Declaration of Dr. Apostolos K. Kakaes
`Patent No. 9,860,044
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.,
`
`Petitioner,
`
`v.
`
`TELEFONAKTIEBOLAGET LM ERICSSON,
`
`Patent Owner
`
`Inter Partes Review Case No. IPR2022-00648
`
`U.S. PATENT NO. 9,860,044
`
`DECLARATION OF APOSTOLOS K. KAKAES, PH.D.
`
`IPR2022-00648
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`Declaration of Dr. Apostolos K. Kakaes
`Patent No. 9,860,044
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`TABLE OF CONTENTS
`I. INTRODUCTION .............................................................................................8
`II. BACKGROUND AND QUALIFICATIONS ..................................................9
`III. MATERIALS AND OTHER INFORMATION CONSIDERED ............15
`IV. UNDERSTANDING OF PATENT LAW ...................................................18
`V.
`SUMMARY OF OPINIONS .......................................................................20
`VI. OVERVIEW OF THE TECHNOLOGY ...................................................21
`VII. OVERVIEW OF THE ’044 PATENT ........................................................30
`A. Claims ............................................................................................................31
`B. Summary of the Specification .....................................................................31
`C. Summary of the Prosecution History .........................................................34
`VIII. LEVEL OF ORDINARY SKILL IN THE ART ........................................35
`IX. OVERVIEW OF THE PRIOR ART REFERENCES ..............................37
`A. Overview of Motorola ..................................................................................37
`B. Overview of LTE Release 8 Standards (TS36.211, TS36.213) ..................40
`C. Overview of LTE Release 9 Technical Report (TR36.912) .......................51
`X. DETAILED ANALYSIS OF BASES OF INVALIDITY .............................52
`A. Motorola in view of LTE Release 8 TS36.211 and TS36.213 Standards or
`Motorola in view of LTE Release 8 TS36.211 and TS 36.213 in further view
`of TR36.912 Renders Obvious All Challenged Claims ....................................52
`1. Reasons to Combine Motorola and LTE Release 8 TS36.211 and TS36.213
`Standards ...........................................................................................................52
`2. Reasons to Combine TR36.912 with Motorola and the LTE Release 8
`TS36.211 and TS36.213 Standards ...................................................................59
`3. Independent Claim 1 ...................................................................................60
`a. Preamble: “A method implemented by a base station of receiving control
`information from a user terminal, the method comprising:” ..........................60
`b. Element [1.1]: “scheduling downlink transmissions to a first user
`terminal only on a single downlink component carrier associated with a
`primary cell and scheduling downlink transmissions to a second user
`terminal on multiple downlink component carriers or on a downlink
`component carrier associated with a non-primary cell;” ................................61
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`Declaration of Dr. Apostolos K. Kakaes
`Patent No. 9,860,044
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`c. Element [1.2]: “receiving, on a first set of radio resources, control
`information associated with the downlink transmissions to the first user
`terminal, wherein the first set of radio resources is reserved for a user
`terminal scheduled to receive downlink transmissions only on a single
`downlink component carrier associated with the primary cell; and” .............67
`d. Element [1.3]: “receiving, on a second set of radio resources, control
`information associated with the downlink transmissions to the second user
`terminal, wherein the second set of radio resources is reserved for a user
`terminal scheduled to receive downlink transmissions on multiple downlink
`component carriers or on a downlink component carrier associated with a
`non-primary cell, the first and second sets of radio resources being on a same
`uplink component carrier associated with the primary cell.” .........................71
`4. Dependent Claim 2 .....................................................................................77
`a. “The method of claim 1, wherein the first and second sets of radio
`resources are different.” .................................................................................77
`5. Dependent Claim 3 .....................................................................................79
`a. “The method of claim 2, wherein the second set of radio resources are
`additional resources as compared to the first set of radio resources.” ...........79
`6. Dependent Claim 4 .....................................................................................82
`a. “The method of claim 1, further comprising transmitting control
`information to the first user terminal to explicitly indicate the first set of
`radio resources on the uplink component carrier associated with the primary
`cell.” ...............................................................................................................82
`7. Dependent Claim 5 .....................................................................................84
`a. “The method of claim 1, further comprising providing the first user
`terminal with an implicit indication to dynamically assign radio resources in
`said first set of radio resources.” ....................................................................84
`8. Dependent Claim 6 .....................................................................................85
`a. “The method of claim 5, wherein the implicit indication is a control
`channel element (CCE) of a Physical Downlink Control Channel (PDCCH)
`used for scheduling the first user terminal.” ..................................................85
`9. Dependent Claim 7 .....................................................................................86
`a. “The method of claim 1, further comprising transmitting control
`information to the second user terminal on a downlink component carrier to
`implicitly or explicitly indicate the second set of radio resources on the uplink
`component carrier associated with the primary cell.” ....................................86
`10. Dependent Claim 8 ..................................................................................89
`a. “The method of claim 7, wherein at least one of the first and second sets
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`Declaration of Dr. Apostolos K. Kakaes
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`of radio resources is indicated explicitly by an uplink control channel
`resource index.” .............................................................................................89
`11. Dependent Claim 9 ..................................................................................90
`a. “The method of claim 8, wherein an explicit indication related to the
`second set of radio resources is transmitted as radio resource control
`signaling.” ......................................................................................................90
`12. Dependent Claim 10 ................................................................................92
`a. “The method of claim 1, further comprising transmitting, on the single
`downlink component carrier, an assignment of radio resources in the second
`set of radio resources when the second user terminal is scheduled to receive
`the downlink transmissions on the multiple downlink component carriers or
`on the downlink component carrier associated with the non-primary cell.” .92
`13. Dependent Claim 11 ................................................................................96
`a. “The method of claim 10, wherein the assignment of radio resources in
`said second set of radio resources is an acknowledgement resource indication
`to dynamically assign radio resources to the second user terminal when the
`second user terminal is scheduled to receive downlink transmissions on the
`multiple downlink component carriers or on the downlink component carrier
`associated with the non-primary cell.” ...........................................................96
`14. Dependent Claim 15 ................................................................................99
`a. “The method of claim 1, wherein the first user equipment is the same as
`the second user equipment.” ..........................................................................99
`15. Dependent Claim 16 ..............................................................................100
`a. “The method of claim 1, wherein the first user equipment is different
`from the second user equipment” .................................................................100
`16.
`Independent Claim 17 ............................................................................100
`a. Preamble: “A base station comprising:” ................................................100
`b. Element [17.1]: “a transmitter to transmit user data on one or more
`downlink component carriers to a first user terminal and a second user
`terminal; and” ...............................................................................................101
`c. Element [17.2]: “a controller to schedule downlink transmissions to the
`first user terminal and the second user terminal, the controller configured to:”
`
`101
`17.
`Independent Claim 18 ............................................................................104
`a. Preamble: “A method implemented by a user terminal of transmitting
`control information in a mobile communication network, the method
`comprising:” .................................................................................................105
`b. Element [18.1]: “receiving an assignment of radio resources for downlink
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`Declaration of Dr. Apostolos K. Kakaes
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`transmissions from a base station;” ..............................................................106
`c. Element [18.2]: “transmitting, on a first set of radio resources, control
`information associated with the downlink transmissions responsive to being
`assigned radio resources only on a single downlink component carrier
`associated with the primary cell for the downlink transmission, wherein the
`first set of radio resources is reserved for a user terminal scheduled to receive
`downlink transmissions on a single downlink component carrier associated
`with the primary cell; and” ...........................................................................107
`d. Element [18.3]: “transmitting, on a second set of radio resources, control
`information associated with the downlink transmissions responsive to being
`assigned radio resources on multiple downlink component carriers or on a
`downlink component carrier associated with a non-primary cell for the
`downlink transmission, wherein the second set of radio resources is reserved
`for a user terminal scheduled to receive downlink transmissions on multiple
`downlink component carriers or on a downlink component carrier associated
`with a non-primary cell, the first and second sets of radio resources being
`on a same uplink component carrier associated with the primary cell.” .......108
`18. Dependent Claim 19 ..............................................................................108
`a. “The method of claim 18, wherein the first and second sets of radio
`resources are different.” ...............................................................................108
`19. Dependent Claim 20 ..............................................................................108
`a. “The method of claim 19, wherein the second set of radio resources are
`additional resources as compared to the first set of radio resources.” .........108
`20. Dependent Claim 21 ..............................................................................109
`a. “The method of claim 18, further comprising receiving control
`information from the base station explicitly indicating the first set of radio
`resources on the uplink component carrier associated with the primary cell.”
`
`109
`21. Dependent Claim 22 ..............................................................................109
`a. “The method of claim 21, wherein said receiving the control information
`comprises receiving an uplink control channel resource index explicitly
`indicating said first set of radio resources.” .................................................109
`22. Dependent Claim 23 ..............................................................................109
`a. “The method of claim 22, wherein an explicit indication relating to the
`second set of radio resources is received as radio resource control signaling.”
`
`109
`23. Dependent Claim 24 ..............................................................................109
`a. “The method of claim 18, further comprising receiving an implicit
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`Declaration of Dr. Apostolos K. Kakaes
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`indication to dynamically assign radio resources in said first set of radio
`resources.” ....................................................................................................110
`24. Dependent Claim 25 ..............................................................................110
`a. “The method of claim 24, wherein the implicit indication is a control
`channel element (CCE) of a Physical Downlink Control Channel (PDCCH)
`on which the assignment of radio resources for downlink transmissions is
`received.” .....................................................................................................110
`25. Dependent Claim 26 ..............................................................................110
`a. “The method of claim 18, further comprising receiving, on the single
`downlink component carrier, an assignment of radio resources in the second
`set of radio resources when the user terminal is scheduled to receive the
`downlink transmissions on the multiple downlink component carriers or on
`the downlink component carrier associated with the non- primary cell.” ...110
`26. Dependent Claim 27 ..............................................................................110
`a. “The method of claim 26, wherein the assignment of radio resources in
`said second set of radio resources is an acknowledgement resource indication
`to dynamically assign radio resources when the user terminal is scheduled to
`receive downlink transmissions on the multiple downlink component carriers
`or on the downlink component carrier associated with the non-primary cell.”
`
`111
`27.
`Independent Claim 33 ............................................................................111
`a. Preamble: “A user terminal for mobile communications, the user
`terminal comprising:” ..................................................................................111
`b. Element [33.1]: “a receiver to receive downlink transmissions from a base
`station;” ........................................................................................................111
`c. Element [33.2]: “a transmitter to transmit control information associated
`with the downlink transmission to a base station; and” ...............................112
`d. Element [33.3]: “a controller to select radio resources for transmission of
`control information associated with the downlink transmissions, the
`controller configured to:” .............................................................................113
`28. Dependent Claim 34 ..............................................................................115
`a. “The user terminal of claim 33, wherein the controller is further
`configured to select, as the second set of radio resources, a set of radio
`resources different than the first set of radio resources.” .............................115
`29. Dependent Claim 35 ..............................................................................116
`a. “The user terminal of claim 34, wherein the controller is further
`configured to select, as the second set of radio resources, additional resources
`as compared to the first set of radio resources.” ..........................................116
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`Declaration of Dr. Apostolos K. Kakaes
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`30. Dependent Claim 36 ..............................................................................116
`a. “The user terminal of claim 33, wherein the controller is further
`configured to receive control information from the base station explicitly
`indicating the first set of radio resources on the uplink component carrier
`associated with the primary cell.” ................................................................116
`31. Dependent Claim 37 ..............................................................................117
`a. “The user terminal of claim 36, wherein the controller is further
`configured to receive, as the control information, an uplink control channel
`resource index explicitly indicating said first set of radio resources.” ........117
`32. Dependent Claim 38 ..............................................................................117
`a. “The user terminal of claim 37, wherein the controller is further
`configured to receive radio resource control signaling including an explicit
`indication relating to the second set of radio resources.” .............................117
`33. Dependent Claim 39 ..............................................................................117
`a. “The user terminal of claim 33, wherein the controller is further
`configured to receive an implicit indication to dynamically assign radio
`resources in said first set of radio resources.” ..............................................117
`34. Dependent Claim 40 ..............................................................................118
`a. “The user terminal of claim 39, wherein the implicit indication comprises
`a control channel element (CCE) of a Physical Downlink Control Channel
`(PDCCH) on which the assignment of radio resources for downlink
`transmissions is received.” ...........................................................................118
`35. Dependent Claim 41 ..............................................................................118
`a. “The user terminal of claim 33, wherein the controller is further
`configured to receive, on the single downlink component carrier, an
`assignment of radio resources in the second set of radio resources when the
`user terminal is scheduled to receive the downlink transmissions on the
`multiple downlink component carriers or on the downlink component
`carrier associated with the non-primary cell.” .........................................118
`XI. SECONDARY CONSIDERATIONS .......................................................118
`XII. CONCLUSION ...........................................................................................119
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`Declaration of Dr. Apostolos K. Kakaes
`Patent No. 9,860,044
`I, Dr. Apostolos K. “Paul” Kakaes, hereby declare as follows:
`INTRODUCTION
`I have been retained as an expert witness on behalf of Apple Inc. (“Apple” or
`
`
`
`I.
`1.
`
`“Petitioner”) to offer technical opinions related to U.S. Patent No. 9,860,044 (Ex.
`
`1001, “the ʼ044 Patent”). I understand that Petitioner requests that the Patent Trial
`
`and Appeal Board (“PTAB” or “Board”) institute an inter partes review (“IPR”)
`
`proceeding of the ʼ044 Patent.
`
`2.
`
`I have been asked to provide my independent analysis of the ʼ044 Patent in
`
`light of the prior art patents and publications cited below.
`
`3.
`
`Specifically, I have been asked to provide my opinions regarding whether or
`
`not claims 1-11, 15-27, 33-41 (the “Challenged Claims”) of the ʼ044 Patent are
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`invalid as being anticipated and/or obvious to a person having ordinary skill in the
`
`art (a POSITA) at the time of the alleged invention.
`
`4.
`
`The ʼ044 Patent is entitled “PUCCH RESOURCE ALLOCATION FOR
`
`CARRIER AGGREGATION IN LTE-ADVANCED.” The named inventors are
`
`David Astely, Robert Baldemair, Dirk Gerstenberger, Daniel Larsson, Lars
`
`Lindbom, and Stefan Parkvall.
`
`5.
`
`The named assignee of the ʼ044 Patent is Telefonaktiebolaget LM Ericsson
`
`(henceforth “Ericsson”).
`
`
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`Declaration of Dr. Apostolos K. Kakaes
`Patent No. 9,860,044
`The ʼ044 Patent issued on January 2, 2018, from U.S. Application No.
`
`
`6.
`
`15/350,360 (the ’360 Application) filed on November 14, 2016. The ’360
`
`Application is a continuation of U.S. Application No. 12/896,993, filed on October
`
`14, 2010, now U.S. Pat. No. 9,497,004, issued on November 15, 2016, and claims
`
`the benefit of U.S. Provisional Patent Application 61/248,661, filed on October 5,
`
`2009.
`
`7.
`
`For the purposes of my Declaration, I have been asked to assume that the
`
`priority date of the alleged invention recited in the Ericsson ’044 Patent is October
`
`5, 2009 (hereinafter the “Priority Date”).
`
`8.
`
`I am not currently, and never have been, an employee of Apple. I received no
`
`compensation for this Declaration beyond my normal hourly compensation based on
`
`my time actually spent analyzing the ’044 Patent, the prior art patents and
`
`publications cited below, and issues related thereto, and my compensation is not
`
`dependent on my opinions or the result of this proceeding.
`
`II. BACKGROUND AND QUALIFICATIONS
`9.
`I am over the age of 18 and am competent to write this Declaration. I have
`
`personal knowledge or have developed knowledge of these technologies based upon
`
`education, training, or experience, of the matters set forth herein. My relevant
`
`experience includes a deep understanding of the systems that we broadly refer to as
`
`“1G,” “2G,” ‘‘3G,” “4G,” and “5G” communications systems.
`
`
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`Declaration of Dr. Apostolos K. Kakaes
`Patent No. 9,860,044
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`10. My CV, which includes my complete education and work experience, is
`
`included as Ex. 1004. I describe several relevant aspects of my experience below.
`
`11.
`
`I am an expert in the field of communication engineering and specifically,
`
`among others, the field of wireless communications. I have almost 40 years of
`
`experience in electrical engineering and computer science and in fixed and mobile
`
`communications networks. I attended the University of Colorado from 1974 to 1980,
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`during which I earned a Bachelor of Science (B.S.) and a Master of Science (M.S.)
`
`in applied mathematics with a minor in electrical engineering. I attended the
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`Polytechnic Institute of New York between 1982 and 1988, during which I earned a
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`Doctor of Philosophy (Ph.D.) in electrical engineering, with a thesis titled
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`“Topological Properties and Design of Multihop Packet Radio Networks.” While
`
`pursuing the Ph.D. degree, I held a joint appointment as Special Research Fellow
`
`and Adjunct Instructor at the Polytechnic Institute of New York between 1985 and
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`1986.
`
`12. Between 1982 and 1987, I worked at AT&T Bell Laboratories in Holmdel,
`
`New Jersey. While at AT&T Bell Laboratories, I worked on modeling, analysis,
`
`design, and performance evaluation of voice and data networks. I developed
`
`algorithms for DNHR (Dynamic, Non-Hierarchical Routing) used in the telephone
`
`network. I also analyzed advanced data services and formulation of long-term plans
`
`
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`Declaration of Dr. Apostolos K. Kakaes
`Patent No. 9,860,044
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`for development of enhanced data services and network design tools to support such
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`services.
`
`13.
`
`I was an Assistant Professor of Electrical Engineering and Computer Science
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`at The George Washington University (GWU), Washington, D.C., between 1987 and
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`1994. During my association with GWU, I taught graduate courses in the area of
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`communication engineering, including communication theory, coding theory, voice
`
`and data networking, and mobile communications. In the early 1990s I developed
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`and taught the first course on Mobile Communications taught at GWU to Electrical
`
`Engineering graduate students. I also received several research awards/grants,
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`including the prestigious NSF Research Initiation Award.
`
`14.
`
`In 1988, I founded Cosmos Communications Consulting Corporation
`
`(“Cosmos”), which is a private communications engineering consulting firm
`
`specializing in mobile communications, and I have been the President of the
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`company since its founding. Since 1994, I have worked full-time at Cosmos. At
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`Cosmos, among various activities, I have consulted on high level technology-related
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`issues and trends to corporate entities, governmental agencies, and international
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`organizations, such as the United Nations. I have provided technical consultancy to
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`engineering firms, operators, and equipment vendors on issues related to existing or
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`evolving technologies for mobile communications, and to the investment
`
`community on issues related to both fixed and wireless communications
`
`
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`Declaration of Dr. Apostolos K. Kakaes
`Patent No. 9,860,044
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`technologies. I developed and taught hundreds of courses to thousands of engineers
`
`around the world in the area of communication engineering, mostly in the area of
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`mobile, wireless communications. I have served as consultant on both civil and
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`criminal legal cases, including several patent infringement cases both at the ITC and
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`in district court as well as in support of IPRs such as the one in this case. I also
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`participated as a technical consultant in the analysis of large patent portfolios for the
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`purposes of due diligence, sales, and merger and acquisition activities for some of
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`the largest companies in the mobile communications space. These projects spanned
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`a multidimensional spectrum of
`
`technologies
`
`in both fixed and mobile
`
`communications as they have evolved over the past more than 30 years.
`
`15. Over the course of my career, I have authored and co-authored some thirty
`
`(30) publications on various aspects of fixed and mobile communications, as noted
`
`in my curriculum vitae. I am a life member of the Institute of Electrical and
`
`Electronics Engineers
`
`(IEEE) and have been actively
`
`involved
`
`in
`
`the
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`Communications Society and the Information Theory Society of the IEEE. Between
`
`1991 and 1992, I served as the Secretary of IEEE Communications Society National
`
`Capital Area Chapter. Between 1992 and 1993, I was the Vice-Chair of IEEE
`
`Communications Society National Capital Area Chapter. I was the Vice-Chair of the
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`Communication Theory Technical Committee of the Communications Society of the
`
`IEEE for the 1993-1996 term, and Treasurer of the Communication Theory
`
`
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`Declaration of Dr. Apostolos K. Kakaes
`Patent No. 9,860,044
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`Technical Committee of the Communications Society of the IEEE for the 1996-1999
`
`term.
`
`16.
`
`I have served as a reviewer for the IEEE, book editors, other technical
`
`publications, and various National Science Foundation (NSF) Panels. I have
`
`organized technical sessions in technical conferences, including the IEEE
`
`International Conference on Communications
`
`(ICC) and
`
`IEEE Global
`
`Communications Conference (Globecom). I served as the Technical Program Chair
`
`for the Communication Theory Mini-Conference in 1992.
`
`17. During the past 35+ years, I have been lucky enough to be part of the
`
`community of engineers that have contributed to the astounding growth of the
`
`mobile communications industry. It started from a niche industry that was thought
`
`of as being something for the “rich and the famous” to becoming one of the most
`
`wide-spread household concepts, providing useful tools to all segments of the global
`
`society, from the wealthy suburbs of New York to the poorest neighborhoods in
`
`Africa and everywhere in between.
`
`18. My involvement in this industry included providing consulting services to
`
`company executives who needed to make deployment plans, taking into
`
`consideration the strengths and weaknesses of the technology, economics, user
`
`value, etc. As such, I have developed a deep understanding of all aspects of a given
`
`technology, its features, added value, and the like. In addition, my consulting
`
`
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`Declaration of Dr. Apostolos K. Kakaes
`Patent No. 9,860,044
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`services included developing courses for the companies that were at the forefront of
`
`this developing technology. By definition, this new, previously non-existent
`
`technology was not taught in university courses, as it was too new. Having
`
`developed hundreds of courses over the years and taught thousands of engineers (and
`
`non-engineers alike), I have a solid understanding and knowledge of the technical
`
`developments and how their importance fits in the larger puzzle of a fast-developing
`
`technology.
`
`19. My consulting included providing training to engineers in the field that were
`
`deploying the various networks. For example, I developed courses and provided
`
`training and consulting to the engineers deploying some of the earliest GSM networks
`
`in Germany and France, to be followed by many countries in Europe and around the
`
`world, including the USA when it was decided that GSM would be used in the USA.
`
`Successful deployments of the initial GSM systems were followed by deployments of
`
`GPRS and EDGE, which was then followed by deployments of 3G UMTS systems
`
`world-wide. Of course, the 3G systems were followed by the currently most wide-
`
`spread deployments of 4G systems, also referred to as LTE, world-wide and most
`
`recently deployments of 5G networks. Thus, my experience includes a deep
`
`understanding of the entirety of each system that we broadly refer to as “1G,” “2G,”
`
`‘‘3G,” “4G”, and “5G.”
`
`
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`Declaration of Dr. Apostolos K. Kakaes
`Patent No. 9,860,044
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`III. MATERIALS AND OTHER INFORMATION CONSIDERED
`20.
`In forming the opinions expressed in this Declaration, I relied upon my
`
`education and many years of experience in the relevant field of the art and have
`
`considered the viewpoint of a person having ordinary skill in the art (a POSITA) as
`
`of the Priority Date of the ʼ044 Patent.
`
`21.
`
`I have considered the materials referenced in this Declaration, including the
`
`’044 Patent, its file history, and other documents listed in the Exhibit List to the ʼ044
`
`Petition. In particular, I have considered the prior art references listed in the Table
`
`below, which counsel has informed me are prior art to the ’044 Patent.
`
`Prior Art
`R1-082999, “Support of UL/DL asymmetric
`carrier aggregation,” 3GPP TSG RAN WG1
`Meeting #54, submitted by Panasonic to 3GPP
`for discussion on August 18-22, 2008
`(“Panasonic”) (Ex. 1006)
`R1-090792, “Control Signalling Design for
`Supporting Carrier Aggregation,” 3GPP TSG
`RAN1 Meeting #56, submitted by Motorola to
`3GPP for discussion on February 9-13, 2009
`(“Motorola”) (Ex. 1007)
`R1-083679, “UL Layered Control Signal
`Structure in LTE-Advanced,” 3GPP TSG RAN
`WG1 Meeting #54bis, submitted by NTT
`DOCOMO to 3GPP for discussion on
`September 29-October 3, 2008 (“Docomo”) (Ex.
`1008)
`
`Publication Date
`Publicly available no later
`than August 12, 2008; see
`also Ex. 1016 (Rodermund
`Decl.)
`
`Publicly available no later
`than February 3, 2009; see
`also Ex. 1016 (Rodermund
`Decl.)
`
`Publicly available no later
`than September 24, 2008; see
`also Ex. 1016 (Rodermund
`Decl.)
`
`
`
`IPR2022-00648
`Apple EX1003 Page 15
`
`

`

`Prior Art
`“Evolved Universal Terrestrial Radio Access
`(E- UTRA); Physical Channels and Modulation,”
`3GPP TS 36.211, Version 8.5.0 (Release 8),
`published December 2008 (“TS36.211”) (Ex.
`1009)
`“Evolved Universal Terrestrial Radio Access
`(E- UTRA); Physical layer procedures,” 3GPP
`TS 36.213, Version 8.5.0 (Release 8)
`(“TS36.213”) (Ex. 1011).
`“Evolved Universal Terrestrial Radio Access
`(E- UTRA); Radio Resource Control (RRC);
`Protocol specification,” 3GPP TS 36.331
`Version 8.5.0 (Release 8) (“TS36.331”) (Ex.
`1012)
`Bala et al., U.S. Patent Publication No.
`2010/0098012 (“Bala”) (Ex. 1014)
`
`H. Holma & A. Toskala, LTE for UMTS -
`OFDMA and SC-FDMA Based Radio Access
`(“Holma”) (Ex. 1015)
`Sesia et al., LTE - The UMTS Long Term
`Evolution: From Theory to Practice (1st Ed.)
`(“Sesia 2009”) (Ex. 1017)
`Pelletier et al., U.S. Pa