Samsung Electronics Co. LTD., Apple Inc., and Samsung
`
`Electronics America, Inc. (Petitioner)
`
`v.
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Before Hon. Hyun J. Jung, Nathan A. Engels, and Paul J. Korniczky
`
`U.S. Patent No. 9,614,943
`Case No. IPR2022-01004
`
`Petitioner Demonstratives
`
`Smart Mobile Technologies, LLC (Patent Owner)
`
`1
`
`Exhibit 1080
`Samsung v. Smart Mobile
`IPR2022-01004
`
`
`
`Electronics America, Inc. (Petitioner)
`
`v.
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Before Hon. Hyun J. Jung, Nathan A. Engels, and Paul J. Korniczky
`
`U.S. Patent No. 9,614,943
`Case No. IPR2022-01004
`
`Petitioner Demonstratives
`
`Smart Mobile Technologies, LLC (Patent Owner)
`
`1
`
`Exhibit 1080
`Samsung v. Smart Mobile
`IPR2022-01004
`
`
`
`2
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`83
`
`80
`
`77
`
`46
`
`42
`
`38
`
`33
`
`13
`
`3
`
`Issue 8: Claims 12, 15, and 18-20 (Grounds 2C and 2E)
`
`Issue 7: The Raleigh-Byrne-WO748 Combination (Claims 3-4 in Ground 2B)
`
`Issue6: Claims 6-7 (Ground 2A)
`
`(1[e], 5[g], 8[f], and 12[f])
`Issue5: The Raleigh-Byrne Combination Renders Obvious The “Processor” Limitations
`
`Combination (Ground 1C)
`Issue 4: Reasonable Expectation of Success For The Byrne-Johnston-Pillekamp
`
`1B)
`Issue 3: Reasonable Expectation of Success For The Byrne-WO748 Combination (Ground
`
`Issue 2: The Byrne-WO748 Combination Renders Obvious Claims 3-4 (Ground 1B)
`
`Issue 1: Byrne Renders Obvious The “Processor” Limitations (1[e], 5[g], 8[f], and 12[f] )
`
`Background / Overview
`
`Table of Contents
`
`2
`
`
`
`3
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`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Background / Overview
`
`3
`
`
`
`4
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`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1001 (’943 patent), Cover.
`
`13-20
`
`EX-1001 (the ’434 patent), Cover; Petition, 1.
`•Dependent claims 2-4, 6, 7, 9, and
`Independent claims 1, 5, 8, and 12
`
`•Challenged Claims
`
`•
`
`1996.
`application 08/764,903 filed Dec. 16,
`possible priority claim to U.S. patent
`Patent” or “EX-1001”)has an earliest
`•U.S. Patent No. 9,614,943 (the “’943
`
`Overview of the ’943 Patent
`
`4
`
`
`
`5
`
`Petition, 3-4; EX-1001 (’943 patent), 7:26-52
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`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Petition, 3-4; EX-1001 (’943 patent), Figure 10
`
`Overview of the ’943 Patent
`
`5
`
`
`
`6
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`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1001 (’943 patent), Claim 1
`
`1[e]
`
`1[d]
`
`1[c]
`
`1[b]
`1[a]
`1[pre]
`
`’943 Patent
`
`Independent Claim 1
`
`6
`
`
`
`7
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`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1001 (’943 patent), Claim 4
`
`EX-1001 (’943 patent), Claim 3
`
`’943 Patent
`
`Dependent Claims 3-4
`
`7
`
`
`
`8
`
`EX-1001 (’943 patent), Claim 5
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`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
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`5[g]
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`5[f]
`
`5[e]
`
`5[d]
`
`5[c]
`
`5[b]
`5[a]
`5[pre]
`
`’943 Patent
`
`Independent Claim 5
`
`8
`
`
`
`9
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`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1001 (’943 patent), Claims 6-7
`
`’943 Patent
`
`Dependent Claims 6-7
`
`9
`
`
`
`10
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`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
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`EX-1001 (’943 patent), Claim 8
`
`8[f]
`
`8[e]
`
`8[d]
`
`8[c]
`
`8[b]
`8[a]
`8[pre]
`
`’943 Patent
`
`Independent Claim 8
`
`10
`
`
`
`11
`
`EX-1001 (’943 patent), Claim 12
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`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
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`12[f]
`
`12[e]
`
`12[d]
`
`12[c]
`
`12[b]
`12[a]
`12[pre]
`
`’943 Patent
`
`Independent Claim 12
`
`11
`
`
`
`12
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`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
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`Institution Decision, 7
`
`Instituted Grounds
`
`12
`
`
`
`13
`
`13
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`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
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`Byrne Renders Obvious The “Processor” Limitations
`
`(1[e], 5[g], 8[f], and 12[f] )
`
`Issue 1
`
`13
`
`
`
`14
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`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Parallel”
`Processes Data Streams “In
`1-2. Byrne’s “Microprocessor”
`
`Streams
`Receives and Processes Data
`1-1. Byrne’s “Microprocessor”
`
`EX-1001 (’943 patent), Claims 1, 5, 8, and 12
`
`Limitations 1[e], 5[g], 8[f], and 12[f]
`
`Byrne Renders Obvious The “Processor” Limitations
`
`14
`
`
`
`15
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`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [5]
`
`output to instructions.”
`“Byrne nowhere limits transceiver
`
`EX-1048 (Jensen 2nd Decl.), [3]-[4]
`
`for processing
`sent to the microprocessor 210
`by the transceivers 220, 230 and
`Data(not“instructions”) received
`
`Dr. Jensen
`
`Petitioner’s Reply, 2
`
`Byrne’s Figure 2
`
`1.1. Byrne’s “Microprocessor” Receives and Processes Data Streams
`
`15
`
`
`
`16
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`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1008 (Byrne), 8:16-38
`
`EX-1048 (Jensen 2nd Dec.), [5]
`
`“instructions.”
`processing are data streams, not
`passed to the microprocessor for
`broadcast information) that is
`data(e.g., security codes,
`Control signals that represent
`
`EX-1048 (Jensen 2nd Dec.), [5]
`
`data streams, not “instructions.”
`strength” and received “data” are
`microprocessor to detect “signal
`Signals that enable Byrne’s
`
`Dr. Jensen
`
`Byrne
`
`1.1. Cordless Processing By Byrne’s “Microprocessor”
`
`16
`
`
`
`17
`
`EX-1076 (US6144848), 18:10-12
`
`EX-1075 (US4352952), 6:21-22
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1008 (Byrne), 8:16-38
`
`Corroborating Evidence
`
`EX-1048 (Jensen 2nd Dec.), [6]
`
`decryption.
`datato perform data encryption and
`microprocessor needs to access
`It was known that the
`
`EX-1048 (Jensen 2nd Dec.), [6]
`
`processes the cellular data.
`understood that the microprocessor
`encryption, a POSITA would have
`For cellular signaling and data
`
`Dr. Jensen
`
`Byrne
`
`1.1. Cellular Processing By Byrne’s “Microprocessor”
`
`17
`
`
`
`18
`
`EX-1049 (Cooklev Dep. Tr.), 28:10-15
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`performed by a transmitter or a receiver.
`Dr. Cooklev agrees that encryption is not limited to being
`
`Petitioner’s Reply, 2
`
`Dr. Cooklev
`
`EX-1048 (Jensen 2nd Dec.), [8]
`
`210 and the respective transceivers 220 and 230.”
`data processing, particularly between the microprocessor
`processors or other components for encryption or other
`“Based on my review, Byrne does not provide additional
`
`processing.”
`switch 260) that are responsible for any type of data
`transceivers 220/230, audio channels 240/250, audio
`“Byrne does not call out any other components (e.g.,
`
`EX-1048 (Jensen 2nd Dec.), [8]
`
`Dr. Jensen
`
`Byrne’s Figure 2
`
`1.1. Byrne’s “Microprocessor” Receives and Processes Data Streams
`
`18
`
`
`
`19
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`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [9]
`
`in Byrne’s Figure 2.”
`data to the “LCD” display 205, as clearly illustrated
`processes the received data streams and supplies
`220, 230 to the microprocessor 210, which then
`are transmitted from the respective transceivers
`found obvious that the data for updating the display
`“Therefore, a POSITA would have understood and
`
`Petitioner’s Reply, 2
`
`Dr. Jensen
`
`EX-1049 (Cooklev Dep. Tr.), 32:8-9
`
`Dr. Cooklev
`
`EX-1008 (Byrne), 8:54-56
`
`Byrne
`
`Byrne’s Figure 2
`
`1.1. Byrne’s “Microprocessor” Receives and Processes Data Streams
`
`19
`
`
`
`20
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Petitioner’s Reply, 2
`
`EX-1008 (Byrne), 7:39-41, 7:48-49
`
`“conventional” transceivers
`
`Byrne
`
`Byrne’s Figure 2
`
`1.1. Byrne’s “Microprocessor” Receives and Processes Data Streams
`
`20
`
`
`
`21
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1049 (Cooklev Dep. Tr.), 43:16-44:1
`
`Dr. Cooklev
`
`Dr. Jensen
`
`1.1. Byrne’s “Microprocessor” Receives and Processes Data Streams
`
`21
`
`
`
`22
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1049 (Cooklev Dep. Tr.), 46:1-47:4
`
`EX-1048 (Jensen 2nd Dec.), [10]
`
`Dr. Cooklev
`
`Dr. Jensen
`
`1.1. Byrne’s “Microprocessor” Receives and Processes Data Streams
`
`22
`
`
`
`23
`
`EX-1050, 1
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [11]-[16]
`
`EX-1048 (Jensen 2nd Dec.), [11]-[19] (citing EX-1050, EX-1051)
`
`microprocessor as the component for cordless/cellular data stream processing.
`Representative chipsets for cellular and cordless communications around 1999 support Byrne’s
`
`Dr. Jensen
`
`1.1. Byrne’s “Microprocessor” Receives and Processes Data Streams
`
`23
`
`
`
`24
`
`EX-1051, 1
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [17]
`
`Dr. Jensen
`
`EX-1048 (Jensen 2nd Dec.), [11]-[19] (citing EX-1050, EX-1051)
`
`microprocessor as the component for cordless/cellular data stream processing.
`Representative chipsets for cellular and cordless communications around 1999 support Byrne’s
`
`1.1. Byrne’s “Microprocessor” Receives and Processes Data Streams
`
`24
`
`
`
`25
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Parallel”
`Processes Data Streams “In
`1-2. Byrne’s “Microprocessor”
`
`Streams
`Receives and Processes Data
`1-1. Byrne’s “Microprocessor”
`
`EX-1001 (’943 patent), Claims 1, 5, 8, and 12
`
`Limitations 1[e], 5[g], 8[f], and 12[f]
`
`Byrne Renders Obvious The “Processor” Limitations
`
`25
`
`
`
`26
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1008 (Byrne), 7:56-8:15
`
`EX-1048 (Jensen 2nd Dec.), [22]
`
`cellular/cordless systems.
`simultaneous/parallel operation of
`Byrne expressly discusses
`
`EX-1048 (Jensen 2nd Dec.), [22]
`
`three modes.
`cordless telephone” as one of
`Byrne identifies a “cellular
`
`Dr. Jensen
`
`Byrne
`
`1.2. Byrne’s “Microprocessor” Processes Data Streams “In Parallel”
`
`26
`
`
`
`27
`
`EX-1048 (Jensen 2nd Dec.), [23]
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1008 (Byrne), 4:46-56
`
`Dr. Jensen
`
`Byrne
`
`1.2. Byrne’s “Microprocessor” Processes Data Streams “In Parallel”
`
`27
`
`
`
`28
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [25]
`
`EX-1008 (Byrne), 4:9-21
`
`Dr. Jensen
`
`Byrne
`
`EX-1048 (Jensen 2nd Dec.), [25]
`cordless data streams in parallel.
`Petitioner’s Reply, 9-10;
`Byrne’s handoversupports that the microprocessor processes cellular and
`
`1.2. Byrne’s “Microprocessor” Processes Data Streams “In Parallel”
`
`28
`
`
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`29
`
`EX-1048 (Jensen 2nd Dec.), [25]
`
`EX-1008 (Byrne), 4:9-21
`
`Dr. Jensen
`
`EX-1069 (GB2282730A), 4:9-21
`
`British App. 9320814.8
`
`Byrne
`
`EX-1048 (Jensen 2nd Dec.), [25]
`cordless data streams in parallel.
`Petitioner’s Reply, 9-10;
`Byrne’s handoversupports that the microprocessor processes cellular and
`
`1.2. Byrne’s “Microprocessor” Processes Data Streams “In Parallel”
`
`29
`
`
`
`30
`
`EX-1008 (Byrne), 8:2-28
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`to control operations
`Operations are not limited
`
`Byrne
`
`POR, 20-22
`
`“not actual open connections”
`refers only to controloperations and
`“cellular and cordless operations”
`Byrne’s discussion of simultaneous
`
`Patent Owner
`
`1.2. Byrne’s “Microprocessor” Processes Data Streams “In Parallel”
`
`30
`
`
`
`31
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [26]
`
`EX-1008 (Byrne), 8:23-28
`
`Byrne
`
`Dr. Jensen
`
`1.2. Byrne’s “Microprocessor” Processes Data Streams “In Parallel”
`
`31
`
`
`
`32
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1008 (Byrne), 10:37-39
`
`3:26-31, 6:35-7:16
`EX-1052 (US4989230, Gillig), 1:62-66,
`
`US 4989230 (Gillig)
`
`EX-1048 (Jensen 2nd Dec.), [24]
`Petitioner’s Reply, 9;
`
`streams in parallel
`an example of processing two data
`Well-known “three-way linking” as
`
`EX-1008 (Byrne), 2:58-3:11
`
`EX-1008 (Byrne), 2:42-46
`
`EX-1008 (Byrne), 1:27-29
`
`Byrne
`
`1.2. Byrne’s “Microprocessor” Processes Data Streams “In Parallel”
`
`32
`
`
`
`33
`
`33
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`The Byrne-WO748 Combination Renders Obvious
`
`Claims 3-4 (Ground 1B)
`
`Issue 2
`
`33
`
`
`
`34
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1001 (’943 patent), Claim 3
`
`’943 Patent
`
`Byrne-WO748 Renders Obvious a “Virtual Network” (Claims 3-4)
`
`34
`
`
`
`35
`
`EX-1048 (Jensen 2nd Dec.), [29]
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [29]
`
`instructions or details.”
`WO748 for known benefits, and the implementation “does not require explicit
`“VPNs were well-known and could be conveniently implemented” in a network like
`
`Dr. Jensen
`
`Byrne-WO748 Renders Obvious a “Virtual Network” (Claims 3-4)
`
`35
`
`
`
`36
`
`EX-1068 (Paulsen), 1:8-43
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`(cited in EX-1003 (Jensen Orig. Dec.), [120])
`EX-1028 (“Virtual Private Networking –The Flexible Approach”), 2
`
`Corroborating Evidence
`
`EX-1048 (Jensen 2nd Dec.), [28]
`
`Paulsen
`
`Dr. Jensen
`
`Byrne-WO748 Renders Obvious a “Virtual Network” (Claims 3-4)
`
`36
`
`
`
`37
`
`EX-1048 (Jensen 2nd Dec.), [28]
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1068 (Paulsen), Figure 2
`
`WO748’s network
`Paulsen’s VPN applied to
`
`EX-1068 (Paulsen), 4:64-5:8
`
`Byrne-WO748 Renders Obvious a “Virtual Network” (Claims 3-4)
`
`Dr. Jensen
`
`37
`
`
`
`38
`
`38
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Reasonable Expectation of Success For The Byrne-
`
`WO748 Combination (Ground 1B)
`
`Issue 3
`
`38
`
`
`
`39
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [32]
`
`for US 8824434), 30:10-15
`EX-2006 (Jensen Dep. Tr. in IPR2022-00766
`
`Dr. Jensen
`
`Dr. Jensen
`
`microcells.”
`telephone to communicate in WO748’s
`Byrne telephone or to modify Byrne’s
`communication system to be used with the
`wired and wireless infrastructure
`“Dr. Jensen’s POSITA could not design a
`Patent Owner
`
`POR, 26
`
`Combination (Ground 1B)
`A Reasonable Expectation of Success Exists For The Byrne-WO748
`
`39
`
`
`
`40
`EX-1007 (WO748), Figure 1
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [33]
`
`EX-1008 (Byrne), Figure 1
`
`Dr. Jensen
`
`reasonable expectation of success for the combination.
`Similarity between Byrne and WO748 confirms a
`
`Combination (Ground 1B)
`A Reasonable Expectation of Success Exists For The Byrne-WO748
`
`40
`
`
`
`41
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [34]
`
`Dr. Jensen
`
`the Byrne-WO748 combination.
`This confirms a POSITA would have sufficient knowledge and skill to implement
`“virtual network,” etc.) and, instead, relies on the state of art for its disclosure.
`The ’943 patent provides limited disclosure of components (“network switch box,”
`
`Combination (Ground 1B)
`A Reasonable Expectation of Success Exists For The Byrne-WO748
`
`41
`
`
`
`42
`
`42
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Reasonable Expectation of Success For The Byrne-
`
`Johnston-Pillekamp Combination (Ground 1C)
`
`Issue 4
`
`42
`
`
`
`43
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Pillekamp’s Antenna Diversity
`
`Johnston’s Antenna Diversity
`
`12[e]
`
`12[d]
`
`Claim 12
`
`Johnston-Pillekamp Combination (Ground 1C)
`A Reasonable Expectation of Success Exists For The Byrne-
`
`43
`
`
`
`44
`
`EX-1048 (Jensen 2nd Dec.), [36]
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Dr. Jensen
`
`Johnston-Pillekamp Combination (Ground 1C)
`A Reasonable Expectation of Success Exists For The Byrne-
`
`44
`
`
`
`45
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [37]
`
`Dr. Jensen
`
`Johnston-Pillekamp Combination (Ground 1C)
`A Reasonable Expectation of Success Exists For The Byrne-
`
`45
`
`
`
`46
`
`46
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`The “Processor” Limitations (1[e], 5[g], 8[f], and 12[f])
`The Raleigh-Byrne Combination Renders Obvious
`
`Issue 5
`
`46
`
`
`
`47
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Combination
`5.5.A Reasonable Expectation of Success Exists For The Raleigh-Byrne
`
`Combine Raleigh and Byrne
`5.4.Abundant Evidence Shows That A POSITA Would Have Been Motivated To
`
`5.3.Raleigh’s Parallel Set of Signal Sequences Are Data Streams
`
`5.2.Raleigh’s Processor(s) Meet the Claimed Processor
`
`Processor Processes Data Streams In Parallel
`5.1.The Raleigh-Byrne Combination Provides An Additional Way That A
`
`Issue 5: Sub-Issues
`
`47
`
`
`
`48
`
`72:25-73:1
`EX-1049 (Cooklev Dep. Tr.),
`signal sequences.”
`digital time domain
`is a parallel set of
`the TSFP 30, there
`“in the output of
`acknowledged that
`Dr. Cooklev
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [39]
`
`72:18-19
`EX-1049 (Cooklev Dep. Tr.),
`
`the TSFP 30.”
`processed by
`sequence is
`encoder symbol
`that “the
`acknowledged
`Dr. Cooklev
`
`EX-1048 (Jensen 2nd Dec.), [38]-[39]
`
`Dr. Jensen
`
`That A Processor Processes Data Streams In Parallel
`5.1. The Raleigh-Byrne Combination Provides An AdditionalWay
`
`48
`
`
`
`49
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [40]
`
`Raleigh’s Figure 11 (“spatial processing”)
`
`Raleigh’s Figure 9 (“MIMO system”)
`
`EX-1048 (Jensen 2nd Dec.), [40]
`
`Raleigh describes parallel processing (e.g., space-time processing, MIMO).
`
`Dr. Jensen
`
`That A Processor Processes Data Streams In Parallel
`5.1. The Raleigh-Byrne Combination Provides An AdditionalWay
`
`49
`
`
`
`50
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1049 (Cooklev Dep. Tr.), 75:16-18
`
`EX-1078 (US 7746886), Cover
`
`Dr. Cooklev
`
`EX-1078 (US 7746886), 2:55-65
`
`Ex-1078
`
`time processing, MIMO) was well-known.
`EX-1048 (Jensen 2nd Dec.), [40]
`As Dr. Cooklev agreed, parallel processing in Raleigh’s technologies (e.g., space-
`
`Dr. Jensen
`
`That A Processor Processes Data Streams In Parallel
`5.1. The Raleigh-Byrne Combination Provides An AdditionalWay
`
`50
`
`
`
`51
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Combination
`5.5.A Reasonable Expectation of Success Exists For The Raleigh-Byrne
`
`Combine Raleigh and Byrne
`5.4.Abundant Evidence Shows That A POSITA Would Have Been Motivated To
`
`5.3.Raleigh’s Parallel Set of Signal Sequences Are Data Streams
`
`5.2.Raleigh’s Processor(s) Meet the Claimed Processor
`
`Processes Data Streams In Parallel
`5.1.The Raleigh-Byrne Combination Provides An Additional Way That A Processor
`
`Issue 5: Sub-Issues
`
`51
`
`
`
`52
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1001 (’943 patent), Claim 1
`
`processors.” EX-1001, 4:21-23, 4:39-42.
`processor and may contain multiple
`processor 406 is not limited to only one
`The ’943 patent describes that “the
`
`processor.”
`The claims do not recite a “single
`
`Co., 192 F.3d 973, 977 (Fed. Cir. 1999)
`“one or more.” Elkay Mfg. Co. v. Ebco Mfg.
`The term “a” is generally interpreted as
`
`•
`
`•
`
`•
`
`’943 Patent
`
`5.2. Raleigh’s Processor(s) Meet the Claimed Processor
`
`52
`
`
`
`53
`
`EX-1048 (Jensen 2nd Dec.), [44]
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [43]
`
`Dr. Jensen
`
`5.2. Raleigh’s Processor(s) Meet the Claimed Processor
`
`53
`
`
`
`54
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`All cited in EX-1048 (Jensen 2ndDec.), [44]
`
`EX-1055 (US 7,895,587), 3:62-64
`
`EX-1056 (US 7,587,581), 7:12-15
`
`EX-1054 (US 7,584,330), Abstract
`
`for a Multiprocessor Microprocessor”), 1
`EX-1046 (“Evaluation of Design Alternatives
`
`Multiprocessor”), Title
`EX-1045 (“The Case for a Single-Chip
`
`Well-Known Processors with Multiple Processing Elements
`
`5.2. Raleigh’s Processor(s) Meet the Claimed Processor
`
`54
`
`
`
`55
`
`EX-1001 (’943 Patent), Figure 5A
`
`EX-1048 (Jensen 2nd Dec.), [44]
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1001 (’943 Patent), 4:41-44
`
`EX-1001 (’943 Patent), 4:21-24
`
`EX-1048 (Jensen 2nd Dec.), [44]
`
`Dr. Jensen
`
`5.2. Raleigh’s Processor(s) Meet the Claimed Processor
`
`55
`
`
`
`56
`
`EX-1060 (Modern Dictionary of Electronics)
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [45]
`
`Dictionary of IEEE Standards Terms)
`EX-1059 (IEEE 100 The Authoritative
`
`EX-1058 (Newton’s Telecom Dictionary)
`
`EX-1048 (Jensen 2nd Dec.), [45]
`
`EX-1057 (A Dictionary of Computing)
`
`Dr. Jensen
`
`5.2. Raleigh’s Processor(s) Meet the Claimed Processor
`
`56
`
`
`
`57
`
`EX-1062, 2
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [45]
`
`EX-1061, 6
`
`Dr. Jensen
`
`5.2. Raleigh’s Processor(s) Meet the Claimed Processor
`
`57
`
`
`
`58
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Combination
`5.5.A Reasonable Expectation of Success Exists For The Raleigh-Byrne
`
`Combine Raleigh and Byrne
`5.4.Abundant Evidence Shows That A POSITA Would Have Been Motivated To
`
`5.3.Raleigh’s Parallel Set of Signal Sequences Are Data Streams
`
`5.2.Raleigh’s Processor(s) Meet the Claimed Processor
`
`Processes Data Streams In Parallel
`5.1.The Raleigh-Byrne Combination Provides An Additional Way That A Processor
`
`Issue 5: Sub-Issues
`
`58
`
`
`
`59
`
`EX-1001 (’943 patent), 4:52-59
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [49]
`
`EX-1001 (’943 patent), 4:24-38
`
`Dr. Jensen
`
`’943 Patent
`
`cellular and cordless).
`types of wireless communication (e.g.,
`The “data streams” require two different
`
`POR, 38-39
`
`Patent Owner
`
`5.3. Raleigh’s Parallel Set of Signal Sequences Are “Data Streams”
`
`59
`
`
`
`60
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1049 (Cooklev Dep. Tr.), 65:8-67:17
`
`Dr. Cooklev
`
`EX-1048 (Jensen 2nd Dec.), [49]
`
`Dr. Jensen
`
`5.3. Raleigh’s Parallel Set of Signal Sequences Are “Data Streams”
`
`60
`
`
`
`61
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Combination
`5.5.A Reasonable Expectation of Success Exists For The Raleigh-Byrne
`
`Combine Raleigh and Byrne
`5.4.Abundant Evidence Shows That A POSITA Would Have Been Motivated To
`
`5.3.Raleigh’s Parallel Set of Signal Sequences Are Data Streams
`
`5.2.Raleigh’s Processor(s) Meet the Claimed Processor
`
`Processes Data Streams In Parallel
`5.1.The Raleigh-Byrne Combination Provides An Additional Way That A Processor
`
`Issue 5: Sub-Issues
`
`61
`
`
`
`62
`
`POR, 52
`
`POR, 48
`
`POR, 41
`
`POR, 40
`
`POR, 39
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Patent Owner
`
`EX-1048 (Jensen 2nd Dec.), [50]-[51]
`Petitioner’s Reply, 22;
`
`•Raleigh is the primary reference in
`
`Owner’s analysis is reversed
`the combination and Patent
`
`Raleigh’s teaching.
`cordless telephone (CCT) based on
`and modifying Byrne’s cellular
`combination as starting with Byrne
`•Patent Owner treats the proposed
`
`Petitioner
`
`Motivated To Combine Raleigh and Byrne
`5.4. Abundant Evidence Shows That A POSITA Would Have Been
`
`62
`
`
`
`63
`
`EX-1005 (Raleigh), Figure 4
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Raleigh
`
`EX-1008 (Byrne), 7:11-13
`
`Byrne
`
`Petition, 43-48
`EX-1048 (Jensen 2nd Dec.), [52]-[53];
`
`the “wireless communication devices.”
`device or building unit, which fall within
`types and sizes, such as a vehicle
`device but to cover devices of various
`combination is not limited to a handheld
`The proposed Raleigh-Byrne
`
`products with limited form factor.
`“handheld device” or other consumer
`“wireless communication device,” not
`The Challenged Claims are directed to
`
`Preambles of Challenged Claims
`
`Motivated To Combine Raleigh and Byrne
`5.4. Abundant Evidence Shows That A POSITA Would Have Been
`
`63
`
`
`
`64
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1049 (Cooklev Dep. Tr.), 83:15-23
`
`EX-1048 (Jensen 2nd Dec.), [52]
`
`EX-1049 (Cooklev Dep. Tr.), 84:2-15
`
`Dr. Jensen
`
`Motivated To Combine Raleigh and Byrne
`5.4. Abundant Evidence Shows That A POSITA Would Have Been
`
`Dr. Cooklev
`
`64
`
`
`
`65
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`for obviousness is not … bodily incorporate[ion].” Id.
`Prior art references need not be “physically combinable,” as the “test
`
`modification nonobvious. Id.
`“[S]imultaneous advantages and disadvantages” would not make the
`
`(Fed. Cir. 2016).
`Dismantling Co. v. Genesis Attachments, LLC, 825 F.3d 1373, 1381
`references to arrive at the claimed solution. Allied Erecting &
`the art would have been motivated to combine the “teachings” of the
`The test for obviousness is whether a person having ordinary skill in
`
`Motivated To Combine Raleigh and Byrne
`5.4. Abundant Evidence Shows That A POSITA Would Have Been
`
`65
`
`
`
`66
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [55]
`
`825 F.3d, at 1381
`Allied Erecting & Dismantling,
`
`Dr. Jensen
`
`Motivated To Combine Raleigh and Byrne
`5.4. Abundant Evidence Shows That A POSITA Would Have Been
`
`66
`
`
`
`67
`
`EX-2008 (“Technology Trend”), 22
`
`EX-1064 (Braitberg), 1:16-27
`
`EX-1063 (Gernert), 1:34-37
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [57]
`
`…
`
`Corroborating Evidence
`
`Dr. Jensen
`
`Motivated To Combine Raleigh and Byrne
`5.4. Abundant Evidence Shows That A POSITA Would Have Been
`
`67
`
`
`
`68
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [58]-[60]
`
`Dr. Jensen
`
`Motivated To Combine Raleigh and Byrne
`5.4. Abundant Evidence Shows That A POSITA Would Have Been
`
`68
`
`
`
`69
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1067, 8:31-32, Figure 2
`
`EX-1066, Figure 1
`
`EX-1048 (Jensen 2nd Dec.), [61]
`
`Motivated To Combine Raleigh and Byrne
`5.4. Abundant Evidence Shows That A POSITA Would Have Been
`
`Dr. Jensen
`
`69
`
`
`
`70
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1037 (Cooklev Dep. Tr.), 92:9-22
`
`devices.
`can contain “handheld”
`Raleigh’s vehicle unit
`Dr. Cooklev agreed that
`
`features
`“portable” and “mobile”
`already satisfies the
`Raleigh’s vehicle unit
`Dr. Cooklev agreed that
`
`EX-1048 (Jensen 2nd Dec.), [62]
`
`portable device in the vehicle.
`a vehicle can be used to transport portable devices by allowing a person to carry a
`
`a vehicle is “mobile,” which is “more than portable.”
`
`•
`
`•
`
`Raleigh’s vehicular remote unit 170a.
`Dr. Cooklev’s testimony aligns with the well-known understanding of
`
`Motivated To Combine Raleigh and Byrne
`5.4. Abundant Evidence Shows That A POSITA Would Have Been
`
`70
`
`
`
`71
`
`EX-1007, Figure 1
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1007 (WO748), 3
`
`EX-1063, Figure 1
`
`EX-1048 (Jensen 2nd Dec.), [63]
`
`Motivated To Combine Raleigh and Byrne
`5.4. Abundant Evidence Shows That A POSITA Would Have Been
`
`Dr. Jensen
`
`71
`
`
`
`72
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [66]
`
`EX-1048 (Jensen 2nd Dec.), [65]
`
`Dr. Jensen
`
`Motivated To Combine Raleigh and Byrne
`5.4. Abundant Evidence Shows That A POSITA Would Have Been
`
`72
`
`
`
`73
`
`EX-1048 (Jensen 2nd Dec.), [67]
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Dr. Jensen
`
`Motivated To Combine Raleigh and Byrne
`5.4. Abundant Evidence Shows That A POSITA Would Have Been
`
`73
`
`
`
`74
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Combination
`5.5.A Reasonable Expectation of Success Exists For The Raleigh-Byrne
`
`Combine Raleigh and Byrne
`5.4.Abundant Evidence Shows That A POSITA Would Have Been Motivated To
`
`5.3.Raleigh’s Parallel Set of Signal Sequences Are Data Streams
`
`5.2.Raleigh’s Processor(s) Meet the Claimed Processor
`
`Processes Data Streams In Parallel
`5.1.The Raleigh-Byrne Combination Provides An Additional Way That A Processor
`
`Issue 5: Sub-Issues
`
`74
`
`
`
`75
`
`01005 for US 9084291), 80:3-81:24
`EX-1037 (Cooklev Dep. Tr. in IPR2022-
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [68]
`
`Dr. Cooklev
`
`EX-1048 (Jensen 2nd Dec.), [69]
`
`Dr. Jensen
`
`Byrne Combination
`5.5. A Reasonable Expectation of Success Exists For The Raleigh-
`
`75
`
`
`
`76
`
`EX-1048 (Jensen 2nd Dec.), [71]
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [70]
`
`Dr. Jensen
`
`Byrne Combination
`5.5. A Reasonable Expectation of Success Exists For The Raleigh-
`
`76
`
`
`
`77
`
`77
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Claims 6-7 (Ground 2A)
`
`Issue 6
`
`77
`
`
`
`78
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Petitioner’s Reply, 27; Petition, 19-20, 65
`
`wireless devices.”
`the connection of a plurality of
`referenced in Ground 2A—“supervises
`Byrne’s server—the same server
`and the explanation in Ground 1A how
`reference to “claim 6 in Ground 1A”
`Patent Owner ignores the Petition’s
`
`Petitioner
`
`devices.”
`connection of a plurality of wireless
`where the server supervises the
`2A of the Petition “fails to address
`Patent Owner contends that Ground
`
`POR, 56
`
`Patent Owner
`
`EX-1001 (’943 patent), Claim 6
`
`’943 Patent
`
`(Ground 2A)
`The Raleigh-Byrne Combination Renders Obvious Claims 6-7
`
`78
`
`
`
`79
`
`Petition, 19-20
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [73]
`
`Dr. Jensen
`
`Byrne
`
`(Ground 2A)
`The Raleigh-Byrne Combination Renders Obvious Claims 6-7
`
`79
`
`
`
`80
`
`80
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`(Claims 3-4 in Ground 2B)
`
`The Raleigh-Byrne-WO748 Combination
`
`Issue 7
`
`80
`
`
`
`81
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Petitioner’s Reply, 27-28
`
`Raleigh-Byrne combination.
`WO748 combination and the obvious
`success in making the obvious Byrne-
`have had a reasonable expectation of
`reiterated above, a POSITA would
`As discussed in the Petition and
`
`Petitioner
`
`capability of a POSITA.
`because of the alleged lack of
`in combining Raleigh-Byrne-WO748
`no reasonable expectation of success
`Patent Owner contends that there was
`
`POR, 56-58
`
`Patent Owner
`
`Making the Raleigh-Byrne-WO748 Combination.
`A POSITA Would Have Reasonably Expected Success in
`
`4 (Ground 2B)
`The Raleigh-Byrne-WO748 Combination Renders Obvious Claims 3-
`
`81
`
`
`
`82
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`EX-1048 (Jensen 2nd Dec.), [75]
`
`Dr. Jensen
`
`POR, 57-58
`
`techniques (OFDM).
`because of one of Raleigh’s example
`than the Byrne-WO748 combination
`combination would be much harder
`that the Raleigh-Byrne-WO748
`Patent Owner additionally contends
`
`Patent Owner
`
`4 (Ground 2B)
`The Raleigh-Byrne-WO748 Combination Renders Obvious Claims 3-
`
`82
`
`
`
`83
`
`83
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`(Grounds 2C and 2E)
`
`Claims 12, 15, and 18-20
`
`Issue 8
`
`83
`
`
`
`84
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Petitioner’s Reply, 28
`Byrne combination above applies here.
`The same analysis as to the Raleigh-
`
`Petitioner
`
`combination.
`arguments in the Raleigh-Byrne
`Patent Owner simply refers to the
`
`POR, 58
`
`Patent Owner
`
`Claims 12, 15, and 18-20 (Grounds 2C and 2E)
`The Raleigh-Byrne-Pillekamp Combination Renders Obvious
`
`84
`
`
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