`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`SAMSUNG ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS
`AMERICA, INC.,
`Petitioner
`
`v.
`
`APEX BEAM TECHNOLOGIES LLC,
`Patent Owner.
`
`
`
`U.S. Patent No. 10,568,113
`
`
`Case No. IPR2023-00601
`
`
`
`DECLARATION OF FRIEDHELM RODERMUND
`IN SUPPORT OF A PETITION FOR INTER PARTES REVIEW OF
`U.S. PATENT NO. 10,568,113
`
`
`
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`
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`Declaration of Friedhelm Rodermund
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`TABLE OF CONTENTS
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`Page
`INTRODUCTION AND ENGAGEMENT ......................................... 1
`I.
`BACKGROUND AND QUALIFICATIONS ...................................... 2
`II.
`SUMMARY OF MY OPINIONS ........................................................ 7
`III.
`PUBLICATION OF 3GPP SPECIFICATIONS AND RELATED
`IV.
`DOCUMENTS ......................................................................................................... 8
`A. General Practices .................................................................................. 8
`B.
`Specific Documents ........................................................................... 21
`1.
`T-doc R1-1710596 ................................................................... 21
`
`2.
`
`3.
`
`T-doc R1-1710078 ................................................................... 26
`
`T-doc R1-1700771 ................................................................... 31
`
`V.
`
`AVAILABILITY FOR CROSS-EXAMINATION ........................... 36
`Right To Supplement ......................................................................... 37
`Signature ............................................................................................ 37
`
`A.
`B.
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`
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`
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`Declaration of Friedhelm Rodermund
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`I, Friedhelm Rodermund, do hereby declare as follows:
`
`I.
`
`INTRODUCTION AND ENGAGEMENT
`
`1.
`
`I have been retained in this matter by the Petitioner to provide testimony
`
`regarding the standard business practices of 3rd Generation Partnership Project
`
`(“3GPP”) for record keeping and publishing technical specifications, change request
`
`proposals, reports, and other documents developed during the course of standards
`
`activities carried out by 3GPP and the European Telecommunications Standards
`
`Institute (“ETSI”).
`
`2.
`
`I have been asked to provide my opinions regarding the authenticity
`
`and dates of public accessibility of the following 3GPP documents:
`
`• T-doc R1-1710596, which represents a 3GPP document with the title
`
`“Discussion of beam recovery procedure” (hereinafter “R1-1710596”)
`
`(Ex. 1006)
`
`• T-doc R1-1710078, which represents a 3GPP document with the title
`
`“Discussion on multi-beam operation for NR-PDCCH” (hereinafter
`
`“R1-1710078”) (Ex. 1021)
`
`• T-doc R1-1700771, which represents a 3GPP document with the title
`
`“On spatial QCL definition” (hereinafter “R1-1700771”) (Ex. 1022)
`
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`3.
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`As an ETSI Project Manager and Secretary, from June 1998 to
`
`December 2004, I have personal knowledge of 3GPP’s standard business and
`
`records keeping practices. I continued following 3GPP’s work ever since. Thus,
`
`based on my experience, personal knowledge, and review of 3GPP’s business
`
`records, I am able to testify regarding the authenticity of certain documents
`
`published by 3GPP and the timing of their publication.
`
`4.
`
`I am also knowledgeable about document management practices and
`
`the usage of email reflectors in 3GPP TSG RAN WG1. This is due to the fact that
`
`all 3GPP working groups used the same document repository on ftp.3gpp.org and
`
`all working groups use the same email exploder tool. Thus, I’m able to testify
`
`regarding the availability and authenticity of any 3GPP documents.
`
`5.
`
`I am being compensated for my time spent on this matter at my usual
`
`rate of €450 per hour. My fee is not contingent on the outcome of this or any matter,
`
`or on the content of any of the testimony I give in this declaration. I have no financial
`
`interest in the Petitioner.
`
`6.
`
`I have been informed that Apex Beam Technologies, LLC (“Apex
`
`Beam Technologies” or “Patent Owner”) is the current assignee of U.S. Patent No.
`
`10,568,113 (“the ’113 Patent”) (Ex. 1001). I have no financial interest in the Patent
`
`Owner or the ’113 patent.
`
`II.
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`BACKGROUND AND QUALIFICATIONS
`
`
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`7.
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`I have more than 20 years of experience working with standards
`
`development organizations including 3GPP, ETSI, and the Open Mobile Alliance
`
`(“OMA”). I have particular experience with the development of standards related to
`
`cellular telecommunications, including the standards for the Universal Mobile
`
`Telecommunications System (“UMTS”), Long Term Evolution (“LTE”), and 5G,
`
`which are all standards developed by the 3GPP.
`
`8.
`
`I attended the University of Technology Aachen in Aachen, Germany,
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`where I performed graduate studies in Electrical Engineering with a focus on
`
`telecommunications technologies (“Dipl.-Ing. TH” degree). I also attended the
`
`University of Technology Trondheim in Trondheim, Norway, and completed my
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`Diploma thesis, “Design of a dual processor computer for digital signal processing
`
`in power electronics,” in 1993.
`
`9.
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`From December 1993 to June 1998, I worked at Mannesmann
`
`Mobilfunk as a System Engineer and Project Manager in Quality Assurance and
`
`Technical Standards. One of my responsibilities was to ensure by managing and
`
`performing related test activities that cellular network equipment was compatible
`
`with the Global System for Mobile Communications (“GSM”) standard developed
`
`by ETSI. During that time, I also started working as a standards delegate. I attended
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`my first ETSI meeting in 1996 (although I was already following ETSI
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`developments from 1992 during my studies).
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`10. From June 1998 to December 2004, I worked at ETSI as a project
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`manager for various ETSI Special Mobile Group (“SMG”) and 3GPP working
`
`groups. First, I served as a secretary of SMG4 “Data Services” and SMG8 “Base
`
`Stations Testing.” Then, as a project manager with the ETSI Mobile Competence
`
`Center (“MCC”), I supported establishing 3GPP as the new international standards
`
`development organization for cellular telecommunications. One of my roles was
`
`acting as Secretary for 3GPP’s Technical Specifications Group Terminals, Working
`
`Group (“T2”), the group which played a leading role in the creation of standards for
`
`Multimedia such as the Multimedia Messaging Service (“MMS”).
`
`11. Later, I was a secretary of the highest-level Technical Specifications
`
`Group Terminals which was besides other things responsible for the development of
`
`test specifications including tests for the radio interface.
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`12.
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`I edited all technical specifications produced by my working groups and
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`presented results to the parent body for approval. I attended all meetings (apart from
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`some sub-working group meetings) and was also responsible for compiling meeting
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`reports, for handling all the meeting documents, and managing the work plan. It was
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`also my role to guide the groups and to advise the chairmen regarding 3GPP working
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`methods and procedures including document handling, and to make sure delegates
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`were aware of their company’s obligations under the 3GPP Intellectual Property
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`Rights policy.
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`13. As part of my responsibilities at ETSI, I acted as a 3GPP custodian of
`
`records by personally managing 3GPP’s public File Transfer Protocol (ftp) folders,
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`which I used to make publicly accessible various 3GPP documents, including
`
`versions of 3GPP specifications, technical reports, liaison statements, change
`
`requests, contributions, agendas, meeting reports, and other 3GPP documents from
`
`my working groups. I am also knowledgeable about document management
`
`practices used in other working groups and within 3GPP in general with regard to
`
`making documents publicly accessible through the same public ftp server of 3GPP.
`
`14. Since I left ETSI as a staff member in 2005, I have been continuously
`
`involved in standardization activities, including with OMA, ETSI, and 3GPP. Since
`
`2017, I also have been attending the ETSI Intellectual Property Rights (“IPR”)
`
`Special Committee, which is responsible for the maintenance of the ETSI IPR
`
`Policy.
`
`15. After I left ETSI, I worked from January 2005 to October 2014 at
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`Vodafone, first as a Project Manager for Mobile Broadcast Standards, and then as
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`Vice Chairman of the Device Management working group of the Open Mobile
`
`Alliance, and then as a Senior Standards Strategist, all with responsibilities as
`
`described on my curriculum vitae. At Vodafone, I was deeply involved in standards
`
`work with ETSI and 3GPP and other standards setting organizations, including as a
`
`delegate to 3GPP SA1 “Services.” As part of my responsibilities, I attended selected
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`3GPP meetings, submitted documents to 3GPP, used 3GPP resources (including
`
`3GPP’s ftp server) extensively, and remained knowledgeable about 3GPP policies
`
`and procedures with regard to document management and public accessibility. I was
`
`also involved in the creation of patents, defense activities related to patent litigations,
`
`and patent evaluation, mostly in the context of standards development.
`
`16. Since leaving Vodafone in 2014, I have performed consulting work
`
`regarding Internet of Things (IoT) and Machine to Machine (M2M) technology and
`
`standards, first at Friedhelm Rodermund Consulting and then as the Founder and
`
`Director of IOTECC GmbH. In connection with my work, I regularly deal with
`
`standards such as OMA’s Lightweight M2M (LwM2M) and 3GPP’s LTE,
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`Narrowband IoT (NB-IoT) and 5G standards. And I have extensively used 3GPP
`
`resources and have remained knowledgeable about 3GPP policies and procedures
`
`with regard to document management and public accessibility.
`
`17.
`
`I also provide consulting services related to patents, in particular around
`
`3GPP Standard Essential Patents (“SEPs”), and I have worked as an expert witness
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`on a number of occasions. I continue to closely follow the maintenance of the ETSI
`
`IPR Policy as a delegate to the ETSI IPR Special Committee. Furthermore, I am
`
`conducting a seminar on SEPs and the Internet of Things at the Technical University
`
`of Ilmenau, Germany.
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`18. At the time of writing this declaration, I am following – including
`
`attending selected meetings – the following standards committees: ETSI oneM2M,
`
`ETSI IPR Special Committee, OMA, and 3GPP.
`
`19. A copy of my curriculum vitae, which includes a detailed description
`
`of my experience and education, is attached as Appendix A. A list of litigation
`
`matters on which I have worked over the last five years is also included in my
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`curriculum vitae.
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`III.
`
`SUMMARY OF MY OPINIONS
`
`20.
`
`It is my opinion that R1-1710596 (Ex. 1006) is an authentic 3GPP T-
`
`doc and would have been publicly accessible through ftp.3gpp.org no later than June
`
`16, 2017.
`
`21.
`
`It is my opinion that R1-1710078 (Ex. 1021) is an authentic 3GPP T-
`
`doc and would have been publicly accessible through ftp.3gpp.org no later than June
`
`17, 2017.
`
`22.
`
`It is my opinion that R1-1700771 (Ex. 1022) is an authentic 3GPP T-
`
`doc and would have been publicly accessible through ftp.3gpp.org no later than
`
`January 10, 2017.
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`
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`IV. PUBLICATION OF 3GPP SPECIFICATIONS AND RELATED
`DOCUMENTS
`A. General Practices
`
`23. Unless otherwise noted, the foregoing and following is an accurate
`
`description of 3GPP general practices from 1998 to the present, including in 2017,
`
`regardless of whether I use the present or past tense to describe those practices.
`
`24.
`
`3GPP was established in 1998 by a group of telecommunications
`
`standard development organizations from Japan, Korea, China, Europe, and the
`
`United States
`
`to
`
`jointly develop worldwide
`
`standards
`
`for mobile
`
`telecommunications. Today, 3GPP consists of seven partners: Association of Radio
`
`Industries and Businesses, Japan (“ARIB”), Alliance for Telecommunications
`
`Industry Solutions, USA (“ATIS”), China Communications Standards Association
`
`(“CCSA”), European Telecommunications Standards
`
`Institute
`
`(“ETSI”),
`
`Telecommunications Standards Development Society,
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`India
`
`(“TSDSI”),
`
`Telecommunications
`
`Technology Association, Korea
`
`(“TTA”),
`
`and
`
`Telecommunication Technology Committee, Japan (“TTC”). In addition to being
`
`one of the founding partners, ETSI hosts the Mobile Competence Centre (“MCC”),
`
`which provides administrative and technical support for the day-to-day work of
`
`3GPP. Furthermore, ETSI manages 3GPP’s IT services such as the 3GPP website,
`
`ftp server, and email exploders.
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`25.
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`3GPP is the world’s leading organization for developing and
`
`maintaining cellular telecommunications standards, which it has done since its
`
`foundation in 1998. As noted above and in my curriculum vitae, I began working for
`
`3GPP, as part of my work at ETSI, the European-based organizational partner of
`
`3GPP.
`
`26.
`
`In the ordinary course of its regularly conducted business activities, and
`
`pursuant to its standard business practices, 3GPP publishes technical specifications,
`
`proposals, reports, and other documents related to the development of cellular
`
`telecommunications standards. Such documents are published for the purposes of
`
`discussion and establishment of industry standards for cellular telecommunications.
`
`This has been 3GPP’s ordinary course of business since when I began working at
`
`ETSI in 1998.
`
`27.
`
`In the ordinary course of 3GPP’s regularly conducted business
`
`activities, and pursuant to its standard business practices, all draft technical
`
`specifications, proposals, reports, and other temporary documents to be discussed or
`
`considered in relation to 3GPP’s telecommunications standards activities were, and
`
`continue to be, assigned a temporary document number and made publicly available,
`
`including on the ftp server associated with the 3GPP website, currently residing at
`
`ftp.3gpp.org. Such documents are referred to as “T-docs.” Final versions of the
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`technical specifications also were, and continue to be, publicly available from that
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`same ftp server.
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`28. The names and the structure of 3GPP working groups, as of today, can
`
`be found at https://www.3gpp.org/3gpp-groups (reproduced below):
`
`29. Each Technical Specification Group (TSG) or Working Group adopts
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`a structured numbering system for the documents associated with their meetings,
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`and those systems typically follow a consistent numbering system as shown in the
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`following example: xminnzzzz. The numbering system normally comprises five
`
`logical elements: (1) x: a single letter corresponding to the TSG; wherein in
`
`2007/2008 x was one of R (Radio Access Network), C (Core and Terminals), S
`
`(Service and System Aspects), or G (GSM/EDGE Radio Access Network); (2) m: a
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`single character corresponding to the Working Group identity (typically 1, 2, 3, etc.)
`
`or, in the case of the TSG itself, the letter “P”; (3) i: normally the hyphen character
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`“-”; (4) nn: the calendar year of the meeting to which the document was submitted;
`
`and (5) zzzz: a running number (some working groups use 5 digits).
`
`30.
`
`In the ordinary course of 3GPP’s regularly conducted business
`
`activities, and pursuant to its standard business practices, from December 1998
`
`onwards, 3GPP published all of its T-docs and all final versions of its technical
`
`specifications on its ftp server, which has always been easily and publicly accessible
`
`from its website and currently resides at ftp.3gpp.org.
`
`31. As early as December 1998, including in 2017, 3GPP’s ftp server was
`
`freely accessible to the general public with no login, password, or membership
`
`requirement.
`
`32. By 1999, at least 100 companies were members of 3GPP (719
`
`companies by December 2020), ranging from Bosch to Ericsson to Nokia to
`
`Samsung and generally including those interested in the discussion, creation, and
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`adoption of cellular telecommunications standards, including UMTS. Each of these
`
`companies typically delegated multiple individuals to regularly participate in 3GPP
`
`meetings. Further, pursuant to 3GPP’s standard business practices, 3GPP working
`
`groups sent emails notifying these individuals as soon as new or additional
`
`documents had been uploaded to 3GPP’s ftp server. Thus, not only did the general
`
`public have access to the documents on the ftp server, but some of the most interested
`
`members of the public—those working to develop standards for cellular
`
`telecommunication or working to implement the standards—were personally
`
`informed of their availability by email. Based on my experience with 3GPP and the
`
`telecommunications industry, I would expect any person implementing a cellular
`
`network or device, e.g., an LTE or 5G network, to consult the corresponding
`
`specifications on the 3GPP ftp server, as well as other related documents. The whole
`
`purpose of 3GPP creating and making these specifications available was so that
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`engineers and other individuals would have ready access to them when developing
`
`and implementing cellular networks and devices.
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`33. By June 1999, 3GPP’s ftp server was well-known to persons in the
`
`cellular telecommunications industry as a source of public information regarding
`
`industry standards and technological advances.
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`34.
`
`3GPP specifications bear a specification number consisting of four or
`
`five digits, e.g., 09.02 or 29.002. The first two digits define the specification series
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`which are defined to group the different aspects of the 3GPP system into, e.g.,
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`requirements, service aspects, radio aspects codecs, security aspects, and test
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`specifications. The series digits are followed by two additional digits for the 01 to
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`13 series or three further digits for the 21 to 55 series. The subjects of the individual
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`specification
`
`series
`
`are
`
`explained
`
`on
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`3GPP’s
`
`website
`
`at
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`https://www.3gpp.org/specifications-technologies/specifications-by-series,
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`and
`
`reproduced below.
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`35. Following a link for a series (e.g., “23 series” link) leads to a 3GPP web
`
`page providing access to all specifications in a series, as shown by the screenshot
`
`below:
`
`
`
`
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`36. As another example of a series, the LTE radio standard is covered in
`
`the “36 series” and is further subdivided into separate sections or specifications. The
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`LTE radio specification series starts at TS 36.101 and ends at TR 36.978. Excluding
`
`withdrawn specifications, the LTE standard consists of more than 250 specifications.
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`37. As another example of a series, the 5G New Radio (NR) standard is
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`covered in the “38 series” and is further subdivided into separate sections or
`
`specifications. Selecting the “38 series” link on website shown in paragraph 33 leads
`
`to the 3GPP portal (portal.3gpp.org) page for all of the 38 series technical
`
`specifications.1 These 5G NR specifications start at TS 38.101 and end at TR 38.921.
`
`Excluding withdrawn specifications, the 5G NR standard consists of more than 140
`
`specifications. Each specification can span from a few pages to hundreds of pages.
`
`One full version of the 5G standard is massive, spanning tens of thousands of pages
`
`across the particular series of technical specifications.
`
`38.
`
`In the ordinary course of 3GPP’s regularly conducted business
`
`activities, and pursuant to its standard business practices, T-docs are usually
`
`uploaded to 3GPP’s ftp server and website before the meeting where they are to be
`
`discussed. Documents created or revised during the course of a meeting are normally
`
`uploaded at the latest during the week following the meeting (e.g., the meeting report
`
`of the meeting is usually published for review during the week following the
`
`meeting).
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`
`
`1
`https://portal.3gpp.org/Specifications.aspx?q=1&series=45&releases=all&draft=Fa
`lse&underCC=False&withACC=False&withBCC=False&numberNYA=False
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`39.
`
`In the ordinary course of 3GPP’s regularly conducted business
`
`activities, and pursuant to its standard business practices, 3GPP maintains archives
`
`that include different versions of the specifications, as well as email communications
`
`to its membership, including emails announcing the uploading of new or additional
`
`documents to 3GPP’s ftp server. These archives are created at the time the emails
`
`are initially sent.
`
`40.
`
`3GPP specifications almost always are duplicated in at least two and
`
`sometime more locations on the ftp server. One location corresponds to a “snapshot”
`
`of the specifications corresponding to a particular plenary meeting cycle—for
`
`instance, the 2018-12 snapshot contains a snapshot of numerous specifications after
`
`the December 2018 3GPP plenary meetings. The second location is an “archive” that
`
`contains all versions over time for a given specification. The screenshot below shows
`
`an excerpt of the “Spec” folder at ftp.3gpp.org:
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`41. While 3GPP aims to upload the updated specifications to both locations
`
`at the same time, occasionally there may be a small difference in the upload date,
`
`and thus the date stamp, for the same specification uploaded to the two locations.
`
`Additionally, specifications which are not yet approved (so called “draft”
`
`specifications) are presented as T-docs at working group and at plenary meetings (as
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`soon as the working group decides to submit the specification to the plenary meeting
`
`for information or approval). In many cases, the T-docs are also distributed on the
`
`email exploder of the working group prior to the meeting, making the T-docs
`
`available to all those subscribed to the email distribution list.
`
`42. The timestamp on 3GPP’s ftp server shows the date when the document
`
`was uploaded the last time. Thus, the timestamp shows the latest possible date the
`
`document became publicly available and accessible on 3GPP’s ftp server. The given
`
`document might have been available earlier and the original timestamp might have
`
`been overwritten because the document was uploaded again. According to my
`
`experience, this is something which happened occasionally. Thus, the ftp timestamp
`
`is reliable as the latest possible upload date but one cannot determine whether it
`
`represents the first upload of a document to the ftp server.
`
`43. An additional means of accessing 3GPP documents including T-docs
`
`and
`
`specifications
`
`is
`
`the
`
`3GPP
`
`portal.
`
`See
`
`https://portal.3gpp.org/Specifications.aspx. 3GPP preserves the posted document
`
`indefinitely on its server for future reference. Id. As detailed below, the 3GPP
`
`website provides the date that a particular version of a technical specification was
`
`uploaded, using the date convention YYYY-MM-DD. The 3GPP portal also
`
`provides a login function to unlock full features, however, login is not required for
`
`searching and downloading technical specifications. Based on my personal
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`experience, throughout the 2017 timeframe, anyone interested in a particular 3GPP
`
`specification could search the 3GPP portal to find and download the latest version
`
`of a technical specification using the 3GPP portal in substantially the same manner
`
`as they would today:
`
`
`
`
`
`https://portal.3gpp.org/Specifications.aspx; see, e.g., 2015 internet archive
`
`https://web.archive.org/web/20150924200802/https://portal.3gpp.org/.
`
`44.
`
`3GPP’s working practice to store their documents on its ftp server, as
`
`described above, has not changed over time. Starting from the first 3GPP meetings
`
`in 1998 until present, all WGs and plenary meetings are represented by dedicated
`
`meeting folders on the ftp server. These meeting folders include the documents
`
`discussed at the meetings. Both the folders and the documents are accessible to the
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`public. Almost every week, a new meeting folder with the respective documents is
`
`added. In addition to the plenary and WG meeting folders, and some other folders,
`
`there is also the “Specs” folder, which holds all 3GPP specifications including the
`
`aforementioned “snapshot” and archive folders. Since the early days of 3GPP a new
`
`folder is added inside the “Specs” folder after each TSG plenary meeting to hold the
`
`latest versions of specifications approved at those TSG plenary meetings. This is still
`
`3GPP’s working practice today; thus, this practice has not changed over time.
`
`45.
`
`3GPP maintains a set of publicly accessible documents2 providing
`
`further details on its way of working:
`
`• 3GPP Working Procedures
`
`• Vocabulary for 3GPP Specifications 3GPP TR 21.905
`
`• Working Methods 3GPP TR 21.900
`
`• Specification Drafting Rules 3GPP TR 21.801
`
`
`
`B.
`
`Specific Documents
`
`1.
`
`T-doc R1-1710596
`
`46. Based on my personal knowledge and my review of 3GPP’s business
`
`records, I recognize Ex. 1006 as a true and correct copy of 3GPP T-doc R1-
`
`
`2 All available from https://www.3gpp.org/delegates-corner/3gpp-working-
`procedures
`
`
`
`21
`
`
`
`Declaration of Friedhelm Rodermund
`
`1710596, which represents a 3GPP document with the title “Discussion of beam
`
`recovery procedure.” The document was authored by Lenovo and Motorola
`
`Mobility and it covered agreements, open issues and proposals related to recovery
`
`from beam failure. On its face, R1-1710596 refers to the RAN WG1 NR (New
`
`Radio) Ad-Hoc meeting #2 held on June 27-30, 2017, in Qingdao, China. Thus,
`
`based on my personal knowledge and experience with ETSI’s and 3GPP’s standard
`
`business practices, this information tells me that R1-1710596 was available either
`
`prior to or during that meeting to at least all attending 3GPP members. The public
`
`availability of the document is confirmed by the date stamp, June 16, 2017, shown
`
`on the historic 3GPP ftp server for the corresponding downloadable file (“R1-
`
`1710596.zip”), as maintained by the Internet Archive at
`
`
`
`https://web.archive.org/web/20170629164646/http://www.3gpp.org:80/ftp/TSG_R
`
`AN/WG1_RL1/TSGR1_AH/NR_AH_1706/Docs/. This information is also shown
`
`on the date stamp for the present-day listing of the same document on the 3GPP ftp
`
`server at
`
`
`
`https://www.3gpp.org/ftp/tsg_ran/WG1_RL1/TSGR1_AH/NR_AH_1706/Docs/ as
`
`shown in the screenshot below:
`
`
`
`22
`
`
`
`
`
`Declaration of Friedhelm Rodermund
`
`
`
`47.
`
`In addition, metadata information for the downloaded and extracted T-
`
`doc file states a last Modified date of “17. June 2017,” as shown in the screenshot
`
`below. The reason why the upload seems to have occurred earlier than the last
`
`modification is because this happened across different time zones. E.g. modification
`
`and upload might have been performed early on June 17 in Asia whereas in Europe
`
`(where ETSI’s FTP server is located) it was still June 16.
`
`
`
`
`
`
`
`
`
`23
`
`
`
`Declaration of Friedhelm Rodermund
`
`
`
`
`
`
`
`48. The official meeting report of the RAN WG1 NR (New Radio) Ad-Hoc
`
`#2 held on June 27-30, 2017, can be found in Appendix B. According to the 3GPP
`
`website at https://portal.3gpp.org/Meetings.aspx#/ which is shown by the screenshot
`
`
`
`24
`
`
`
`Declaration of Friedhelm Rodermund
`
`below, that meeting was attended by 394 individuals (out of 556 registered
`
`participants):
`
`49. The meeting report includes in the zip file the meeting’s document list
`
`of which an excerpt can be found in Appendix C3. R1-1710596 is listed in row 718
`
`and is tagged as “available” which clearly shows the document was available at the
`
`
`
`
`3 Given the size of the document list with over 2000 rows (documents) and over 30
`columns the Appendix only includes the columns relevant for this declaration: TDoc, Title,
`Source, TDoc Status, Reservation date, Uploaded.
`
`
`
`25
`
`
`
`Declaration of Friedhelm Rodermund
`
`meeting. Furthermore, the “Upload” date is shown as “2017-06-15” as can be seen
`
`by the screenshot below:
`
`
`
`
`
`50. Thus, based on my personal knowledge and experience with ETSI’s
`
`and 3GPP’s standard business practices, this information tells me that this document
`
`was available via the public 3GPP ftp server by June 16, 2017, at the latest.
`
`
`
`
`
`2.
`
`T-doc R1-1710078
`
`51. Based on my personal knowledge and my review of 3GPP’s business
`
`records, I recognize Ex. 1021 as a true and correct copy of 3GPP T-doc R1-
`
`1710078, which represents a 3GPP document with the title “Discussion on multi-
`
`beam operation for NR-PDCCH.” The document was authored by CATT and it
`
`covered agreements, open issues for discussion and proposals related to multi-
`
`beam operation for NR-PDCCH. On its face, R1-1710078 refers to the RAN WG1
`
`NR (New Radio) Ad-Hoc meeting #2 held on June 27-30, 2017, in Qingdao,
`
`China. Thus, based on my personal knowledge and experience with ETSI’s and
`
`
`
`26
`
`
`
`Declaration of Friedhelm Rodermund
`
`3GPP’s standard business practices, this information tells me that R1-1710596 was
`
`available either prior to or during that meeting to at least all attending 3GPP
`
`members. The public availability of the document is confirmed by the date stamp,
`
`June 17, 2017, shown on the historic 3GPP ftp server for the corresponding
`
`downloadable file (“R1-1710078.zip”), as maintained by the Internet Archive at
`
`
`
`https://web.archive.org/web/20170629164646/http://www.3gpp.org:80/ftp/TSG_R
`
`AN/WG1_RL1/TSGR1_AH/NR_AH_1706/Docs/. This information is also shown
`
`on the date stamp for the present-day listing of the same document on the 3GPP ftp
`
`server at
`
`
`
`https://www.3gpp.org/ftp/tsg_ran/WG1_RL1/TSGR1_AH/NR_AH_1706/Docs/ as
`
`shown in the screenshot below:
`
`
`
`
`
`
`
`
`
`27
`
`
`
`Declaration of Friedhelm Rodermund
`
`52.
`
`In addition, metadata information for the downloaded and extracted T-
`
`doc file states a last Modified date of “16. June 2017,” as shown in the screenshot
`
`
`
`below:
`
`
`
`28
`
`
`
`Declaration of Friedhelm Rodermund
`
`
`
`
`
`53. The official meeting report of the RAN WG1 NR (New Radio) Ad-
`
`Hoc #2 held on June 27-30, 2017, can be found in Appendix B. According to the
`
`3GPP website at https://portal.3gpp.org/Meetings.aspx#/ which is shown by the
`
`
`
`29
`
`
`
`Declaration of Friedhelm Rodermund
`
`screenshot below, that meeting was attended by 394 individuals (out of 556
`
`registered participants):
`
`54. The meeting report includes in the zip file the meeting’s document list
`
`of which an excerpt can be found in Appendix C4. R1-1710078 is listed in row 200
`
`and is tagged as “available” which clearly shows the document was available at the
`
`
`
`
`4 Given the size of the document list with over 2000 rows (documents) and over 30
`columns the Appendix only includes the columns relevant for this declaration: TDoc, Title,
`Source, TDoc Status, Reservation date, Uploaded.
`
`
`
`30
`
`
`
`Declaration of Friedhelm Rodermund
`
`meeting. Furthermore, the “Upload” date is shown as “2017-06-17” as can be seen
`
`by the screenshot below:
`
`
`
`
`
`
`
`55. Thus, based on my personal knowledge and experience with ETSI’s
`
`and 3GPP’s standard business practices, this information tells me that R1-1710078
`
`was available via the public 3GPP ftp server by June 17, 2017, at the latest.
`
`
`
`
`
`3.
`
`T-doc R1-1700771
`
`56. Based on my personal knowledge and my review of 3GPP’s business
`
`records, I recognize Ex. 1022 as a true and correct copy of 3GPP T-doc R1-
`
`1700771, which represents a 3GPP document with the title “On spatial QCL
`
`definition.” The document was authored by Ericsson and it elaborated on the QCL
`
`(quasi co-located) definition for 5G New Radio. On its face, R1-1700771 refers to
`
`the RAN WG1 ”ah-NR” (Ad Hoc–New Radio) meeting held on January 16-20,
`
`2017, in Spokane, USA. Thus, based on my personal knowledge and experience
`
`
`
`31
`
`
`
`Declaration of Friedhelm Rodermund
`
`with ETSI’s and 3GPP’s standard business practices, this information tells me that
`
`R1-1700771 was available either prior to or during that meeting to at least all
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