PATENT OWNER’S
`DEMONSTRATIVE EXHIBITS
`
`SEPTEMBER 15, 2023
`
`ORAL ARGUMENT
`
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., AND APPLE INC.
`
` v.
`
`SMART MOBILE TECHNOLOGIES LLC
`
`U.S. PATENT NO. 9,614,943 B1
`
`IPR2022-01004
`
`PHILIP J. GRAVES, COUNSEL FOR PATENT OWNER
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 1 of 47
`
`
`DEMONSTRATIVE EXHIBITS
`
`SEPTEMBER 15, 2023
`
`ORAL ARGUMENT
`
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., AND APPLE INC.
`
` v.
`
`SMART MOBILE TECHNOLOGIES LLC
`
`U.S. PATENT NO. 9,614,943 B1
`
`IPR2022-01004
`
`PHILIP J. GRAVES, COUNSEL FOR PATENT OWNER
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 1 of 47
`
`
`
`Table Of Contents
`
`• Byrne Grounds
`– Byrne Does Not Disclose A Processor That Processes A
`First and Second Data Stream
`– Byrne Does Not Disclose A Processor That Processes Two
`Data Streams In Parallel
`• Byrne-Raleigh Grounds
`– Raleigh Does Not Disclose A Processor That Processes A
`First And Second Data Stream
`– Raleigh Does Not Disclose First And Second Data
`Streams That Are Processed By The Processors
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`2
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 2 of 47
`
`
`
`A Processor That Comprises Multiple Channels And Is
`Configured To Process First And Second Data Streams In
`Parallel
`
`EX-1001, claims 1, 5, 8, 12.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`3
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 3 of 47
`
`
`
`The Petition v. Byrne’s Disclosure
`
`Petitioner’s Argument
`
`Actual Signal Flow
`
`The data from the antennas
`does not touch the processor
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`Pet., 16; POR, 8, 15; EX-1003, ¶87; EX-2004, ¶¶35, 48; EX-1008, Fig. 2 (annotated).
`
`4
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 4 of 47
`
`
`
`Petitioner Points To The Signals Received Over Byrne’s
`Antennas As The First And Second Data Streams
`
`POR, 9; EX-2004, ¶36.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`5
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 5 of 47
`
`
`
`Petitioner Points To The Signals Received Over Byrne’s
`Antennas As The First And Second Data Streams
`
`POR, 9; EX-2004, ¶36.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`6
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 6 of 47
`
`
`
`Byrne’s Cordless And Cellular “Data Streams” Are Not
`Received Or Processed By Byrne’s Microprocessor
`
`POR, 9; EX-2004, ¶37.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`7
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 7 of 47
`
`
`
`Byrne’s Microprocessor “Monitors Control Signals”
`And Controls The Phone
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`POR, 9, 15; EX-1008, 7:56-8:2, 8:16-33, 38-43, Fig. 2 (annotated).
`
`8
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 8 of 47
`
`
`
`Byrne’s Microprocessor “Monitors Control Signals”
`And Controls The Phone
`
`POR, 9, 15; EX-2004, ¶38.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`9
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 9 of 47
`
`
`
`Figure 3: Does Not Teach Simultaneous
`Cordless And Cellular Calls
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`POR, 13-14; EX-1008, Fig. 3; EX-2004, ¶44.
`
`10
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 10 of 47
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`
`
`Figure 4: Does Not Teach Simultaneous
`Cordless And Cellular Calls
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`POR, 14; EX-1008, Fig. 4; EX-2004, ¶45.
`
`11
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`Smart Mobile Technologies LLC, Exhibit 2019
`Page 11 of 47
`
`
`
`The Microprocessor Controls The Flow Of The Signals,
`But Does Not Process The Signals Themselves
`
`Microprocessor 210 does
`not transmit the cordless
`or cellular streams to the
`audio switch, because
`those streams never reach
`the microprocessor.
`Instead, the
`microprocessor controls
`the audio switch to link
`the cordless or cellular
`audio channel to the
`output device.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`POR, 9, 15; EX-1008, 38-43, Fig. 2 (annotated).
`
`12
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 12 of 47
`
`
`
`The Microprocessor Controls The Flow Of The Signals,
`But Does Not Process The Signals Themselves
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`POR, 14-15; EX-1008, 8:39-43, Fig. 2 (annotated); EX-2004, ¶¶47-49.
`
`13
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 13 of 47
`
`
`
`Dr. Jensen Admits “No Express Disclosure” That The Cordless
`Information Is Passed To The Microprocessor
`
`POR, 16-17; EX-2007, 33:11-34:4.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`14
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 14 of 47
`
`
`
`Reply: Control Signals Are Data Streams (They’re Not)
`
`• Pure ipse dixit.
`The Petition relies on the cellular
`•
`and cordless communications
`received by the phone to satisfy
`“data streams.”
`• “Signals . . . indicating received
`signal strength” and “for
`detecting receive data” are not
`the signals received by Byrne’s
`phone, they are generated
`internally.
`
`Sur-Reply, 1-2; EX-1048, ¶5.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`15
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`Smart Mobile Technologies LLC, Exhibit 2019
`Page 15 of 47
`
`
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`Reply: Control Signals Are Data Streams (They’re Not)
`
`What does Byrne really
`say?
`
`So Byrne does not distinguish
`“control signals,” it adds more
`examples of such signals.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`Sur-Reply, 2-3; EX-1008, 8:16-28; EX-1048, ¶5.
`
`16
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 16 of 47
`
`
`
`Reply: Microprocessor Encrypts Data Streams –
`This Is A New Argument
`
`Petition
`
`“[A] POSITA would have understood or
`found obvious that, when “both cellular
`and cordless operations are in progress at
`the same time,” microprocessor 210
`processes the cordless data stream (first
`data stream) and the cellular data stream
`(second data stream) in parallel. Id.; EX-
`1003, ¶87.” Pet., 17.
`
`“Byrne describes digital protocols (e.g.,
`CT2/DECT for cordless, and GSM/DCS for
`cellular) for its system, and thus Byrne’s
`system transmits/receives data carrying
`digital information on these protocols. EX-
`1003, ¶88; EX-1008, 7:19-24, 8:16-38,
`Abstract. Therefore, a POSITA would have
`understood or found obvious that Byrne’s
`cordless and cellular systems involve data
`streams being processed, which include
`digital voice and control data generated
`for telephone calls. EX-1003, ¶88.” Pet., 17.
`
`POSITA knowledge
`based on “cellular
`and cordless
`operations . . . at the
`same time” and use of
`cellular and cordless
`digital protocols. No
`mention of encryption.
`
`Reply
`
`“Byrne describes that “microprocessor
`210 controls the CCT 200 in a similar way
`when operating as a cellular telephone,
`but appropriately modified for the
`signaling protocols and data encryption
`used in the cellular system.” EX-1008,
`8:29-33. As Byrne explains, the “signaling
`protocols, data encryption techniques
`and the like … are well known in the art,
`and the microprocessor can be
`arranged to operate in a known manner
`to effect control of the signals in such
`systems.” Id., 8:33-38. As Dr. Jensen
`explains, to perform known cellular
`signaling and data encryption
`operations, a POSITA would have
`understood that Byrne’s microprocessor
`receives and processes the cellular
`data. EX-1048, ¶6.” Reply, 4.
`
`Sur-Reply, 4-5; Pet., 17; Reply, 4.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`17
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 17 of 47
`
`
`
`Petitioner May Not Change Its Arguments In Reply
`
`“It is of the utmost importance that petitioners in the IPR proceedings adhere to the
`requirement that the initial petition identify ‘with particularity’ the ‘evidence that supports
`the grounds for the challenge to each claim.’ 35 U.S.C. § 312(a)(3). . . . [T]he expedited
`nature of IPRs bring with it an obligation for petitioner to make their case in their petition.
`. . .’” Intelligent Bio-Sys., Inc. v. Illumina Cambridge Ltd., 821 F.3d 1359, 1369 (Fed. Cir.
`2016).
`
`“Petitioner’s Reply is not an opportunity to advance new arguments based on new
`testimony in an effort to show that challenged claims are unpatentable . . . Patent Owner
`argues, and we agree, that consideration of arguments raised improperly by Petitioner
`for the first time in its Reply is unwarranted.” Axonics, Inc. v. Medtronic, Inc., IPR2020-
`00712, Paper 42, at 35 (PTAB Sept. 22, 2021).
`
`“We further find Petitioner’s need to file a supplemental declaration from Dr. Panescu, . . .
`supports our determination that Petitioner improperly seeks to advance new arguments
`in its Reply. Such testimony is not offered in support of the arguments advanced in the
`Petition, but to instead present a new rationale based on new features that go well-
`beyond proper supplemental testimony.” Axonics, IPR2020-00712, Paper 42, at 37
`
`“Moreover, we agree with Patent Owner that it would be prejudicial to Patent Owner to
`be required to refute what amounts to a new ground of unpatentability not raised in the
`Petition, but instead asserted for the first time by Petitioner in its Reply. Thus, reaching the
`merits of the new arguments raised by Petitioner on an incomplete record is
`unwarranted in this case.” Axonics, IPR2020-00712, Paper 42, at 38 n.10.
`
`Sur-Reply, 4-5.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`18
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 18 of 47
`
`
`
`Petitioner’s New “Encryption” Argument Fails On The Merits
`
`Reply
`
`The New Argument Fails
`
`No explanation as to how encryption
`for cellular operations would suggest
`that the microprocessor processes
`cordless and cellular data streams.
`
`No explanation as to why a POSITA
`would read this snippet to teach a
`microprocessor configured to encrypt
`both cellular and cordless data streams
`in parallel.
`
`•
`
` •
`
`“Byrne describes that “microprocessor
`210 controls the CCT 200 in a similar way
`when operating as a cellular telephone,
`but appropriately modified for the
`signaling protocols and data encryption
`used in the cellular system.” EX-1008,
`8:29-33. . . . As Dr. Jensen explains, to
`perform known cellular signaling and
`data encryption operations, a POSITA
`would have understood that Byrne’s
`microprocessor receives and processes
`the cellular data. EX-1048, ¶6.” Reply, 4.
`
`“From Byrne’s description and a
`POSITA’s general knowledge, a POSITA
`would have understood and found
`obvious that, in Byrne, the
`microprocessor processes cordless and
`cellular data streams.” Reply, 5
`
`Sur-Reply, 5-6.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`19
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 19 of 47
`
`
`
`Petitioner’s Evidence Undermines
`Its New “Encryption” Argument
`
`Petitioner’s New EX-1075
`
`Sequential encryption of one
`data block at a time
`precludes processing cellular
`and cordless data streams in
`parallel
`
`Sur-Reply, 5-6; EX-1075, 6:5-58.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`20
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 20 of 47
`
`
`
`Petitioner’s New “Encryption” Argument Rests On A
`Mischaracterization Of Dr. Cooklev’s Testimony
`
`Reply
`
`“Dr. Cooklev confirmed that data
`encryption requires a processor and
`embedded software, such as Byrne’s
`microprocessor. EX-1049, 19:5-23:10. He
`also recognized that types of processors
`(e.g., “general-purpose processors” or
`“application-specific integrated
`circuits”) for implementing data
`encryption and other security software
`were known before the Critical Date,
`and that such processors and their
`operations were well within a POSITA’s
`knowledge and skill. EX-1049, 24:5-25:8,
`31:19-32:3. Further, as of the Critical
`Date, Dr. Cooklev was not aware of any
`transmitters and receivers capable of
`performing encryption, nor was he
`aware of components other than a
`processor being leveraged for data
`encryption. EX-1049, 26:18-28:15.” Reply,
`5
`
`A processor is not
`considered to be a
`dedicated digital chip,
`and Dr. Cooklev was
`not aware of
`transceivers performing
`encryption only
`because he had not
`investigated.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`Sur-Reply, 6-7; Reply, 5; EX-1049, 18:16-25, 20:4-8, 26:14-23.
`
`21
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 21 of 47
`
`
`
`Reply: Byrne’s Display Receives Data Streams
`From The Receivers (It Doesn’t)
`
`Nothing
`suggests that
`the
`microprocessor
`processes even
`a single data
`stream, much
`less cellular
`and cordless
`data streams in
`parallel, to
`update the
`display.
`
`Sur-Reply, 7; EX-1008, 8:44-58, Fig. 3.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`22
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 22 of 47
`
`
`
`Table Of Contents
`
`• Byrne Grounds
`– Byrne Does Not Disclose A Processor That Processes A
`First and Second Data Stream
`– Byrne Does Not Disclose A Processor That Processes Two
`Data Streams In Parallel
`• Byrne-Raleigh Grounds
`– Raleigh Does Not Disclose A Processor That Processes A
`First And Second Data Stream
`– Raleigh Does Not Disclose First And Second Data
`Streams That Are Processed By The Processors
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`23
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 23 of 47
`
`
`
`Byrne’s Processor Does Not Process Cordless And Cellular
`Data Streams In Parallel
`
`“Operating” does
`not mean a live
`connection.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`POR, 20; EX-1008, 8:2-28; EX-2004, ¶57; EX-2006, 170:15-171:2; 172:20-173:2.
`
`24
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 24 of 47
`
`
`
`Petitioner’s Fallback: Would Have Been Obvious
`To Process Streams in Parallel
`
`• But . . . Why? No
`Explanation
`
`• Dr. Jensen admits
`that there were other
`ways that Byrne
`could have
`processed cellular
`and cordless
`operations.
`
`POR, 21-22; EX-2007, 103:16-104:4.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`25
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 25 of 47
`
`
`
`Petitioner’s “Parallel Monitoring Of Signal Characteristics
`Argument Is Wholly Unsupported
`
`Where does
`Byrne disclose
`“simultaneously”
`considering
`predetermined
`criteria?
`
`Reply
`
`Byrne describes simultaneously
`considering “received signal strength,”
`“bit error rate, frame error rate or the
`like” in assessing the cellular and
`cordless systems. EX-1008, 4:46-56. To
`compare signal strength and bit/frame
`error rate, a POSITA would have
`understood and found obvious that
`Byrne’s system maintains parallel open
`connections and processes signals
`received over the parallel open
`connections to assess signal strength
`and error rate of data (e.g., bits/frames)
`conveyed in those signals. EX-1048, ¶23.
`Reply, 8.
`
`Byrne teaches
`that it is
`“advantageous[]
`” to monitor
`signals
`intermittently.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`Sur-Reply, 8-9; Reply, 8; EX-1008, 4:46-56, 5:9-19.
`
`26
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 26 of 47
`
`
`
`Reply: New Gillig “Three-Way Linking” Argument
`
`Petition
`
`Reply
`
`“[A] POSITA would have understood or
`found obvious that, when “both cellular
`and cordless operations are in progress at
`the same time,” microprocessor 210
`processes the cordless data stream (first
`data stream) and the cellular data stream
`(second data stream) in parallel. Id.; EX-
`1003, ¶87.” Pet., 17.
`
`The Petition says nothing about
`Gillig or three-way linking. Byrne
`does not disclose three way linking.
`Byrne’s citation to Gillig does not
`reference three way linking.
`Petitioner’s Byrne-Gillig
`combination is a new ground.
`
`“Indeed, simultaneous cellular/cordless
`operation, which involves processing
`two data streams in parallel, was well-
`known as evidenced in Gillig, which is
`referenced in Byrne and describes three-
`way linking that uses parallel cellular and
`cordless connections. EX-1008, 1:27-29,
`2:42-3:11, 10:37-39; EX-1052, 1:62-66, 3:26-
`31, 6:35-7:16. From Byrne’s express
`disclosure of simultaneous operation (EX-
`1008, 8:1-15) and Byrne’s reference to Gillig
`including its three-way linking, a POSITA
`would have understood and found
`obvious that Byrne’s phone (i.e., its
`microprocessor) performs parallel
`processing of cellular/cordless data
`streams while Byrne is in simultaneous
`cellular/cordless operation, consistent with
`or in a manner similar to Gillig’s three-way
`linking. EX-1048, ¶24.” Reply, 9.
`
`Sur-Reply, 9; Pet., 17; Reply, 9.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`27
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 27 of 47
`
`
`
`Petitioner’s New Gillig “Three-Way Linking”
`Argument Fails On The Merits
`
`Reply
`
`The New Argument Fails
`
`“Indeed, simultaneous cellular/cordless operation,
`which involves processing
`two data streams in parallel, was well-known as
`evidenced in Gillig, which is
`referenced in Byrne and describes three-way linking
`that uses parallel cellular and cordless connections. EX-
`1008, 1:27-29, 2:42-3:11, 10:37-39; EX-1052, 1:62-66, 3:26-
`31, 6:35-7:16. From Byrne’s express disclosure of
`simultaneous operation (EX-1008, 8:1-15) and Byrne’s
`reference to Gillig including its three-way linking, a
`POSITA would have understood and found obvious
`that Byrne’s phone (i.e., its
`microprocessor) performs parallel processing of
`cellular/cordless data streams while Byrne is in
`simultaneous cellular/cordless operation, consistent
`with or in a manner similar to Gillig’s three-way linking.
`EX-1048, ¶24.” Reply, 9.
`
`• No explanation as to how Gillig’s three-
`way linking functionality discloses
`Byrne’s microprocessor processing
`cellular and cordless data streams in
`parallel.
`
`
`• Gillig’s three way linking does not
`involve a microprocessor processing
`cellular and cordless signals in parallel,
`or at all.
`
`
`
`Sur-Reply, 11; Reply, 9.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`28
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 28 of 47
`
`
`
`Reply: New “Handover” Argument
`
`Reply
`
`The New Argument Fails
`
`• No explanation as to why the handover
`would require Byrne’s microprocessor to
`process cellular and cordless data
`streams in parallel.
`
`• New argument not in the Petition.
`
`“Byrne’s device is designed to “automatically handover to a
`system having a good service
`(e.g. cordless to cellular)” so that it does not lose an ongoing
`call (“actual open connection”). EX-1008, 4:9-14. Therefore,
`it would have been understood and obvious that Byrne’s
`phone processes both cordless and cellular data streams in
`parallel during the handover process, which transitions a call
`from one service to another without losing it. EX-1048, ¶25.
`The British applications referenced in Byrne confirm this. Id.;
`EX-1069 (“Byrne-730”), 5-6; EX-1070, 7-9; EX-1071, 4, 10-12. For
`example, Byrne-730’s dual-mode terminal performs a
`handover from cordless to cellular (“mobile”) where, “[a]fter
`the establishment of the connection [to cellular/mobile] is
`completed the mobile station part informs the cordless
`telephone part about the matter and the latter releases the
`radio path of the cordless telephone system.” EX-1069, 5-6.
`During the handover, therefore, an existing call connection
`over one service is released only after a new connection
`over the other service is established; prior to such release,
`overlap and processing are both necessary and obvious. EX-
`1048, ¶25.” Reply, 9-10.
`
`Sur-Reply, 11; Reply, 9-10.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`29
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 29 of 47
`
`
`
`Reply: Control Signals Are Data Streams
`
`Reply
`
`Petitioner is Wrong
`
`“[A] POSITA would have found it obvious that Byrne’s
`microprocessor processes cellular/cordless data streams
`simultaneously in performing the control operations. EX-1048,
`¶26. As mentioned above, Byrne’s microprocessor describes
`parallel consideration of signal strength and bit/frame error
`rate. EX-1008, 4:46-56.
`
`Even assuming this consideration is limited to assessment of
`control signals, it still involves parallel processing of data
`streams. In fact, Byrne describes control signals with
`“broadcast information relevant to the cordless system.” EX-
`1008, 8:23-28. Processing this “information” while a cellular
`call is in progress involves processing a first data stream (e.g.,
`the broadcast information) in parallel with a second data
`stream (e.g., the cellular call data). EX-1048, ¶26. Neither the
`claims, nor the ’943 patent’s specification, requires audio
`from two networks to be simultaneously processed. Id. Thus,
`even assuming that Patent Owner is correct in asserting that
`Byrne’s simultaneous operation is limited to simultaneous
`processing of control information (it is not), that simultaneous
`processing still satisfies the
`claims. Id..” Reply, 10-11.
`
`• As shown above, Byrne’s microprocessor
`does not describe “parallel
`consideration” of control signals.
`• Control signals are not the cellular and
`cordless data streams, and are not data
`streams at all.
`• Byrne’s “broadcast information relevant
`to the cordless system” is not a data
`stream, and there is no evidence that it
`would be processed in parallel with
`cellular call data.
`
`Sur-Reply, 11; Reply, 9-10.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`30
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 30 of 47
`
`
`
`Table Of Contents
`
`• Byrne Grounds
`– Byrne Does Not Disclose A Processor That Processes A
`First and Second Data Stream
`– Byrne Does Not Disclose A Processor That Processes Two
`Data Streams In Parallel
`• Byrne-Raleigh Grounds
`– Raleigh Does Not Disclose A Processor That Processes A
`First And Second Data Stream
`– Raleigh Does Not Disclose First And Second Data
`Streams That Are Processed By The Processors
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`31
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 31 of 47
`
`
`
`The Claims Require At Least One Processor Configured To
`Process Multiple Data Streams In Parallel And That
`Comprises Multiple Channels
`
`“We agree with the district court that while the claim term ‘a microprocessor’
`does not require there be only one microprocessor, the subsequent limitations
`referring back to ‘said microprocessor’ require that at least one microprocessor
`be capable of performing each of the claimed functions.” Salazar v. AT&T
`Mobility LLC, 64 F.4th 1311, 1317 (Fed. Cir. 2023).
`
`At least one processor
`must comprise “multiple
`ones of the one or more
`channels” and be
`“configured to process
`a first data stream and a
`second data stream in
`parallel.
`
`POR, 25-26; EX1001, claim 1.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`32
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 32 of 47
`
`
`
`No Disclosure Of Parallel Processing In Raleigh
`
`POR, 32-33; EX-2004, ¶67.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`33
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 33 of 47
`
`
`
`Raleigh’s “Substreams” Are Not Processed In Parallel
`
`Parallel signal sequences
`=/=
`Parallel processing
`
`Parallel transmission
`=/=
`Parallel processing
`
`POR, 32-33; Pet., 58-59.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`34
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 34 of 47
`
`
`
`Raleigh’s “Substreams” Are Not Even Transmitted In Parallel
`
`Where is the
`parallel
`transmission?
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`POR, 33; Pet., 58-59; EX-1005, 7:36-52.
`
`35
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 35 of 47
`
`
`
`Dr. Jensen’s Second Declaration: Ipse Dixit And Incorrect
`
`Dr. Jensen’s Supplemental
`Declaration, ¶40
`
`Raleigh further expressly discloses that parallel
`processing of sequences is part of the
`generation of the parallel set of digital time
`domain signal sequences for parallel
`transmission. For example, Raleigh teaches with
`respect to Figure 9 that “[f]or the MIMO system,
`each transmitter antenna 51 is preceded by
`one of MT identical Transmitter SOP processors.
`Likewise, each receiver antenna 111 precedes
`one of MR identical Receiver SOP processors.”
`EX-1005, 13:53-56. Referring to Figure 9 below, it
`is clear that these “Transmitter SOP processors”
`and “Receiver SOP processors” are arranged in
`parallel, meaning each Transmit SOP processor
`can perform its processing independently from
`and in parallel with the others, and each
`Receiver SOP processor can perform its
`processing independently from an in parallel
`with the others.” Reply, 10-11.
`
`Petitioner is Wrong
`
`• No explanation as to why a POSITA
`would understand that Raleigh’s
`Transmitter and Receiver SOP
`processors, each of which is
`dedicated to a separate antenna,
`are “arranged in parallel.”
`• No explanation as to why a POSITA
`would understand processors
`“arranged in parallel” to connote
`parallel processing.
`• Dr. Jensen states that Raleigh’s SOP
`processors operate “independently”
`from one another. This is not
`parallel processing.
`
`Sur-Reply, 16-17; EX-1048, ¶40.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`36
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 36 of 47
`
`
`
`Dr. Jensen’s Second Declaration: Ipse Dixit And Incorrect
`
`Dr. Jensen’s Supplemental
`Declaration, ¶40
`
`Additionally, Figure 11 “shows M symbols: z(1,1)
`through z(1,M). … Each TSW 210A-C applies a
`weight vector to the symbol appearing at its
`input, and the elements of the resultant vector
`are routed to MT summing junctions 211.” EX-
`1005, 16:15-21. The fact that the weighted
`symbols are summed in each junction 211
`means that they all need to be available at the
`same time, indicating that the weighting, which
`is a processing step, is performed in parallel.
`Identical processing is applied to all of the
`frequency bins (symbols) forming the input:
`“The spatial processing described above can
`be applied to the other N-1 frequency bins in
`addition to frequency bin 1. The block diagram
`for such a system is depicted in FIG. 13 for the
`transmitter…” EX-1005,..” Reply, 10-11.
`
`Petitioner is Wrong
`
`• No explanation as to why
`summation of the symbols requires
`that the inputs be available at the
`same time. In fact, they could be
`added one by one.
`• No explanation as to why, even if
`the inputs were available at the
`same time, summation of the
`inputs requires parallel processing.
`
`Sur-Reply, 16-17; EX-1048, ¶40.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`37
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 37 of 47
`
`
`
`No Single Processor That Comprises Multiple Data Streams
`Or Processes Multiple Streams In Parallel
`
`Petition: One processor for all antennas
`
`Raleigh: One processor for each antenna
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`POR, 36-37; Pet., 57; EX-1005, 13:52-55; EX-2004, ¶70.
`
`38
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 38 of 47
`
`
`
`Reply: The Claims Cover Multiprocessors
`And Multi-Thread Processors
`
`However – there is
`a separate SOP
`processor for each
`antenna. So
`Raleigh’s
`processors are not
`separate
`processing
`elements of a
`multicore or
`multithread
`processor.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`Sur-Reply, 18; EX-1005, 13:52-55; EX-2004, ¶70.
`
`39
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 39 of 47
`
`
`
`Reply: Raleigh Suggests A “Single Processor”
`Implementation
`
`False – Raleigh
`contains no such
`suggestion, and
`expressly states
`the opposite.
`Illustrating
`components
`with blocks is not
`enough.
`
`Sur-Reply, 19-20; EX-1048, ¶45.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`40
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 40 of 47
`
`
`
`Reply: New Argument To Modify Raleigh As A “Single
`Processor” Implementation
`
`Petition
`
`Reply
`
`Petitioner
`relied only
`on TSFP 30.
`Argument
`to modify
`Raleigh is
`New and
`Untimely.
`
`“Further, it was widely known and obvious to
`implement the functions of the “SOP
`processors” in a single processor (e.g., single-
`chip multiprocessor) for several known
`benefits. Id. (citing EX-1045, EX-1046, EX-1054,
`EX-1056, EX-1055). As Dr. Jensen explained, a
`POSITA would have been motivated to
`implement Raleigh’s “SOP processors” (the
`functionalities thereof) using such known
`single processors to gain their known
`benefits. EX-1048, ¶46 (citing EX-1061, EX-
`1062).” Reply, 9.
`
`Sur-Reply, 19-20; Pet., 58; Reply, 9.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`41
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 41 of 47
`
`
`
`Table Of Contents
`
`• Byrne Grounds
`– Byrne Does Not Disclose A Processor That Processes A
`First and Second Data Stream
`– Byrne Does Not Disclose A Processor That Processes Two
`Data Streams In Parallel
`• Byrne-Raleigh Grounds
`– Raleigh Does Not Disclose A Processor That Processes A
`First And Second Data Stream
`– Raleigh Does Not Disclose First And Second Data
`Streams That Are Processed By The Processors
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`42
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 42 of 47
`
`
`
`Petition: Raleigh’s “Parallel Set Of Digital Time Domain Signal
`Sequences” Are The First And Second Data Streams
`
`POR, 38; Pet., 58-59; EX-1003, ¶190.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`43
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 43 of 47
`
`
`
`The Claims Require That The Processor Be Configured To
`Process The First And Second Data Streams
`
`POR, 38; EX-1001, claims 1, 5, 8, 12.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`44
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 44 of 47
`
`
`
`The Petition’s “Parallel Set Of Digital Time Domain Signal
`Sequences” Are Generated By The Processors
`
`Per the Petition,
`Raleigh’s “processor”
`processes the symbol
`stream (the input) to
`generate the parallel
`set of digital time
`domain signal
`sequences (the
`output). There is only
`one symbol stream.
`So neither the symbol
`stream, nor the
`parallel set of digital
`time domain signal
`sequences, satisfy the
`claimed first and
`second data streams
`
`POR, 38; Pet., 58-59; EX-1003, ¶190.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`45
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 45 of 47
`
`
`
`Raleigh’s “Bins” Are Not Channels
`
`POR, 39; EX-2004, ¶73.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`46
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 46 of 47
`
`
`
`PATENT OWNER’S
`DEMONSTRATIVE EXHIBITS
`
`SEPTEMBER 15, 2023
`
`ORAL ARGUMENT
`
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., AND APPLE INC.
`
` v.
`
`SMART MOBILE TECHNOLOGIES LLC
`
`U.S. PATENT NO. 9,614,943 B1
`
`IPR2022-01004
`
`PHILIP J. GRAVES, COUNSEL FOR PATENT OWNER
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Smart Mobile Technologies LLC, Exhibit 2019
`Page 47 of 47
`
`
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