Exhibit A-35 - Invalidity of U.S. Patent No. 10,715,235 in view of U.S. Patent No. 6,031,877 (“Saunders”)
`
`Based upon XR Communications’ Complaint, Infringement Contentions, and apparent claim constructions and application of the claims to the
`accused products, as best as they can be deciphered, the reference charted below anticipates or at least renders obvious the asserted claims. These
`invalidity contentions are not an admission that the accused products are covered by or infringe the asserted claims, particularly when these
`claims are properly construed and applied. These invalidity contentions are not an admission that concedes or acquiesces to any claim
`construction implied or suggested by XR Communications’ Complaint or Infringement Contentions. These invalidity contentions are not
`asserting any claim construction positions through these charts, including whether the preamble is a limitation. The portions of the prior art
`reference cited below are not exhaustive but are exemplary in nature.
`
`U.S. Patent No. 6,031,877 to Saunders (“Saunders”), filed February 5, 1998, and published February 29, 2000, qualifies as prior art under at least
`pre-AIA 35 U.S.C. § 102(a), (b), and €. As described in the following claim chart, the asserted claims of the U.S. Patent No. 10,715,235 (the
`“’235 Patent”) are invalid as anticipated by Saunders.
`
`To the extent that Saunders is found not to anticipate one or more of the asserted claims of the ’235 Patent, these claims are invalid as obvious in
`view of Saunders alone, in view of the background knowledge and ordinary creativity of a person having ordinary skill in the art at the time the
`’235 Patent was invented, or in combination with other prior art references disclosed in Defendants’ Invalidity Contentions Cover Pleading and
`accompanying charts, including without limitation as set forth below.
`
`Claim 1
`U.S. Patent No. 10,715,235
`No.
`1pre A receiver for use in a wireless
`communications system, the
`receiver comprising:
`
`U.S. Patent No. 6,031,877
`To the extent the preamble is limiting, Saunders expressly or inherently discloses this claim
`element.
`
`See, e.g.,
`
`“An apparatus and a method for receiving and transmitting information from an array of
`adaptive antenna elements, wherein a predictive filter supplies an estimate of received signal
`samples likely to be received in a burst immediately preceding a transmission. Combination of
`this estimate with received signal samples obtained from actual (historically received) signals,
`received over a predetermined number of frames, yield estimates of optimum beamforming
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 1 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 1 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`coefficients for application to data for transmission from an adaptive array of antenna
`elements. As such, available processing time for obtaining the beamforming coefficients is
`increased.” Saunders, Abstract.
`
`“This invention relates, in general, to communication systems and is particularly applicable to
`communication systems using an adaptive beamforming technique.” Saunders, 1:5-7.
`
`“Apparatus for receiving and transmitting information from an array of adaptive antenna
`elements, the apparatus comprising storage means for storing received information and
`characterised by: a predictive filter for estimating, in response to the received information,
`predicted information likely to be received by the apparatus in at least one future transmission
`to the apparatus; and means for combining the previously received information and the
`predicted information to generate beamforming coefficients for weighting information to be
`transmitted subsequently from the array of adaptive antenna elements, thereby allowing
`beamforming coefficients to be calculated prior to receipt of information to be received by the
`apparatus in at least one future transmission to the apparatus.
`
`An a second aspect of the present invention there is provided a method of receiving and
`transmitting information in an apparatus having an array of adaptive antenna elements, the
`method comprising the step of storing received information and characterised by the steps of:
`estimating, in response to the received information, predicted information likely to be received
`by the apparatus in at least one future transmission to the apparatus; and combining the
`previously received information and the predicted information to generate beamforming
`coefficients for weighting information to be transmitted subsequently from the array of
`adaptive antenna elements, thereby allowing beamforming coefficients to be calculated prior to
`receipt of information to be received by the apparatus in at least one future transmission to the
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 2 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 2 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`
`apparatus.” Saunders, 2:49-3:10.
`
`“The apparatus 40 is a communication device, such as a base station or a mobile unit (as
`appropriate)[.]” Saunders, 5:19-20.
`
`“Furthermore, implementation of the present invention may be at a mobile unit or at a base
`station responsible for control of many mobile units.” Saunders, 6:15-18.
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 3 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 3 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`
`Saunders, Figure 3.
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 4 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 4 of 54
`
`

`

`No.
`1a
`
`U.S. Patent No. 10,715,235
`an antenna, wherein the antenna
`comprises a first antenna element
`and a second antenna element;
`
`U.S. Patent No. 6,031,877
`Saunders expressly or inherently discloses this claim element.
`
`See, e.g.,
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 5 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 5 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`
`Saunders, Figure 3.
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 6 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 6 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`“Turning now to FIG. 3, a functional diagram of a mechanism and apparatus 40 for adaptive
`beamforming (in accordance with a preferred embodiment of the present invention) is
`illustrated. The apparatus 40 is a communication device, such as a base station or a mobile unit
`(as appropriate), that comprises an array of antenna elements 41 for receiving and transmitting
`encoded signals 42. The array of antenna elements 41 is coupled to an array of antenna
`switches 44 arranged to selectively couple an array of receivers 46 or an array of transmitters
`48 to the array of antenna elements 41.” Saunders, 5:16-25.
`
`“1. Apparatus (40) for receiving and transmitting information (42) from an array (41) of
`adaptive antenna elements, the apparatus comprising storage means (49) for storing received
`information (x) and characterised by:
`
`a predictive filter (68) for estimating, in response to the received information, predicted
`information (x) likely to be received by the apparatus in at least one future transmission to the
`apparatus; and
`
`means (70) for combining the previously received information (x) and the predicted
`information (x) to generate beamforming coefficients (wopt) for weighting information (76) to
`be transmitted subsequently from the array (41) of adaptive antenna elements, thereby allowing
`beamforming coefficients to be calculated prior to receipt of information to be received by the
`apparatus (40) in at least one future transmission to the apparatus.” Saunders, cl 1.
`
`“The use of adaptive antennas (AA) in communication systems (particularly frequency
`division multiplexed (FDM) systems, such as the pan-European digital cellular Global System
`for Mobile (GSM) communication and alternate code-division multiple access (CDMA)
`systems) is becoming increasingly attractive because such adaptive antennas offer general
`improvements in system performance, and especially handling (traffic) capacity. As will be
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 7 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 7 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`1b
`
`a transceiver operatively coupled to
`the antenna and configured to
`transmit and receive
`electromagnetic signals using the
`antenna; and
`
`U.S. Patent No. 6,031,877
`appreciated, a high degree of beam accuracy is achieved in an adaptive antenna system by
`accurately varying the phase and amplitude (magnitude) components of a transmitted wave.
`More specifically, phases and magnitudes of a set of transmitted waves, emanating from an
`array of antenna elements of a transceiver, are varied by "weighting" individual elements in the
`array such that an antenna radiation pattern (of a base site, for example) is adapted (optimised)
`to match prevailing signal and interference environments of a related coverage area, such as a
`cell.” Saunders, 1:10-28.
`
`Saunders expressly or inherently discloses this claim element.
`
`See, e.g.,
`
`“The use of adaptive antennas (AA) in communication systems (particularly frequency
`division multiplexed (FDM) systems, such as the pan-European digital cellular Global System
`for Mobile (GSM) communication and alternate code-division multiple access (CDMA)
`systems) is becoming increasingly attractive because such adaptive antennas offer general
`improvements in system performance, and especially handling (traffic) capacity. As will be
`appreciated, a high degree of beam accuracy is achieved in an adaptive antenna system by
`accurately varying the phase and amplitude (magnitude) components of a transmitted wave.
`More specifically, phases and magnitudes of a set of transmitted waves, emanating from an
`array of antenna elements of a transceiver, are varied by "weighting" individual elements in the
`array such that an antenna radiation pattern (of a base site, for example) is adapted (optimised)
`to match prevailing signal and interference environments of a related coverage area, such as a
`cell.” Saunders, 1:10-28.
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 8 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 8 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`
`Saunders, Figure 3.
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 9 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 9 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`“Turning now to FIG. 3, a functional diagram of a mechanism and apparatus 40 for adaptive
`beamforming (in accordance with a preferred embodiment of the present invention) is
`illustrated. The apparatus 40 is a communication device, such as a base station or a mobile unit
`(as appropriate), that comprises an array of antenna elements 41 for receiving and transmitting
`encoded signals 42. The array of antenna elements 41 is coupled to an array of antenna
`switches 44 arranged to selectively couple an array of receivers 46 or an array of transmitters
`48 to the array of antenna elements 41.” Saunders, 5:16-25.
`
`“1. Apparatus (40) for receiving and transmitting information (42) from an array (41) of
`adaptive antenna elements, the apparatus comprising storage means (49) for storing received
`information (x) and characterised by:
`
`a predictive filter (68) for estimating, in response to the received information, predicted
`information (x) likely to be received by the apparatus in at least one future transmission to the
`apparatus; and
`
`means (70) for combining the previously received information (x) and the predicted
`information (x) to generate beamforming coefficients (wopt) for weighting information (76) to
`be transmitted subsequently from the array (41) of adaptive antenna elements, thereby allowing
`beamforming coefficients to be calculated prior to receipt of information to be received by the
`apparatus (40) in at least one future transmission to the apparatus.” Saunders, cl 1.
`
`1c
`
`a processor operatively coupled to
`the transceiver, the processor
`configured to:
`
`Saunders expressly or inherently discloses this claim element.
`
`See, e.g.,
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 10 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 10 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`“The mechanism of the present invention therefore allows beamforming coefficients to be
`calculated in advance of the receipt of a burst (because previously received signals influence
`subsequent beamforming coefficients), such as before time-slot t3 in the case of the base
`station of FIG. 1. Consequently, additional time-slots are made available for processing
`between reception and transmission of data, thereby providing increased buffering 30. This
`increased buffering is shown in FIG. 2 in which a relative timing advantage obtained through
`the implementation of the present invention can be seen relative to a corresponding processing
`time for the duplex communication channel of FIG. 1. It will be understood that the increased
`buffering 30 may be an entire frame or greater, but it is at least the additional period provided
`between the last actual received burst and the burst estimated by the linear predictive filter
`(which may occur in the same frame).
`
`Although predictive filtering in itself requires processing within a microprocessor (or the like)
`of a communication device, the additional time provided to the communication device allows
`either the use of more sophisticated decoding and beamforming algorithms (the latter of which
`will improve the resolution and accuracy for beamforming within the communication system,
`generally) or the use of a slower (and hence less expensive) processor. However, the additional
`processing required in the communication device may be optimised by an appropriate
`limitation of the number of bursts, B, used during estimation.” Saunders, 4:30-57.
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 11 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 11 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`
`Saunders, Figure 3.
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 12 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 12 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`1d
`
`receive a first signal transmission
`from a remote station via the first
`antenna element and a second
`signal transmission from the remote
`station via the second antenna
`element simultaneously;
`
`U.S. Patent No. 6,031,877
`“As will be appreciated, correlation matrix estimators 52 and 70, weight calculators 56 and 72,
`beamformers 58 and 74 and signal predictor 68 are typically implemented within a
`microprocessor 90, while register 54 can be located internally (as shown) or externally to the
`microprocessor 90.” Saunders, 5:60-64.
`Saunders expressly or inherently discloses this claim element.
`
`See, e.g.,
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 13 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 13 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`
`Saunders, Figure 3.
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 14 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 14 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`“The array of antenna elements 41 [included in apparatus 40] is coupled to an array of antenna
`switches 44 arranged to selectively couple an array of receivers 46 or an array of transmitters
`48 to the array of antenna elements 41.” Saunders, 5:22-25.
`
`“In a receive path, information bearing signals (i.e. x) received by the array of antenna
`elements 41 and processed by the array of receivers 46 are coupled to a buffer 49 through an
`analog-to-digital converter 50. The buffer 49 is arranged to store at least B bursts. Data x
`stored in the buffer 49 is input into a correlation matrix estimator 52 that is also responsive to a
`register 54 containing a stored replica of the training sequence, s. The correlation matrix
`estimator 52 provides values for Rxx and rxd (in accordance with eqn. 2) in response to x and
`s. A weight calculator 56 receives Rxx and rxd to implement eqn. 1 to produce values of wopt
`(i.e. the beamforming coefficients for the receive path) that are applied to respective samples
`from buffer 49 in a beamformer 58. An output from the beamformer 58 is coupled to a
`demodulator 60 that in turn provides a decoded output signal 62 to output device 64, such as a
`speech decoder or a visual display unit (VDU).” Saunders, 5:26-42.
`
`“The apparatus 40 is a communication device, such as a base station or a mobile unit (as
`appropriate)[.]” Saunders, 5:19-20.
`
`“Furthermore, implementation of the present invention may be at a mobile unit or at a base
`station responsible for control of many mobile units.” Saunders, 6:15-18.
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 15 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 15 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`“where B is the number of sample portions (such as bursts) that are taken into consideration
`per estimation (which may, in certain circumstances involve more than one burst per frame), as
`expressed in the article "Signal Acquisition and Tracking with Adaptive Arrays in the Digital
`Mobile Radio System IS-54 with Flat-Fading" by J. H. Winters, published in IEEE
`Transactions on Vehicular Technology in November 1993, 42(4), pages 377-384. As such, an
`estimation of the correlation matrices is based on actual received signals.” Saunders, 2:33-42.
`
`“According to eqn. 2, a received signal vector, x(k), of a frame k can be derived (from a cross-
`correlation of bits of a training sequence, such as a known mid-amble sequence in the specific
`case of GSM) once per burst transmission, while the number of bursts required per estimation,
`B, is adjusted according to an anticipated rate-of-change of Rxx. However, eqn. 2 requires the
`use of x(n) and is therefore subject to the limited available time between reception and
`transmission of information by a communication device, e.g. the base station or the mobile
`unit.
`
`The preferred embodiment of the present invention utilises linear predictive filtering to supply
`an estimate of received signal samples, x(n), likely to be received in the burst immediately
`preceding a transmission, and combines this estimate with received signal samples obtained
`from actual (historically received) signals received over an arbitrary (predetermined) number
`of bursts or frames, e.g. three frames.” Saunders, 3:54-4:4.
`
`“rxd =E[x*s] is a correlation of a received signal vector with a desired signal vector, s, that is
`sent during a defined training sequence of a burst.” Saunders, 2:9-11.
`
`To the extent that this reference does not expressly disclose this claim limitation, in light of
`Plaintiff’s apparent claim construction and infringement positions with respect to the Accused
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 16 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 16 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`Products, a POSITA would have understood it to implicitly disclose it or would have found the
`claim limitation obvious.
`
`Additionally, it would have been obvious to a person of ordinary skill in the art to modify this
`reference with any one or more of the references disclosed in Defendants’ Invalidity
`Contentions based on knowledge of one of ordinary skill in the art and for the reasons
`articulated Defendants’ Invalidity Contentions Cover Pleading.
`
`1e
`
`determine first signal information
`for the first signal transmission;
`
`Saunders expressly or inherently discloses this claim element.
`
`See, e.g.,
`
`“Indeed, upon receipt of a signal, information contained within the signal (typically) must be
`sampled, stored and then demodulated (by synchronisation and equalisation processes).”
`Saunders, 1:43-46.
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 17 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 17 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`
`Saunders, Figure 3.
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 18 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 18 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`“In a receive path, information bearing signals (i.e. x) received by the array of antenna
`elements 41 and processed by the array of receivers 46 are coupled to a buffer 49 through an
`analog-to-digital converter 50. The buffer 49 is arranged to store at least B bursts. Data x
`stored in the buffer 49 is input into a correlation matrix estimator 52 that is also responsive to a
`register 54 containing a stored replica of the training sequence, s. The correlation matrix
`estimator 52 provides values for Rxx and rxd (in accordance with eqn. 2) in response to x and
`s.” Saunders, 5:26-35.
`
`“Rxx is the received signal cross-correlation matrix and equals E[x*xT ].” Saunders, 2:12-13.
`
`“where B is the number of sample portions (such as bursts) that are taken into consideration
`per estimation (which may, in certain circumstances involve more than one burst per frame), as
`expressed in the article "Signal Acquisition and Tracking with Adaptive Arrays in the Digital
`Mobile Radio System IS-54 with Flat-Fading" by J. H. Winters, published in IEEE
`Transactions on Vehicular Technology in November 1993, 42(4), pages 377-384. As such, an
`estimation of the correlation matrices is based on actual received signals.” Saunders, 2:33-42.
`
`“According to eqn. 2, a received signal vector, x(k), of a frame k can be derived (from a cross-
`correlation of bits of a training sequence, such as a known mid-amble sequence in the specific
`case of GSM) once per burst transmission, while the number of bursts required per estimation,
`B, is adjusted according to an anticipated rate-of-change of Rxx. However, eqn. 2 requires the
`use of x(n) and is therefore subject to the limited available time between reception and
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 19 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 19 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`transmission of information by a communication device, e.g. the base station or the mobile
`unit.
`
`The preferred embodiment of the present invention utilises linear predictive filtering to supply
`an estimate of received signal samples, x(n), likely to be received in the burst immediately
`preceding a transmission, and combines this estimate with received signal samples obtained
`from actual (historically received) signals received over an arbitrary (predetermined) number
`of bursts or frames, e.g. three frames.” Saunders, 3:54-4:4.
`
`“Therefore, according to a preferred embodiment of the present invention, an estimation of the
`correlation matrix is provided by
`
`Saunders, 4:22-26.
`
`“As will be appreciated, correlation matrix estimators 52 and 70, weight calculators 56 and 72,
`beamformers 58 and 74 and signal predictor 68 are typically implemented within a
`microprocessor 90, while register 54 can be located internally (as shown) or externally to the
`microprocessor 90.” Saunders, 5:60-64.
`
`“1. Apparatus (40) for receiving and transmitting information (42) from an array (41) of
`adaptive antenna elements, the apparatus comprising storage means (49) for storing received
`information (x) and characterised by:
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 20 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 20 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`a predictive filter (68) for estimating, in response to the received information, predicted
`information (x) likely to be received by the apparatus in at least one future transmission to the
`apparatus; (…)” Saunders, cl 1.
`
`1f
`
`determine second signal
`information for the second signal
`transmission, wherein the second
`signal information is different than
`the first signal information;
`
`Saunders expressly or inherently discloses this claim element.
`
`See, e.g.,
`
`See claim [1e].
`To the extent that this reference does not expressly disclose this claim limitation, in light of
`Plaintiff’s apparent claim construction and infringement positions with respect to the Accused
`Products, a POSITA would have understood it to implicitly disclose it or would have found the
`claim limitation obvious.
`
`Additionally, it would have been obvious to a person of ordinary skill in the art to modify this
`reference with any one or more of the references disclosed in Defendants’ Invalidity
`Contentions based on knowledge of one of ordinary skill in the art and for the reasons
`articulated Defendants’ Invalidity Contentions Cover Pleading.
`
`1g
`
`determine a set of weighting values
`based on the first signal information
`and the second signal information,
`wherein the set of weighting values
`
`Saunders expressly or inherently discloses this claim element.
`
`See, e.g.,
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 21 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 21 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`is configured to be used by the
`transceiver to construct one or more
`beam-formed transmission signals;
`
`U.S. Patent No. 6,031,877
`“Apparatus for receiving and transmitting information from an array of adaptive antenna
`elements, the apparatus comprising (…) means for combining the previously received
`information and the predicted information to generate beamforming coefficients for weighting
`information to be transmitted subsequently from the array of adaptive antenna elements,
`thereby allowing beamforming coefficients to be calculated prior to receipt of information to
`be received by the apparatus in at least one future transmission to the apparatus.
`
`An a second aspect of the present invention there is provided a method of receiving and
`transmitting information in an apparatus having an array of adaptive antenna elements, the
`method comprising the step of (…) combining the previously received information and the
`predicted information to generate beamforming coefficients for weighting information to be
`transmitted subsequently from the array of adaptive antenna elements, thereby allowing
`beamforming coefficients to be calculated prior to receipt of information to be received by the
`apparatus in at least one future transmission to the apparatus.” Saunders, 2:49-3:10.
`
`“1. Apparatus (40) for receiving and transmitting information (42) from an array (41) of
`adaptive antenna elements, the apparatus comprising storage means (49) for storing received
`information (x) and characterised by: (…)
`
`means (70) for combining the previously received information (x) and the predicted
`information (x) to generate beamforming coefficients (wopt) for weighting information (76) to
`be transmitted subsequently from the array (41) of adaptive antenna elements, thereby allowing
`beamforming coefficients to be calculated prior to receipt of information to be received by the
`apparatus (40) in at least one future transmission to the apparatus.” Saunders, cl 1.
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 22 of 54
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`Exhibit 2009
`IPR2022-01155
`Page 22 of 54
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`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`
`Saunders, Figure 3.
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 23 of 54
`
`Exhibit 2009
`IPR2022-01155
`Page 23 of 54
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`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`“In a receive path, information bearing signals (i.e. x) received by the array of antenna
`elements 41 and processed by the array of receivers 46 are coupled to a buffer 49 through an
`analog-to-digital converter 50. The buffer 49 is arranged to store at least B bursts. Data x
`stored in the buffer 49 is input into a correlation matrix estimator 52 that is also responsive to a
`register 54 containing a stored replica of the training sequence, s. The correlation matrix
`estimator 52 provides values for Rxx and rxd (in accordance with eqn. 2) in response to x and
`s. A weight calculator 56 receives Rxx and rxd to implement eqn. 1 to produce values of wopt
`(i.e. the beamforming coefficients for the receive path) that are applied to respective samples
`from buffer 49 in a beamformer 58.” Saunders, 5:26-39.
`
`“In a transmit path, the data stored in the buffer 49, relating to the previous frames, is input
`into a signal predictor 68 arranged to calculate x, according to eqn. 3. The data x stored in the
`buffer 49 is also input into a correlation matrix estimator 70 (further responsive to x and also
`the replica of the training sequence, s, stored in the register 54) which implements one of eqn.
`4 or eqn. 5 to produce Rxx and rxd. A second weight calculator 72 (which may be weight
`calculator 56) receives Rxx and rxd to implement eqn. 1 to produce values of wopt (for the
`transmit path) that are applied, in a beamformer 74 (which may be beamformer 58), to data 76
`from an input device, such as a modem or keyboard. An output from the beamformer 74 is
`coupled to an array of modulators 80 that in turn provide encoded output signals 82 to the array
`of transmitters 48 and, ultimately, to the array of antenna elements 41 through the array of
`antenna switches 44.” Saunders, 5:43-59.
`
`“As will be appreciated, correlation matrix estimators 52 and 70, weight calculators 56 and 72,
`beamformers 58 and 74 and signal predictor 68 are typically implemented within a
`microprocessor 90, while register 54 can be located internally (as shown) or externally to the
`microprocessor 90.” Saunders, 5:60-64.
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 24 of 54
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`Exhibit 2009
`IPR2022-01155
`Page 24 of 54
`
`

`

`No.
`
`U.S. Patent No. 10,715,235
`
`U.S. Patent No. 6,031,877
`“With respect to selection of beamforming coefficients in typical communication systems (and
`as will be understood), an optimum selection (corrected, of course, for differences between the
`up-link and down-link frequencies) is provided by the Wiener solution:
`
`Saunders, 1:53-2:18.
`
`1h
`
`cause the transceiver to transmit a
`third signal to the remote station via
`the antenna, the third signal
`comprising content based on the set
`
`Saunders expressly or inherently discloses this claim element.
`
`See, e.g.,
`
`Invalidity of U.S. Patent No. 10,715,235 in view of Saunders
`
`Page 25 of 54
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`IPR2022-01155
`Page 25 of 54
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`

`

`No.
`
`U.S. Patent No. 10,715,235
`of weighting values.
`
`U.S. Patent No. 6,031,877
`“An output from the beamformer 58 [that produces beamforming coefficients (wopt) for
`weighting information] is coupled to a demodulator 60 that in turn provides a decoded output
`signal 62 to output device 64, such as a speech decoder or a visual display unit (VDU).”
`Saunders, 5:39-42.
`
`“An output from the beamformer 74 [that produces beamforming coefficients (wopt) for
`weighting information] is coupled to an array of modulators 80 that in turn provide encoded
`output signals 82 to the array of transmitters 48 and, ultimately, to the array of antenna
`elements 41 through the array of antenna switches 44.” Saunders, 5:55-59.
`
`Claim 2
`No.
`2
`
`U.S. Patent No. 10,715,235
`The receiver as recited in claim 1,
`wherein the first signal transmission
`and the second signal transmission
`comprise electromagnetic signals
`comprising one or more
`transmission peaks and one or more
`transmission nulls.
`
`U.S. Patent No. 6,031,877
`Saunders expressly or inherently discloses this claim element.
`
`See, e.g.,
`
`“The use of adaptive antennas (AA) in communication systems (particularly frequency
`division multiplexed (FDM) systems, such as the pan-European digital cellular Global System
`for Mobile (GSM) communication and alternate code-division multiple access (CDMA)
`systems) is becoming increasingly attractive because such adaptive antennas offer general
`improvements in system performance, and especially handling (traffic) capacity. As will be
`appreciated, a high degree of beam accuracy is achieved in an adaptive antenna system by
`accurately varying the phase and amplitude (magnitude) components of a transmitted wave.
`More specifically, phases and magnitudes of a set o