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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Ericsson Inc., Nokia of America Corporation,
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`Petitioners
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`v.
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`Godo Kaisha IP Bridge 1
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`Patent Owner
`
`
`Patent No. 8,077,594 B2
`Filing Date: August 10, 2010
`Issue Date: December 13, 2011
`
`Title: Radio Communication Base Station Device and Correlation Setting Method
`
`Inter Partes Review No. IPR2022-00726
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`DECLARATION OF MARK MAHON
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`Exhibit 1031
`IPR2022-00726
`U.S. Patent 8,077,594
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`
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`I, Mark Mahon, a resident of Port Matilda, PA, over 18 years of age, hereby
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`declare as follows:
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`I.
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`INTRODUCTION
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`1.
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`I have personal knowledge of all of the matters about which I testify in
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`this declaration.
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`2. My name is Dr. Mark Mahon. I have been retained by Nokia of America
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`Corporation and Ericsson, Inc. (“Petitioners”) as an independent expert consultant
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`in this proceeding before the United States Patent and Trademark Office (“PTO”)
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`against Godo Kaisha IP Bridge 1 (“Patent Owner”) regarding U.S. Patent No.
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`8,077,594 (“the ’594 patent”). I have been asked to submit this Declaration on behalf
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`of Petitioners.
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`3.
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`I am being compensated for my work in this proceeding at a rate of
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`$475 per hour and receiving reimbursement for expenses incurred in the course of
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`my work. My compensation is not contingent in any way on either the opinions I
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`have reached or the outcome of this case.
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`4.
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`This declaration is directed to claims 1-13 of the ’594 Patent (“the
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`Challenged Claims”) and sets forth certain opinions I have formed, the conclusions
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`I have reached, and the bases for each. The conclusions I present are based on my
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`own judgment. I am not an employee of Petitioners, their counsel, the inventors of
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`the ’594 Patent, or of any affiliated companies.
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`1
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`5.
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`Based on my experience, knowledge of the art at the relevant time,
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`analysis of prior art references, and the understanding a person of ordinary skill in
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`the art would have of the claim terms in light of the specification, it is my opinion
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`that the Challenged Claims of the ’594 Patent are unpatentable over the prior art
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`references discussed below.
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`II.
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`PERSONAL AND PROFESSIONAL BACKGROUND
`A. Overview
`I am a Teaching Professor in the School of Electrical Engineering and
`6.
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`Computer Science at Pennsylvania State University, University Park, PA (“Penn
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`State” or “PSU”). I have worked on telecommunications networks, including AMPS,
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`IS-95, CDMA2000, GSM, EDGE, UMTS, LTE, and 5G cellular systems since 1988.
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`7.
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`I received my B.S. in Electronics Engineering from the University of
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`Scranton in 1987. I received my M.S. in Electrical Engineering and Ph.D. in
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`Acoustics from Penn State in 1991 and 2001, respectively.
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`8.
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`In 1988, after I received my bachelor’s degree, I joined the Central
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`Intelligence Agency (CIA) while pursuing my M.S. degree at Penn State part-time.
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`My first job at the CIA involved designing and testing systems to automatically
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`capture and characterize telecommunication signals and emissions from various
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`computer networking devices.
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`2
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`9.
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`I returned to Penn State in early 1990 to pursue graduate research full-
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`time and complete my M.S. degree. My graduate research work focused on
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`wideband beamforming and adaptive signal processing. After completing my M.S.
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`degree in EE in 1991, I accepted a full-time faculty research position at the Applied
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`Research Lab at PSU, primarily working on classified programs, and began working
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`on diverse radio frequency and acoustic sensor systems including wireless
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`communications and small wireless networks for acoustic tracking, source
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`localization, and feature extraction.
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`10.
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`I began pursuing my Ph.D. part-time in 1993 while continuing my
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`faculty research position. In 1997, as part of my faculty research position, I began
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`working on classified programs focused on mathematical analytical modeling of
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`cellular communication networks and the development of hardware and software
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`systems to test against cellular networks. My role was to develop the algorithms and
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`write the code running on a specially developed embedded system. For this work, I
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`received a letter of recognition as the “genius behind the VELA software algorithms”
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`from the Director of National Reconnaissance Office (NRO) Systems Engineering
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`and Technology Office. As part of this same work, I was extensively involved in
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`protocol and signaling analysis as well as researching model-specific performance
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`and unique functional characteristics associated with individual mobile devices. The
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`work involved testing dozens of handsets from many manufacturers in controlled
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`3
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`
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`and real-world environments against network simulators and live operational
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`networks for each research project.
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`11.
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`In 2000 my research extended into utilizing non-orthogonal wavelets
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`for improving detection and localization of cellular handsets from high altitude
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`sensor systems. In 2001, I completed my Ph.D. and my research focused on the
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`utilization of advanced communication signals for wideband characterization and
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`remote sensing of propagation channels.
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`12. Beginning in 2003 my cellular communications research work focused
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`on GSM, EDGE, UMTS, and LTE cellular systems under grants sponsored primarily
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`by the Department of Defense. This classified research work required 3GPP protocol
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`analysis and development of real-time embedded hardware and software systems
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`capable of interacting with cellular networks and cellular handsets. A large portion
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`of my work was directed at architectures, protocols, software, and signaling.
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`13.
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`I have been working on classified projects since 1988. Before 1998,
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`because the work was not deemed highly classified, I was able to publish eight
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`journal and conference papers prior to 2000. Between 1999 and 2015, however, I
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`was allowed to publish only one article in an unclassified symposium and published
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`and presented about a dozen articles in classified settings. This is because during this
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`period, the vast majority of my research was highly classified. As a result, nearly all
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`of my research results were summarized in classified reports and not available to the
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`4
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`
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`general public. Further, because the U.S. government owns any intellectual property
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`resulting from the sponsored research work, I did not pursue or file patent
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`applications.
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`14.
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`In 2015, I transferred to the School of Electrical Engineering and
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`Computer Science at Penn State as a teaching faculty member. In that role, I have
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`continued teaching graduate and undergraduate courses, guiding Ph.D. and M.S.
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`students in communication and mobile networking (including LTE and 5G cellular
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`networks), and pursuing research in this and related areas. Since 2015, I have been
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`an author on four refereed papers as listed in my curriculum vitae (CV).
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`Because of my decades of research and my continuing work at Penn State, I
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`have intimate knowledge of telecommunication networks, including the technology
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`involved in the patents in this case. I have been highly recognized as an expert in
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`such systems within the research community. I was recognized twice by the National
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`Reconnaissance Office with commendation letters (one is quoted above) for work
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`dealing with detecting cellular signals in low signal to noise ratio environments. The
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`U.S. government awarded me over $12M between 2003 and 2015 for projects
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`focused on mobile communication devices and networks, in which I served as a
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`Principal Investigator (PI), Co- PI, and/or technical lead.
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`15. Additionally, during my research career, I interacted extensively with
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`computer scientists and engineers responsible for the design, development, and
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`
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`5
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`
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`testing of telephony and data networking systems and testbeds. As a research faculty
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`member, I oversaw engineers and computer scientists that executed many joint
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`projects with development organizations. These interactions exposed me to a wide
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`range of computer scientists and engineers working on telecommunication network
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`technologies. Since 2011, I have been teaching undergraduate and graduate classes
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`in communication and mobile networking and am familiar with the curricula being
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`taught to electrical engineers and computer scientists. The interactions with a wide
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`range of computer scientists and engineers working on telecommunication network
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`technologies and the familiarity with the classes taught to electrical engineers and
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`computer scientists have allowed me to have a good understanding of the level of
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`skills possessed by a person of ordinary skill as defined in Section VI below.
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`B.
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`16.
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`Experience with LTE, OFDM, and Other Technologies Relevant
`to the ’594 Patent
`I have extensive experience with mobile networks in general and LTE
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`specifically. While most of my research efforts between 1998 to 2015 were highly
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`classified, I can state that they included detailed investigation of network
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`architectures, signaling, and functional behavior. A typical research effort would
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`involve studying 3GPP, 3GPP2, IEEE, and other protocol standards to fully
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`comprehend all aspects of L1, L2, and L3 requirements including timing, bit-level
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`construction of the control and user plane messages, and timing characteristics for a
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`
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`6
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`
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`given standard as well as functional behavior of network components and user
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`equipment.
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`17. From 2006 through 2015 my research focused specifically on LTE. My
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`research continues to this day, although I am no longer operating in a classified
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`environment. During this time, I investigated the performance and functional
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`differences of many varied network and handset devices to see how differing
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`signaling and environmental factors influenced the behavior of user equipment in a
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`given network environment. This included how synchronization, timing, and signal
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`to interference plus noise ratio (SINR) for a given device would affect specific
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`functional aspects including elements of the receiver structure, decoding and
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`demodulation performance, calculation of parameters used by the device for making
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`decisions and deriving parameters reported to the network.
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`18. As part of my research work, I built several custom LTE platforms that
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`implemented specific network-side and user equipment-side functionality including
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`custom signal generation and processing structures, particularly the signal
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`processing chains on both the transmit and receive sides. This equipment was
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`developed using network simulation hardware in a laboratory environment and was
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`later tested with LTE networks in both controlled and fully operational
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`environments.
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`7
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`19.
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`Implementing the transmit and receive chains for custom built LTE-
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`enabled equipment required me to gain an intimate understanding of the relevant
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`3GPP protocol specifications and the underlying OFDM structures. I am currently
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`guiding the research of graduate students pursuing research into sparse coding
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`multiple-input multiple-output (MIMO) techniques to improve throughput in dense-
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`user environments, optimized distributed processing algorithms, and
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`the
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`implementation of blockchain coding techniques to improve handover security in
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`4G (LTE)/5G (NR) networks.
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`III. MATERIALS REVIEWED AND CONSIDERED
`20. My findings contained in this declaration are based on my education,
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`research, experience, and background in the field of computer and communication
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`networks, and specifically, in relation to LTE networks and wireless communication
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`systems, as well as on my investigation and study of prior art references and other
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`documents disclosed in this declaration.
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`Exhibit No.
`EX-1001
`
`Description
`U.S. Patent No. 8,077,594 (“the ’594 Patent”)
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`EX-1002
`
`EX-1003
`
`
`
`File History of U.S. Patent No. 8,077,594 (U.S. Patent
`Application No. 12/853,582 (“the ’582 Application”))
`3GPP TR 25.814 V7.1.0 (2006-09) Technical Report, 3rd
`Generation Partnership Project; Technical Specification
`Group Radio Access Network; Physical Layer Aspects for
`Evolved Universal Terrestrial Radio Access (UTRA)
`(Release 7) (“3GPP TR 25.814”)
`
`8
`
`
`
`Exhibit No.
`EX-1004
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`EX-1005
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`EX-1006
`EX-1007
`EX-1008
`EX-1009
`EX-1010
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`EX-1011
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`EX-1012
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`EX-1013
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`EX-1014
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`EX-1015
`EX-1016
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`EX-1017
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`
`
`Description
`R1-072296, TSG-RAN Working Group 1 Meeting #49;
`Agenda Item 7.11.2: UL Sounding (“the Nokia SRS
`Contribution”)
`3GPP TS 36.300 V8.0.0 (2007-03) Technical Specification,
`3rd Generation Partnership Project; Technical Specification
`Group Radio Access Network; Evolved Universal Terrestrial
`Radio Access (E-UTRA) and Evolved Universal Terrestrial
`Radio Access Network (E-UTRAN); Overall Description;
`Stage 2 (Release 8) (“36.300 v8.0.0”)
`3GPP TR 25.814 archive directory listing
`3GPP TS 36.213 archive directory listing
`3GPP TS 36.300 archive directory listing
`3GPP TS 36.211 archive directory listing
`3GPP TR 21.905 v8.1.0, “Vocabulary for 3GPP
`Specifications (Release 8)” dated June 2007
`Appendix 7.1 – ’594 Patent LTE from Patent Owner’s
`infringement contentions, served September 15, 2021.
`R1-073172, 3rd Generation Partnership Project; Technical
`Specification Group Radio Access Network; Evolved
`Universal Terrestrial Radio Access (E-UTRA); Physical
`Channels and Modulation (Release 8), 3GPP TS 36.211
`v1.2.0 (2007-06) (“36.211 v1.2.0”)
`3rd Generation Partnership Project; Technical Specification
`Group Radio Access Network; Physical layer procedures
`(Release 8), 3GPP TS 36.213 v1.2.0 (2007-05) (“36.213
`v1.2.0”)
`Draft Report of 3GPP TSG RAN WG1 #49b v0.1.0 (“49b
`v010”)
`Listserve record of July 5, 2007 e-mail attaching 49b v010
`3rd Generation Partnership Project; Technical Specification
`Group Radio Access Network; Evolved Universal Terrestrial
`Radio Access (E-UTRA); Physical Channels and
`Modulation (Release 8), 3GPP TS 36.211 v1.2.0 (2007-06)
`(Republication of EX-1012)
`Joint Claim Construction Chart from co-pending district
`court litigation (March 15, 2022)
`
`9
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`
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`Exhibit No.
`EX-1018
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`EX-1019
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`EX-1020
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`EX-1027
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`EX-1028
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`EX-1100
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`EX-1150
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`
`
`Description
`IP Bridge’s Opening Markman Brief from co-pending
`district court litigation (Feb. 15, 2022)
`IP Bridge’s Unopposed Motion to Continue Claim
`Construction Hearing from co-pending district court
`litigation
`Order granting IP Bridge’s Unopposed Motion to Continue
`Claim Construction Hearing and resetting claim construction
`hearing from co-pending district court litigation
`“About 3GPP,” available at https://www.3gpp.org/about-
`3gpp
`“LTE Overview,” available at
`http://www.3gpp.org/technologies/keywords-acronyms/98-
`lte
`
`Declaration of Craig Bishop
`
`Declaration of Antti Toskala
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`IV. MY UNDERSTANDING OF CERTAIN PATENT LAW PRINCIPLES
`21. As a technical expert, I am not offering any legal opinions. Rather I am
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`offering technical assessments and opinions. In rendering my analysis, I have been
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`informed by counsel regarding various legal standards for determining patentability.
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`I have applied those standards in forming my technical opinions expressed in this
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`report.
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`22.
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`I understand that in this proceeding, Petitioners have the burden of
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`proving that the Challenged Claims are invalid by a preponderance of the evidence.
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`10
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`I understand that “preponderance of the evidence” means that a fact or conclusion is
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`more likely true than not true.
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`23. The patent claims define the invention made by the inventors and define
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`what the patent owner owns and what the owner may prevent others from using. I
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`understand that an independent claim sets forth all the requirements that must be met
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`to be covered by that claim. I further understand that a dependent claim does not
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`itself recite all of the requirements of the claim but refers to another claim and
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`incorporates all of the requirements of the claim to which it refers.
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`24.
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`I understand that a claim in an issued patent is unpatentable as
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`anticipated if the recited invention is described in a single prior-art reference that
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`discloses each limitation, either expressly or inherently.
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`25.
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`It is my understanding that a claimed invention is unpatentable if the
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`differences between the invention and the prior art are such that the subject matter
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`as a whole would have been obvious at the time the invention was made to a person
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`having ordinary skill in the art to which the subject matter pertains. Obviousness, as
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`I understand it, is based on the scope and content of the prior art, the differences
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`between the prior art and the claim, and the level of ordinary skill in the art.
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`26.
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`I understand that a patent claim may be unpatentable as obvious over a
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`single prior art reference or in view of a combination of prior art references. I
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`understand that prior art references may also be combined with the knowledge of a
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`11
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`person of ordinary skill in the art. I further understand that a person of ordinary skill
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`in the art is presumed to know the relevant prior art. I understand that the
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`obviousness analysis may take into account the inferences and creative steps that a
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`person of ordinary skill in the art would employ.
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`27.
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`I understand that when evaluating obviousness, one must not consider
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`whether the claimed invention would have been obvious to a layman or to an expert;
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`not use hindsight when comparing the prior art to the claimed invention; not consider
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`what was learned from the teachings of the patent. In particular, I understand that it
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`is improper to use the patent claims as a road map for selecting and combining items
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`of prior art. In other words, one should avoid using the challenged patent as a guide
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`through the prior art references, combining the right references in the right way so
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`as to achieve the result of the claims at issue. Instead, one must put oneself in the
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`place of a person of ordinary skill at the time the invention was made and consider
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`only what was known before the invention was made and not consider what was
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`only known after the invention was made.
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`28.
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`I understand that obviousness should be considered in light of the
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`problems known to the person having ordinary skill in the art at the relevant time
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`and the complexity of the alternatives for solving the problem. That individual
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`elements of the claimed invention are disclosed in the prior art is not alone sufficient
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`to reach a conclusion of obviousness.
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`12
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`29.
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`I also understand that when considering the obviousness of a patent
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`claim, one must consider whether a teaching, suggestion, or motivation to combine
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`the references exists so as to avoid impermissibly applying hindsight when
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`considering the prior art. I understand that a teaching, suggestion, or motivation may
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`be found explicitly or implicitly: (1) in the prior art; (2) in the knowledge of those
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`of ordinary skill in the art; or (3) from the nature of the problem to be solved. I also
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`understand that the legal determination of the motivation to combine references
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`allows recourse to logic, judgment, and common sense, but that any such motivation
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`to combine references must still avoid the improper application of hindsight or
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`reliance on the patentee’s disclosure of his invention as found in the patent
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`specification, drawings, and claims.
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`30.
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`I further understand that certain secondary considerations may support
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`or rebut the obviousness of a claim. I understand that such secondary considerations
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`include, among other things, commercial success of the patented invention,
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`skepticism of those having ordinary skill in the art at the time of the invention,
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`unexpected results of the invention, any long-felt but unresolved need in the art that
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`was satisfied by the alleged invention, the failure of others to make the alleged
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`invention, praise of the alleged invention by those having ordinary skill in the art,
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`and copying of the alleged invention by others in the field. I understand that there
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`must be a nexus—a connection—between any such secondary considerations and
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`13
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`
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`the alleged invention. I also understand that contemporaneous independent invention
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`by others is a secondary consideration tending to show obviousness.
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`31.
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`I understand that in determining whether a prior art reference would
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`have been combined with other prior art or with other information within the
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`knowledge of a person of ordinary skill in the art, the following are examples of
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`approaches and rationales that may be considered:
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`• combining prior art elements according to known methods to yield
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`predictable results;
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`• simple substitution of one known element for another to obtain
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`predictable results;
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`• use of a known technique to improve similar devices in the same way;
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`• applying a known technique to a known device ready for improvement
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`to yield predictable results;
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`• applying a technique or approach that would have been “obvious to
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`try,” i.e., choosing from a finite number of identified, predictable
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`solutions, with a reasonable expectation of success;
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`• known work in one field of endeavor may prompt variations of it for
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`use in either the same field or a different one based on design incentives
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`or other market forces if the variations would have been predictable to
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`one of ordinary skill in the art;
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`14
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`
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`• numerical ranges disclosed in the prior art that overlap with numerical
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`limitations set forth in the challenged claims;
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`• whether certain aspects of the patented subject matter were result-
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`effective, such that a person of ordinary skill in the art would know that
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`such element is determinative as to the effectiveness of the patent
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`subject matter; and
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`• some teaching, suggestion, or motivation in the prior art that would
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`have led one of ordinary skill to modify the prior art reference or to
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`combine prior art reference teachings to arrive at the claimed invention.
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`I understand that this teaching, suggestion or motivation may come
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`from prior art references or from the knowledge or common sense of
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`one of ordinary skill in the art.
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`32.
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`I understand that in an inter partes review proceeding, the PTAB will
`
`apply the same standard applied in federal courts to construe patent claims. I
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`understand that under this standard, terms should be interpreted in view of their
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`ordinary and accustomed meaning as understood by one of ordinary skill in the art.
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`V.
`
`PRIORITY OF THE CHALLENGED CLAIMS
`I have been asked to assume that the ’594 patent’s earliest effective
`33.
`
`filing date is August 8, 2007, which is the filing date of the Japanese Patent
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`Application that the ’594 patent claims priority to.
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`15
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`
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`VI. LEVEL OF ORDINARY SKILL IN THE ART
`I have been asked to provide a definition for the level or ordinary skill
`34.
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`in the art for a person of ordinary skill in the art (“POSITA”) in the field of the ’594
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`patent on August 8, 2007. As stated in the ’594 patent, the “present invention relates
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`to a radio communication base station apparatus and an association setting method.”
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`EX-1001 1:7-8. More particularly, the ’594 Patent relates to uplink SRS and random
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`access preamble reception in LTE base stations. EX-1001 1:12-2:22.
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`35.
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`In my opinion, a person having ordinary skill in the art in reference to
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`the ’594 patent would possess (1) the equivalent of an undergraduate degree in
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`Electrical Engineering, Computer Science, or Computer Engineering, or equivalent;
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`and (2) at least two years of experience in design, development, and/or testing of
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`cellular networks. Such a person would have been familiar with the public discussion
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`and proposals made as part of the 3GPP LTE standards-setting body. Additional
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`education could substitute for professional experience, and significant work
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`experience could substitute for formal education.
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`36. As of August 8, 2007, I had at least the credentials of a person of
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`ordinary skill in the art, and I am capable of addressing the issues in this Declaration
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`from the perspective of such a person. As a result of my education, academic
`
`experience, and industrial experience, I am familiar with cellular networks,
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`
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`16
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`
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`including their design, with the state of that technology on August 8, 2007, when the
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`Japanese Patent Application the ’594 patent claims priority to was filed.
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`VII. TECHNICAL BACKGROUND
`37. The ’594 Patent relates to random access preambles and sounding
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`reference signals in the LTE uplink. EX-1001 1:12-62. As set forth below, both both
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`random access preambles and sounding reference signals were part of the proposed
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`LTE uplink well before the claimed priority date for the ’594 Patent. See, e.g., EX-
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`1003 at 75-77; 82-87. Below I summarize the history and operation of cellular
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`standards generally before specifically addressing the LTE random access preambles
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`and sounding reference signals the ’594 Patent relates to.
`
`A. History of Cellular Standards
`38. Wireless communications have evolved since the days of the earliest
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`cellular phones. Mobile communications were originally developed for military
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`purposes. The idea transitioned to the commercial world primarily through the
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`development of cellular communication systems which began offering commercial
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`service beginning in 1979. Some of the first-generation (“1G”) cellular systems were
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`Nippon Telephone and Telegraph (“NTT”), Advanced Mobile Phone System
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`(“AMPS”), Nordic Mobile Telephone (“NMT”), and the British Total Access
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`Communication System (“TACS”). These analog systems used simple, narrowband
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`analog communication technology and only carried user’s voice signals. Second-
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`
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`17
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`
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`generation (“2G”) systems such as the Global System for Mobile communications
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`(“GSM”) were deployed beginning in the early 1990s and were designed, in part, to
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`enable more efficient transmission of data. 2G systems introduced digital
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`modulation techniques, and numerous other improvements. The European
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`Telecommunications Standards Institute (ETSI) was the primary entity responsible
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`for developing the first GSM standards. The GSM core network architecture was
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`built on Circuit-Switched (CS) technology, which enabled low-rate circuit-switch
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`data connections. EX-1028.
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`39. To establish faster networks, a global consortium known as the 3rd
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`Generation Partnership Project (“3GPP”) was created in 1998. See, e.g., EX-1027.
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`3GPP adopted an organized process for developing new wireless standards. The
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`process is complex, but can be summarized as follows: 3GPP member organizations,
`
`including industry leaders, like Ericsson and Nokia, participate in working groups
`
`addressing specific aspects of the network architecture (Radio Access, Service &
`
`Systems, and Core Network & Terminals) and submit proposals to address specific
`
`technology issues covered by the working group’s responsibilities. The various
`
`3GPP working groups are made up of engineers from the participating companies,
`
`which review, discuss, and analyze the proposals, and weigh pros and cons for each
`
`competing submission. The process is typically iterative, so after one meeting there
`
`would be continued discussions offline using an e-mail reflector, another round of
`
`
`
`18
`
`
`
`proposals, liasons with other working groups, and another meeting. Eventually,
`
`agreement is reached over enough aspects of the communication system that it can
`
`be reduced to writing in a technical specification. The technical specification, once
`
`completed, is approved by the participating member organizations. This process is
`
`also iterative, so each specification has numerous approved drafts. Each
`
`specification also belongs to a Release, which consists of an interdependent set of
`
`specifications which together define a specific generation of a communication
`
`standard. 3GPP hosts copies of both the final specification for each release as well
`
`as copies of earlier drafts and proposals.
`
`40.
`
`3GPP developed a third-generation (“3G”) mobile network called the
`
`Universal Mobile Telecommunications Standard (“UMTS”). In order to achieve
`
`higher data rates, UMTS incorporated Wideband Code Division Multiple Access
`
`(WCDMA) technology for the air interface and used CS connections for real time
`
`services (like voice calls), and packet-switched (PS) connections for data services.
`
`EX-1028. UMTS became the dominant 3G mobile standard.
`
`41.
`
`In 2004, a new fourth-generation (“4G”) system called Long Term
`
`Evolution (“LTE”) was proposed as a successor to UMTS, and 3GPP began work
`
`developing the LTE standard. Release 8 (“R8”) of LTE was completed in December
`
`2008. The goal of LTE was to allow faster data by achieving high radio spectral
`
`
`
`19
`
`
`
`efficiency and efficient scheduling both in the time and frequency domain as well as
`
`an all PS-switched evolved packet core (EPC). EX-1028.
`
`42. For downlink transmissions, LTE is based on Orthogonal Frequency
`
`Division Multiplexing (“OFDM”), a multicarrier technology that subdivides
`
`available bandwidth into numerous orthogonal narrowband subcarriers. In the
`
`downlink, LTE implements Orthogonal Frequency Divisional Multiple Access
`
`(“OFDMA”) to share these subcarriers among multiple end user devices. OFDMA
`
`leads to high peak-to-average power ratio (PAPR), which in turn requires expensive
`
`power amplifiers unsuitable for UEs. EX-1028 at 2-3. To avoid this requirement,
`
`Single Carrier-Frequency Division Multiple Access (SC-FDMA) was adopted for
`
`uplink transmissions. Id. This results in more efficient use of available spectrum.
`
`EX-1028. The figure below illustrates an exemplary frequency domain arrangement
`
`for theOFDMA (downlink) and SC-FDMA (uplink) technologies adopted in LTE.
`
`EX-1028 at 2.
`
`
`
`20
`
`
`
`
`
`43.
`
`In OFDMA (downlink) and SC-FDMA (uplink), different users send
`
`and receive data using different frequency and time resources. Channel response
`
`varies with frequency and time in chaotic, real-world environments. For example,
`
`shadowing, scattering, refraction, reflections, moving receivers, or weather
`
`conditions in a propagation channel between a user and a base station can have
`
`different effects on different frequencies leading to fading characterized as slow,
`
`fast, flat, or frequency-selective. Some frequencies may also be subject to stronger
`
`multipath interference (dispersive channel), where a signal bounces off of buildings
`
`or terrain to arrive at a receiver at different times. And when a user moves or
`
`conditions change, the frequencies more strongly affected by fading or multipath
`
`loss for that user change. As a result, each user’s uplink channel characteristics vary
`
`over time and frequency.
`
`44.
`
`In this environment, the network’s ability to use frequency resources
`
`efficiently depends on scheduling users to transmit at times and frequencies where
`
`the channel conditions between the user and the base station are good. Because
`
`channel conditions can change quickly, the engineers working on LTE recognized a
`
`need to measure the channel characteristics between a base station and each user
`
`trying to transmit to that base station. During LTE’s standardization, numerous
`
`techniques were developed to help measure and identify the best frequencies for
`
`
`
`21
`
`
`
`scheduling user transmissions. These techniques included LTE’s random access
`
`channel (or RACH) and LTE’s sounding reference signal (or SRS).
`
`B. Random Access in LTE
`In wireless networks, when a wireless device wants to begin sending or
`45.
`
`receiving data, it must first contact the network through a random access procedure.
`
`Random access procedures were not new in LTE. For example, in the General Packet
`
`Radio System (GPRS) (a 2G and 3G packet data transmission system), a random
`
`access channel, or RACH, was used by mobile stations to send a channel request
`
`message on the uplink to the network to request packet resources on the air interface.
`
`EX-1029 at § 6.6.4.7.1.1. The network would then respond with uplink assignments
`
`for the requesting mobile station. Id.
`
`46.
`
`In LTE, a similar random access procedure was contemplated. EX-
`
`1003 at § 9.1.2.1.1.3. As with random access procedures in earlier standards, the
`
`LTE random access procedure was to be used for time alignment. EX-1003 at §
`
`9.1.2.1.1.2. Additionally, the engineers developing LTE planned to use the random
`
`access procedure to measure uplink channel quality. EX-1003 at § 9.1.2.1.1.1.
`
`47. TR
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