UNITED STATES PATENT AND TRADEMARK OFFICE
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`———————
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`———————
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`Apple Inc.,
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`Petitioner,
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`- vs. -
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`Togail Technologies Ltd.,
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`Patent Owner.
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`U.S. Patent No. 10,791,502
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`———————
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`DECLARATION OF CRAIG BISHOP
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`Ex.1005
`APPLE INC. / Page 1 of 41
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`
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`———————
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`Apple Inc.,
`
`Petitioner,
`
`- vs. -
`
`Togail Technologies Ltd.,
`
`Patent Owner.
`
`U.S. Patent No. 10,791,502
`
`———————
`
`DECLARATION OF CRAIG BISHOP
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`Ex.1005
`APPLE INC. / Page 1 of 41
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`Declaration of Craig Bishop
`Inter Partes Review of 10,791,502
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`I.
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`TABLE OF CONTENTS
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`INTRODUCTION ............................................................................................... 3
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`II. QUALIFICATIONS ........................................................................................... 4
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`III. PUBLIC AVAILABILITY OF 3GPP STANDARDS PROPOSALS AND
`TDOCS ....................................................................................................................... 9
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`a.
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`b.
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`c.
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`d.
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`e.
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`f.
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`Prominence and Purpose of 3GPP ........................................................ 9
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`3GPP’s Policy of Making Documents Public .....................................11
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`3GPP Structure and Standards Development Process ........................11
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`3GPP Documents – TDocs ..................................................................13
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`Distribution over the 3GPP Listserv ...................................................15
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`The 3GPP Website’s Public File Repository ......................................18
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`IV. Ex.1007, R2-1801795 (“OPPO”) ......................................................................26
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`V. Ex.1108, R2-1802094 (“Vivo”) ........................................................................29
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`VI. Ex.1012, R2-1800041 (“Asustek”) ...................................................................33
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`VII. Ex.1013, R2-1708072 (“Huawei”) ...................................................................37
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`VIII.
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`DECLARATION.................................................................................41
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`Declaration of Craig Bishop
`Inter Partes Review of 10,791,502
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`I.
`
`INTRODUCTION
`
`I, Craig Bishop, declare as follows:
`
`
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`I have been retained as an independent expert witness on behalf of
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`Apple Inc. related to Inter Partes Review (“IPR”) of U.S. Patent No. 10,791,502
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`(“the ’502 patent”).
`
`
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`I am being compensated for my work in this matter at my accustomed
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`hourly rate. I am also being reimbursed for reasonable and customary expenses
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`associated with my work and testimony in this investigation. My compensation is
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`not contingent on the results of my study, the substance of my opinions, or the
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`outcome of this matter.
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`
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`In the preparation of this declaration I have reviewed Exhibits
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`Ex.1007, Ex.1008, Ex.1012, and Ex.1013, each of which is a type of material that
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`experts in my field would reasonably rely upon when forming their opinions.
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`
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`In forming the opinions expressed within this declaration, I have
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`considered:
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`1) The exhibits listed above; and
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`2) My own academic background, knowledge, and professional
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`experiences in the field of wireless communications and 3GPP
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`standards-development, as described below.
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`
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`Although I have attempted to organize the information presented in
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`3
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`this declaration into helpful sections and/or divisions, my opinions are supported
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`by the information in the declaration in its entirety.
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`II. QUALIFICATIONS
`
` My complete qualifications and professional experience are described
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`in my curriculum vitae, a copy of which has been submitted as Ex.1006. The
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`following is a summary of my relevant qualifications and professional experience.
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`
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`I earned my Bachelor of Electronic Engineering degree with Honors
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`from Polytechnic of Central London in 1989. In 2005, I earned my MSC in
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`Computer Science with Distinction from the University of Kent.
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`
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`After graduating with my first degree, I worked as an operations
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`engineer at the British Broadcasting Corporation (BBC) for 4 years, then as a civil
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`servant at the UK Radiocommunications Agency until 1996, during which time I
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`became involved in telecommunications standardization in the European
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`Telecommunication Standards Institute (“ETSI”), working in particular in
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`Technical Committee Radio Equipment and Systems (TC RES2) concerned with
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`the standardization of Private Mobile Radio (PMR). From 1994 through 1996, I
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`acted as Rapporteur for voice and data related PMR standards ETS 300 113, ETS
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`300 219 and ETS 300 390. I participated as the only TC RES2 delegate on behalf
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`of the UK Radiocommunications Agency, generating proposals in support of UK
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`administration and business requirements, downloading and reviewing other
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`meeting input documents when available, and proposing changes as necessary to
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`ensure input documents and the resulting specifications were in line with said
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`requirements.
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`
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`In 1996, I joined Samsung Electronic Research Institute as a Senior
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`Standards Engineer where I worked for 16 years, eventually becoming Director of
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`Standards and Industry Affairs in 2011. My work at Samsung mainly focused on
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`the standardization of GSM/GPRS, UMTS, and LTE/EPS systems. Initially, I
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`participated in ETSI Special Mobile Group (SMG) committees SMG1, SMG2,
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`SMG4, SMG5, SMG9 and relevant UMTS related sub-committees until 1999,
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`working on the air interface radio access network protocols, service, and terminal
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`aspects of UMTS and GSM/GPRS. I was specifically involved in the ETSI SMG2
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`meetings leading up to selection of WCDMA as the radio access technology for the
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`Frequency Division Duplex mode of UMTS.
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` Beginning in 1998, I worked as a Principal Standards Engineer on the
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`3rd Generation Partnership Project (3GPP) on UMTS. I have been involved with
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`3GPP since its inception. I attended the inaugural 3GPP TSG meetings held in
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`December 1998, and I began attending Working Group (WG) meetings in 1999. I
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`mainly attended Radio Access Network (RAN) WG1, RAN WG2, Services &
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`System Aspects (SA) WG1, Terminals (T) WG2, and other Working Groups and
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`Technical Specification Group (TSG) plenary meetings covering similar technical
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`aspects as in my previous work in ETSI. As examples, RAN WG1 was, and is, a
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`Working Group responsible for the specification of the physical layer of the latest
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`wireless cellular standards, and RAN WG2 was, and is, a Working Group
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`responsible for signaling protocol layers 2 and 3 residing just above the physical
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`layer. As part of this work, I would prepare meeting contributions in support of
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`Samsung’s research and development activities. Also, by way of preparation for
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`each meeting, I would download contributions, typically all of the meeting’s
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`contributions, and review those of interest to Samsung, and where necessary,
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`prepare additional input to the meeting based on said review.
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` Beginning in 2000, I acted as project manager and then as system
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`engineer at Samsung, providing technical requirements for the team working on
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`Samsung’s UMTS modem development. This involved scrutiny of ongoing
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`standardization work, particularly in RAN WG1, RAN WG2, and TSG Core
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`Network (CN) WG1, from which I would download, and assess the impact of,
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`contributions on Samsung’s development project, ensuring that Samsung’s
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`development team was kept informed about the latest developments as layers 2 and
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`3 of the UMTS standard were stabilized.
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` During this period, in addition to authoring and presenting technical
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`contributions for the 3GPP standard, and producing technical requirements for the
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`radio modem, I acted as Rapporteur for 3GPP Technical Reports covering User
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`Equipment (“UE”) capability requirements (3GPP TR 21.904) from 1999–2000,
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`and the Evolution of the 3GPP System (3GPP TR 21.902) in 2003 (the first Study
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`Item to consider the 3GPP system beyond UMTS towards LTE/EPS).
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`
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`In 2005, I became Head of Advanced Technologies, Standards and
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`Regulation (ATSR) at Samsung. In addition to my managerial duties which
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`included responsibility for standards, research, and regulatory engineers including
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`three standards engineers who were regularly attending RAN WG2 and Core
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`Network and Terminals (CT) WG1 Working Groups, I personally continued to
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`work on 3GPP standardization issues. From 2005 until 2008, I regularly attended
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`and participated in SA WG2 meetings, and from 2008 until 2011 I regularly
`
`attended and participated in SA WG1 meetings. I also attended SA plenary
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`meetings from 2008 until I left Samsung in 2013. As well as generating
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`contributions in support of Samsung’s research and development as preparation for
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`each meeting, I would download and review documents from other 3GPP
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`members, identifying those of interest to Samsung and, where necessary, preparing
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`additional contributions on behalf of Samsung. The work required a sound working
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`knowledge of the broader 3GPP system to ensure effective management of the
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`ATSR team, effective participation in meeting discussions, expert assessment of
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`third-party standards contributions, and provision of implementation guidance to
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`Samsung developers.
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` From 2006 until I stopped attending SA WG1 meetings in 2011, I
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`authored and presented over 100 contributions to SA WG2 and SA WG1 meetings
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`at 3GPP and appeared as an author/co-author on 18 patent applications related to
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`User Equipment operation in the IMS and the 3GPP Core Network.
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`
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`In 2011, I became Director of Standards and Industry Affairs at
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`Samsung, and in November of that year I was elected to the Board of ETSI on
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`which I served for a term of 3 years until November 2014.
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` My company Bishop Communications Ltd is a member of ETSI, and
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`as part of various projects undertaken, I have continued to regularly access the
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`3GPP and ETSI document servers, and to keep abreast of 3GPP and ETSI
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`document handling practices.
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` Through my extensive work on 3GPP standardization issues, I have
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`become very familiar with 3GPP’s practices relating to making final specifications,
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`draft standards, and standards-related contributions publicly available.
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` For the purposes of my analysis in this declaration, I have been
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`informed by counsel that a person of ordinary skill in the art (“POSITA”) in the
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`field of the ’502 Patent in the 2017 timeframe, would include someone who had a
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`Bachelor’s degree in electrical engineering, computer engineering, computer
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`science, or equivalent training, and at least 2 - 3 years of technical experience
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`working in the field of cellular telecommunication, including experience designing
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`or implementing 4G / 5G networks. Moreover, I recognize that additional
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`education may substitute for some of the experience, and experience may
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`substitute for educational background.
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`III. PUBLIC AVAILABILITY OF 3GPP STANDARDS PROPOSALS
`AND TDOCS
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` Based on my years of experience working in various capacities on
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`3GPP standards issues, I am familiar with the regular business practices of the 3rd
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`Generation Partnership Project (“3GPP”) relating to technical documents including
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`how 3GPP makes these documents public.
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`a. Prominence and Purpose of 3GPP
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`
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`3GPP was inaugurated in December 1998 to produce Technical
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`Specifications and Technical Reports for the Universal Mobile
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`Telecommunications System (UMTS), a 3G Mobile System based on evolved
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`GSM core networks and a new radio access network known as UTRA (UMTS
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`Terrestrial Radio Access). Ex.1101 at 238. At that time, various standards
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`organizations agreed to cooperate to produce a complete set of globally applicable
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`Technical Specifications for the next 3G standard that would then be transposed
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`into standards by regional standardizations bodies.
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`
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`3GPP is a partnership between organizational partners, market
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`representation partners, and individual members such as companies. Ex.1106 at 4-8
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`(3GPP Working Procedures, 2000). By January 2000, there were 284 companies
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`participating as members of 3GPP. Ex.1101, 241. And by 2017, there were 583
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`members. Ex.1112, 10.
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`
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`3GPP produces technical standards covering cellular
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`telecommunications networks, including User Equipment or Mobile Device (UE)
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`technologies, Radio Access Network (RAN) technologies, Core Network (CN)
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`technologies, and service and system capabilities. Beginning in 1998 and
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`continuing through today, POSITAs were tracking the developments of the latest
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`3GPP specifications and reports to ensure that the standards being developed were
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`in line with the technologies being developed by their employers, and vice-versa. It
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`is my opinion that a POSITA in cellular communications would have to be familiar
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`with 3GPP and the specification-related documents in order to properly perform
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`their job. Indeed, even from the early days of 3GPP, textbooks and articles about
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`cellular communications commonly directed readers to the 3GPP website for
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`information regarding standards development. Ex.1101, 246; Ex.1107, 37. As a
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`POSITA in cellular communications myself by 1999, I would regularly visit and
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`refer others to the 3GPP website for the latest developments in 3G and have
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`continued to do so since that time for the evolution and subsequent generations of
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`mobile communications systems.
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` My personal experience at Samsung confirms 3GPP’s prominence as
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`the preeminent mobile communications specifications setting body even from
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`shortly after its inauguration when engineers and managers at Samsung responsible
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`for developing 3G modem software (but not attending 3GPP meetings) would
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`regularly ask me about which release(s) or version(s) of given 3GPP specifications
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`they should be developing their products. By June 2017, its preeminence had long
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`since been secured and there were 5 billion subscribers to systems employing the
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`GSM family of technologies specified by 3GPP. E.g., Ex.1111, Ex.1110.
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`b. 3GPP’s Policy of Making Documents Public
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`
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`3GPP’s policy has always been to make 3GPP documents available to
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`the public. Because the purpose of 3GPP was worldwide adoption of a common
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`standard, no restrictions on distribution or discussion were placed on 3GPP
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`documents, but rather the dissemination and sharing of 3GPP documents was
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`specifically encouraged and necessary for creating an industry-wide standard.
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`Ex.1108, 8 (“No password is needed to access any information on the 3GPP Web
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`site, all information is openly published.”).
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`c. 3GPP Structure and Standards Development Process
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` Within 3GPP, responsibility for producing specifications has always
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`been delegated to Technical Specification Groups (TSGs). Ex.1106, 11. At its
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`inception, 3GPP was divided into four Technical Specification Groups (TSGs),
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`each covering a particular category of technology, one such TSG being the Radio
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`Access Network (RAN). POSITAs will be aware of the division of work by subject
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`matter among the TSGs and among the Working Groups (WGs) within each TSG.
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`Ex.1102, 175–76; Ex.1103, 46 (Figure 4.3 showing division of work by subject
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`matter among RAN WGs in 2001). In the 2017-2018 timeframe, there remained
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`three Technical Specifications Groups each comprising a number of Working
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`Groups (WGs). Ex.1109. Each WG also focusses on particular subject matter, and
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`the majority of the standards-development work is conducted at the WG level in
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`regular (approximately bi-monthly) meetings. Ex.1101, 243. In addition,
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`particularly at times when major new technologies are being defined, ad hoc
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`meetings are sometimes held that focus only on those technologies, e.g., LTE, 5G
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`New Radio (“5GNR” or just “NR”). A description of each Working Group’s
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`technology area can be found on the Working Group home pages on the 3GPP
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`website. See, e.g., Ex.1116 (RAN WG2 Homepage). For example, RAN WG2
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`(also called “RAN2” or “R2”) was and remains “in charge of the Radio Interface
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`architecture and protocols (MAC, RLC, PDCP)” including “the specification of the
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`Radio Resource Control (RRC) protocol.” Ex.1116, 1.
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` The Working Groups meet regularly. The attendees (also called
`
`“delegates”) at these meetings are engineers representing telecommunications
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`companies from around the world, including Nokia, Samsung, AT&T, Ericsson,
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`Qualcomm, and Huawei among others. Ex.1115. RAN Working Group 2 meetings
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`often had around 300 delegates in attendance in 2017 - 2018. Ex.1115, (listing 295
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`delegate participants at RAN WG2 Meeting #101). The vast majority of these
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`delegates were and would have represented POSITAs.
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` Although attendance at 3GPP meetings was generally limited to 3GPP
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`members, the public, including POSITAs, would have been made aware of
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`Working Group meeting dates and times as well as the technical documents it
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`produced on 3GPP’s website. Ex.1116 (archived RAN WG2 page having links to
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`meeting information, email exploder lists, and technical documents); Ex.1114
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`(3GPP Calendar page). Interested POSITAs would have been well aware of the
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`meeting information pages for each TSG Working Group in 2017 - 2018.
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`d. 3GPP Documents – TDocs
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` The technical specifications and reports developed by 3GPP were and
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`are driven by the technical contributions of 3GPP member companies. As part of
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`that development process, various types of documents are produced. As relevant to
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`this case, the 3GPP process involves the consideration of temporary documents or
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`“TDocs,” which are also referred to as proposals, contributions, or change requests.
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`TDocs result in the production of technical specifications.
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` Prior to each Working Group meeting, members of the Working
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`Group prepare TDocs to e.g., identify, discuss, and/or propose a new feature or
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`change(s) to an existing feature or to identify a technical issue for discussion.
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`POSITAs will know that TDocs can be a helpful source of technical information
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`regarding the 3GPP specifications. Ex.1102, 175 (textbook explaining that “[o]ne
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`way to find a more detailed description of the specific methodology or parameter
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`in the specification is to go through the contribution papers (called technical
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`documents, or tdocs) that 3GPP uploads on their meeting website”).
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` Each TDoc is assigned a TDoc number, according to a standard
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`format set by 3GPP.1 As described in the 3GPP Working Procedures from 2016,
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`the numbering system followed the format xminnzzzz. Ex.1113,19-20. This is the
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`same format that has been in use since 1999. Within the format, “x” referred to the
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`relevant TSG. For example, “R” was used for TSG RAN. Likewise, “m” referred
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`to the relevant Working Group. Ex.1113, 20. A document for RAN WG2 would
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`therefore begin with “R2.” Ex.1113, 20. The two digits “nn” represented the year
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`(e.g., 17), and the digits “zzzz” represented the unique document number2.
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`Ex.1113, 20.
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` Each TDoc would include in its header the meeting at which the
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`contributor intended the TDoc to be discussed. Most TDocs were uploaded to the
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`
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`1 Some documents other than technical contributions (such as meeting reports)
`were also assigned TDoc numbers, for ease of reference.
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`2 In 1999 there were three ‘z’ digits, increasing to four in 2000. A fifth ‘z’ digit
`was added by RAN Working Group 2 from 2017 to cater for the increasing number
`of TDocs being submitted each year.
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`3GPP website for public viewing prior to the relevant Working Group meeting
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`listed on the TDoc, although some TDocs, including those created during
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`meetings, were uploaded during or after the meeting. Ex.1108, 9. Specifically,
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`“TDoc numbers start to be allocated some weeks before a 3GPP meeting, and the
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`authors then create [the TDocs] and they or the group’s secretary uploads them to
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`the public file server as soon as possible.” Ex.1108, 9 (emphasis added). The
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`documents were uploaded to the public file repository in an area allocated to the
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`particular Working Group. Ex.1116 (RAN WG2 Homepage with link to WG2’s
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`“Meeting documents”). Immediately upon upload, any member of the public could
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`download and access the TDocs and other documents offered for discussion. This
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`is the process that POSITAs have known to be in place for decades which has been
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`in place since I began attending Working Group meetings in 1999.
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`e. Distribution over the 3GPP Listserv
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` An important means of distributing draft specifications and other
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`information to 3GPP members, interested POSITAs, and interested members of the
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`public was through the 3GPP email listservs (also referred to as the “email
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`exploder” or “email reflector”). All TSGs and Working Groups, including TSG
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`RAN, RAN WG1, and RAN WG2, have listservs corresponding to their groups.
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`Each listserv acts as an email alias that distributes emails and email attachments
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`sent to that alias to every person subscribed to that listserv.
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` Subscribing to a listserv was simple and was open to any member of
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`the public—not just 3GPP members. Ex.1146. The email listservs were featured
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`prominently on 3GPP’s Specification Groups page and could be accessed via the
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`“Email Lists” link. Ex.1145. That link would take a user to a page providing
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`instructions to subscribe to and access the list of ETSI email listservs including
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`those for 3GPP. Ex.1146. It is my opinion that the 3GPP email listservs were well
`
`known among persons interested in following or participating in the development
`
`of wireless cellular standards. Ex.1101, 240 (textbook noting that “[g]iven that
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`3GPP has participants from all over the world, the use of the Internet, email
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`exploders [i.e., listservs] and other such facilities have proved invaluable for
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`distributing and sharing information, working drafts and so on”); Ex.1105, Section
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`5 (“The vast majority of the technical discussions and decision making in both
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`IETF and 3GPP is done over mailing lists. … It is recommended that interested
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`individuals subscribe to and participate in these lists.”).
`
` There were hundreds of subscribers (and often over a thousand) to the
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`RAN WG1 and RAN WG2 listservs. Ex.1144. The people that subscribed were
`
`typically engineers, such as me, but also technology strategists and technical
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`managers. The subscriber list typically included at least all those persons who
`
`planned to attend an upcoming meeting where a TDoc may be discussed. The
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`typical practice among people who were to attend an upcoming meeting was to use
`
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`the WG’s listserv to review and discuss opinions about the ideas conveyed in
`
`TDocs. The email listserv for RAN WG2 provided an efficient way for
`
`contributors to quickly and efficiently disseminate their views. The number of
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`subscribers for a particular WG listserv usually far exceeded the number of people
`
`attending those WG meetings. For example, 295 delegates attended RAN WG2
`
`Meeting #101, whereas the RAN WG2 email list had around 1000 subscribers
`
`between 2012 and 2021. See, e.g., Ex.1144, Ex.1143.
`
` No confidentiality limitations or restrictions on further dissemination
`
`were placed on documents distributed via the listservs. Ex.1108, 9 (“This
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`distribution on the group’s email exploder is important, because once that happens,
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`the document is effectively in the public domain, since membership of the exploder
`
`is open to all and is (almost) unpoliced.”) (emphasis added). This has been the
`
`practice and understanding since I became involved with 3GPP in 1998-1999. The
`
`listservs were also used to distribute information about upcoming TSG or WG
`
`meetings, such as invitations, draft agenda and draft reports for each meeting. E.g.,
`
`Ex.1142 (listserv emailed invitation to RAN2 meeting #101); Ex.1141 (listserv
`
`emailed draft agenda for RAN2 meeting #101); Ex.1140 (listserv email attaching
`
`draft report from RAN2 meeting #101).
`
` The listserv emails were (and remain) archived in a public online
`
`archive (available at http://list.etsi.org/scripts/wa.exe?INDEX). In my experience,
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`Inter Partes Review of 10,791,502
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`this archive has existed and been accessible to POSITAs since the email lists were
`
`created in 1998. Ex.1104 (archived copy of 1998 email). Each archived email
`
`contains a computer-generated date stamp indicating when the email was sent and
`
`thereby when any attached document became publicly disclosed through
`
`distribution to listserv subscribers. The listserv archives are text searchable, and
`
`include advanced searching features. For example, and without limitation, the
`
`archives can be searched using keywords, quoted phrases, and terms and
`
`connectors (e.g., “and,” “or,” and “and not”). The archives have been text
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`searchable since at least 2002.
`
`f. The 3GPP Website’s Public File Repository
`
` All TDocs, technical reports, and technical specifications have also
`
`always been freely available to interested POSITAs (and to any interested member
`
`of the public) through the public file repository accessible via the 3GPP website.
`
`POSITAs would have been well aware of 3GPP and of the 3GPP website. 3GPP
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`documents were accessible to any member of the public through the 3GPP website
`
`without providing any login credentials or other exclusive access criteria.
`
`
`
`It is my opinion that, during the relevant 2017 - 2018 timeframe,
`
`POSITAs could and did locate relevant documents of interest on the 3GPP website
`
`using reasonable diligence based on the website’s indexing scheme or the TDoc’s
`
`naming convention. The documents on the 3GPP website were (and remain)
`
`
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`Inter Partes Review of 10,791,502
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`organized according to the relevant Working Groups within 3GPP (each of which
`
`focused on particular subject matter) and then further organized based on the
`
`meetings of those groups. POSITAs would have known which Working Groups
`
`focused on particular subject matter.
`
` An interested POSITA (or any member of the public) could locate
`
`documents of interest by first navigating a web browser to the 3GPP website
`
`(www.3gpp.org/home.htm). For example, in the 2017 - 2018 timeframe, to locate
`
`documents from the 3GPP home page, a user could have clicked “Specification
`
`Group” and then the link to the Working Group of their choice, e.g., RAN WG2.
`
`Ex.1109; Ex.1116. The accessed page contained links to the 3GPP’s public file
`
`repository. Ex.1139. By way of an alternative to navigating to the 3GPP file
`
`repository from the 3GPP website, a user could have accessed the file repository
`
`directly through the web address www.3gpp.org/ftp. Ex.1138, or using dedicated
`
`FTP client software connecting to ftp.3gpp.org.
`
` The top two levels of indexing within the file repository are based
`
`wholly on subject matter, as reflected by the division of subject matter among the
`
`various TSGs and Working Groups. Specifically, an individual would select the
`
`relevant TSG covering the subject matter of interest:
`
`
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`Inter Partes Review of 10,791,502
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`Ex.1138. If the individual were interested in the radio access aspects of 3GPP, they
`
`would click “tsg_ran.” From there, the individual would click on the particular
`
`RAN Working Group covering the subject matter of interest:
`
`
`
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`Ex.1137. For example, if the individual were interested in the Radio Interface
`
`architecture and protocols (MAC, RLC, PDCP), the specification of the Radio
`
`Resource Control protocol, the strategies of Radio Resource Management and the
`
`services provided by the physical layer to the upper layers, the individual would
`
`know to choose the folder for WG2. Ex.1139.
`
` Once a user is in the relevant Working Group folder (RAN WG2 in
`
`this example), an individual would see a list of all meetings held by RAN WG2:
`
`
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`Inter Partes Review of 10,791,502
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`Ex.1139. As shown, a folder existed for each meeting. For example,
`
`“TSGR2_101” corresponds to TSG RAN WG2 Meeting #101, and the timestamp
`
`associated with the meeting #101 directory indicates that as of January 27, 2018
`
`(the date of the archive in Ex.1139), it had last been updated on September 14,
`
`
`
`
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`2017. Ex.1139.
`
` A POSITA would know which meeting(s) would have covered
`
`particular subject matter based on the publicly available meeting agendas. E.g.,
`
`Ex.1136 (proposed agenda for RAN WG2 Meeting #101). Many POSITAs would
`
`have received the meeting agendas directly via the WG listservs Ex.1141. The
`
`meeting agendas were usually stored on the 3GPP website server within the agenda
`
`folder for each meeting. Ex.1135 (RAN WG2 Meeting #101 Folder). Further, A
`
`POSITA could ascertain what subject matter was addressed at each meeting by
`
`reviewing the draft or approved report issued after each meeting. E.g., Ex.1130
`
`(draft report of RAN WG2 Meeting #101). Such reports were also included within
`
`each meeting folder:
`
`
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`Ex.1135.
`
`In my experience, whilst the servers used for 3GPP file repository and many of its
`
`directories have been updated since 1999, the original upload date for files
`
`including specifications has always been preserved, providing a true and accurate
`
`indication of their earliest availability for download.
`
` Once an individual navigated to the desired meeting folder, for
`
`example “TSGR2_101,” the individual could then select the “docs” folder to view
`
`the documents associated with that meeting. The documents within this folder were
`
`listed by TDoc number, and POSITAs would have known to review the summary
`
`meeting report for each meeting, as well as the email listserv, to determine what
`
`topics were discussed at that meeting. Ex.1134; Ex.1140; Ex.1133 (list of TDocs
`
`submitted to RAN WG2 #101); Ex.1133 (ftp directory listing for RAN WG2 #101
`
`TDocs list). It was common knowledge that a list of TDocs existed and that it
`
`could be used to identify relevant TDocs. In the TDocs list, each TDoc was listed
`
`by TDoc number, title (reflecting subject matter), source (i.e., the party who
`
`contributed the TDoc), as well as the agenda item that TDoc related to and other
`
`parameters. Ex.1132. For example, the end of meeting (“eom”) TDocs list for from
`
`RAN WG2 Meeting #101 indicates that some 2405 documents were submitted for
`
`that meeting. Thus, a POSITA could narrow the set of relevant TDocs to those of
`
`interest based on the categorization of the TDoc by agenda item. It was also well
`
`
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`known to POSITAs that a list of TDocs for a particular Working Group meeting
`
`was accessible via on the 3GPP website.
`
`
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