UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`LG ELECTRONICS, INC.,
`Petitioner,
`
`v.
`
`CONSTELLATION DESIGNS, LLC,
`Patent Owner.
`
`Case No. IPR2023-00319
`U.S. Patent No. 10,693,700
`
`DECLARATION OF GIUSEPPE CAIRE REGARDING PATENT
`OWNER’S PRELIMINARY RESPONSE FOR INTER PARTES REVIEW OF
`U.S. PATENT NO. 10,693,700
`
`Constellation Exhibit 2001
`LG Electronics, Inc. v. Constellation Designs, LLC
`IPR2023-00319
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`LG ELECTRONICS, INC.,
`Petitioner,
`
`v.
`
`CONSTELLATION DESIGNS, LLC,
`Patent Owner.
`
`Case No. IPR2023-00319
`U.S. Patent No. 10,693,700
`
`DECLARATION OF GIUSEPPE CAIRE REGARDING PATENT
`OWNER’S PRELIMINARY RESPONSE FOR INTER PARTES REVIEW OF
`U.S. PATENT NO. 10,693,700
`
`Constellation Exhibit 2001
`LG Electronics, Inc. v. Constellation Designs, LLC
`IPR2023-00319
`
`
`
`Case No. IPR2023-00319
`Patent No. 10,693,700
`
`TABLE OF CONTENTS
`
`Introduction ...................................................................................................... 3
`I.
`Qualifications ................................................................................................... 3
`II.
`III. Materials Considered ....................................................................................... 5
`IV. Using “Constellations” In Digital Communications ....................................... 6
`A.
`Overview of a Digital Communication System .................................... 7
`1.
`The Transmitter ........................................................................... 8
`2.
`The Receiver ............................................................................. 10
`Constellation Mapping and Demapping .............................................. 11
`1.
`Constellation Point Locations and Labels ................................ 11
`2.
`The Mapper ............................................................................... 13
`3.
`The Demapper ........................................................................... 14
`Prior Art Approaches ..................................................................................... 17
`A.
`Channel Capacity Measures ................................................................ 18
`B.
`The Shannon Channel Capacity Limit ................................................ 21
`C.
`Prior Art Approaches Failed To Achieve the Shannon Limit ............. 22
`1.
`Constellation Point Locations That Are Equally Spaced ......... 23
`The Challenged ’700 Patented Inventions ..................................................... 24
`A.
`The Patent’s Improved Approach to Implementing Non-
`Uniform Constellations ....................................................................... 24
`1.
`Optimizing Constellation Locations and Labels ....................... 24
`
`V.
`
`VI.
`
`B.
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`1
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`Constellation Exhibit 2001
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`2.
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`Case No. IPR2023-00319
`Patent No. 10,693,700
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`4.
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`3.
`
`The ʼ700 Patent Describes Optimizing Single-Dimension
`and Multi-Dimension Constellations ........................................ 25
`Non-Uniform Constellations Optimized For Particular
`Code Rates ................................................................................ 28
`Using Multiple Optimized Constellations For a System
`Having Multiple Code Rate and SNR Operating Points .......... 33
`The Challenged Claims ....................................................................... 34
`B.
`VII. The Petition .................................................................................................... 36
`VIII. The Challenged Claims Are Entitled to Priority of at Least the ʼ777
`Patent Because the ʼ777 Patent Has Sufficient Written Description to
`Show the Inventors Possessed The Claimed Invention At the Time of
`the ʼ777 Patent Application’s Filing .............................................................. 37
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`2
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`Case No. IPR2023-00319
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`I, Dr. Giuseppe Caire, hereby declare as follows:
`
`I.
`
`Introduction
`1.
`My name is Giuseppe Caire. I have been retained in the above-
`
`referenced inter partes review proceeding by Constellation Designs, LLC, to
`
`evaluate United States Patent No. 10693,700 (the “’700 patent”) against certain
`
`references that are presented by the Petitioner. As detailed in this report, it is my
`
`opinion that the Petition does not establish that of the challenged claims are
`
`anticipated or rendered obvious by the references presented by the Petitioner. If
`
`requested by the Patent Trial and Appeal Board, I am prepared to testify at trial
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`about my opinions expressed herein.
`
`II. Qualifications
`2.
`I have over thirty years of experience in the field of electrical
`
`engineering. For the past nine years I have held a Full Professorship and faculty
`
`position as the Chair of Communications and Information Theory at Technische
`
`Universität Berlin. In my work and research, I have researched and written about
`
`Information Theory, Communication Theory and Coding Theory, Wireless
`
`Communication Systems, Signal Processing and Statistics.
`
`3.
`
`Prior to my appointment at the Technische Universität, Berlin I was a
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`tenured Full Professor at the University of Southern California, Los Angeles from
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`3
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`2005-2016. Although I am currently at the Technische Universität Berlin, I have
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`retained the title of Adjunct Research Professor at the University of Southern
`
`California, Los Angeles since 2016. Prior to my tenure at the University of Southern
`
`California, Los Angeles, I spent seven years as a Professor at Eurecom Institute, and
`
`held various Assistant Professorships from 1995-1998.
`
`4.
`
`I studied Electrical Engineering and received my Ph.D. in 1994 from
`
`the Politecnico di Torino, my Master’s Degree in 1992 from Princeton University,
`
`and my Bachelor of Science Degree in 1990 from the Politecnico di Torino. In
`
`addition to my studies at undergraduate and graduate levels and academic
`
`qualifications, I have held industrial research positions such as my current role as
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`the Director of the Huawei-TU Berlin Joint Innovation Center, which has a focus on
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`fundamental research in wireless technology.
`
`5.
`
`I have authored or co-authored over four hundred publications in the
`
`areas of computer networks, and telecommunications. My publication and patents
`
`are listed on my curriculum vitae, which is attached hereto as EX2012.
`
`6.
`
`In 2021, I was awarded the Leibniz Price, which is awarded to
`
`“exceptional scientists and academics for their outstanding achievements in the field
`
`of research” and known as the most important research award in Germany. In 2022,
`
`I was elected a Member of the Berline Brandenburg Akademie der Wissenschaften
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`(BBAW). Further, I served as President of the Institute of Electrical and Electronics
`
`Engineers (IEEE) Information Theory Society in 2011.
`
`7.
`
`As a result of my background in information and communication
`
`theory, I have extensive knowledge regarding the state of the technical art in this
`
`area at the time of filing of the ‘700 patent.
`
`8.
`
`One of my papers was cited and relied upon by Petitioner. Specifically,
`
`I am co-author of EX1018 an article titled “Bit-Interleaved Coded Modulation”
`
`which was published in IEEE Transactions on Information Theory, Vol. 44, No. 3,
`
`May 1998 at pp. 927-946. This paper has been cited in other publications over thirty
`
`two hundred (3200) times (Google Scholar).
`
`III. Materials Considered
`9.
`In preparing this declaration, I have reviewed the specification and
`
`claims of U.S. Patent No. 10,693,700 (“’700 Patent” (EX1001)) and the file history
`
`of the ‘700 patent (EX1002). I understand the ‘700 patent was issued on June 23,
`
`2020 from U.S. Patent Application No. 16/726,037, which forms part of a chain of
`
`continuations including application Ser. No. 12/156,989 filed Jun. 5, 2008 and
`
`issued on Jul. 12, 2011 as U.S. Pat. No. 7,978,777, which claimed priority to U.S.
`
`Provisional Application 60/933,319 filed Jun. 5, 2007. (EX1010).
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`10.
`
`I have also reviewed the Petition and all publications and exhibits cited
`
`in the Petition.
`
`11.
`
`I have also reviewed relevant parts of the publications and exhibits cited
`
`in this declaration, including the following publications:
`
` U. Madhow, Fundamentals of Digital Communiation, Cambridge University
`
`Press 2008 (“Madhow” (EX2003)); and
`
` R.G. Gallager, Principles of Digital Communication, Cambridge University
`
`Press 2008 (“Gallager” (EX2004)).
`
`IV. Using “Constellations” In Digital Communications
`12.
`The challenged patent concerns an improved method and system for
`
`using “constellations” in a digital communication system. A digital communication
`
`system is used to transmit digital bits (sequences of 0s and 1s) from one device (a
`
`transmitter) to another (a receiver). As explained below in more detail, a
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`“constellation” point is a carrier signal value (such as amplitude and/or phase) that
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`can be used to represent a longer sequence of bits. Transmitting information using
`
`an appropriate constellation point signal value can make a data communication
`
`system faster and more efficient.
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`Overview of a Digital Communication System
`A.
`13. A digital communication system typically includes a transmitter that
`
`sends information to a receiver over a wireless or wired channel. (EX2003 at 2-4;
`
`EX2004 at 1-5, 95, 181-183, 208-209).
`
`14. As illustrated in the above overview, information in the form of user
`
`bits (sequences of 0s and 1s) is input to the transmitter, which first converts those
`
`bits into an electromagnetic signal and then transmits that electromagnetic signal
`
`over the channel to the receiver. (EX2003 at 2-4; EX2004 at 1-5, 95, 181-183, 208-
`
`209). As the electromagnetic signal passes through the channel, bits and data can be
`
`lost or corrupted; in this manner, the channel introduces “noise” (signal loss) to the
`
`transmission. (EX2003 at 2-4; EX2004 at 1-5, 95, 181-183, 208-209). The receiver
`
`receives the electromagnetic signal (along with any noise introduced by its passage
`
`through the channel) and converts the received signal back into bits. (EX2003 at 2-
`
`4; EX2004 at 1-5, 95, 181-183, 208-209).
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`15.
`
`Each digital communication system has a measurable “capacity,”
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`which is the maximum amount of information that the system can reliably send over
`
`the channel. (EX2003 at 252; EX2004 at 253-254, 311-312).
`
`The Transmitter
`1.
`In a digital communication system, the transmitter typically includes
`
`16.
`
`three main components: a coder, a mapper, and a modulator. (EX2003 at 2-4;
`
`EX2004 at 1-5, 95, 181-183, 208-209).
`
`17.
`
`The coder is used to transform the input user bits into a longer sequence
`
`of output bits according to error-correcting codes to enable later error correction by
`
`the receiver. (EX2003 at 2-3; EX2004 at 11, 298). For example, the coder may add
`
`additional redundant bits to the input user bits that would later enable to the
`
`receiver’s decoder to use error-correcting codes (such as turbo codes or Low
`
`Density Parity Check (LDPC) codes) to help detect or recover user bits lost to noise
`
`during transmission. (EX2003 at 2-3; EX2004 at 11, 298).
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`18.
`
`The amount of expansion in the number of bits from the input user bits
`
`to the longer sequence of output bits is referred to as the code rate. The code rate is
`
`a ratio of the relative length of the input user bits to the length of the output bits.
`
`For example, a code rate of 1/2 indicates that for every bit in the sequence of input
`
`user bits, there are 2 bits in the sequence of output bits. Similarly, a code rate of 3/5
`
`indicates that for every 3 bits in the sequence of input user bits, there are 5 bits in
`
`the sequence of output bits.
`
`19.
`
`The resulting new bit sequence is input to the mapper, which maps this
`
`new sequence to constellation points, which are one or more carrier signal values
`
`(such as amplitude and/or phase) that can be used to represent a longer sequence of
`
`bits. (EX2003 at 7; EX2004 at 181-209). Such mapping and constellations are a
`
`focal point of the challenged claims and are discussed in more detail in the following
`
`“Constellation Mapping and Demapping” section.
`
`20. Next, the mapper provides these constellation values to the modulator,
`
`which creates a signal to be modulated to reflect the constellation values provide by
`
`the mapper and then be sent through the channel. (EX2003 at 2-3; EX2004 at 181-
`
`209). There are numerous different ways for a modulator to apply such information
`
`to a carrier signal. (EX2003 at 2-3; EX2004 at 181-209). For example, in a Pulse
`
`Amplitude Modulation (PAM), the modulator can modify (modulate) the amplitude
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`of the carrier signal so that the signal’s different amplitudes will represent different
`
`bit sequences. (EX2003 at 45; EX2004 at 184-196).
`
`The Receiver
`2.
`In a digital communication system, the receiver typically mirrors the
`
`21.
`
`transmitter and includes: a de-modulator, a demapper, and a decoder. (EX2003 at
`
`2-4; EX2004 at 1-5, 11, 95, 181-183, 208-209).
`
`22.
`
`The extracted signal values are then input to the demapper, which is
`
`used to help identify which bit sequence corresponds to the extracted constellation
`
`signal values. (EX2003 at 3-4; EX2004 at 181-209). Such demapping is discussed
`
`in more detail in the following “Constellation Mapping and Demapping” section.
`
`23. Next, the decoder uses information from the demapper and the
`
`structure of the error-correcting code to try to identify the appropriate bit sequence
`
`and recover any of the user bits lost or corrupted due to noise during transmission.
`
`(EX2003 at 3-4, EX2004 at 11).
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`B.
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`Constellation Mapping and Demapping
`1.
`Constellation Point Locations and Labels
`24. As discussed above, the transmitter’s coder provides sequences of bits
`
`(comprising the original user bits plus error correcting bits) to the mapper. The
`
`mapper then maps each sequence to constellation points.
`
`25. A constellation point has at least two characteristics: (1) it is a value
`
`associated with a variable characteristic of the signal transmitted over the channel;
`
`and (2) it represents a unique bit sequence. As explained below, the former is a
`
`constellation point’s “location,” and the latter is its “label.”
`
`26.
`
`Signal characteristics that may be used as constellation point locations
`
`include amplitude, phase, and frequency. (EX2003 at 2-3, 45; EX2004 at 181-209).
`
`The particular signal characteristic (or characteristics) used as constellation point
`
`locations can depend on the type of modulation performed by the modulator.
`
`(EX2003 at 2-3, 45; EX2004 at 181-209). For example, recall that if a modulator
`
`uses pulse amplitude modulation (PAM) to apply information to the carrier signal,
`
`the resulting signal’s different amplitudes are used to represent different bit
`
`sequences. (EX2003 at 45; EX2004 at 184-196). In such a system, the signal’s
`
`different amplitudes may serve as constellation point locations.
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`27.
`
`To illustrate, if the transmitter can send a high frequency signal having
`
`pulses of any amplitude between 0 and 1.0 volts, then any amplitude between 0 and
`
`1.0 volts can be chosen and used as a constellation point. For example, if four
`
`constellation points are needed, each of 0, .33, .66, and 1.0 volts could be used as
`
`an individual constellation point. Where a particular constellation point falls on the
`
`spectrum of available values is called its “location.”.
`
`28.
`
`To continue this simplified illustration, if each sequence of bits to be
`
`communicated from the transmitter to the receiver comprises a series of shorter 2-
`
`bit sequences (00, 01, 10, and 11), then each of those 2-bit sequences can be
`
`assigned to a corresponding constellation point. For example, using the
`
`constellation points identified above, the 01 sequence could be assigned any one of
`
`the 0, .33, .66, and 1.0 volt constellation points. The sequence to which a
`
`constellation point is assigned is its “label.”
`
`29.
`
`To continue this simplified illustration, if each sequence of bits to be
`
`communicated from the transmitter to the receiver comprises a series of shorter 2-
`
`bit sequences (00, 01, 10, and 11), then each of those 2-bit sequences can be
`
`assigned to a corresponding constellation point. For example, using the
`
`constellation points identified above, the 01 sequence could be assigned any one
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`of the 0, .33, .66, and 1.0 volt constellation points. The sequence to which a
`
`constellation point is assigned is its “label.”
`
`30.
`
`To complete this simplified example, the following depicts the
`
`location and labels for four constellation points. The first constellation point is
`
`located at 0.0 volts and is labeled to “00,” the second is located at .33 volts and is
`
`labeled to the “01,” and so on.
`
`Constellation
`Label
`“00”
`“01”
`“10”
`“11”
`
`Constellation
`Location
`0
`.33
`.66
`1.0
`
`The Mapper
`2.
`The transmitter’s mapper uses these constellation labels and locations
`
`31.
`
`to map a bit sequence to a corresponding sequence of constellation points. (EX2003
`
`at 7; EX2004 at 181-209). For example, to send sequence “10000111”, the mapper
`
`would take each 2-bit sequence, and map it to its corresponding constellation point.
`
`Applying the locations and labels from the below table using the PAM example, the
`
`sequence “10000111” would be broken into its composite bit sequences 10, 00, 01,
`
`and 11, which would be mapped to the voltages .66, 0.0, .33, and 1.0 respectively.
`
`Constellation
`Label
`
`Constellation
`Location
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`“00”
`“01”
`“10”
`“11”
`
`0
`.33
`.66
`1.0
`
`32.
`
`The resulting output of the example mapper is the sequence 0.66, 0.0,
`
`0.33. and 1.0 shown in the following figure, in which the y-axis represents voltage
`
`and the x-axis represents time. For reference, the transmitted bit sequence is shown
`
`for each time slot below the figure.
`
`The Demapper
`3.
`33. On the receiver side, the demodulator receives and demodulates the
`
`received signal, which is a noisy version of the transmitted signal, in an attempt to
`
`extract the transmitted constellation point signal values. (EX2003 at 3-4; EX2004
`
`at 181-209). But because noise results from the transmission, the demodulated
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`signal may not be identical to the constellation points output from the mapper (as
`
`shown above) but might include errors. (EX2003 at 3-4; EX2004 at 181-209). An
`
`example output of the demodulator is shown below, in which a time-dependent
`
`continuous waveform is shown in black including noise, the average of the time-
`
`dependent continuous waveform is shown in red, the output of the demodulator is
`
`shown as discrete time values in black, and the figure is again annotated with the
`
`corresponding bit sequence:
`
`34.
`
`This demodulated signal is then sent to the demapper so that the
`
`demapper can convert the demodulated signal values back to bits based on the
`
`constellation points. (EX2003 at 3-4; EX2004 at 181-209). But because of the noise
`
`introduced during transmission, the signal characteristic (e.g., amplitude, phase,
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`frequency) values of received pulses may not exactly match the assigned
`
`constellation point locations. (EX2003 at 3-4; EX2004 at 181-209). Accordingly,
`
`in some implementations, the demapper uses a predetermined set of signal
`
`characteristic (e.g., amplitude, phase, frequency) ranges to attempt to determine the
`
`corresponding bit sequence1. (EX2003 at 127).
`
`35. Continuing the ongoing example, the demapper could use the following
`
`amplitude ranges to map the received signal to a corresponding bit sequence:
`
`Output of
`Demodulator
`(y)
`y <= .25
`.25 < y <= .5
`.5 < y <= .75
`.75 <= y
`
`Bit
`Sequence
`
`“00”
`“01”
`“10”
`“11”
`
`Applying this demapping scheme:
`
` if the output of the demodulator is less than or equal to .25 volts, then
`
`the bit sequence is “00”;
`
`1 For the purpose of illustrating the basic operation of a demapper, the described
`example illustrates a demapper that performs “hard” decisions, that is, outputs
`actual decisions on which bit sequence corresponds to the input signal. In many
`implementations, the demapper performs “soft” decisions, that is, outputs
`probabilities on which bit sequence corresponds to the input signal.
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` if the output of the demodulator is greater than .25 but less than or
`
`equal to .5, then the bit sequence is “01”;
`
` if the output of the demodulator is greater than .25 but less than .75,
`
`then the bit sequence is “10”; and
`
` if the output of the demodulator is greater than .75, then the bit
`
`sequence is “11”.
`
`36. Using this mapping, the example output from the demodulator (shown
`
`in the figure above) would be demapped to “10” for the first pulse, demapped to
`
`“00” for the second pulse, demapped to “01” for the third pulse, and demapped to
`
`“11” for the fourth pulse. Put together, these component bits result in the sequence
`
`“10000111.”2
`
`V.
`
`Prior Art Approaches
`37. Digital communications systems and constellations as described above
`
`were generally known in the art. A primary—and wholly unrealized—goal in
`
`designing such systems was to design systems able to perform very close to the
`
`ultimate limit for reliable transmission of information, which is established by
`
`2 To simplify the illustrative example, it does not include any error correction
`coding.
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`Shannon channel coding theorem and is known as the Shannon channel capacity
`
`limit.
`
`38.
`
`In designing these prior art systems, conventional wisdom dictated that
`
`constellation locations must be equally spaced apart so that that each constellation
`
`point is as far as possible from its neighboring points. But this and all other prior art
`
`approaches fell far short of their “holy grail,” the Shannon limit.
`
`A.
`39.
`
`Channel Capacity Measures
`Each digital communication system has a measurable “capacity,”
`
`which is the maximum amount of information that the system can reliably send over
`
`the channel. (EX2003 at 252; EX2004 at 253-254, 311-312). As detailed in the
`
`challenged ʼ700 Patent, two different ways of measuring capacity are “joint
`
`capacity” and “parallel decode capacity.” (EX1001 at 5:6-8; 6:42-7:30).
`
`40.
`
`In general, letting X denote the channel input signal (sent by the
`
`transmitter) and Y the channel output signal (obtained at the receiver), Shannon
`
`channel coding theorem proves that the capacity C is equal to the maximum of the
`
`mutual information I(X;Y) where the maximization is over all possible statistical
`
`distributions of the input X, subject to physical constraints imposed on the channel
`
`(e.g., average transmit power). As a consequence, in order to determine the channel
`
`capacity it is essential to define what the channel input X and the channel output Y
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`are. In particular, when the channel input is any possible (unquantized) signal
`
`value, subject to the average power constraint, and the channel output Y is the
`
`(unquantized) signal sampled at the receiver, and the channel introduces additive
`
`Gaussian noise, we have the well-known Shannon capacity formula measured in
`
`bit/second given as C = B log(1 + SNR) where B is the channel bandwidth (in Hz)
`
`and SNR is the Signal to Noise Ratio, i.e., the ratio between the signal power and
`
`the noise power at the receiver. When the input X is constrained to be a point of a
`
`discrete constellation (i.e., a finite set of values defined by the corresponding
`
`amplitude and phase of the transmitted signal), and the output Y is defined as
`
`before, as the unquantized signal value at the receiver, the corresponding capacity
`
`is generally less than the above Shannon limit and depends on the constellation X.
`
`41. A non-trivial design problem consists of finding constellations X
`
`approaching the above limit in a certain range of SNR, while maintaining some
`
`simplicity in the actual modulator design. This type of constellation-dependent
`
`capacity is referred to in the literature as ``coded-modulation’’ (CM) capacity, or
`
`also ``joint decoding capacity’’ in some works, since it assumes that the receiver
`
`treats the received signal as a whole, without any form of simplifying (and
`
`suboptimal) preprocessing.
`
`19
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`Constellation Exhibit 2001
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`
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`Case No. IPR2023-00319
`Patent No. 10,693,700
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`42. A simplified and “pragmatic’’ approach to system design was
`
`proposed under the name of “pragmatic coded modulation” in Zehavi, Zehavi, E.,
`
`1992. 8-PSK trellis codes for a Rayleigh channel. IEEE Transactions on
`
`Communications, 40(5), pp.873-884, and popularized by Caire et al. as Bit-
`
`Interleaved Coded Modulation in EX1018 (G. Caire, G. Taricco, and E. Biglieri,
`
`“Bit-interleaved coded modulation,” IEEE Transactions on Information Theory,
`
`vol. 44, no. 3, pp. 927–946, 1998).
`
`43.
`
`This approach considers that, at the transmitter, a sequence of binary
`
`coded information bits (output by a binary encoder) is interleaved (i.e., the order
`
`of the sequence is scrambled according to a specific permutation pattern). The
`
`interleaved sequence is partitioned into small blocks called ``labels’’, and each
`
`label is mapped onto signal constellation points via a mapping referred to as
`
`“binary labeling’’ of the constellation points. At the receiver, a particular
`
`processing referred to as “demapper’’ produces soft values that represent the
`
`“likelihood’’ of each bit in the labels. The sequence of likelihoods is then treated
`
`as the output of a virtual channel. As such, the appropriate capacity metric for
`
`such a method is different, and was found through an explicit formula in Caire et
`
`al. (EX2015). This is known as BICM capacity, or also “parallel decoding
`
`capacity’’ since it is as if the label bits were input to individual bit-wise parallel
`
`20
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`Constellation Exhibit 2001
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`
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`Case No. IPR2023-00319
`Patent No. 10,693,700
`
`channels, and then decoded in parallel at the receiver. Generally speaking, while
`
`the joint decoding capacity is a function of only the constellation X, the parallel
`
`decoding capacity is a function of both X and the binary labeling, i.e., for the same
`
`constellation X the parallel decoding capacity is different for different binary
`
`labelings of the points.
`
`44.
`
`In general, for a given constellation X, the joint decoding capacity is
`
`an upper bound to the parallel decoding capacity for any possible binary labeling.
`
`It should also be said that, more recently, some authors have proposed an iterative
`
`decoder/demapper scheme for which some soft likelihood values are fed back from
`
`the decoder to the demapper, and the demapper is recalculated on the basis of this
`
`feedback information. This reprocessing can be performed multiple times in an
`
`iterative fashion. It has been shown that this iterative processing of BICM (so-
`
`called BICM-ID, that stands for BICM with Iterative Demapping) can significantly
`
`reduce the gap between the BICM (parallel decoding) capacity and the CM (joint
`
`decoding) capacity. This however comes at a non-trivial increase in the
`
`decoder/demapper complexity.
`
`The Shannon Channel Capacity Limit
`B.
`45. Regardless of which measure is used, each communication channel’s
`
`capacity is constrained by the Shannon channel capacity limit, which represents the
`
`21
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`Constellation Exhibit 2001
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`
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`Case No. IPR2023-00319
`Patent No. 10,693,700
`
`theoretically best capacity a channel could possibly achieve in light of physically
`
`unsurmountable limits on error correction methods. (EX2003 at 252-255, 263-264;
`
`EX2004 at 1,184-187, 253). Just as nothing can move faster than the speed of light,
`
`no channel’s capacity can exceed the Shannon capacity limit. (EX2003 at 252-255,
`
`263-264; EX2004 at 1).
`
`46.
`
`Shannon calculated at this capacity limit by determining the maximum
`
`possible efficiency of error correcting methods. (EX2003 at 252-255, 263-264;
`
`EX2004 at 1,184-187, 253). This maximum amount of error correction is then
`
`compared to the levels of noise and data corruption to determine the Shannon limit,
`
`which is the maximum amount of data that can reliably transmitted over a given
`
`communication channel using error correcting methods of the maximum possible
`
`efficiency. (EX2003 at 252-255, 263-264; EX2004 at 1,184-187, 253).
`
`Prior Art Approaches Failed To Achieve the Shannon Limit
`C.
`47. Claude Shannon first published the Shannon channel capacity limit in
`
`1948. (EX2004 at 1). But although Shannon’s limit formed a critical foundation
`
`to information theory, he did not describe any practical method for achieving this
`
`capacity limit. (EX2004 at 1). Thus, for the next 60 years, achieving a channel
`
`capacity near or equaling this limit became the ultimate goal for communication
`
`systems designers. (EX2004 at 1).
`
`22
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`Constellation Exhibit 2001
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`
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`Case No. IPR2023-00319
`Patent No. 10,693,700
`
`Constellation Point Locations That Are Equally Spaced
`1.
`The ʼ700 Patent’s Background explains that the most prevalent (by far)
`
`48.
`
`approach at the time of the invention was to locate constellation points with equal
`
`spacing between points to maximize the distance between neighboring constellation
`
`points. (EX1001 at 1:46-50).
`
`49. As already discussed and illustrated above, noise is introduced when
`
`constellation points are sent from the transmitter to the receiver. (EX2003 at 2-4;
`
`EX2004 at 1-5, 95, 181-183, 208-209).
`
`50.
`
`The prevailing wisdom was that if constellation points were located
`
`close together (for example, if one constellation point at 0.7 volts and another at 0.6),
`
`then there was a greater chance that noise would cause the demapper to mistake one
`
`transmit signal value for another, resulting in the wrong bit sequence being selected
`
`and output. Thus, to minimize the chances of noise resulting in the demapper
`
`erroneously selecting the wrong bits, it was well accepted that constellation points
`
`should be spaced equally apart, to maximize the distance between any two
`
`neighboring locations. (EX1001 at 1:44-52).
`
`51. Accordingly, most viable systems spread constellation locations evenly
`
`over the range of values that the locations could take, putting as much distance
`
`between any two points as the range of values allowed, and resulting in equal spacing
`
`23
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`Constellation Exhibit 2001
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`
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`Case No. IPR2023-00319
`Patent No. 10,693,700
`
`between constellation points. (EX1001 at 1:44-52; 2:6-17;7:61-63). At the time of
`
`the invention, such “equally spaced” locations were well accepted as the best
`
`approach with no drawbacks to be improved upon. (EX1001 at 1:44-52, 2:6-17;
`
`7:61-63).
`
`VI. The Challenged ’700 Patented Inventions
`A.
`The Patent’s Improved Approach to Implementing Non-Uniform
`Constellations
`1.
`Optimizing Constellation Locations and Labels
`The ʼ700 Patent discloses that one way to freely assigning
`
`52.
`
`constellation point locations and labels is to optimize those locations and labels.
`
`(EX1001 at 2:30-34, 2:51-53, 3:7-10, 3:15-17, 3:22-24).
`
`53.
`
`In general, optimization requires choosing an objective function (such
`
`as a system’s capacity) and then repeatedly (iteratively) changing variables (such
`
`as constellation locations and labels) until an optimized solution for the objective
`
`function is achieved. (EX2008 at 20).
`
`54.
`
`In the optimization approach disclosed in the ʼ700 Patent, the
`
`objective function to be optimized can be the system’s capacity, such as its
`
`parallel decode capacity. (EX1001 at 6:42-63). In addition, the independent
`
`variables that may be iteratively changed until an optimized capacity is achieved
`
`24
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`Constellation Exhibit 2001
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`
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`Case No. IPR2023-00319
`Patent No. 10,693,700
`
`to include the constellation locations and labels. (E.g., EX1001 at 3:4-12;
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