throbber

`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`Xiaodong Li, et al.
`In re Patent of:
`10,965,512 Attorney Docket No.: 18768-0206IP1
`U.S. Patent No.:
`March 30, 2021
`
`Issue Date:
`Appl. Serial No.: 17/012,813
`
`Filing Date:
`September 4, 2020
`
`Title:
`METHOD AND APPARATUS USING CELL-SPECIFIC AND
`COMMON PILOT SUBCARRIERS IN MULTI-CARRIER,
`MULTI CELL WIRELESS COMMUNICATION NETWORKS
`
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`DECLARATION OF MATTHEW C. VALENTI, Ph.D. IN
`SUPPORT OF PETITION FOR INTER PARTES REVIEW OF
`U.S. PATENT NO. 10,965,512
`
`
`
`
`1
`
`GM 1035
`
`

`

`I.
`
`Engagement
`1.
`I have been retained by General Motors LLC, Nissan North
`
`America, Inc., Tesla, Inc., and American Honda Motor Co., Inc. (“Petitioner”
`
`or “Petitioners”) to provide this declaration concerning the technical subject
`
`matter relevant to a petition for inter partes review of U.S. Patent No.
`
`10,965,512 (“’512 patent”).
`
`2.
`
`I am over 21 years of age and otherwise competent to make this
`
`Declaration. I make this Declaration based on facts and matters within my own
`
`knowledge and on information provided to me by others.
`
`3.
`
`Specifically, I was asked to review the declaration of Dr. Paul Min
`
`that was submitted by the Petitioner in IPR2022-01539 as Exhibit 1003 (“the
`
`Min Declaration”) and form an opinion of whether I agreed with the facts,
`
`analysis, and conclusions in that declaration.
`
`4. My compensation in this matter is not based on the substance of my
`
`opinions or the outcome of this matter. I have no financial interest in the
`
`Petitioners.
`
`5.
`
`In writing this declaration, I have considered my own knowledge
`
`and experience, including my work experience in the field of mobile and
`
`wireless communication systems and my experience working with others
`
`2
`
`

`

`involved in this field, including in the design and analysis of mobile and
`
`wireless communication systems.
`
`II. Background and Qualifications
`
`A. Educational Background
`6.
`I received a Bachelor of Science degree in Electrical Engineering
`
`from the Virginia Polytechnic Institute & State University (Virginia Tech) in
`
`May 1992. I received a Master of Science degree in Electrical Engineering
`
`from Johns Hopkins University in May 1995 and a Ph.D. in Electrical
`
`Engineering from Virginia Tech in 1999.
`
`B.
`7.
`
`Professional Experience
`From 1992 to 1995 I served as an Electronics Engineer at the
`
`U.S. Naval Research Laboratory in Washington DC. During this time, I worked
`
`on adaptive antenna
`
`technology,
`
`including systems
`
`that performed
`
`beamforming.
`
`8.
`
`From 1995 to 1999, I was a Graduate Research Assistant and
`
`Instructor in the Bradley Department of Electrical and Computer Engineering
`
`at Virginia Tech. For my Ph.D. research while working as a research assistant,
`
`I conducted in-depth investigations into signal processing and error-control
`
`coding techniques specifically tailored for mobile radio systems. A key focus
`
`
`
`3
`
`

`

`of my research was on understanding the crucial role played by pilot symbols
`
`and their utilization in channel estimation processes.
`
`9.
`
`From 1999 to present, I have been a faculty member at West
`
`Virginia University in Morgantown, West Virginia, starting out as an Assistant
`
`Professor, being promoted to Associate Professor with tenure in 2005, and then
`
`to Professor in 2010. At WVU, I regularly teach the senior undergraduate
`
`course on Wireless Networking (CPE 462), which covers key concepts behind
`
`modern cellular networks, including orthogonal frequency division multiple
`
`access (OFDMA) and techniques for managing interference such as frequency
`
`reuse. I also teach graduate courses on Coding Theory (EE 567) and
`
`Communication Theory (EE 561). In addition to my teaching, I run an active
`
`funded research program focused on wireless communications and signal
`
`processing. I have advised over 50 graduate students who worked in my lab,
`
`including 10 Ph.D. students, to degree completing.
`
`10.
`
`I have authored numerous technical papers on various aspects of
`
`mobile and wireless communication systems that have been published in well-
`
`respected, peer-reviewed journals, such as the IEEE Transactions on
`
`Communications, IEEE Transactions on Wireless Communications, IEEE
`
`Transactions on Vehicular Technology, and the International Journal on
`
`Wireless Information Networks.
`
`4
`
`

`

`11.
`
`A representative publication of mine is entitled “Iterative channel
`
`estimation and decoding of pilot symbol assisted turbo codes over flat-fading channels”
`
`which was published in the Sept. 2001 issue of the IEEE Journal on Selected
`
`Area in Communications. In this paper, I developed refined methods for
`
`performing channel estimation for wireless communication systems that use
`
`pilots and error-control codes. The paper has been cited over 390 times by other
`
`researchers who found the work useful.
`
`12.
`
`Taken as a whole, my academic and practical experience have
`
`given me a substantial basis upon which to evaluate the technology that is in
`
`question in the claims of the ’512 Patent. Based on my experience and
`
`education, and the acceptance of my publications and professional recognition
`
`by peers in my field, I believe that I am qualified to opine as to the knowledge
`
`and level of skill of one of ordinary skill in the art at the time of the alleged
`
`invention of the ’512 patent (which I further describe below) and what such a
`
`person would have understood at that time, and the state of the art during that
`
`time.
`
`13.
`
`A complete copy of my curriculum vitae, which includes a list of
`
`my publications and contains further details on my education, experience,
`
`publications, patents, and other qualifications to render an expert opinion, is
`
`attached as Appendix A.
`
`
`
`5
`
`

`

`III.
`
`Information Considered
`14.
`In drafting this declaration and forming the opinions therein, I
`
`relied on my years of education, research, and industry and academic
`
`experience, including my direct experience and contribution in the area of
`
`design and analysis of mobile and wireless communication systems. I also
`
`relied on the materials listed in Appendix B.
`
`15.
`
`I reserve the right to rely upon these materials and other materials
`
`to rebut arguments raised by the Patent Owner.
`
`16.
`
`I reserve the right to supplement this declaration in response to
`
`additional evidence that may become known.
`
`17.
`
`In connection with any testimony that I may be asked to give to
`
`the Patent Trial and Appeal Board, I may use as exhibits various documents that
`
`relate to matters set forth in this declaration.
`
`IV. Opinions
`18.
`After considering the Min Declaration and the other materials
`
`listed in Appendix B, I agree with the facts, analysis, and conclusions in the
`
`Min Declaration, and I adopt the testimony in sections II and IV-XV of the Min
`
`Declaration as my own for purposes of this proceeding with the exception that,
`
`for Section IX, I would substitute my biographical information for Dr. Min’s.
`
`More specifically, for Section IX, I note that, like Dr. Min, I too was a POSA
`
`6
`
`

`

`at the time based on my Ph.D. from Virginia Tech in 1999 and my at least five
`
`years of experience with mobile wireless communications, and I adopt Dr.
`
`Min’s definition of a POSA.
`
`19.
`
`I declare all statements made herein of my own knowledge are
`
`true and that all statements made on information and belief are believed to be
`
`true; and further that the statements were made with the knowledge that willful
`
`false statements and the like so made are punishable by fine or imprisonment, or
`
`both, under Section 1001 of Title 18 of the United States Code.
`
`
`
`
`
`
`
`Date: June 2, 2023
`
`Respectfully submitted,
`
`By:
`Matthew C. Valenti, Ph.D.
`
`
`
`
`
`7
`
`

`

`APPENDIX A
`APPENDIX A
`
`8
`
`

`

`MATTHEW C. VALENTI, P.E.
`IEEE Fellow
`Professor
`Lane Department of Computer Science and Electrical Engineering
`West Virginia University
`
`–– CONTACT ––––––––––––––––––––––––––––––––––––––––––––––––––––––––––
`929 Riverview Dr
`
`Morgantown, WV 26505 USA
` (304) 685-9322
` Matthew.C.Valenti@gmail.com
` http://community.wvu.edu/~mcvalenti/
`–– EDUCATION ––––––––––––––––––––––––––––––––––––––––––––––––––––––––
`
`Ph.D. in Electrical Engineering
`Virginia Polytechnic Institute & State University (Virginia Tech), Blacksburg, VA, August 1999
`M.S. in Electrical Engineering
`Johns Hopkins University, Baltimore, MD, May 1995
`B.S. in Electrical Engineering
`Virginia Polytechnic Institute & State University (Virginia Tech), Blacksburg, VA, May 1992
`–– PROFESSIONAL EXPERIENCE –––––––––––––––––––––––––––––––––––––––
`West Virginia University, Lane Department of Computer Science and Electrical Engineering
`Professor – 2010 to present
`Associate Professor – 2005 to 2010
`Assistant Professor – August 1999 to 2005
`Administrative Capacities:
`Raymond J. Lane Department Chair – July 2020 to June 2021
`Interim Chair – July 2019 to June 2020
`Center for Identification Technology Research (CITeR), an NSF I/UCRC
`Director, WVU Site – August 2014 to present.
`Virginia Tech, Bradley Department of Electrical and Computer Engineering
`Bradley Fellow, Graduate Research Assistant, and Instructor – August 1995 to July 1999
`U.S. Naval Research Laboratory, Washington, DC
`Electronics Engineer – Summer 1991, May 1992 to August 1995
`–– LICENSES –––––––––––––––––––––––––––––––––––––––––––––––––––––––––––
`Professional Engineer (P.E.)
`Registered in the state of West Virginia since 2011
`Amateur Radio License
`Amateur Extra Class. Call sign KC8NHN. Licensed since 1999
`
`9
`
`

`

`2
`
`MATTHEW C. VALENTI
`
`–– TECHNICAL EXPERT EXPERIENCE –––––––––––––––––––––––––––––––––––
`1. DLA Piper for Motorola
`Dates: 2023
`Venue: US. International Trade Commission (ITC)
`Case: Maxell, Ltd. v. Motorola Mobility LLC, Lenovo Group Ltd., and Lenovo (U.S.) Inc.
`In the Matter of Certain Mobile Electronic Devices
`US. International Trade Commission (ITC) Investigation No. 337-TA-1324
`
`Technology: LTE and 5G NR wireless technology. Dual connectivity operation.
`Activity:
`Expert Report (invalidity), rebuttal report (noninfringement, domestic industry
`practice). Deposition (Mar. 15, 2023). Prepared to give court testimony.
`Case settled on June 20, 2023, two days before the hearing was scheduled.
`2. Sidley Austin for Lenovo
`Dates: 2022-2023
`Venue: United States District Court; District of Delaware
`Cases: Interdigital Technology Corporation v. Lenovo Holding Company, Inc.,
`
`Civil Action No. 19-1590-LPS
`Technology: Wireless technology including control signaling for LTE and HSPA.
`Activity:
`Expert Reports (invalidity and noninfringement). Deposition (Aug. 26, 2022).
`Case is ongoing with a pending trial.
`3. Kirkland & Ellis for Samsung
`Dates: 2022-2023
`Venue: United States Patent and Trademark Office
`Cases: Petition for Inter Partes Review (IPR) of US Patent Nos. 7,116,710; 7,421,032;
`7,916,781; and 8,284,833 (all owned by California Institute of Technology and petitioned
`by Samsung Electronics Co., Ltd)
`Technology: Forward error correction (FEC) coding including low density parity check (LDPC)
`codes and irregular repeat accumulate (IRA) codes.
`Expert Declarations (in support of IPR Petitions). Case is ongoing.
`Activity:
`4. Fish & Richardson for Apple
`Dates: 2022
`Venue: United States District Court; Eastern District of Texas Marshall Division
`Cases: Ericsson, Inc. and Telefonaktiebolaget L.M. Ericsson v. Apple Inc.,
`
`Civil Action No. 2:21-cv-0036
`Technology: 5G NR wireless technology.
`Activity:
`Expert Reports (Patent portfolio technical evaluation and rebuttal). Deposition (Sept.
`28, 2022). Prepared to give testimony before a jury.
`Case settled on December 8, 2022 after the fourth day of trial.
`5. Fish & Richardson for Apple and its Brazilian entities
`Dates: 2022
`Venue: Brazil Courts: (1) 1st Business Court of the Capital District of Rio de Janeiro State (Case
`No. 0010664-19.2022.8.19.0001), and (2) Federal Court of Rio de Janeiro, 31st Court
`specialized in IP matters (Case No. 5016043-83.2022.4.02.5101)
`Cases: (1) Telefonaktiebolaget L.M. Ericsson vs. Allied Tecnologia S.A. and (2) Apple
`Computer Brasil Ltda. and Allied Tecnologia S.A. vs. Telefonaktiebolaget L.M. Ericsson
`Technology: Wireless technology including random access signaling for LTE.
`Activity:
`Expert Declarations (invalidity, noninfringement, and rebuttal).
`
`10
`
`

`

`MATTHEW C. VALENTI
`
`
`3
`
`Activity:
`
`6. Erise IP for Apple
`Dates: 2021-2022
`Venue: United States Patent and Trademark Office
`Cases: Petition for Inter Partes Review (IPR) of US Patent Nos. 8,023,990; 8,798,658; and
`9,277,436 (all owned by Ericsson). IPR cases IPR2021-00459, IPR2022-00461, and
`IPR2022-00467 (petitioned by Apple Inc.). Request for Ex Parte Re-examination of US
`Patent No 10,476,722 (owned by Ericsson). Attorney Docket No. Apple.990
`Technology: Wireless technology including LTE-A minimization of drive testing (MDT) and 5G
`NR synchronization.
`Expert Declarations (in support of IPR Petitions and Ex Parte Re-examination).
`Deposition (Sept. 21, 2022 for the ‘658 patent).
`7. Foley Hoag for Rideshare Displays, Inc.
`Dates: 2021-2022
`Venue: United States Patent and Trademark Office
`Cases: Patent owner’s response to Inter Partes Review (IPR) of US Patent Nos. 9,892,637;
`10,169,987; 10,395,525; 10,559,199; and 10,748,417 (all owned by Rideshare Displays,
`Inc.). IPR cases IPR2021-01598 to IPR2021-01602 (petitioned by Lyft, Inc.)
`Technology: Vehicle identification technology.
`Activity:
`Expert Declarations (in support of Patent Owner’s responses to IPR Petitions,
`responses to Board’s decision to institute, and motions to amend claims). Deposition
`(Sept. 9, 2022).
`8. Fish & Richardson for LG Electronics, Inc., LG Electronics USA, Inc., Dell Inc., and Dell
`Technologies, Inc.
`Dates: 2021-2022
`Venue: United States Patent and Trademark Office
`Cases: Petition for Inter Partes Review (IPR) of US Patent Nos. 8,467,366 and 10,833,908
`(owned by Neo Wireless LLC). IPR cases IPR2021-01480 and IPR2022-00277
`(petitioned by Dell Inc.)
`Technology: Wireless technology including OFDM transmissions, random access, and ranging
`signals.
`Expert Declarations (in support of IPR Petitions).
`Activity:
`9. Kirkland & Ellis for Lenovo
`Dates: 2020-2021
`Venue: UK High Court
`Cases:
`InterDigital Technology Corporation and others v Lenovo Group Limited and others
`(Claim No. HP-2019 000032)
`Technology: Wireless technology including control signaling for LTE.
`Activity:
`Expert Report (invalidity, non-essentiality, two rebuttal reports). Court Testimony
`(UK bench trial): Mar. 5-9, 2021.
`10. Fish & Richardson for LG Electronics, Inc.
`Dates: 2019-2020
`Venue: United States Patent and Trademark Office
`Cases: Petition for Inter Partes Review (IPR) of US Patent No. 7,039,435 (owned by Bell
`Northern Research). IPR case IPR2020-00319 (petitioned by LG Electronics, Inc.)
`Technology: Wireless technology including power control of wireless transmissions.
`Activity:
`Expert Declaration (in support of IPR Petition).
`
`11
`
`

`

`MATTHEW C. VALENTI
`
`
`4
`
`11. Fish & Richardson for Apple
`Dates: 2017-2019
`Venue: United States District Court; Southern District of California
`Cases: Apple Inc. v. Qualcomm Inc., Civil Action No. 3:17-cv-00108
`Technology: LTE wireless technology.
`Activity:
`Expert Report (Patent portfolio technical evaluation). Deposition (Oct. 17, 2018).
`Testimony before jury was scheduled for April 22, 2019, but case settled after
`opening arguments.
`12. Quinn Emanuel Urquhart & Sullivan for Samsung
`Dates: 2017-2018
`Venue: United States District Court; Northern District of California (San Francisco Division)
`and United States Patent and Trademark Office
`Cases: Samsung Electronics Co., LTD, et al. (counterclaim-plaintiffs) v. Huawei Technologies
`Co., LTD., et al. (counterclaim-defendants), Case No. 16-cv-02787-WHO
`Huawei Technologies Co., LTD vs. Samsung Electronics Co., LTD, Case IPR2017-
`01974 (US Patent 8,457,588)
`Huawei Technologies Co., LTD vs. Samsung Electronics Co., LTD, Case IPR2017-
`01982 (US Patent 8,228,827)
`Technology: LTE wireless technology.
`Activity:
`Declarations (Claim Construction, 2 Patent Owner’s Responses to Petition for IPR);
`Expert Report (Infringement); Rebuttal Report (Validity). Depositions (June 20,
`2018, Aug. 10, 2018, Aug. 11, 2018).
`13. Baker Botts for AT&T; Gibson, Dunn & Crutcher for T-Mobile
`Dates: 2016-2017
`Venue: United States District Court; District of Delaware
`Cases:
`(a) Intellectual Ventures I LLC v. AT&T Mobility LLC et al., Civil Action No. 12-CV-
`193-LPS (D. Del.); Intellectual Ventures I LLC v. AT&T Mobility LLC et al., Civil
`Action No. 1:15-CV-00799-LPS.
`(b) Intellectual Ventures I LLC v. T-Mobile USA Inc. et al. D. Del. Case No. 1:13-cv-
`1632-LPS.
`Technology:
`HSDPA wireless technology.
`Activity:
`Expert Report; Declaration; Sur-Reply Report. Deposition (Mar. 23, 2017).
`14. Rothwell Figg for LG; Paul Hastings for Samsung; Mayer Brown for Motorola Mobility
`Dates: 2016
`Venue: United States District Court; Southern District of California
`Cases:
`(a) Odyssey Wireless Inc. v. LG Electronics USA, Inc. et al., Civil Action No. 3:15-cv-
`01746-H-RBB (S.D. Cal.).
`(b) Odyssey Wireless Inc. v. Samsung Electronics Co. et al., Civil Action No. 3:15-cv-
`01738-H-RBB (S.D. Cal.).
`(c) Odyssey Wireless Inc. v. Motorola Mobility, Civil Action No. 3:15-cv-01741-H-RBB
`(S.D. Cal.).
`Technology: LTE wireless technology.
`Activity:
`Expert Report (noninfringement). Deposition (Aug. 24, 2016).
`15. Sheppard Mullin for Samsung; Gibson Dunn and Wilmer Hale for Intel; Boies Schiller for Apple
`Dates: 2016
`Case: Various regulatory agencies’ investigations of Qualcomm Incorporated (“Qualcomm”),
`including the Korean Fair Trade Commission (the “KFTC”) and the United States
`Federal Trade Commission (the “FTC”).
`Technology: LTE wireless technology.
`Activity:
`Declaration (technical analysis of patent portfolio).
`
`
`
`12
`
`

`

`5
`
`MATTHEW C. VALENTI
`
`16. Boies, Schiller & Flexner for Apple; Sheppard, Mullin, Richter & Hampton for HTC; Kilpatrick
`Townsend & Stockton for Lenovo and Motorola Mobility; Quinn Emanuel Urquhart & Sullivan
`for Samsung; McDermott Will & Emery for ZTE; Sidley Austin for Microsoft
`Dates: 2016
`Venue: United States District Court; District of Delaware
`Cases:
`(a) Evolved Wireless, LCC, v. Apple Inc., Civil Action No. 1:15-cv-00542-SLR.
`(b) Evolved Wireless, LCC, v. HTC Corporation and HTC America, Inc., Civil Action
`No. 1:15-cv-00543-SLR. (c) Evolved Wireless, LCC, v. Lenovo Group Ltd., Lenovo
`(United States) Inc., and Motorola Mobility, Civil Action No. 1:15-cv-00544-SLR.
`(d) Evolved Wireless, LCC v. Samsung Electronics Co., Ltd. and Samsung Electronics
`America, Inc., Civil Action No. 1:15-cv-00545-SLR. (e) Evolved Wireless, LCC v. ZTE
`Corporation, ZTE (USA) Inc., and ZTE Solutions Inc., Civil Action No. 1:15-cv-00546-
`SLR. (f) Evolved Wireless, LCC v. Microsoft Corporation, Microsoft Mobile OY and
`Nokia Inc., Civil Action No. 1:15-cv-00547-SLR.
`Technology: LTE wireless technology.
`Activity:
`Declaration (claim construction).
`17. Williams & Connolly
`Dates: 2015
`Case: Confidential Parties (Leading Global Wireless Communication Companies)
`Consolidated Arbitrations Under the International Chamber of Commerce Rules.
`Technology: LTE wireless technology.
`Activity:
`Expert Report (patent portfolio technical evaluation).
`18. Kirkland & Ellis for Samsung
`Dates: 2013
`Case:
`Samsung Electronics and Samsung Telecommunications America v. Ericsson Inc.
`In the Matter of Certain Wireless Communications Equipment and Articles Therein
`US. International Trade Commission (ITC) Investigation No. 337-TA-866
`
`Technology: LTE wireless technology.
`Activity:
`Expert Report (infringement, domestic industry practice), rebuttal report (validity).
`Court testimony (ITC bench trial): direct (Oct. 23, 2013) and rebuttal (Oct. 30,
`2013).
`19. Quinn Emanuel Urquhart & Sullivan, LLP for Samsung
`Dates: 2013
`Case:
`Samsung Electronics GmbH v. Apple Inc.
`
`German Patent Court, Case Number 5 Ni 49/11
`Technology: Turbo codes; LTE wireless technology.
`Activity:
`Declaration (validity).
`20. Kirkland & Ellis for DIRECTV
`Dates: 2009
`Case: Rembrandt Data Technologies v. DIRECTV, Inc. et al.
`Eastern District of Virginia, Case No. 1:08cv1009
`Technology: Telephone modems; set-top boxes.
`Activity:
`Rebuttal Expert Report (non-infringement). Deposition (May 20, 2009).
`21. Kirkland & Ellis for Samsung
`Dates: 2006
`Case:
`Samsung Electronics and Samsung Telecommunications America v. Ericsson Inc.
`In the Matter of Certain Wireless Communications Equipment, Articles Therein, and
`Products Containing the Same
`ITC Investigation No. 377-TA-577
`Technology: WCDMA/UMTS wireless technology; mobile phone handsets.
`Activity:
`Declaration (domestic industry practice). Deposition (Nov. 17, 2006).
`
`
`13
`
`

`

`6
`
`MATTHEW C. VALENTI
`
`–– OTHER RECENT TECHNICAL CONSULTING –––––––––––––––––––––––––––
`1. 4D Tech Solutions, Morgantown, WV
`Nonorthogonal Frequency Division Multiplexing
`July 2017 to December 2018.
`2. WPL, Manhattan Beach, CA
`Survivable, Secure and Dependable Wireless Communications
`August 2016 to February 2017.
`–– HONORS AND AWARDS –––––––––––––––––––––––––––––––––––––––––––––
`IEEE Communications Society, Communication Theory Technical Committee Outstanding
`Service Award (2021)
`Career award for service to the communication theory community
`IEEE MILCOM Award for Sustained Technical Achievement (2019)
`Career award for contributions to military communications
`Fellow, Institute of Electrical and Electronics Engineers (IEEE)
`Elevated to Fellow in 2018 for contributions to cooperative diversity and the development of
`distributed turbo codes
`WVU Foundation Outstanding Teaching Award (2013)
`Highest teaching award at West Virginia University
`Outstanding Teacher (2012, 2009, 2006, 2003, and 2001)
`Outstanding Advisor (2012, 2004)
`Outstanding Researcher (2008, 2001, and 2000)
`West Virginia University, Statler College of Engineering & Mineral Resources (College-level awards)
`Bradley Fellow, August 1995-May 1998
`Virginia Tech, Bradley Department of Electrical Engineering (highest departmental fellowship)
`–– PUBLICATIONS ––––––––––––––––––––––––––––––––––––––––––––––––––––––
`Refereed Journal Articles
`1. P. Das, R. Plesh, V. Talreja, N. Schmid, M.C. Valenti, J. Skufca, and S. Schuckers, “Empirical
`assessment of end-to-end iris recognition system capacity,” IEEE Transactions on Biometrics,
`Behavior, and Identity Science, vol. 5, no. 2, pp. 154-169, April 2023.
`2. F. Taherkhani, V. Talreja, J. Dawson, M.C. Valenti, and N.M. Nasrabadi “Profile to frontal face
`recognition in the wild using coupled conditional generative adversarial network,” IET Biometrics, vol.
`11, no. 3, pp. 260-272, May 2022.
`3. T. Ketseoglou, M.C. Valenti, and E. Ayanoglu “Millimeter wave massive MIMO downlink per-group
`communications with hybrid linear precoding,” IEEE Transactions on Vehicular Technology, vol. 70,
`no. 7, pp. 6841-6854, July 2021.
`4. V. Talreja, M.C. Valenti and N. M. Nasrabadi, “Deep hashing for secure multimodal biometrics,”
`IEEE Transactions on Information Forensics and Security, vol. 16, pp. 1306-1321, 2021.
`5. F. Taherkhani, V. Talreja, M.C. Valenti, and N.M. Nasrabadi “Error-corrected margin-based deep
`cross-modal hashing for facial image retrieval,” IEEE Transactions on Biometrics, Behavior, and
`Identity Science, vol. 2, no. 3, pp. 279-293, July 2020.
`6. E. Hriba and M.C. Valenti, “Correlated blocking in mmwave cellular networks: Macrodiversity,
`outage,
`and
`interference,” Electronics
`(Special
`Issue
`on Millimeter-Wave
`(mmWave)
`Communications), vol. 8, no. 10, article number 1187, Oct. 2019.
`7. T. Ferrett and M.C. Valenti, “Noncoherent LDPC-coded physical-layer network coding using
`multitone FSK,” IEEE Transactions on Communications, vol. 66, no. 6, pp. 2384-2395, June 2018.
`
`14
`
`

`

`7
`
`MATTHEW C. VALENTI
`
`8. D. Torrieri, S. Talarico, and M.C. Valenti, “Analysis of a frequency-hopping millimeter-wave cellular
`uplink,” IEEE Transactions on Wireless Communications, vol. 15, no. 10, pp. 7089-7098, Oct. 2016.
`9. K. Venugopal, M.C. Valenti, and R. W. Heath, Jr., “Device-to-device millimeter wave
`communications: Interference, coverage, rate, and finite topologies,” IEEE Transactions on Wireless
`Communications, vol. 15, no. 9, pp. 6175-6188, Sept. 2016.
`10. D. Torrieri, S. Talarico, and M.C. Valenti, “Performance comparisons of geographic routing protocols
`in mobile ad hoc networks,” IEEE Transactions on Communications, vol. 63, no. 11, pp. 4276-4286,
`Nov. 2015.
`11. P. Rost, S. Talarico, and M.C. Valenti, “The complexity-rate tradeoff of centralized radio access
`networks,” IEEE Transactions on Wireless Communications, vol. 14, no. 11, pp. 6164-6176, Nov.
`2015.
`12. M.C. Valenti, D. Torrieri, and S. Talarico, “A direct approach to computing spatially averaged outage
`probability,” IEEE Communications Letters, vol. 18, no. 7, pp. 1103-1106, July 2014.
`13. S. Talarico, N.A. Schmid, M. Alkhweldi, and M.C. Valenti, “Distributed estimation of a parametric
`field: Algorithms and performance analysis,” IEEE Transactions on Signal Processing, vol. 62, no. 5,
`pp. 1041-1053, Mar 1, 2014.
`14. D. Torrieri, M.C. Valenti, and S. Talarico, “An analysis of the DS-CDMA cellular uplink for arbitrary
`and constrained topologies,” IEEE Transactions on Communications, vol. 61, no. 8, pp. 3318-3326,
`Aug. 2013.
`15. D. Torrieri and M.C. Valenti, “Exclusion and guard zones in DS-CDMA ad hoc networks,” IEEE
`Transactions on Communications, vol. 61, no. 6, pp. 2468-2476, June 2013.
`16. D. Torrieri and M.C. Valenti, “The outage probability of a finite ad hoc network in Nakagami fading,”
`IEEE Transactions on Communications, vol. 60, pp. 3509-3518, Nov. 2012.
`17. M.C. Valenti and X. Xiang, “Constellation shaping for bit-interleaved LDPC coded APSK,” IEEE
`Transactions on Communications, vol. 60, pp. 2960-2970, Oct. 2012.
`18. M.C. Valenti, D. Torrieri, and T. Ferrett, “Noncoherent physical-layer network coding with FSK
`modulation: Relay receiver design issues,” IEEE Transactions on Communications, vol. 59, no. 9, pp.
`2595-2604, Sept. 2011.
`19. D. Torrieri and M.C. Valenti, “Rapidly-converging series representations of a mutual-information
`integral,” ISRN Communications and Networking, vol. 2011, Article ID 546205, 6 pages, 2011.
`20. M.C. Valenti, S. Cheng, and D. Torrieri “Iterative multisymbol noncoherent reception of coded
`CPFSK,” IEEE Transactions on Communications, vol. 58, no. 7, pp. 2046-2054, July 2010.
`21. D. Torrieri and M.C. Valenti, “Efficiently decoded full-rate space-time block codes,” IEEE
`Transactions on Communications, vol. 58, no. 2, pp. 480-488, Feb. 2010.
`22. S. Cheng, M.C. Valenti, and D. Torrieri, “Coherent continuous-phase frequency-shift keying:
`Parameter optimization and code design,” IEEE Transactions on Wireless Communications, vol. 8, no.
`4, pp. 1792-1802, Apr. 2009.
`23. D. Torrieri and M.C. Valenti, “Constellation labeling maps for low error floors,” IEEE Transactions
`on Wireless Communications, vol. 7, no. 12, pp. 5401-5407, Dec. 2008.
`24. D. Torrieri, S. Cheng, and M.C. Valenti, “Robust frequency hopping for interference and fading
`channels,” IEEE Transactions on Communications, vol. 56, no. 8, pp. 1343-1351, Aug. 2008.
`25. K. Vardhe, D. Reynolds, and M.C. Valenti, “The performance of multi-user cooperative diversity in
`an asynchronous CDMA uplink,” IEEE Transactions on Wireless Communications, vol. 7, no. 5, pp.
`1930-1940, May 2008.
`
`15
`
`

`

`8
`
`MATTHEW C. VALENTI
`
`26. R. Iyer Seshadri and M.C. Valenti, “Capacity-based parameter optimization of bit-interleaved coded
`CPM with differential detection,” IEEE Transactions on Vehicular Technology, vol. 57, no. 1, pp. 345-
`353, Jan. 2008
`27. S. Cheng, M.C. Valenti, and D. Torrieri, “Robust iterative noncoherent reception of coded FSK over
`block fading channels,” IEEE Transactions on Wireless Communications, vol. 6, no. 9, pp. 3142-3147,
`Sept. 2007.
`28. S. Wei, D.L. Goeckel, and M.C. Valenti, “Asynchronous cooperative diversity,” IEEE Transactions
`on Wireless Communications, vol. 5, no. 6, pp. 1547-1557, June 2006.
`29. B. Zhao and M.C. Valenti, “Position-based relaying with hybrid-ARQ for efficient ad hoc
`networking,” EURASIP Journal on Wireless Communications and Networking, vol. 5, no. 5, pp. 610-
`624, Dec. 2005.
`30. M.C. Valenti and S. Cheng, “Iterative demodulation and decoding of turbo coded M-ary noncoherent
`orthogonal modulation,” IEEE Journal on Selected Areas in Communications, vol. 23, no. 9, pp. 1738-
`1747, Sept. 2005.
`31. J. Sun and M.C. Valenti, “Joint synchronization and SNR estimation for turbo codes in AWGN
`channels,” IEEE Transactions on Communications, vol. 53, no. 7, pp. 1136-1144, July 2005.
`32. B. Zhao and M.C. Valenti, “Practical relay networks: A generalization of hybrid-ARQ,” IEEE Journal
`on Selected Areas in Communications, vol. 23, no. 1, pp. 7-18, Jan. 2005.
`33. B. Zhao and M.C. Valenti, “Distributed turbo coded diversity for the relay channel,” IEE Electronics
`Letters, vol. 39, no. 10, pp. 786-787, May 15, 2003.
`34. M.C. Valenti and J. Sun, “The UMTS turbo code and an efficient decoder implementation suitable for
`software defined radios,” International Journal on Wireless Information Networks, vol. 8, no. 4, pp.
`203-216, Oct. 2001.
`35. M.C. Valenti and B.D. Woerner, “Pilot symbol assisted detection of turbo codes over flat-fading
`channels," IEEE Journal on Selected Areas in Communications, vol. 19, pp. 1697-1705, Sept. 2001.
`36. M.C. Valenti and B.D. Woerner, “Iterative multiuser detection, macrodiversity combining and
`decoding for the TDMA cellular uplink”, IEEE Journal on Selected Areas in Communications, vol. 19,
`pp. 1570-1583, Aug. 2001.
`37. M.C. Valenti and B.D. Woerner, “Distributed multiuser detection for the TDMA cellular uplink,” IEE
`Electronics Letters, vol. 35, no. 21, pp. 1803-1804, Oct. 21, 1999.
`38. M.C. Valenti and B.D. Woerner, “Refined channel estimation for coherent detection of turbo codes
`over flat-fading channels,” IEE Electronics Letters, vol. 34, no. 17, pp. 1648-1649, Aug. 20, 1998.
`Magazine Articles
`1. P. Rost, I. Berberana, A. Maeder, H. Paul, V. Suryaprakash, M.C. Valenti, D. Wubben, A. Dekorsy,
`and G. Fettweis, “Benefits and challenges of virtualization in 5G radio access networks,” IEEE
`Communications Magazine, vol. 53, no. 12, Communications Standards Supplement, pp. 75-82, Dec.
`2015.
`2. N. Chandran and M.C. Valenti, “Cellular communication systems: Three generations of evolution in
`wireless technology,” IEEE Potentials, vol. 20, no. 1, pp. 32-35, Feb./March 2001.
`Book Chapters
`1. E. Hriba and M.C. Valenti, “Correlated blocking in mmwave cellular networks: Macrodiversity,
`outage, and interference,” in Millimeter-Wave (mmWave) Communications, MDPI, 2020, pp. 137-153.
`2. V. Talreja, T. Ferrett, M.C. Valenti, and A. Ross, “A framework for secure selfie-based biometric
`authentication in the cloud,” Chapter 14 of Selfie Biometrics: Advances and Challenges, Springer,
`2019, pp. 275-297.
`
`16
`
`

`

`9
`
`MATTHEW C. VALENTI
`
`3. P. Rost, M.C. Valenti, S. Talarico, and A. Maeder, “The tradeoff of computational complexity and
`achievable rates in C-RANs,” Chapter 3 of Cloud Radio Access Networks: Principles, Technologies,
`and Applications, Cambridge University Press, 2017.
`4. M.C. Valenti and M. Fanaei, “The interplay between modulation and channel coding,” Chapter 5 of
`Transmission Techniques for Digital Communications, Elsevier, 2016.
`5. M.C. Valenti and D. Reynolds, “Distributed space-time block codes,” Chapter 6 in Cooperative
`Cellular Wireless Networks, Edited by E. Hossain, D.I. Kim, and V.K. Bhargava, Cambridge
`University Press, 2011, pp. 153-175.
`6. M.C. Valenti, S. Cheng, and R. Iyer Seshadri, “Turbo and LDPC codes for digital video
`broadcasting,” in Turbo Code Application: A Journey from a Paper to Realization, Edited by K.
`Sripimanwat, Springer, 2005.
`7. M.C. Valenti and J. Sun, “Turbo codes,” in Handbook of RF and Wireless Technologies, Edited by F.
`Dowla Editor, Newnes Press, 2004, pp. 375-399.
`Refereed Conference Papers
`1. J.D. Pabon, S. Alkhandari, M.C. Valenti, and X. Yu, “Air-aided communication between ground
`assets in a Poisson forest,” in Proc. IEEE Military Commun. Conf. (MILCOM), (Rockville, MD), Nov.
`2022.
`2. V. Talreja, N.M. Nasrabadi, and M.C. Val

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket