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`571-272-7822
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`UNITED STATE PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC., HP INC., AMAZON.COM, INC.,
`AMAZON.COM SERVICES LLC,
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., GOOGLE LLC,
`DELL TECHNOLOGIES INC. and DELL INC.,
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`PETITIONER,
`v.
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`XR COMMUNICATIONS LLC
`Patent Owner.
`____________
`
`IPR2022-00367
`Patent 10,715,235 B2
`____________
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`Record of Oral Hearing
`Held: May 5, 2023
`____________
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`
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`Before BARBARA A. PARVIS, JAMES J. MAYBERRY, and
`NORMAN BEAMER, Administrative Patent Judges.
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`571-272-7822
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`Paper No. 33
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`UNITED STATE PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC., HP INC., AMAZON.COM, INC.,
`AMAZON.COM SERVICES LLC,
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., GOOGLE LLC,
`DELL TECHNOLOGIES INC. and DELL INC.,
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`PETITIONER,
`v.
`
`XR COMMUNICATIONS LLC
`Patent Owner.
`____________
`
`IPR2022-00367
`Patent 10,715,235 B2
`____________
`
`Record of Oral Hearing
`Held: May 5, 2023
`____________
`
`
`
`Before BARBARA A. PARVIS, JAMES J. MAYBERRY, and
`NORMAN BEAMER, Administrative Patent Judges.
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`IPR2022-003671
`Patent 10,715,235 B2
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`APPEARANCES:
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`ON BEHALF OF THE PETITIONER:
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`USMAN A. KHAN
`DAVID HOLT
`W. KARL RENNER
`Fish & Richardson P.C.
` 7 Times Square
` New York, New York, 10036
` (212) 765-5070
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`ON BEHALF OF THE PATENT OWNER:
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`PHILIP WANG
`REZA MIRZAIE
`CHRISTIAN W. KONKLE
`Russ, August & Kabat
`12424 Wilshire Boulevard, 12th Floor
` Los Angeles, California 90025
`(310) 826-7474
`212-257-((2179212-257 212-257-5797
`
`The above-entitled matter came on for hearing on Friday, May 5, 2023,
`commencing at 2:01 p.m., EST, at the U.S. Patent and Trademark Office,
`600 Dulany Street, Alexandria, Virginia.
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`P R O C E E D I N G S
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`JUDGE MAYBERRY: Good afternoon, and welcome. I am Judge
`Mayberry, and with me on your screens should be Judges Parvis and
`Beamer. Like counsel, we are located remotely, and joining by audio-video
`link.
`
`We are here for oral arguments in IPR2022-00367, which concerns
`U.S. Patent Number 10,715,235, which we will refer to as the '235 patent, in
`the proceeding styled Apple, Inc., et al., v. XR Communications, LLC.
`Before we go over some ground rules, I'd like to start with appearances by
`the parties. We'll start with Petitioner's counsel.
`MR. KHAN: Petitioner here, represented by Usman Khan, David
`Holt, and Karl Renner.
`JUDGE MAYBERRY: All right. Thank you. And for Patent
`Owner?
`MR. WANG: Good afternoon, Your Honors. This is Philip Wang on
`behalf of Patent Owner, XR Communications. And I'm joined on the phone,
`I believe, by my colleagues, Christian Konkle and Reza Mirzaie.
`JUDGE MAYBERRY: Right. Thank you. I'm also going to ask
`Judges Parvis and Beamer to acknowledge that they can hear the parties, and
`just to make sure the parties can hear them.
`JUDGE PARVIS: Let me try it again. This is Judge Parvis. I can
`hear the parties.
`JUDGE MAYBERRY: Thanks. And Judge Beamer?
`JUDGE BEAMER: Yes, I can hear.
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`JUDGE MAYBERRY: All right. Thank you. Before we get started,
`I'd like to go over some of the mechanics of the hearings. First, thank you
`all for accommodating this hearing by video today. Our primary concern is
`your ability to be heard and present your case on the record as you see fit.
`If, at any time during the hearing, you encounter technical difficulties
`that you feel undermines your ability to adequately represent your client,
`please let us know immediately. You should have been given contact
`information from our hearings team. If you lose connection or encounter
`some other problem, you should use that information to contact them.
`Our hearing order included some information on the conduct of a
`video hearing. I want to reemphasize that when you are not speaking, please
`mute your connection. Also, when you do speak, please identify yourself.
`This will help the court reporter prepare an accurate transcript.
`The judges have access to a complete trial record of this proceeding,
`including the parties' demonstratives. We ask, when you refer to a slide,
`please refer to the slide by number so that we can follow along and so the
`transcript is clear. Also, if you refer to an exhibit or a paper, please identify
`the exhibit or paper by number.
`As specified in the order, each party will have 60 minutes total to
`present arguments. Petitioner bears the burden of proving unpatentability,
`and will go first. Petitioner may reserve rebuttal time, then Patent Owner
`will respond to Petitioner's case. Patent Owner may reserve surrebuttal time.
`Petitioner may use its rebuttal time to reply to Patent Owner's responsive
`arguments. Patent Owner may use its surrebuttal time to reply to Petitioner's
`responsive arguments. We're going to take a short break after Patent
`Owner's first set of responsive arguments.
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`Now, we do have one housekeeping matter to go over. Patent Owner
`filed two different exhibits numbered Exhibit 2009, and two exhibits
`numbered Exhibit 2010. So, we're going to ask Patent Owner to refile the
`Exhibit 2009 that was filed on June 16, 2022 and the Exhibit 2010 filed on
`June 16, 2022, as Exhibits 2015 and 2016, respectively. These, I believe, are
`the next sequential exhibits.
`And we also ask Patent Owner to file a brief paper identifying the new
`exhibit numbers, indicating that the new exhibits are the same as the
`previous exhibits, and were only cited in Patent Owner's preliminary sur-
`reply that was filed on June 16, 2022. Although these two exhibits were
`correctly numbered, because they're just used in a limited manner pre-
`institution, it seems the cleanest to renumber these, and especially since
`2010 is a declaration filed in support of the Patent Owner response. But
`we're not going to file a separate order directing this action, so this is it.
`Any questions from Patent Owner's counsel about these instructions?
`MR. WANG: No, thank you, Your Honor. I apologize for the
`clerical error, and we'll clear that up shortly --
`JUDGE MAYBERRY: All right, thank you.
`MR. WANG: -- and do as you instructed.
`JUDGE MAYBERRY: All right, thanks. And while you're here,
`Patent Owner Counsel, do you have any other questions before we start?
`MR. WANG: No, I do not.
`JUDGE MAYBERRY: And Petitioner's counsel, any questions
`before we start?
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`MR. KHAN: No questions, Your Honor. But I would like to note
`that we're joined also by Tanya Manno from Apple, and Tony Baca from
`HP.
`
`JUDGE MAYBERRY: All right, thank you. And with that,
`Petitioner's counsel, you may start your arguments when you're ready. I'd
`first like to ask you, do you have any idea how much rebuttal time, if any,
`you would like to reserve?
`MR. KHAN: We would like to reserve 20 minutes of rebuttal time.
`JUDGE MAYBERRY: Right, thanks.
`MR. KHAN: Please let me know when I can start, and I'll --
`JUDGE MAYBERRY: I'm sorry. Start as soon as you're ready.
`MR. KHAN: Great. Good afternoon, Your Honors, and may it please
`the Board. Thank you for accepting our oral hearing request and giving us
`the opportunity to present our case and answer any questions you may have.
`If it's okay, I'll be referencing the oral hearing demonstratives that we
`shared, and going -- referencing the slides there. So, with that, if I could ask
`Your Honors as to please turn to slide 2.
`As a quick overview, the IPR addresses claims 8 to 14 of the '235
`patent, which were method claims in the past. This issues in -- the issues
`involved in this proceeding are limited to independent claim 8, because
`Patent Owner did not advance arguments against the other claims. As
`reflected by the grounds here, the petition presents a single-reference
`obviousness ground against claim 8, because Burke renders obvious all the
`claim features, including multiple antenna elements, and other features that
`we will discuss in more detail today. If Your Honors could please turn to
`slide 3.
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`Slide 3 includes a table of contents for the slide deck, and notes the
`issues in this proceeding. The first two issues are related to feature 8a. And
`to a large extent, the issues for features 8d and 8e rise and fall with the issues
`for feature 8a.
`As we will explain in this presentation, these issues arose because
`Patent Owner applies the incorrect standard for determining obviousness --
`namely, that the Petitioner has to explicitly show how Burke's advice would
`implement an array of antennas, basically asking for a blueprint of Burke's --
`of how Burke's device would Burke when it implements an antenna array.
`Based on this incorrect standard, Patent Owner has alleged that
`Petitioner fails to satisfy its burden. By the end of my presentation, it will be
`clear that these issues are, in fact, non-issues, because Burke's disclosure on
`its own renders claim 8 obvious. Let's briefly take a look at the claim
`language. So, if Your Honors could turn to the -- to slide 5.
`Slide 5 is a reproduction of claim 8. The features that are the subject
`of discussion in these proceedings are identified in green -- specifically,
`feature 8a, which recites, "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."
`Features 8d and 8e are determining sets where determining second
`signal for the second signal transmission, wherein the second signal is
`different from the first signal information; and finally, the 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
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`transmission signals. Now, before we dig into the issues, we thought it
`would be beneficial to provide an overview of Burke's teachings. Now, with
`that, if Your Honors could turn to slide 6.
`And slide 6 shows Burke's Figure 2. As shown in slide 6, there is a
`base station 104 with antenna array elements 110A to 110M, and it can
`transmit multiple signals to the mobile station 106. This particular figure
`shows that there are two signal transmissions that have different -- each one
`of them has peaks and nulls, and a particular directionality so that they can
`be sent in different directions, in different paths, but yet, received by the
`mobile station 106.
`What Burke explicitly teaches us is that these signals that are
`transmitted from the base station to the mobile station, that these signals can
`be configured with different weights and delays such that they are -- as they
`traverse the various multipaths, they will arrive simultaneously at the
`receiving device, the mobile station. If Your Honors could turn to the next
`slide, please, slide 7.
`Now, what Burke also tells us is that in addition to receiving these
`signals simultaneously, the antenna shown as 112 of the mobile station, well,
`this could, in fact, be an array of diversity antennas for deploying diversity
`techniques known in the art. As one example of a known diversity
`technique, Burke, in its summary paragraph, indicates that space-time
`diversity can be deployed in its system. So, Burke explicitly says that its
`mobile station can include an array of diversity antennas.
`Turning to the next slide, slide 8. Slide 8 includes the copy of Burke's
`Figure 12, which depicts one example embodiment of the components of a
`receiver at the mobile station. These -- basically, these components are used
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`to perform routine receiver operations such as channel estimation and other
`signal processing operations to obtain the signal data via the demodulator
`shown at the top of the figure. If Your Honors could please turn to slide 9.
`Now, in describing Burke's Figure 12, which was the receiver, as
`shown here in the top snippet, which has been produced from Burke's
`column 25, it's literally the second line describing Figure 12. Burke
`explicitly, again, notes that the antenna can be implemented as an array of
`diversity antennas -- antenna elements for deploying diversity techniques.
`This is consistent with the description of Figure 2.
`In fact, the notion that Burke's receiving mobile station would have
`similar structure such as an antenna array like that of the transmitting base
`station is not entirely surprising. For instance, in several communications
`systems, the architecture of the transmitting and receiving devices can be
`similar, but opposite, where, for example, a transmitter uses encoding and
`modulation, a receiver side would use a decoder and a demodulator.
`In Burke, there's similar discussion. And here, in -- for example,
`shown in the second snippet, that the base station and mobile station can also
`have similar processors. For example, the same type of pre-correction
`processor that's used in the base station can also be used in the mobile
`station. Dr. Akl, in the bottommost snippet, also conveys the same thought,
`by pointing out that in Burke, the transmitting and receiving devices both
`have antenna arrays, and that such arrays would be beneficial to implement
`diversity techniques. This is not something that he just said, as we noted
`earlier. This is taught explicitly by Burke itself.
`JUDGE MAYBERRY: Excuse me, Counsel.
`MR. KHAN: Yes.
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`JUDGE MAYBERRY: This is Judge Mayberry. If I may ask a
`question, the Figure 2 of Burke, you would at least agree that it shows
`antenna 110 as a diversity antenna, showing A through M elements, and 112
`as a single antenna. So, at least, as depicted, Burke is presenting antenna
`112 as a single antenna.
`MR. KHAN: Yes, Your Honor. As depicted, that is the case. Burke,
`in fact, is very flexible in his disclosure in saying that Burke's system can
`work with a single antenna, or multiple antenna elements at the receiver
`side.
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`JUDGE MAYBERRY: And does this not cut against the footnote 1
`of Dr. Akl's second declaration then, which seems to suggest to me that there
`would be advantages of having them both be the same?
`MR. KHAN: I'm not sure -- could you explain, Your Honors, what
`you mean by cutting against?
`JUDGE MAYBERRY: Well, I mean, if there were advantages with
`both the base station and mobile station having antenna arrays, why not just
`show the mobile station with antenna arrays?
`MR. KHAN: Well, because there is flexibility in design, right? There
`can be benefits of employing a single antenna. There can be benefits of
`employing multiple antenna elements. Burke's disclosure gives you the
`flexibility to do either/or, right? And that's why it describes it as such.
`JUDGE MAYBERRY: All right. Thank you.
`MR. KHAN: Thank you. If Your Honors could turn to slide 10. So,
`in slide 10 --
`JUDGE PARVIS: This is Judge Parvis. A question I have, we see
`two signals being transmitted from base station 104, and those are both
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`received by 112. And as Petitioner presents its arguments with respect to a
`configuration that's not shown in Figure 2 or Figure 12, it would be helpful
`to tie in Petitioner's position with respect to those two signals that Petitioner
`is relying on. The -- are those signals both transmitted to every element in
`the array, for example? That's one question that I have.
`MR. KHAN: Yes, Your Honors. We'll actually show that in our
`subsequent slides. And typically, when you do have antenna array elements,
`the signals that are transmitted from the transmitting device will all be
`received by the various antenna elements on the antenna array. So, if Your
`Honors could turn to slide 10.
`On slide 10, we list the topics for discussion here or the issues. I'd
`like to just note and apologize for a typographical error here. The heading
`says "five topics," and clearly, it's just four. And with that, if we could
`transition to the first topic, which is a Burke's mobile station has a plurality
`of antenna elements.
`If Your Honors could please turn to slide 11. And slide 11, we just
`repeat for your benefit the language that is recited in feature 8a -- mainly
`requires two antenna elements of an antenna at receiving a first signal
`transmission and a second signal transmission simultaneously. Slide 12,
`please.
`Now, Patent Owner argues that Burke's mobile station uses an antenna
`with only a single antenna element. Patent Owner repeats this argument
`several times in their papers. But this incorrect statement and
`mischaracterization of Burke ignores the explicit disclosure in Burke's
`specification that the mobile station can have an array of diversity antennas,
`which means that it would have had more than one antenna element.
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`Now, we also address how well known the use of antenna arrays was.
`As noted in the next slide, slide 13, even Patent Owner's experts conceded
`that antenna arrays have been known for a long time, that the use and
`implementation of an antenna array in a mobile station would have been
`well known and obvious.
`Turning to the next slide, slide 14, we now come to the topic that's
`perhaps been briefed most by the parties. As highlighted in green here, topic
`number 2, is that Burke renders obvious a mobile station having two antenna
`elements receiving two signals simultaneously. If Your Honors could turn
`to slide 15, please.
`For your reference, here, again, at the top, we've included the
`language of claim feature 8a. Now, turning to Burke's Figure 2 again,
`Burke's Figure 2 clearly depicts multiple signal transmissions being received
`from a remote station here at a base station. And its specification explicitly
`states that the multiple signals can be received simultaneously.
`In the second snippet there, Burke also specifically tells us that an
`array of diversity antennas can be used in place of antenna 112, or as a form
`of implementing antenna 112. So, based just on this disclosure, we know
`that Burke's antenna array receives two signal transmissions simultaneously
`from the base station. Now, I want to --
`JUDGE MAYBERRY: I'm sorry -- excuse me, Counsel. Judge
`Mayberry here. If I could break this down a little -- and it was something
`that you had said in response to Judge Parvis's question as well. So, looking
`at this slide, you've got your colorized version of Figure 2, where we have
`signals 130A and 132A. And if I understand Petitioner's position, we have,
`let's say, two elements at antenna 112 -- element 112A and 112B. Did I
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`understand you correctly to say that signal 130A and 130B will be received
`at both 112A and 112B?
`MR. KHAN: That's correct, Your Honor.
`JUDGE MAYBERRY: So, when we get to the claim language -- and
`maybe you're getting to this -- it requires that, in this example, 130A, should
`be received at 112A at the same time 132A would be received at 112B. Is
`that the correct reading of the claim?
`MR. KHAN: That's correct. Yes, Your Honor.
`JUDGE MAYBERRY: Why wouldn't it be the appropriate reading of
`Burke's disclosure that 130A and 130B arrive at 112A at the same time, and
`130A and 130B arrive at 112B at the same time, but that those two times are
`different?
`MR. KHAN: Yes. So, I'd like to maybe do a slight clarification here.
`And maybe for the benefit of our discussion, we can turn to slide 19. Now,
`this is one of the references that would be submitted in the petition that
`corroborates what a POSITA's understanding would have been of employing
`a diversity technique when using an antenna array.
`As you can see -- and answering Judge Parvis's question earlier --
`when -- you have a transmitting device on the left and you have two
`receiving devices on the right. And each signal that is transmitted from one
`antenna element is received by both of the receiving antenna elements on the
`receiver. And also, the second antenna element that's transmitting from the
`transmitter, its two signals are also received by both antenna elements in the
`receiving device.
`So, what happens in these systems is that -- and Burke teaches -- if we
`can go back, for instance, to what I've mentioned earlier and I noted in slide
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`6, that you can apply weights and delays, right, to cause the various signals
`to be received simultaneously. And so, what happens in Burke's system
`when you are sending multiple signals from one antenna array to another
`antenna array is that you can configure the signals by applying weights and
`delays so that they -- irrespective of which path they take, they can arrive at
`the designated antenna simultaneously.
`JUDGE MAYBERRY: Thank you, Counsel. And what I just
`probably heard you say right at the end is that you would apply these
`weights and delays so that they would arrive at the designated antenna
`element at the same time.
`MR. KHAN: That's correct, Your Honor. So, if we have --
`JUDGE MAYBERRY: The same requires, though, the signals to
`arrive at two different elements at the same time.
`MR. KHAN: That's right, Your Honors. It's two different antenna
`elements at the same time. And we will also discuss this concept further
`with respect to the Goldsmith reference, which is another corroborating
`reference that we gave. It's coming up in a few slides.
`JUDGE MAYBERRY: All right. Thank you.
`JUDGE PARVIS: This is Judge Parvis. The -- looking at the slide
`20, I mean, it -- that's a figure that was shown -- that figure is in the
`Petitioner's reply. Is that correct?
`MR. KHAN: That is correct, yes.
`JUDGE PARVIS: That figure has on the left-hand side a portion of a
`figure from one reference. And on the right-hand side, it has a portion of a
`figure from a different reference. Is that correct?
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`MR. KHAN: No, Your Honors. They're both from Burke. So, the
`big-picture figure is Burke's Figure 2. And then we've included Burke's
`Figure 12 -- just two copies of Burke's Figure 12. So, they're all from Burke.
`JUDGE PARVIS: Okay. So -- but the right-hand side -- Figure 12 of
`Burke does not look exactly like what's on the right-hand side. You've
`actually reproduced Burke twice.
`MR. KHAN: It's two copies of Burke's Figure 12, yes.
`JUDGE PARVIS: Did that figure that's illustrated on slide 20 -- was
`that actual figure in the petition?
`MR. KHAN: So, that actual figure was not in the petition, Your
`Honor. But what was in the petition was an explanation that there's several
`ways of achieving diversity in -- as taught by Burke. And then we have
`referenced several different references that explain what diversity --
`achieving diversity would mean.
`And so, what we have the knowledge to explain it is that this is just
`one example. In fact, immediately after we provided this example, we also
`noted that there's another example implementation where you don't need to
`duplicate the figures. And so, there's just several different example
`implementations through which you can arrive at receiving two signals at an
`antenna array simultaneously.
`JUDGE PARVIS: Did Petitioner need to include this figure in the
`petition, or is this, in Petitioner's view, acceptable in your reply?
`MR. KHAN: No, Your Honors. This Petitioner is not -- I'm sorry,
`this figure is not necessary. We think Burke's disclosure by itself renders the
`claims obvious. Now, we included this just to clarify to Patent Owner in
`response to the Patent Owner's remarks that, in fact, there are several various
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`implementations here that are well known in the art. In fact, the claims,
`Your Honors, if you look at these, are method claims. The only structural
`elements that are required are single -- the two antenna elements to do the
`receiving. They don't require the D12 (phonetic) implementations there.
`And that -- and there's a lot of flexibility in designing receiver systems so
`that you can effectively receive two signals simultaneously at two different
`antenna elements.
`JUDGE PARVIS: I think I understand Petitioner's position. Thank
`
`you.
`
`JUDGE MAYBERRY: Excuse me, Counsel. Judge Mayberry again.
`While we're on your slide 20 -- and we kind of hijacked you a little bit, but
`that helped me understand a little bit more. When we're looking at this
`figure -- and you added these four arrows, four black arrows, two coming
`from 130A and two coming from 132A, going to the two different antenna
`each. Is it Petitioner's position that all four of those signals arrive
`simultaneously?
`MR. KHAN: No, it's not, Your Honors. It's -- that's not necessary.
`What we know is that the first signal can arrive at the first antenna element
`at the same time that the second signal arrives at the second antenna
`element. Typically, when you have, for example -- and the reason that's the
`case is because when you're emitting a signal from one particular antenna, it
`takes two different paths. It takes two different paths to arrive at two
`different antennas. So, the timing will probably be off there a little bit.
`Whereas if the second signal is being emitted from a second antenna
`element, it can be configured -- its timing can be configured with weights
`and with delays so that it arrives at the second transmission -- the second
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`IPR2022-003671
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`antenna element at the same time that the first signal transmitted by the first
`antenna element is received by the receiver antenna element. Does that
`make sense? If you'd like me to clarify further, I can.
`JUDGE MAYBERRY: I think I understand what you said, but in my
`follow-up, can you direct us to evidence in the record that supports that aside
`from Burke's statements? Because Burke's statements, I could follow.
`Burke's, if we -- again, looking at your modified figure here on slide 20, if
`we only had the top version of Figure 12 there, we only have the two black
`lines. I would understand Burke's disclosure to tell me that those two black
`lines arrive at the same time.
`But now, what I think I heard you say is that with your now two
`versions of Figure 12 there, the top black line arrives at the top antenna
`element at the same time that the bottom black line arrives at the bottom
`antenna element. And I'm trying to get evidence to support that
`understanding.
`MR. KHAN: I see. So, maybe we can do -- if Your Honors could
`turn to slide 17. In slide 17, this is one of the -- and I apologize, it might be
`a little bit of indirect answer before I actually get to answering your
`question. But Goldsmith was one of the corroborating references that
`explained how diversity antennas work. And Goldsmith teaches us that
`when you're using diversity techniques, you implement directional antennas.
`Directional antennas, as you saw in Burke, it can be configured with
`one major lobe and a few minor side lobes, and they will provide directional
`transmission in a particular direction. And in receiver diversity, these are
`associated with multiple receiver antennas, right? It tells us that when you're
`implementing diversity in receiver antennas, right, then you're going to be
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`using multiple receiver antennas. The reason we do that is for array gain,
`diversity gain, et cetera. And so, Goldsmith -- and that also leads to FNR
`enhancements, et cetera.
`Now, going to the -- going to Figure 20, what happens when you have
`directional transmissions from antenna elements? So, you have that one
`directional -- in slide 20, you have the green signal, which is the first signal
`transmission. It's really being configured directionally to arrive at the first
`antenna element.
`The second signal transmission, which is the red signal, that's really
`being configured to be received by the second transmission antenna element.
`That's the primary destination for these. That's why they're directional in
`nature, right?
`Now, are -- does that mean that these other -- that the first signal and
`second signal will not be received by the other antenna elements? No, they
`do. They do get received by the other antenna elements, but that's not the
`primary target. They're directionally targeting a particular antenna element.
`And that's what's shown here in Figure 20, where you see there's kind of like
`a main direction of the signal towards one particular antenna element, and
`then another one.
`And so, when you're configuring these signals, you configure them to
`arrive at the same time at the antenna element that they're being configured
`for, right? That's the directionality it's being configured for. And so, Burke
`already tells us all of this. It tells us that, look, I'm using antenna arrays for
`diversity. And Goldsmith tells us, in receivers diversity, there is
`directionality used. There's directionality used, and it's used so that we can
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`realize all these performance enhancements, right, these antenna gains and
`other things like that.
`JUDGE MAYBERRY: Okay, thank you.
`MR. KHAN: Mm-hmm.
`JUDGE BEAMER: This is Judge Beamer. Going back to slide 20, if
`I understand what you're saying, the way that you make sure that one signal
`transmission arrives at the same time as a second transmission from a
`different antenna is that you adjust the delays, and maybe other parameters,
`such that both signals get to a particular destination at the same time. Is that
`what you're saying?
`MR. KHAN: That is correct, Your Honor.
`JUDGE BEAMER: So, it seems to me, just focusing on this figure --
`let's take what you've labeled as the first signal transmission, which is
`coming from the green antenna and going to the first antenna. And then
`there's a line right below that that's coming from the red antenna, and it's
`going to the same place. And so, each of those have to be adjusted in a
`different way in order to reach that first antenna at the same time. Is that --
`MR. KHAN: That's -- I'm sorry. Please go ahead.
`JUDGE BEAMER: Is that right?
`MR. KHAN: That's not what I'm saying. In fact, what I'm saying is
`that that last black line at the bottom of Figure 20, right, that's going to the
`second antenna element, that black line and the one at the topmost is going
`from the green lobe directly to the first lobe, right? These can be configured
`to arrive at the respective antenna elements at the same time.
`JUDGE BEAMER: So --
`MR. KHAN: And if you look at -- I'm sorry, go ahead.
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`JUDGE BEAMER: Well, I understood that's what you're saying. But
`that means that the second black line, which is not labeled, which is going
`from the red antenna to the first antenna, could not be coming -- arriving at
`the same time
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