UNITED STATES PATENT AND TRADEMARK OFFICE
`
` _________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________
`
`LENOVO (UNITED STATES) INC. and
`MOTOROLA MOBILITY LLC,
`Petitioners
`
`v.
`
`THETA IP, LLC
`Patent Owner
`
`_________________
`
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`___________________
`
`DECLARATION OF R. JACOB BAKER, P.E., PH.D.
`IN SUPPORT OF PETITIONERS’ REPLIES TO
`PATENT OWNER’S RESPONSES
`
`IPR2023-00697
`Petitioners Lenovo (United States) Inc.
`and Motorola Mobility LLC - Ex. 1019
`
`1 of 45
`
`

`

`TABLE OF CONTENTS
`
`I.
`
`INTRODUCTION ........................................................................................... 1
`
`1.
`
`Materials Considered ............................................................................. 1
`
`II.
`
`IMPEDANCE (’825 Patent and ’202 Patent) .................................................. 2
`
`1.
`
`2.
`
`Patent Owner and Dr. Larson’s argument that the “impedance” is an
`AC circuit parameter and thus can only be used when referring to an
`AC circuit is incorrect. .......................................................................... 3
`
`Even if Patent Owner’s narrow construction of the term “impedance”
`is accepted, Rauhala still teaches varying an impedance in connection
`with a supply current control circuit. .................................................... 7
`
`III.
`
`SIGNAL PATH (’825 Patent and ’202 Patent) .............................................11
`
`1.
`
`2.
`
`3.
`
`The entireties of the amplifier shown in Figure 6 and the mixer shown
`in Figure 7 of Rauhala are within the signal path. ..............................12
`
`A POSITA would have understood from the ’202 patent and ’825
`patent that a “signal path” includes amplifiers and mixers in their
`entireties. .............................................................................................21
`
`The amplifier of Figure 6 and the mixer of Figure 7 cannot be divided
`as Dr. Larson and Patent Owner suggest. ...........................................23
`
`IV. DETERMINING (’825 Patent and ’202 Patent) ...........................................28
`
`V.
`
`COMPARING (’202 Patent) .........................................................................33
`
`1.
`
`2.
`
`The ’202 patent prescribes no particular manner of “comparing”
`signal strengths. ...................................................................................33
`
`Rauhala’s signal-to-noise ratio and/or bit error ratio satisfy the
`“comparing” limitations. .....................................................................37
`
`VI. DRIVE CURRENT (’825 Patent) .................................................................39
`
`VII. AUTHENTICITY ..........................................................................................42
`
`VIII. CONCLUSIONS ...........................................................................................43
`
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`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`
`
`I.
`
`I, R. Jacob Baker, declare as follows:
`
`INTRODUCTION
`
`1. My name is R. Jacob Baker Ph.D., P.E., and I am a Professor of Electrical
`
`and Computer Engineering at the University of Nevada, Las Vegas. I have
`
`prepared this declaration as an expert witness on behalf of Lenovo (United States)
`
`Inc. and Motorola Mobility LLC (collectively, “Petitioners”).
`
`2.
`
`This declaration contains my opinions in response to the Patent Owner’s
`
`assertions and those of its expert, and the bases and rationale for these opinions.
`
`3.
`
`For my efforts in connection with the preparation of this declaration, I have
`
`been compensated at my usual and customary rate for this type of consulting
`
`activity. My compensation is in no way contingent on the results of these or any
`
`other proceedings related to U.S. Patent No. 10,129,825 (“’825 patent”) and U.S.
`
`Patent No. 10,524,202 (“’202 patent”) (collectively, “Tsividis patents”).
`
`4. My qualifications are set forth in my previous declarations in these matters
`
`(IPR2023-00697, Ex. 1002; IPR2023-00698, Ex. 1002.)
`
`1. Materials Considered
`
`5.
`
`I have considered information from various sources in forming the opinions
`
`presented below. In addition to those mentioned in my previous declarations, I
`
`have reviewed the following documents:
`
`
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`1
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`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`(A) Patent Owner’s Preliminary Responses and the accompanying
`
`exhibits in each of IPR2023-00697 and IPR2023-00698, including the
`
`Declaration of Lawrence E. Larson (Ex. 2005);
`
`(B)
`
`the Institution Decisions in each of IPR2023-00697 and
`
`IPR2023-00698;
`
`(C) Patent Owner’s Responses and the accompany exhibits in each
`
`of IPR2023-00697 and IPR2023-00698, including the Declaration of
`
`Lawrence E. Larson (Ex. 2015);
`
`(D) Transcript of Deposition of Lawrence E. Larson taken on April
`
`18, 2024 (Ex. 1018).
`
`II.
`
`6.
`
`IMPEDANCE (’825 Patent and ’202 Patent)
`
`As I explained in my previous Declaration (see IPR2023-00697, Ex. 1002 at
`
`¶¶ 128-135; IPR2023-00698, Ex. 1002 at ¶¶ 126-136 and 145-151) and elaborated
`
`on below (see supra Section II.1-2), a person of ordinary skill in the art (POSITA)1
`
`1 In the Institution Decisions in both IPR proceedings, the Board adopted
`
`Petitioners’ proposal for a POSITA (“bachelor’s degree in electrical engineering,
`
`electronics engineering, or the equivalent, and two or more years of experience”)
`
`as a better reflection of the level of skill in the prior art. IPR2023-00697,
`
`Institution Decision at 9; IPR 2023-00698, Institution Decision at 13.
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`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`would have understood Rauhala to teach the claimed “causing … an impedance to
`
`vary,” especially in light of Rauhala’s disclosure of a supply current control circuit
`
`implemented in a differential amplifier and the correct construction of the term
`
`“impedance,” as discussed below.
`
`1.
`Patent Owner and Dr. Larson’s argument that the “impedance” is
`an AC circuit parameter and thus can only be used when referring to an
`AC circuit is incorrect.
`
`7.
`
`Patent Owner and Dr. Larson point to a limited set of definitions provided in
`
`electrical engineering dictionaries in alleging that the relevant circuit in Rauhala
`
`fails to disclose varying an impedance. IPR2023-00697, POR at 27; IPR2023-
`
`00698, POR at 30-31; Ex. 2015 at ¶ 55. More specifically, Patent Owner and Dr.
`
`Larson assert that the term “impedance” should be afforded a very narrow
`
`interpretation, namely the opposition of a circuit to alternating current (AC). Id.
`
`Based on this construction, Patent Owner and Dr. Larson argue the impedance is
`
`an AC parameter and thus a POSITA would have only used the term when
`
`referring to AC circuits. IPR2023-00697, POR at 29; IPR2023-00698, POR at 32;
`
`Ex. 2015 at ¶ 56. In my opinion, this is factually incorrect.
`
`8.
`
`Instead, a POSITA would have understood that impedance has a broader
`
`meaning, as I explained in my previous Declarations. IPR2023-00697, Ex. 1002 at
`
`¶ 134; IPR2023-00698, Ex. 1002 at ¶¶ 134 and 294. For example, in the same
`
`
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`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`dictionary Patent Owner cites in the POR (Graf, Modern Dictionary of Electronics,
`
`Seventh Edition), “impedance” is also defined as “[c]ombined opposition to
`
`current resulting from resistance, capacitance, and inductance,” without any
`
`mention of the type of current (e.g., alternating or direct) that is opposed. IPR2023-
`
`00697, IPR2023-00698, POR at 30; POR at 27; Ex. 1006 at 9. Another definition
`
`listed among several definitions includes “[t]he combination of resistance and
`
`reactance,” also without any mention of the type of current. Id.
`
`9.
`
`As evidenced by the numerous definitions, in the above-mentioned
`
`dictionary, a POSITA would have been familiar with the fact that impedance is a
`
`
`
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`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`concept substantially broader than the overly-restrictive definition proposed by PO,
`
`but one that includes resistance.
`
`10. Dr. Larson states “[i]mpedance is often symbolized with Z, and is given by
`
`the formula (cid:1852) = √((cid:1844)(cid:2870) + ((cid:1850)(cid:3013) + (cid:1850)(cid:3004))(cid:2870)), where R is resistance, XL is inductive
`
`reactance, and XC is capacitive reactance.” Ex. 2015 at 54. To be precise, the
`
`formula provided by Dr. Larson expresses the magnitude of an impedance. In the
`
`formula provided by Dr. Larson, the real part of impedance includes the portion
`
`related to the resistance R, and the imaginary part of impedance includes the
`
`portion related to the inductive reactance XL and the capacitive reactance XC.
`
`Additionally, a more universally-accepted formula for impedance in Cartesian
`
`form is (cid:1852) = (cid:1844) + (cid:1862)(cid:1850), where the real part of impedance is the resistance R and the
`
`imaginary part is the reactance X. IPR2023-00697, Ex. 1010 at 7. As clearly
`
`expressed in these equations, impedance is the sum of any real part, i.e., resistance,
`
`and any imaginary part, i.e., reactance, present in a circuit. Based on the above, a
`
`POSITA would not have concluded that a circuit does not have impedance simply
`
`because either the real part or the imaginary part does not exist within the circuit
`
`(i.e. has a value of zero).
`
`11. With respect to Figure 6 in Rauhala, neither Patent Owner nor Dr. Larson
`
`disputes that the supply current control circuit 62 includes resistors that can be
`
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`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`added or removed from the circuit using the corresponding switches, and that such
`
`arrangement enables the adjustment of the bias current for the linear unit 61, i.e., a
`
`differential amplifier. IPR2023-00697, POR at 22 and 48; IPR2023-00698, POR at
`
`24-25 and 55-56; Ex. 1004 at [0021] and Figure 6. Based on the formulas for
`
`impedance discussed above, when viewing Figure 6 of Rauhala, a POSITA would
`
`have concluded that the resistors in circuit 62 constitute, which is circuitry in the
`
`amplifiers A1, A2, and A3 in the signal path, the real part of the impedance.
`
`12.
`
`In my view, it would be unreasonable for a POSITA to have concluded that
`
`circuit 62 does not have an impedance. In other words, it does not matter whether
`
`the circuit in question is purely resistive, purely reactive, or a combination of both
`
`– a POSITA would have understood that a circuit has an impedance, as long as the
`
`circuit has a resistive and/or a reactive component therein. Dr. Larson also
`
`recognizes this – that capacitance and/or inductance can be missing in a circuit
`
`(Ex. 1018 at 54:7-55:3), and that impedance Z is non-zero even when one or more
`
`of resistance, capacitive reactance, and inductive reactance are absent in the circuit.
`
`Ex. 1018 at 55:3-13 (“Q: And looking at the formula you provided for Z, you could
`
`still calculate … the value of Z if any of R, XL or XC are zero; correct? A: So I
`
`think you are asking if any one of R, XL, or XC is zero, could you still calculate Z,
`
`and the answer to that is yes. Q: Would your answer change if two of those
`
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`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`variables were zero? A: No. My answer would not change if two were zero.”).
`
`Based on the foregoing, and for the reasons set forth in my previous declarations
`
`(IPR2023-00697, Ex. 1002; IPR2023-00698, Ex. 1002;) it is my opinion that a
`
`POSITA would have understood that the resistors in the circuit illustrated in Figure
`
`6 of Rauhala have an impedance.
`
`2.
`Even if Patent Owner’s narrow construction of the term
`“impedance” is accepted, Rauhala still teaches varying an impedance in
`connection with a supply current control circuit.
`
`13. As discussed above, Patent Owner and Dr. Larson advance a construction
`
`that an impedance is a total opposition to alternating current and is thus an AC
`
`parameter (see supra Section II.), and asserts that a POSITA would have only used
`
`the term when referring to an AC circuit. IPR2023-00697, POR at 29; IPR2023-
`
`00698, POR at 32; Ex. 2015 at ¶ 56. This is incorrect. However, even if this
`
`construction is accepted by the Board, the supply current control circuit 62 in
`
`Figure 6 of Rauhala teaches varying an impedance by changing the resistances.
`
`14. As discussed in my previous Declaration, in Figure 6 of Rauhala, the current
`
`kI is adjusted, or varied, based on the removal or inclusion of resistors R3 and R2.
`
`IPR2023-00697, Ex. 1002 at ¶¶ 131-133. Through the use of a current mirror, the
`
`current I in the transistor Q2 is also adjusted, or varied, accordingly. IPR2023-
`
`00697, Ex. 1002 at ¶ 134. The current I sets the bias current for the linear unit 61, a
`
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`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`differential amplifier denoted as “diff. amp.” in the figure. Ex. 1004 at [0022] and
`
`Figure 6.
`
`
`
`15. As shown in Figure 6 of Rauhala, the currents kI and I flow to the collectors
`
`of the respective bipolar transistors, Q1 and Q2. Id. A bipolar transistor has an
`
`impedance between its base and emitter terminals due to the diffusion capacitance
`
`resulting from the current flowing in its collector, IC. This diffusion capacitance,
`
`Cd, is characterized by the formula Cd = b* IC/VT, where VT is the thermal voltage
`
`and b is the base-transit-time constant. Ex. 1016 at 48. Similarly, changing the
`
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`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`collector currents changes the output impedances of the transistors Q1, Q2 (shown
`
`above), and the transistors in the differential amplifier 612 (shown below in more
`
`detail).
`
`
`
`16. Specifically, the output impedance, ro, between the collector and the emitter
`
`of a bipolar transistor changes inversely with changes in the collector current as
`
`given by ro = VA/IC where VA is the transistor’s Early voltage. Ex. 1016 at 52. As
`
`2 It had been well known to a POSITA long before the effective filing date of the
`
`’825 and ’202 patents that a differential amplifier includes multiple transistors. Ex.
`
`1016 at 151. Patent Owner’s expert, Dr. Larson, also agreed in cross-examination
`
`that the differential amplifier 61 in Rauhala’s FIG. 6 incorporates transistors. Ex.
`
`1018 at 93:1-95:5.
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`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`kI and I, namely the collector currents of the transistors Q1 and Q2, change based
`
`on the removal or inclusion of resistors R3 and R2, the impedances, that is, the
`
`resistances3 and capacitances, between the collector, base, and emitter terminals of
`
`the transistors Q1, Q2, and the transistors in the differential amplifier 61, also
`
`change. Dr. Larson also acknowledged this phenomenon in reference to Rauhala’s
`
`Figure 6 during his cross-examination. Ex. 1018 at 95:6-96:16 (“Q: And would the
`
`transistors of linear unit or differential amplifier 61 have impedances? … A: If
`
`your question is do the transistors in differential amplifier 61 include impedances?
`
`Yes, they would have, they would have impedances … Q: And as supply current I
`
`changes, would the impedances of the transistors in the differential amplifier also
`
`change? … A: Yeah. As the supply current I to the differential amplifier changes,
`
`that will change the DC bias current through the transistors and that will change
`
`their impedances.”).
`
`
`3 The resistances of the transistors in the differential amplifier 61 provide an
`
`opposition to the flow of the AC current or signal received at the differential
`
`amplifier 61. Therefore, even under the construction proposed by Patent Owner
`
`and Dr. Larson, these resistances are an impedance since they provide an
`
`opposition to the flow of an AC current.
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`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`In light of the above, it is my opinion that a POSITA would have understood
`
`17.
`
`that the adjustment of kI and I through the use of resistors R3 and R2 leads to the
`
`variance of the impedance in the circuit illustrated in Rauhala’s Figure 6 by
`
`changing the resistances and capacitances between the terminals of the transistors
`
`Q1, Q2, and the differential amplifier 61 in Figure 6 of Rauhala.
`
`III. SIGNAL PATH (’825 Patent and ’202 Patent)
`
`18. As explained in my previous declarations, a POSITA would have understood
`
`Rauhala to teach varying an impedance in a signal path. IPR2023-00697, Ex. 1002
`
`at ¶¶81-82, 128-135, 139-141; IPR2023-00698, Ex. 1002 at ¶¶ 86-87, 126-136.
`
`19.
`
`I understand that Patent Owner and Dr. Larson consider indispensable
`
`portions of amplifiers and mixers, such as 62 in Figure 6, to be excluded from the
`
`“signal path.” I disagree with Patent Owner’s and Dr. Larson’s conclusions
`
`regarding the “signal path” for the reasons set forth below. However, even if these
`
`indispensable portions were to be excluded, so that the only portion of the
`
`amplifier or mixer that was left was, for example, circuit 61 or circuit 71, the
`
`resistances and capacitances between the terminals of the transistors used in circuit
`
`61 and circuit 71 change with I (and kI), as discussed in detail in the previous
`
`section.
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`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`1.
`The entireties of the amplifier shown in Figure 6 and the mixer
`shown in Figure 7 of Rauhala are within the signal path.
`
`20. Rauhala shows and describes various configurations of a radio receiver. Ex.
`
`1004 at [0011]-[0012]. Rauhala plainly states that a “signal path structure” of such
`
`a radio receiver is shown in Figure 2. Id. at [0012] (emphasis added). The signal
`
`path shown in Figure 2 includes an antenna ANT, detector DET, and “linear units”
`
`between the antenna and the detector. Id. at [0013]. During operation of the radio
`
`receiver, radio signals are received by the antenna ANT and are input to filter F1.
`
`The output of filter F1 is then input to amplifier A1. The output of amplifier A1 is
`
`then input to filter F2. The output of filter F2 is then input to amplifier A2. The
`
`output of amplifier A2 is then input to mixer M1. The output of mixer M1 is then
`
`input to amplifier A3. The output of amplifier A3 is then input to filter F3. The
`
`output of filter F3 is then input to mixer M2. The output of mixer M2 is then input
`
`to filter F4. The output of filter F4 is then input to amplifier detector DET. From
`
`detector DET, a baseband signal sb is output. Id. at [0012]-[0013]. As another
`
`example, Figure 4 of Rauhala shows an identical signal path. Id. at [0017]-[0018]
`
`and Figure 4.
`
`21. Based on the descriptions of the connections between antenna ANT, the
`
`filters, the mixers, the amplifiers, and detector DET in Rauhala, and based on the
`
`depiction of these components in Figure 2 and Figure 4, a POSITA would have
`
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`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`understood that the signal path extends from antenna ANT through detector DET
`
`to the receiver’s output sb. This signal path is highlighted in annotated Figure 2 and
`
`Figure 4 below:
`
`
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`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`
`
`
`
`22. The signal path shown in each of Figure 2 and Figure 4 of Rauhala passes
`
`through and therefore includes all of antenna ANT, filter F1, amplifier A1, filter
`
`F2, amplifier A2, mixer M1, amplifier A3, filter F3, mixer M2, filter F4, and
`
`detector DET. A POSITA would have understood that these components are all in
`
`the signal path at least by virtue of the lines connecting each respective functional
`
`block in Figures 2 and 4, and by Rauhala’s explicit description of how the
`
`components are coupled to each other. Ex. 1004 at [0012]. Dr. Larson agreed
`
`during his cross-examination. Ex. 1018 at 23:8-26:5.
`
`23. With reference to Figure 2, Rauhala explains that control signals CA1, CA2,
`
`and CA3 are output from control unit 22 to amplifiers A1, A2, and A3, respectively.
`
`The control signals “set[] the supply current” for amplifiers A1, A2, and A3. Id. at
`14
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`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`[0013]. Similar control signals CM1 and CM2 are output from control unit 22 to
`
`mixers M1 and M2, respectively, to set the supply currents for the mixers M1 and
`
`M2. Id. at [0013]. With reference to Figure 4, Rauhala explains that control signal
`
`CA is output from control unit 42 to amplifiers A1 and A2, and control signal CM is
`
`output from control unit 42 to mixers M1 and M2 and amplifier A3. Id. at [0017].
`
`Similar to the control signals of control circuit 22, the control signals of control
`
`circuit 42 also set the supply current for the corresponding components in the
`
`signal path. Id. at [0017]. Control signals CA1, CA2, CA3, CM1, and CM2 of control
`
`circuit 22 are shown highlighted green in annotated Figure 2 below, and control
`
`signals CA and CM of control circuit 42 are also shown highlighted green in
`
`annotated Figure 4 below.
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`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`
`
`
`
`24. As shown in annotated Figure 2, control signals CA1, CA2, CA3, CM1, and CM2
`
`are transmitted from control unit 22 to the signal path. In particular, control signals
`
`CA1, CA2, CA3, CM1, and CM2 are transmitted from control unit 22 to respective
`
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`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`amplifiers (blue) and mixers (red) in the signal path. Similarly, as shown in
`
`annotated Figure 4, control signals CA and CM are transmitted from control unit 42
`
`to respective amplifiers (blue) and mixers (red) in the signal path. Rauhala states
`
`that Figure 6 shows “an example of a linear unit's supply current control” in which
`
`the linear unit is “an amplifier realized by a differential pair.” Ex. 1004 at [0021].
`
`Based on Rauhala’s own characterization of amplifiers as “linear units,” a
`
`POSITA would have readily understood that the circuitry in Figure 6 corresponds
`
`to any or all of amplifiers A1, A2, and A3 within the signal path shown in Figures
`
`2 and 4, and is indeed intended to illustrate how any or all of amplifiers A1, A2,
`
`and A3 function within the signal path.
`
`25. Rauhala further explains that “[s]witches ka and kb,” shown in control circuit
`
`62 of Figure 6, “are controlled with a two-bit digital signal c=AB.” Id. at [0021]. A
`
`POSITA would have understood that any of control signals CA1, CA2, and CA3,
`
`which is transmitted to amplifiers in the signal path of Figure 2 from control unit
`
`22, corresponds to the two-bit digital signal c. Figure 6, reproduced below with
`
`annotations, shows that two-bit digital signal c (green) is transmitted to current
`
`control circuit 62 of the amplifier (blue):
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`17
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`

`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`
`
`26.
`
`Just as control signals CA1, CA2, and CA3 are received by amplifiers A1, A2,
`
`and A3 in the signal path shown in Figure 2, a POSITA would have understood
`
`that two-bit digital signal c is likewise received by an amplifier in the signal path.
`
`A POSITA would therefore have understood that circuit 61 and current control
`
`circuit 62 are collectively an amplifier in a signal path. Contrary to Dr. Larson’s
`
`conclusion, both circuit 61 and current control circuit 62 are therefore within the
`
`signal path. But even if one were to exclude current control circuit 62 and focus
`
`only on circuit 61 of the amplifiers A1, A2, and A3 of the signal path, the
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`impedances (capacitances and resistances) between the terminals of the transistors
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`

`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`used in circuit 61 change with control signals CA1, CA2, and CA3 as discussed in
`
`detail in the previous section. See supra Section II.2.
`
`27.
`
`In a similar manner, Rauhala refers to Figure 7 and states that “another
`
`example of controlling a linear unit's supply current” is shown, where the linear
`
`unit “is an analog multiplier used as a mixer.” Id. at [0023]. Based on Rauhala’s
`
`own characterization of mixers as “linear units,” a POSITA would have readily
`
`understood that the circuitry in Figure 7 corresponds to either or both of mixers M1
`
`and M2 within the signal path shown in Figures 2 and 4, and is indeed intended to
`
`demonstrate how either or both of mixers M1 and M2 function within the signal
`
`path.
`
`28. Rauhala further explains that “[s]witch k,” shown in control circuit 72 of
`
`Figure 7, “is controlled with a one-bit digital signal c.” Id. at [0023]. A POSITA
`
`would have understood that the one-bit digital signal c corresponds to one of
`
`control signals CM1 and CM2, which are transmitted to mixers in the signal path of
`
`Figure 2 from control unit 22, or control signal CM, which is transmitted to mixers
`
`in the signal path of Figure 4 from control unit 42. Figure 7, reproduced below
`
`with annotations, shows that one-bit digital signal c (green) is transmitted to
`
`control circuit 72 of the mixer (red):
`
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`19
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`

`

`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`
`
`29.
`
`Just as control signals CM1 and CM2 are received by mixers M1 and M2 in the
`
`signal path shown in Figure 2 (and just as control signal CM is received by mixers
`
`M1 and M2 in the signal path shown in Figure 4), a POSITA would have
`
`understood that one-bit digital signal c is likewise received by a mixer in the signal
`
`path. A POSITA would have therefore understood that circuit 71 and control
`
`circuit 72 are collectively a mixer in a signal path, and would receive one-bit
`
`digital signal c from another component like control unit 22 or 42. Contrary to Dr.
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`

`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`Larson’s conclusion, both circuit 71 and control circuit 72 are therefore within the
`
`signal path. Even if one were to exclude indispensable control circuit 72 from the
`
`mixer in the signal path, the impedances of the transistors in circuit 71, a circuit
`
`Dr. Larson concedes is in the signal path, would still be adjusted, as explained in
`
`the previous section discussing how the capacitance and resistance between the
`
`terminals of a transistor change with changes in the bias current resulting from
`
`changing digital signal c. See supra Section II.2.
`
`2.
`A POSITA would have understood from the ’202 patent and ’825
`patent that a “signal path” includes amplifiers and mixers in their
`entireties.
`
`30. Dr. Larson’s conclusions that Rauhala’s Figure 6 amplifier and Figure 7
`
`mixer are each only partially within the signal path are contradicted by the Tsividis
`
`patents. Based on the Tsividis patents, a POSITA would have understood a “signal
`
`path” to include amplifiers and mixers in their entirety.
`
`31. The claims of the Tsividis patents define each instance of “signal path” only
`
`by the functional components it includes. Claim 1 of the ’825 patent, for example,
`
`recites “a receiver signal path comprising a plurality of circuits, wherein the
`
`plurality of circuits includes an amplifier, a filter, and a mixer.” IPR2023-00697,
`
`Ex. 1001 at 13:1-3; see also id. at 13:45-48 (claim 3); id. at 16:18-21 (claim 8).
`
`Claim 7 of the ’202 patent similarly recites a “receiver having a signal path
`
`
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`21
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`

`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`comprising a plurality of circuits including at least an amplifier, a filter, and a
`
`mixer.” IPR2023-00698, Ex. 1001 at 13:60-62; see also id. at 14:33-35 (claim 11);
`
`id. at 15:13-15 (claim 13). The claims do not state that only particular portions of
`
`amplifiers or only particular portions of mixers are within the “signal path.”
`
`32. The specifications of the Tsividis patents are consistent with the claims. In
`
`particular, the Tsividis patents repeatedly describe signal paths in terms of the
`
`functional components they include. The Tsividis patents state, for example, that
`
`an “integrated circuit includes a signal path having a low-noise amplifier
`
`configured to receive the signal, a mixer having an input coupled to an output of
`
`the low-noise amplifier, and a low-pass filter having an input coupled to an output
`
`of the mixer.” IPR2023-00697, Ex. 1001 at 2:10-14; IPR2023-00698, Ex. 1001 at
`
`2:12-16. With reference to a receiver shown in Figure 1, the Tsividis patents state
`
`that the “receiver includes a signal path formed by low-noise amplifier 102, I and
`
`Q mixers 104 and 106, low pass filters 108 and 110, and baseband amplifiers 114
`
`and 116.” IPR2023-00697, Ex. 1001 at 4:18-20; IPR2023-00698, Ex. 1001 at 4:19-
`
`21. With reference to Figure 15, the Tsividis patents state that “a transmitter
`
`portion consistent with an embodiment of the present invention [includes] a signal
`
`path formed by gain stage 1510 and power amplifier 1520.” IPR2023-00697, Ex.
`
`1001 at 12:24-27; IPR2023-00698, Ex. 1001 at 12:26-29.
`
`
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`22
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`24 of 45
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`

`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`33. The claims and specification of the Tsividis patents both describe a “signal
`
`path” only in terms of the functional components it includes, such as amplifiers,
`
`mixers, and filters. The Tsividis patents do not purport to exclude any portions of
`
`amplifiers or mixers from a signal path. Based on the claims and the written
`
`description of the Tsividis patents, a POSITA would have understood a “signal
`
`path” to include functional components, such as amplifiers and mixers, in their
`
`entireties.
`
`3.
`The amplifier of Figure 6 and the mixer of Figure 7 cannot be
`divided as Dr. Larson and Patent Owner suggest.
`
`34. By excluding control circuits 62 and 72 from the “signal path,” Dr. Larson
`
`suggests that each of the amplifiers mixers shown in Figure 2 are divisible into
`
`separate portions. This is incorrect. Separating circuit 61 from control circuit 62
`
`would render circuit 61 nonfunctional. Similarly, separating circuit 71 from control
`
`circuit 72 would render circuit 71 nonfunctional.
`
`35. Circuit 61 of Figure 6 is coupled to a higher power supply voltage Vcc
`
`terminal and to a collector of transistor Q2 in control circuit 62. Ex. 1004 at
`
`[0021]. Control circuit 62 is coupled to the higher power supply voltage Vcc
`
`terminal and to lower power supply voltage VEE terminal. Id. As a result of the
`
`configuration, a current kI flows to a collector of transistor Q1. Id. As a result of
`
`the current mirror formed by transistors Q1 and Q2, a proportional current I flows
`
`
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`23
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`

`Declaration of R. Jacob Baker, P.E., Ph.D.
`IPR2023-00697 and IPR2023-00698
`U.S. Patent Nos. 10,129,825 and 10,524,202
`
`
`from circuit 61 to the collector of transistor Q2. Currents kI (yellow) and I (purple)
`
`are shown highlighted below in annotated Figure 6:
`
`
`
`36. For circuit 61 to perform any electrical function, including amplification of a
`
`signal received at the “in” terminals,