowledge is key to determining obviousness.”
`
`Pet. Rep., 20.
`
`“In these proceedings, Petitioner has set forth an obviousness ground in which Dr. Akl (an
`expert in this subject matter) explained, with the corroboration of three other references, that
`the use of two antenna elements in Burke’s antenna array to receive two signal
`transmissions, respectively, in the manner claimed by the ’235 Patent would have been
`obvious as it was consistent with practices and knowledge of a POSITA at the effective
`priority date of the ’235 Patent. Pet., 20-30.”
`
`“in an attempt to analogize this IPR to Arendi, XR mischaracterizes
`Petitioners’ obviousness ground as relying on ‘“common sense” arguments.’
`POR, 18-19. Nowhere in the Petition does Petitioner use such a rationale or even
`the words “common sense.”
`
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`
`Pet. Rep., 22-23.
`
`24
`
`Pet. Rep., 21.
`
`24
`
`
`
`The ’235 Patent provides a similar level of description of an antenna
`array as Burke
`
`’235 Patent
`
`Petitioner Reply
`In addition to mischaracterizing Burke, XR also
`turns to the ’235 Patent’s
`FIG. 3 in an attempt to distinguish Burke from
`the ’235 Patent. POR, 21. But even
`FIG. 3 does not bother to show the various
`antenna elements and instead just illustrates
`a single box and labels it antenna array 302.
`EX1001, FIG. 3. This
`depiction reinforces Petitioners’ position.
`Pet. Rep., 18-19.
`
`EX1001, FIG. 3; Pet. Rep., 18-19.
`
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`
`25
`
`25
`
`
`
`Five Topics For Discussion
`
`1. Burke’s mobile station has a plurality of antenna elements
`(feature [8a])
`2. Burke’s disclosure renders obvious a mobile station
`having two antenna elements receiving two signals
`simultaneously (feature [8a])
`3. Burke discloses sending two signal transmissions with
`different signal information (feature [8d])
`4. Burke’s pre-correction processor can be similarly
`implemented in Burke’s mobile station and base station
`(feature [8e])
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`26
`
`26
`
`
`
`The ’235 Patent – Independent Claim 8
`
`[8pre] A method in a wireless communications system, the method
`comprising:
`[8a] 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,
`[8b] wherein the first signal transmission and the second signal
`transmission comprise electromagnetic signals comprising one or more
`transmission peaks and one or more transmission nulls;
`[8c] determining first signal information for the first signal transmission;
`[8d] determining second signal information for the second signal
`transmission, wherein the second signal information is different than the
`first signal information;
`[8e] 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; and
`[8f] transmitting to the remote station a third signal comprising content
`based on the set of weighting values.
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX-1001, 32:33-58.
`
`27
`
`27
`
`
`
`Burke clearly discloses two signals with different signal
`information
`
`Burke
`
`Petitioner Reply
`“As shown in Burke’s FIG. 2 …, the first and second signal transmissions have different
`nulls, peaks, zeros, and directivity. EX-1006, 4:19-62; EX-1003, ¶[94].”
`
`EX1006, FIG. 2; Pet., 38.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Pet., 37.
`
`28
`
`28
`
`
`
`Signal information is determined by the receiver
`
`Burke
`
`EX1006, FIG. 12; Pet., 34.
`
`“Demodulator 1250 receives the output from one or more PN despreaders 1220 and demodulates
`those signals to produce the desired data.” EX-1006, 27:36-39.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`29
`
`EX1006, 27:36-39; Pet., 35.
`
`29
`
`
`
`Five Topics For Discussion
`
`1. Burke’s mobile station has a plurality of antenna elements
`(feature [8a])
`2. Burke’s disclosure renders obvious a mobile station
`having two antenna elements receiving two signals
`simultaneously (feature [8a])
`3. Burke discloses sending two signal transmissions with
`different signal information (feature [8d])
`4. Burke’s pre-correction processor can be similarly
`implemented in Burke’s mobile station and base station
`(feature [8e])
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`30
`
`30
`
`
`
`The ’235 Patent – Independent Claim 8
`
`[8pre] A method in a wireless communications system, the method
`comprising:
`[8a] 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,
`[8b] wherein the first signal transmission and the second signal
`transmission comprise electromagnetic signals comprising one or more
`transmission peaks and one or more transmission nulls;
`[8c] determining first signal information for the first signal transmission;
`[8d] determining second signal information for the second signal
`transmission, wherein the second signal information is different than the
`first signal information;
`[8e] 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; and
`[8f] transmitting to the remote station a third signal comprising content
`based on the set of weighting values.
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX-1001, 32:33-58.
`
`31
`
`31
`
`
`
`Burke’s base station uses weights received from the
`mobile station
`
`Burke
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`32
`
`EX1006, FIG. 5; Pet., 43.
`
`32
`
`
`
`weights
`
`Burke’s pre-correction processor can be used in the
`same manner in the base station and mobile station
`Burke
`“a pre-correction processor, such as any
`pre-correction processor 310 described
`above, may be deployed within the
`mobile station instead of or in addition
`to one deployed in the base station 104.
`In this alternative, the channel and
`noise estimates are delivered to the pre-
`correction processor, weights and/or
`delays are calculated and transmitted
`to the base station via message
`generator 1285, transmitter 1290, and
`antenna 112. Those of skill in the art will
`recognize the various trade-offs
`associated with signaling computed
`parameters rather than estimate
`information as well as distributing
`computing power between the mobile
`stations 106 and base stations 104.”
`EX1006, 27:22-35; Pet., 41.
`
`EX1006, FIG. 6; Pet., 42.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`33
`
`33
`
`
`
`Burke renders [8e] obvious
`
`Patent Owner Response
`“Dr. Akl fails to explain how the pre-correction processor 310 would be modified to
`accommodate an antenna 112 comprising multiple antenna elements.”
`
`POR, 32.
`
`Dr. Akl’s second declaration
`“A POSITA would have understood that the above-noted process would not be
`substantively different whether one antenna is receiving transmitted signals or
`multiple antenna elements of an antenna array are receiving signals. Burke’s system
`would have be[en] able to provide feedback from one or more antenna
`elements in the manner described above so that the base station 104 can
`optimize its beam-formed signals for reception by multiple antenna elements
`instead of just one antenna. … in contrast to XR’s assertions, no
`substantive modification of Burke’s pre-correction processor 310 is
`needed, and any slight changes would have been obvious to a POSITA.”
`
`EX1044, ¶[22].
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`34
`
`34
`
`
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