UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`TELEFONAKTIEBOLAGET LM ERICSSON,
`Patent Owner
`
`U.S. PATENT NO. 11,039,312
`
`DECLARATION OF FRIEDHELM RODERMUND
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW OF U.S.
`PATENT NO. 11,039,312
`
`Page 1
`
`APPLE 1015
`
`1
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`TELEFONAKTIEBOLAGET LM ERICSSON,
`Patent Owner
`
`U.S. PATENT NO. 11,039,312
`
`DECLARATION OF FRIEDHELM RODERMUND
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW OF U.S.
`PATENT NO. 11,039,312
`
`Page 1
`
`APPLE 1015
`
`1
`
`
`
`
`
`TABLE OF CONTENTS
`
`Page
`INTRODUCTION AND ENGAGEMENT ......................................... 3
`I.
`BACKGROUND AND QUALIFICATIONS ...................................... 5
`II.
`SUMMARY OF MY OPINIONS ........................................................ 9
`III.
`PUBLICATION OF 3GPP SPECIFICATIONS AND RELATED
`IV.
`DOCUMENTS ....................................................................................................... 10
`A. General Practices ................................................................................ 10
`B.
`Specific Documents ........................................................................... 21
`1.
`S3-172482 ................................................................................ 21
`
`2.
`
`3.
`
`4.
`
`S3-191204 ................................................................................ 25
`
`S3-19xyza ................................................................................ 29
`
`TS 33.501 v15.3.1 .................................................................... 30
`
`V.
`
`
`
`A.
`B.
`
`AVAILABILITY FOR CROSS-EXAMINATION ........................... 39
`Right To Supplement ......................................................................... 39
`Signature ............................................................................................ 39
`
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 2
`
`2
`
`2
`
`
`
`
`
`I, Friedhelm Rodermund, do hereby declare as follows:
`
`I.
`
`INTRODUCTION AND ENGAGEMENT
`
`1.
`
`I have been retained in this matter by Apple Inc. (“Petitioner” or
`
`“Apple”) to provide testimony regarding 3GPP’s standard business practices for
`
`record keeping and publishing technical specifications, change request proposals,
`
`reports, and other documents developed during the course of standards activities
`
`carried out by the 3rd Generation Partnership Project (“3GPP”) and the European
`
`Telecommunications Standards Institute (“ETSI”).
`
`2.
`
`I have been asked to provide my opinions regarding the authenticity
`
`and dates of public accessibility of the following 3GPP documents:
`
`• T-doc S3-172482, which represents a document with the title
`
`“Discussion on protection of Network Steering
`
`Information”
`
`(hereinafter “S3-172482”) (Ex. 1014)
`
`• T-doc S3-191204, which represents a document with the title “KAUSF
`
`desynchronization problem and solutions – updated version after conf
`
`call on 25 Apr.” (hereinafter “S3-191204”) (Ex. 1013)
`
`• Draft T-doc S3-19xyza, which represents a document with the title
`
`“KAUSF desynchronization problem and solutions” (hereinafter “S3-
`
`19xyza”) (Ex. 1012)
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 3
`
`3
`
`3
`
`
`
`
`
`• Version 15.3.1 of technical specification 3GPP TS 33.501 (“Technical
`
`Specification Group Services and System Aspects; Security
`
`architecture and procedures for 5G system (Release 15)”) (hereinafter
`
`“TS 33.501 v15.3.1”, Ex. 1006)
`
`3.
`
`As an ETSI Project Manager and Secretary, from June 1998 to
`
`December 2004, I have personal knowledge of 3GPP’s standard business and
`
`records keeping practices. I continued following 3GPP’s work ever since. Thus,
`
`based on my experience, personal knowledge, and review of 3GPP’s business
`
`records, I am able to testify regarding the authenticity of certain documents
`
`published by 3GPP and the timing of their publication.
`
`4.
`
`I am also knowledgeable about document management practices and
`
`the usage of email reflectors in TSG SA WG3. This is due to the fact that all 3GPP
`
`working groups used the same document repository on http://ftp.3gpp.org and all
`
`working groups use the same email exploder tool. Thus, I’m able to testify
`
`regarding the availability and authenticity of any 3GPP documents and any 3GPP
`
`exploder emails.
`
`5.
`
`I am being compensated for my time spent on this matter at my usual
`
`rate of €450 per hour. My fee is not contingent on the outcome of this or any
`
`matter, or on the content of any of the testimony I give in this declaration. I have
`
`no financial interest in Petitioner.
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 4
`
`4
`
`4
`
`
`
`
`
`6.
`
`I have been informed that Ericsson (hereinafter referred to as “Patent
`
`Owner”) alleges ownership and is the current assignee of U.S. Patent No.
`
`11,039,312 (“the ’312 Patent”) (Ex. 1001). I have no financial interest in the Patent
`
`Owner or the ’312 Patent.
`
`II.
`
`BACKGROUND AND QUALIFICATIONS
`
`7.
`
`I have more than 20 years of experience working with standards
`
`development organizations including the Third Generation Partnership Project
`
`(“3GPP”), the European Telecommunications Standards Institute (“ETSI”), and the
`
`Open Mobile Alliance (“OMA”). I have particular experience with the
`
`development of standards related to cellular telecommunications, including the
`
`standards for the Universal Mobile Telecommunications System (“UMTS”), Long
`
`Term Evolution (“LTE”), and 5G, which are all standards developed by the 3GPP.
`
`A true and correct copy of my curriculum vitae (C.V.) is attached as Appendix A.
`
`8.
`
`I attended the University of Technology Aachen in Aachen, Germany,
`
`where I performed graduate studies in Electrical Engineering with a focus on
`
`telecommunications technologies (“Dipl.-Ing. TH” degree). I also attended the
`
`University of Technology Trondheim in Trondheim, Norway, and completed my
`
`Diploma thesis, “Design of a dual processor computer for digital signal processing
`
`in power electronics,” in 1993.
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 5
`
`5
`
`5
`
`
`
`
`
`9.
`
`From December 1993 to June 1998, I worked at Mannesmann
`
`Mobilfunk as a System Engineer and Project Manager in Quality Assurance and
`
`Technical Standards. One of my responsibilities was to ensure by managing and
`
`performing related test activities that cellular network equipment was compatible
`
`with the Global System for Mobile Communications (“GSM”) standard developed
`
`by ETSI. During that time, I also started working as a standards delegate. I
`
`attended my first ETSI meeting in 1996 (although I was already following ETSI
`
`developments from 1992 during my studies).
`
`10. From June 1998 to December 2004, I worked at ETSI as a project
`
`manager for various ETSI Special Mobile Group (“SMG”) and 3GPP working
`
`groups. First, I served as a secretary of SMG4 “Data Services” and SMG8 “Base
`
`Stations Testing.” Then, as a project manager with the ETSI Mobile Competence
`
`Center (“MCC”), I supported establishing 3GPP as the new international standards
`
`development organization for cellular telecommunications. One of my roles was
`
`acting as Secretary for 3GPP’s Technical Specifications Group Terminals,
`
`Working Group (“T2”), the group which played a leading role in the creation of
`
`standards for Multimedia such as the Multimedia Messaging Service (“MMS”).
`
`11. Later, I was a secretary of the highest-level Technical Specifications
`
`Group Terminals which was besides other things responsible for the development
`
`of test specifications including tests for the radio interface.
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 6
`
`6
`
`6
`
`
`
`
`
`12.
`
`I edited all technical specifications produced by my working groups
`
`and presented results to the parent body for approval. I attended all meetings (apart
`
`from some sub-working group meetings) and was also responsible for compiling
`
`meeting reports, for handling all the meeting documents, and managing the work
`
`plan. It was also my role to guide the groups and to advise the chairmen regarding
`
`3GPP working methods and procedures including document handling, and to make
`
`sure delegates were aware of their company’s obligations under the 3GPP
`
`Intellectual Property Right policy.
`
`13. As part of my responsibilities at ETSI, I acted as a 3GPP custodian of
`
`records by personally managing 3GPP’s public File Transfer Protocol (ftp) folders,
`
`which I used to make publicly accessible various 3GPP documents, including
`
`versions of 3GPP specifications, technical reports, liaison statements, change
`
`requests, contributions, agendas, meeting reports, and other 3GPP documents from
`
`my working groups. I am also knowledgeable about document management
`
`practices used in other working groups and within 3GPP in general with regard to
`
`making documents publicly accessible through the same, public ftp server of
`
`3GPP.
`
`14. Since I left ETSI as a staff member in 2005, I have been continuously
`
`involved in standardization activities, including with Open Mobile Alliance, ETSI,
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 7
`
`7
`
`7
`
`
`
`
`
`and 3GPP. Since 2017, I also have been attending the ETSI IPR Special
`
`Committee, which is responsible for the maintenance of the ETSI IPR Policy.
`
`15. After I left ETSI, I worked from January 2005 to October 2014 at
`
`Vodafone, first as a Project Manager for Mobile Broadcast Standards, and then as
`
`Vice Chairman of the Device Management working group of the Open Mobile
`
`Alliance, and then as a Senior Standards Strategist, all with responsibilities as
`
`described on my C.V. At Vodafone, I was deeply involved in standards work with
`
`ETSI and 3GPP and other standards setting organizations, including as a delegate
`
`to 3GPP SA1 “Services.” As part of my responsibilities, I attended selected 3GPP
`
`meetings, submitted documents to 3GPP, used 3GPP resources (including 3GPP’s
`
`ftp server) extensively, and remained knowledgeable about 3GPP policies and
`
`procedures with regard to document management and public accessibility. I was
`
`also involved in the creation of patents, defense activities related to patent
`
`litigations, and patent evaluation, mostly in the context of standards development.
`
`16. Since leaving Vodafone in 2014, I have performed consulting work
`
`regarding Internet of Things (IoT) and Machine to Machine (M2M) technology
`
`and standards, first at Friedhelm Rodermund Consulting and then as the Founder
`
`and Director of IOTECC GmbH. In connection with my work, I regularly deal with
`
`standards such as OMA’s Lightweight M2M, 3GPP’s LTE, Narrowband IoT (NB-
`
`IoT) and 5G standards. And I have extensively used 3GPP resources and have
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 8
`
`8
`
`8
`
`
`
`
`
`remained knowledgeable about 3GPP policies and procedures with regard to
`
`document management and public accessibility.
`
`17.
`
`I also provide consulting services related to patents, in particular
`
`around 3GPP Standard Essential Patents (“SEPs”), and I have been working as an
`
`expert witness on a number of occasions. I continue to closely follow the
`
`maintenance of the ETSI IPR Policy as a delegate to the ETSI IPR Special
`
`Committee. Furthermore, I’m conducting a seminar on SEPs and the Internet of
`
`Things at the Technical University of Ilmenau, Germany.
`
`18. At the time of writing this declaration, I am following – including
`
`attending selected meetings - the following standards committees: ETSI oneM2M,
`
`ETSI IPR Special Committee, Open Mobile Alliance, and 3GPP.
`
`19. A copy of my curriculum vitae, which includes a detailed description
`
`of my experience and education, is attached as Appendix A. A list of litigation
`
`matters on which I have worked over the last five years is also included in my
`
`curriculum vitae.
`
`III.
`
`SUMMARY OF MY OPINIONS
`
`20.
`
`It is my opinion that S3-172482 (Ex. 1014) is an authentic 3GPP T-
`
`doc and would have been publicly accessible through ftp.3gpp.org no later than
`
`October 2, 2017.
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 9
`
`9
`
`9
`
`
`
`
`
`21.
`
`It is my opinion that S3-191204 (Ex. 1013) is an authentic 3GPP T-
`
`doc and would have been publicly accessible through ftp.3gpp.org no later than
`
`April 28, 2019.
`
`22.
`
`It is my opinion that S3-19xyza (Ex. 1012) is an authentic 3GPP draft
`
`T-doc and would have been publicly accessible through the ETSI email archive
`
`list.etsi.org no later than April 9, 2019.
`
`23.
`
`It is my opinion that TS 33.501 v15.3.1 (Ex. 1006) is a technical
`
`specification published by 3GPP and would have been publicly accessible through
`
`ftp.3gpp.org as of December 26, 2018.
`
`IV. PUBLICATION OF 3GPP
`SPECIFICATIONS AND RELATED DOCUMENTS
`A. General Practices
`
`24. Unless otherwise noted, the following is an accurate description of
`
`3GPP general practices from 1998 to the present, regardless of whether I use the
`
`present or past tense to describe those practices.
`
`25.
`
`3GPP was established in 1998 by a group of telecommunications
`
`standard development organizations from Japan, Korea, China, Europe, and the
`
`United States to jointly develop worldwide standards for mobile
`
`telecommunications. Today, 3GPP consists of seven partners: Association of Radio
`
`Industries and Businesses, Japan (“ARIB”), Alliance for Telecommunications
`
`Industry Solutions, USA (“ATIS”), China Communications Standards Association
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 10
`
`10
`
`10
`
`
`
`
`
`(“CCSA”), European Telecommunications Standards Institute (“ETSI”),
`
`Telecommunications Standards Development Society, India (“TSDSI”),
`
`Telecommunications Technology Association, Korea (“TTA”),
`
`Telecommunication Technology Committee, Japan (“TTC”). In addition to being
`
`one of the founding partners, ETSI hosts the Mobile Competence Centre (“MCC”),
`
`which provides administrative and technical support to the day-to-day work of
`
`3GPP. Furthermore, ETSI manages 3GPP’s IT services such as the 3GPP website,
`
`ftp server, and email exploders.
`
`26.
`
`3GPP is the world’s leading organization for developing and
`
`maintaining cellular telecommunications standards, which it has done since its
`
`foundation in 1998. As noted above and in my C.V., I began working for 3GPP, as
`
`part of my work at ETSI, the European-based organizational partner of 3GPP.
`
`27.
`
`In the ordinary course of its regularly conducted business activities,
`
`and pursuant to its standard business practices, 3GPP publishes technical
`
`specifications, proposals, reports, and other documents related to the development
`
`of cellular telecommunications standards. Such documents are published for the
`
`purposes of discussion and establishment of industry standards for cellular
`
`telecommunications. This has been 3GPP’s ordinary course of business since when
`
`I began working at ETSI in 1998.
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 11
`
`11
`
`11
`
`
`
`
`
`28.
`
`In the ordinary course of 3GPP’s regularly conducted business
`
`activities, and pursuant to its standard business practices, all draft technical
`
`specifications, proposals, reports, and other temporary documents to be discussed
`
`or considered in relation to 3GPP’s telecommunications standards activities were,
`
`and continue to be, assigned a temporary document number and made publicly
`
`available, including on the ftp server associated with the 3GPP website, currently
`
`residing at ftp.3gpp.org. Such documents are referred to as “T-docs.” Final
`
`versions of the technical specifications also were, and continue to be, publicly
`
`available from that same ftp server.
`
`29. The names and the structure of 3GPP working groups can be found
`
`below1:
`
`
`1 See https://www.3gpp.org/specifications-groups
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 12
`
`12
`
`12
`
`
`
`
`
`
`
`30. Each Technical Specification Group (TSG) or Working Group adopts
`
`a structured numbering system for the documents associated with their meetings,
`
`and those systems typically follow a consistent numbering system as shown in the
`
`following example: xminnzzzz. The numbering system normally comprises five
`
`logical elements: (1) x: a single letter corresponding to the TSG; where in
`
`2007/2008 x was one of R (Radio Access Network), C (Core and Terminals), S
`
`(Service and System Aspects), or G (GSM/EDGE Radio Access Network); (2) m:
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 13
`
`13
`
`13
`
`
`
`
`
`A single character corresponding to the Working Group identity (typically 1, 2, 3,
`
`etc.) or, in the case of the TSG itself, the letter “P”; (3) i: Normally the hyphen
`
`character “-”; (4) nn: the calendar year of the meeting to which the document was
`
`submitted; (5) zzzz: a running number (some Working Groups use 5 digits).
`
`31.
`
`In the ordinary course of 3GPP’s regularly conducted business
`
`activities, and pursuant to its standard business practices, from December 1998
`
`onwards, 3GPP published all its T-docs and all final versions of its technical
`
`specifications on its ftp server, which has always been easily and publicly
`
`accessible from its website and currently resides at ftp.3gpp.org.
`
`32. As early as December 1998, 3GPP’s ftp server was freely accessible
`
`to the general public with no login, password, or membership requirement.
`
`33. By 1999, at least 100 companies were members of 3GPP (by
`
`December 2020: 719 companies), ranging from Bosch to Ericsson to Nokia to
`
`Samsung and generally including those interested in the discussion, creation, and
`
`adoption of cellular telecommunications standards, including UMTS. Each of these
`
`companies typically delegated multiple individuals to regularly participate in 3GPP
`
`meetings. Further, pursuant to 3GPP’s standard business practices, 3GPP working
`
`groups sent emails notifying these individuals as soon as new or additional
`
`documents had been uploaded to 3GPP’s ftp server. Thus, not only did the general
`
`public have access to the documents on the ftp server, but some of the most
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 14
`
`14
`
`14
`
`
`
`
`
`interested members of the public—those working to develop standards for cellular
`
`telecommunication or working to implement the standards—were personally
`
`informed of their availability by email. Based on my experience with 3GPP and the
`
`telecommunications industry, I would expect any person implementing a cellular
`
`network or device, e.g., an 5G network or device, to consult the corresponding
`
`specifications on the 3GPP ftp server, as well as other related documents. The
`
`whole purpose of 3GPP creating and making these specifications available was so
`
`that engineers and other individuals would have ready access to them when
`
`developing and implementing cellular networks and devices.
`
`34.
`
`3GPP specifications bear a specification number consisting of four or
`
`five digits, e.g., 09.02 or 29.002. The first two digits define the specification series
`
`which are defined to group the different aspects of the 3GPP system into e.g.
`
`requirements, service aspects, radio aspects codecs, security aspects, and test
`
`specifications. The series digits are followed by two additional digits for the 01 to
`
`13 series or three further digits for the 21 to 55 series. The subjects of the
`
`individual specification series are explained on 3GPP’s website at
`
`https://www.3gpp.org/specifications/specification-numbering, and reproduced
`
`below:
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 15
`
`15
`
`15
`
`
`
`
`
`
`
`35. For instance, the 5G New Radio (NR) standard is covered in the “38
`
`series” and is further subdivided into separate sections or specifications. Each
`
`specification can span from a few pages to hundreds of pages. One full version of
`
`the 5G standard is massive, spanning tens of thousands of pages. As another
`
`example, security aspects are covered in the “33 series”.
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 16
`
`16
`
`16
`
`
`
`
`
`36.
`
`In the ordinary course of 3GPP’s regularly conducted business
`
`activities, and pursuant to its standard business practices, T-docs are usually
`
`uploaded to 3GPP’s ftp server and website before the meeting where they are to be
`
`discussed. Documents created or revised during the course of a meeting are
`
`normally uploaded at the latest during the week following the meeting (e.g., the
`
`meeting report of the meeting is usually published for review during the week
`
`following the meeting).
`
`37.
`
`In the ordinary course of 3GPP’s regularly conducted business
`
`activities, and pursuant to its standard business practices, 3GPP maintains archives
`
`that include different versions of the specifications, as well as email
`
`communications to its membership, including emails announcing the uploading of
`
`new or additional documents to 3GPP’s ftp server. These archives are created at
`
`the time the emails are initially sent.
`
`38. At least as early as July 1999, all of 3GPP’s email archives, including
`
`the dedicated email list for TSG SA WG3 were freely accessible to the general
`
`public at https://list.etsi.org/ with no login, password, or membership requirement.
`
`The screenshot below represents the subscription page of the 3GPP SA WG3 email
`
`list demonstrating that this webpage is publicly available and that only email
`
`address and name have to be entered to join the email list. Alternatively, everyone
`
`interested can obtain a LISTSERV password for managing subscriptions
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 17
`
`17
`
`17
`
`
`
`interactively without email confirmations. I can confirm that this webpage looked
`
`similar in 2019 and that subscription was already possible for every interested
`
`individual since the early days of 3GPP in 1999.
`
`
`
`
`
`39. Each of 3GPP’s member companies typically assigned one or more
`
`individuals to regularly participate in these email lists. Thus, not only did the
`
`general public have access to the emails in 3GPP’s email archives, but some of the
`
`most interested members of the public–those working to develop standards for
`
`cellular telecommunication–personally received copies of such emails through
`
`their participation in the email lists.
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 18
`
`18
`
`18
`
`
`
`
`
`40. By June 1999, 3GPP’s email archives were well-known to persons in
`
`the cellular telecommunications industry as a source of public information and of
`
`technical specifications, proposals, meeting announcements, technical discussions
`
`and reports regarding industry standards and technological advances.
`
`41. Based on my experience with 3GPP and the telecommunications
`
`industry, I would expect a person interested in the development of cellular
`
`standards, e.g., 5G, to consult the emails archives of the working groups and TSGs
`
`that person is interested in, and/or, to be subscribed to the corresponding email
`
`reflectors to receive any email notifications in real-time.
`
`42.
`
`3GPP specifications almost always are duplicated in at least two and
`
`sometime more locations on the ftp server. One location corresponds to a
`
`“snapshot” of the specifications corresponding to a particular plenary meeting
`
`cycle, e.g., the 2018-12 snapshot contains a snapshot of numerous specifications
`
`after the December 2018 3GPP plenary meetings. The second location is an
`
`“archive” that contains all versions over time for a given specification. While
`
`3GPP aims to upload the updated specifications to both locations at the same time,
`
`occasionally there may be a small difference in the upload date, and thus the date
`
`stamp, for the same specification uploaded to the two locations. Additionally,
`
`specifications which are not yet approved (so called “draft” specifications) are
`
`presented as T-docs at working group and at plenary meetings (as soon the
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 19
`
`19
`
`19
`
`
`
`
`
`working group decides to submit the specification to the plenary meeting for
`
`information or approval). In many cases, the T-docs are also distributed on the
`
`email exploder of the working group prior to the meeting, making the T-docs
`
`available to all those subscribed to the email distribution list.
`
`43. The timestamp on 3GPP’s ftp server shows the date when the
`
`document was uploaded the last time. Thus, the timestamp shows the latest
`
`possible date the document became publicly available and accessible on 3GPP’s
`
`ftp server. The given document might have been available earlier and the original
`
`timestamp might have been overwritten because the document was uploaded again.
`
`According to my experience, this is something which happened quite frequently.
`
`Thus, the ftp timestamp is reliable as the latest possible upload date but one cannot
`
`determine whether it represents the first upload of a document to the ftp server.
`
`44.
`
`3GPP’s working practice to store their documents on their ftp server,
`
`as described above, has not changed over time. Starting from the first 3GPP
`
`meetings in 1998 until present, all WGs and plenary meetings are represented by
`
`dedicated meeting folders on the ftp server. These meeting folders include the
`
`documents discussed at the meetings. Both the folders and the documents are
`
`accessible to the public. Almost every week, a new meeting folder with the
`
`respective documents is added. In addition to the plenary and WG meeting folders,
`
`and some other folders, there is also the “Specs” folder, which holds all 3GPP
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 20
`
`20
`
`20
`
`
`
`
`
`specifications including the aforementioned “snapshot” and archive folders. Since
`
`the early days of 3GPP a new folder is added inside the “Specs” folder after each
`
`TSG plenary meeting to hold the latest versions of specifications approved at those
`
`TSG plenary meetings. This is still 3GPP’s working practice today; thus, this
`
`practice has not changed over time.
`
`B.
`
`Specific Documents
`
`1.
`
`S3-172482
`
`45. Based on my personal knowledge and my review of 3GPP’s business
`
`records, I recognize Ex. 1014 as a true and correct copy of T-doc S3-172482, which
`
`represents a document with the title “Discussion on protection of Network Steering
`
`Information.” The document was authored by Ericsson and includes proposals for
`
`securing the Network Steering information from the HPLMN to the UE. On its face,
`
`S3-172482 refers to the TSG-SA WG3 meeting #88bis held on October 9-13, 2017,
`
`in Singapore. Thus, based on my personal knowledge and experience with ETSI’s
`
`and 3GPP’s standard business practices, this information tells me that S3-172482
`
`was available either prior to or during that meeting to at least all attending 3GPP
`
`members. The public availability of the document is confirmed by the date stamp,
`
`October 2, 2017, for the present-day listing of the document on the 3GPP ftp server
`
`at
`
`
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 21
`
`21
`
`21
`
`
`
`https://www.3gpp.org/ftp/tsg_sa/WG3_Security/TSGS3_88Bis_Singapore/Docs,
`
`as shown in the screenshot below:
`
`
`
`46.
`
`In addition, metadata information for the downloaded and extracted T-
`
`doc file states a last Modified date of “2. October 2017”, as shown in the screenshot
`
`
`
`below:
`
`
`
`
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 22
`
`22
`
`22
`
`
`
`47.
`
`The official meeting report of the TSG-SA WG3 meeting #88bis held
`
`on October 9-13, 2017, can be found in Appendix D. According to the 3GPP website
`
`at https://portal.3gpp.org/Meetings.aspx#/ which is shown by the screenshot below,
`
`that meeting was attended by 54 individuals (out of 62 registered participants):
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 23
`
`23
`
`
`
`
`
`
`
`
`
`48.
`
`In the meeting report, T-doc S3-172482 is referred to on page 57. There
`
`the document is mentioned as “noted” which clearly shows the document was
`
`available at the meeting. The screenshot below shows the excerpt of page 57:
`
`
`
`
`
`
`
`
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 24
`
`24
`
`24
`
`
`
`
`
`
`
`
`
`49. Furthermore, the document was mentioned in an email sent via the
`
`3GPP_TSG_SA_WG3 email exploder on October 6, 2017, as shown in Appendix
`
`E. As of today, this email exploder has around 570 subscribers as can be seen at
`
`https:// list.3gpp.org/. According to my experience I would expect around 500
`
`subscribers by April 2017.
`
`50. Thus, based on my personal knowledge and experience with ETSI’s
`
`and 3GPP’s standard business practices, this information tells me that this document
`
`was available to all 3GPP members and the general public by October 2, 2017, at
`
`the latest.
`
`
`
`2.
`
`S3-191204
`
`51. Based on my personal knowledge and my review of 3GPP’s business
`
`records, I recognize Ex. 1013 as a true and correct copy of T-doc S3-191204, which
`
`represents a document with the title “KAUSF desynchronization problem and solutions
`
`– updated version after conf call on 25 Apr.” The document was authored by NEC
`
`and discusses issues around the lack of synchronization between the UE and the
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 25
`
`25
`
`25
`
`
`
`
`
`AUSF with respect to the KAUSF. On its face, S3-191204 refers to the TSG-SA WG3
`
`meeting #95 held on May 6-10, 2019, in Reno, USA. Thus, based on my personal
`
`knowledge and experience with ETSI’s and 3GPP’s standard business practices, this
`
`information tells me that S3-191204 was available either prior to or during that
`
`meeting to at least all attending 3GPP members. The public availability of the
`
`document is confirmed by the date stamp, April 28, 2019, for the present-day listing
`
`of the document on the 3GPP ftp server at
`
`
`
`https://www.3gpp.org/ftp/tsg_sa/WG3_Security/TSGS3_95_Reno/Docs, as shown
`
`in the screenshot below:
`
`
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 26
`
`26
`
`26
`
`
`
`52.
`
`In addition, metadata information for the downloaded and extracted T-
`
`doc file states a last Modified date of “26. April 2019”, as shown in the screenshot
`
`below:
`
`
`
`53. The official meeting report of the TSG SA WG3 meeting #95 held on
`
`May 6-10, 2019, can be found in Appendix B. According to the 3GPP website at
`
`
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 27
`
`27
`
`27
`
`
`
`https://portal.3gpp.org/Meetings.aspx#/ which is shown by the screenshot below,
`
`that meeting was attended by 67 individuals (out of 81 registered participants):
`
`
`
`
`
`
`
`54.
`
`In the meeting report, T-doc S3-191204 is referred to on page 11-12.
`
`There the document is mentioned as “noted” which clearly shows the document was
`
`available at the TSG SA WG3 meeting #95. The screenshot below shows the excerpt
`
`of page 11-12:
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`
`
`Page 28
`
`28
`
`28
`
`
`
`
`
`
`
`
`
`
`
`55. Thus, based on my personal knowledge and experience with ETSI’s
`
`and 3GPP’s standard business practices, this information tells me that this document
`
`was available to all 3GPP members and the general public by April 28, 2019, at the
`
`latest.
`
`
`
`3.
`
`S3-19xyza
`
`56. Based on my personal knowledge and my review of 3GPP’s business
`
`records, I recognize Ex. 1012 as a true and correct copy of draft T-doc S3-19xyza,
`
`which represents a document with the title “KAUSF desynchronization problem and
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 29
`
`29
`
`29
`
`
`
`
`
`solutions.” The document was authored by NEC and discusses issues around the lack
`
`of synchronization between the UE and the AUSF with respect to the KAUSF. On its
`
`face, S3-19xyza refers to the TSG-SA WG3 meeting #95 held on May 6-10, 2019,
`
`in Reno, USA. Thus, based on my personal knowledge and experience with ETSI’s
`
`and 3GPP’s standard business practices, this information tells me that draft T-doc
`
`S3-19xyza was available either prior to or during that meeting to at least all attending
`
`3GPP members. S3-19xyza was a draft T-doc which led to T-doc S3-191204
`
`described in the previous section of this declaration.
`
`57. The public availability of the document is confirmed by the ETSI email
`
`archive. The document was distributed via the 3GPP_TSG_SA_WG3 email
`
`exploder on April 9, 2019, as shown in Appendix C. As of today, this email exploder
`
`has around 570 subscribers as can be seen at https:// list.3gpp.org/. According to my
`
`experience I would expect around 500 subscribers by April 2019.
`
`58. Thus, based on my personal knowledge and experience with ETSI’s
`
`and 3GPP’s standard business practices, this information tells me that this document
`
`was available to all subscribers of the public 3GPP_TSG_SA_WG3 email exploder,
`
`and thus also to the general public by April 9, 2019, at the latest.
`
`
`
`4.
`
`TS 33.501 v15.3.1
`
`DECLARATION OF FRIEDHELM RODERMUND
`
`Page 30
`
`30
`
`30
`
`
`
`
`
`59.
`
` Based on my personal knowledge and my review of 3GPP’s business
`
`records, I recognize Ex. 1006 as a true and correct copy of version 15.3.1 of
`
`technical report 3GPP TS 33.501 (“Technical Specification Group Services and
`
`System Aspects; Security architecture and procedures for 5G system (Release
`
`15)”) which shows on its cover page “2018-12” as the year (2018) and month
`
`(December) during which this document was rel
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
