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`_____________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_____________________________
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`MEDIATEK INC. AND NXP USA, INC.
`Petitioners,
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`v.
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`Bell Northern Research, LLC,
`Patent Owner.
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`_____________________________
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`IPR2023-01414
`U.S. Patent 8,416,862
`Filing Date: September 28, 2005
`Issue Date: April 9, 2013
`_____________________________
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`DECLARATION OF JONATHAN WELLS, Ph.D.
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`1
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`TABLE OF CONTENTS
`ASSIGNMENT ............................................................................................... 4
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`QUALIFICATIONS........................................................................................ 4
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`I.
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`II.
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`LEGAL PRINCIPLES .................................................................................... 9
`III.
`A. Anticipation ..................................................................................................... 9
`B. Obviousness ..................................................................................................10
`C. Claim Construction .......................................................................................12
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`IV.
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`PERSON OF ORDINARY SKILL IN THE ART ........................................14
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`V. MATERIALS CONSIDERED ......................................................................15
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`VI. BACKGROUND OF THE ’862 PATENT ...................................................19
`A.
`Subject Matter Overview ..............................................................................19
`B.
`File History of the ’862 Patent ......................................................................29
`C.
`Priority Date of the ’862 Patent .....................................................................32
`D. Background Knowledge of Matrices and their Singular Value Decomposition
`(SVD) ............................................................................................................33
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`VII. OVERVIEW OF CONCLUSIONS FORMED AND PRIOR ART
`REFERENCES ..............................................................................................35
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`VIII. ANALYSIS OF LI ’748 IN VIEW OF TONG AND MAO .........................36
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`IX. ANALYSIS OF TONG IN VIEW OF MAO ................................................83
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`X.
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`ANALYSIS OF LI ’054 IN VIEW OF MAO .............................................110
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`XI. ANALYSIS OF LI ’054 IN VIEW OF MAO AND YANG ......................143
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`XII. ANALYSIS OF POON IN VIEW OF MAO ..............................................149
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`XIII. SUPPORT FOR TONG IN EARLIER-FILED PROVISIONAL
`APPLICATION ...........................................................................................174
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`XIV. ADDITIONAL REMARKS ........................................................................177
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`2
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`3
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`MediaTek Exhibit 1003, Page 3 of 195
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`I, Jonathan Wells, Ph.D. of Pleasanton, California, declare that:
`ASSIGNMENT
`I.
`I have been retained as a technical expert by counsel on behalf of
`1.
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`MediaTek USA INC. (“MediaTek”) and NXP USA, Inc. (“NXP”). I refer to
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`MediaTek and NXP collectively as “Petitioners” herein. I understand that
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`Petitioners are requesting that the Patent Trial and Appeal Board (“PTAB” or “the
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`Board”) institute an inter partes review (“IPR”) proceeding of U.S. Patent No.
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`8,416,862 (“the ’862 patent”) (EX1001).
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`2.
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`I have been asked to provide my independent analysis of the ’862
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`patent in light of the prior art publications cited below. I previously submitted an
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`opinion in support of LG’s petition for inter partes review in IPR2020-00108 on
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`the identical grounds presented herein, which was instituted by the Patent Trials
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`and Board.
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`3.
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`I am not, and never have been, an employee of MediaTek or NXP. I
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`received no compensation for this declaration beyond my normal hourly
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`compensation based on my time actually spent analyzing the ’862 patent, the prior
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`art publications cited below, and the issues related thereto, and I will not receive
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`any added compensation based on the outcome of any IPR or other proceeding
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`involving the ’862 patent.
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`II. QUALIFICATIONS
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`4
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`4.
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`I received a B.Sc. in Physics with Physical Electronics, awarded with
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`first class honors, from the University of Bath in Bath, United Kingdom, in 1987.
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`In 1991, I earned by Ph.D., also from the University of Bath. I earned my M.B.A.,
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`awarded with distinction, from Massey University in New Zealand, in 1998.
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`5.
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`I have over 35 years of wireless communications experience in areas
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`including cellular technologies, wireless devices, network infrastructure, and
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`wireless rules and regulations. I have written a textbook and multiple industry
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`reports and journal/conference papers which focus on wireless communications
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`systems. For example, I am the author of “Multi-Gigabit Microwave and
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`Millimeter-Wave Wireless Communications,” published by Artech House in 2010. I
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`have also authored four comprehensive industry reports on cellular connectivity for
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`Mobile Experts. I have lectured as part of undergraduate programs at University of
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`California, Berkeley, Carnegie Mellon University, and University of Bath, and have
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`given over two dozen lectures and conference presentations on topics germane to
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`wireless communications. I am also a listed inventor of several patents, and am an
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`author of over 40 academic and commercial publications and presentations.
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`6.
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`I began my career in 1985, as an Engineer for Plessey Research,
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`Caswell, United Kingdom, developing high-speed fiber optic transmitter/receiver
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`devices. In 1987, I worked at British Aerospace, Filton, Bristol, United Kingdom,
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`designing and fabricating novel mixer devices, to support my Ph.D. research.
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`5
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`Later in 1990, as a Post-Doctoral Research Officer for University of Bath, I
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`designed and fabricated novel quantum amplifiers in a clean room environment and
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`developed computer models to predict semiconductor device performance.
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`7.
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`In 1983, I joined Matra Marconi Space, Portsmouth, United Kingdom,
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`as a Senior Design Engineer and developed a GaAs MMIC mixer and MIC
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`transmitter board for two satellite payloads and performed theoretical analysis and
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`modeling of low noise VCOs.
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`8.
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`From 1994 to 1998, I worked for MAS Technology (now Aviat
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`Networks), Wellington, New Zealand, first as Senior RF Design Engineer and later
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`as RF Group Manager. I was responsible for RF hardware development for
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`cellular and telecommunications applications; developed three generations of
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`wireless transmission, switching, and multiplexing products; designed and
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`sustained responsibility for satellite ground station terminals; and was responsible
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`for company’s European regulatory approvals.
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`9.
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`In 1998, I joined Adaptive Broadband (now GE Digital Energy),
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`Rochester, New York, first as Engineering Group Leader and later as Director
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`Wideband Products. I was responsible for the Terrestrial Infrastructure Group,
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`providing telecommunications products for cellular and private network
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`applications; managed P&L responsibility for $4M wireless division; and was
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`6
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`responsible for the development of a family of digital radios and associated
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`switching/multiplexing equipment.
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`10. From 2000 to 2004, I worked for Stratex Networks (now Aviat
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`Networks), San Jose, California, as Director Product Development. I was
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`responsible for global product development of high-end digital microwave radios
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`primarily for cellular backhaul applications; led RF/microwave development team
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`of 35 engineers based in two continents; performed technical leadership of flagship
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`Eclipse product, shipping over 250,000 units; and was responsible for technical
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`management of overseas manufacturing subcontractors.
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`11.
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`In 2005, I joined GigaBeam Corporation, Herndon, Virginia, as
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`Director Product Management and Global Regulatory Affairs. I was responsible for
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`product strategy for industry-transforming high data rate wireless product; initiated
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`market development in over 40 countries including in Europe, Canada, Caribbean,
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`Latin America, the Middle East, and Asia; and participated and drove standard
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`development in FCC, CEPT, and ETSI technical meetings.
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`12. Since 2007, I have been an independent consultant with AJIS
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`Consulting, where I provide independent technical consulting on wireless
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`communications and emerging wireless fields. The services I provide include:
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`acting as a technical expert support of 2G, 3G, 4G, and 5G cellular and wireless
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`patent litigation; providing analysis of cellular and mobile wireless patents and
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`7
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`infringing equipment; providing cellular and wireless technology technical and
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`industry analysis for companies, analysts, and investment institutions, and
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`researching and publication of analyst reports; providing wireless product
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`development and marketing strategies; providing specialized technical workshops
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`on various wireless technologies, including cellular networks, mm-wave radios,
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`security sensors, and short range radios; and providing specialized global
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`regulatory tasks and product approvals.
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`13.
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`I have been a member of the Institute of Electrical and Electronic
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`Engineers (IEEE) since 1995 and was elected as a Senior Member in 1999. In
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`2019, I was recognized by the IEEE Santa Clara Valley Section, one of the largest
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`IEEE Sections in the world, as their 2019 “Outstanding Engineer.” This was
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`awarded “For acknowledged expertise in the field of wireless communications and
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`wireless technology, for his willingness to mentor others in the field, and for his
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`work in the development of the next generation of creative and innovative
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`technical products.”
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`14. My curriculum vitae, attached to this declaration as Appendix A, sets
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`forth details of my background and relevant experience. My CV includes a listing
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`of cases for which I have provided expert testimony over the last four years and a
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`complete list of publications I have authored. Based on my experience and
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`education, I believe that I am qualified to opine as to the knowledge and level of
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`8
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`skill of one of ordinary skill in the art at the time of the alleged invention of the
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`’862 patent (which I further describe below) and what such a person would have
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`understood at that time, and the state of the art during that time. Based on my
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`experiences, I understand and know of the capabilities of persons of ordinary skill
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`in this field during the early-to-mid 2000s and specifically during the time before
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`the time of the alleged invention of the ’862 patent. Indeed, I taught, participated in
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`organizations, and worked closely with many such persons in the field during that
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`time frame.
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`III. LEGAL PRINCIPLES
`In forming my analysis and conclusions expressed in this declaration, I
`15.
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`have applied the legal principles described in the following paragraphs, which
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`were provided to me by counsel for the Petitioners.
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`A. Anticipation
`I have been informed that a patent claim is invalid as anticipated if
`16.
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`each and every element of a claim, as properly construed, is found either explicitly
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`or inherently in a single prior art reference. Under the principles of inherency, if
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`the prior art necessarily functions in accordance with, or includes the claimed
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`limitations, it anticipates.
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`17.
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`I have been informed that a claim is invalid if the claimed invention
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`was known or used by others in the U.S., or was patented or published anywhere,
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`9
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`before the Applicant’s invention. I further have been informed that a claim is
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`invalid if the invention was patented or published anywhere, or was in public use,
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`on sale, or offered for sale in this country, more than one year prior to the filing
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`date of the patent application (critical date). Further, I have been informed that a
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`claim is invalid if an invention described by that claim was described in a U.S.
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`patent granted on an application for a patent (or in a published application for a
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`U.S. patent) that was filed by another in the U.S. before the date of invention for
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`such a claim.
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`B. Obviousness
`I have been informed that a patent claim is invalid as “obvious” in
`18.
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`light of one or more prior art references if it would have been obvious to a person
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`of ordinary skill in the art at the time of the alleged invention (“POSITA”), taking
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`into account (1) the scope and content of the prior art, (2) the differences between
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`the prior art and the claims, (3) the level of ordinary skill in the art, and (4) any so
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`called “secondary considerations” of non-obviousness, which include: (i) “long felt
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`need” for the claimed invention, (ii) commercial success attributable to the claimed
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`invention, (iii) unexpected results of the claimed invention, and (iv) “copying” of
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`the claimed invention by others.
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`19. While I do not know the exact date that the alleged invention claimed
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`in the ’862 patent was made, I do know that the ’862 patent claims priority to a
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`10
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`number of other patent applications. In particular, the ’862 patent is a continuation-
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`in-part of U.S. App. Serial No. 11/168,793 (“’793 application”, EX1014), and
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`claims priority to U.S. Provisional App. Serial No. 60/673,451 (“’451 provisional”,
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`EX1010), filed April 21, 2005, and U.S. Provisional App. Serial No. 60/698,686
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`(“’686 provisional”, EX1011), filed July 13, 2005. Based on my analysis of the
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`applications to which the ’862 patent claim priority (explained below in Section
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`VI.C), for purposes of my analysis here, I have applied a date of July 13, 2005, as
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`the date of the alleged invention in my obviousness analysis, although in many
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`cases the same analysis would hold true even if the date of the alleged invention
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`occurred earlier than July 13, 2005 (especially given the earlier publication or
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`filing dates of the prior art in Exhibits 1004, 1005, 1006, 1007, 1008, and 1009, as
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`described below). See ¶24 (below).
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`20.
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`I have been informed that a claim can be obvious in light of a single
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`prior art reference or multiple prior art references. To be obvious in light of a
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`single prior art reference or multiple prior art references, there must be a reason
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`that would have prompted a POSITA to modify the single prior art reference, or
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`combine two or more references, in a manner that provides the elements of the
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`claimed invention. This reason may come from a teaching, suggestion, or
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`motivation to combine, or may come from the reference(s) themselves, the
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`knowledge or “common sense” of a POSITA, or from the nature of the problem to
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`be solved, and this reason may be explicit or implicit from the prior art as a whole. I
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`have been informed that, under the law, the combination of familiar elements
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`according to known methods is likely to be obvious when it does no more than
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`yield predictable results. I also understand it is improper to rely on hindsight in
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`making the obviousness determination.
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`C. Claim Construction
`I understand that, for purposes of my analysis in this inter partes
`21.
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`review proceeding, the terms appearing in the patent claims should be interpreted
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`according to their “ordinary and customary meaning,” which is often referred to as
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`the Phillips standard. In determining the ordinary and customary meaning, I
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`understand that the words of a claim are first given their plain meaning that those
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`words would have had to a person of ordinary skill in the art at the time of the
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`alleged invention. I also understand that the structure of the claims, the
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`specification and file history also may be used to better construe a claim insofar as
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`the plain meaning of the claims cannot be understood. Moreover, I understand that
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`even treatises and dictionaries may be used, albeit under limited circumstances, to
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`determine the meaning attributed by a person of ordinary skill in the art to a claim
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`term at the time of filing. I have followed this approach in my analysis, and for all
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`of the claim terms considered in this declaration, I have applied the plain and
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`ordinary meaning of those terms. To this end, I was informed that, in the litigation
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`12
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`in which the same claim construction standard was applied, the district court
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`indicated that no formal constructions for the ’862 patent claims were required
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`under the Phillips standard because the plain and ordinary meaning of the claim
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`language was recognizable without adoption of any formal construction. EX1020,
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`104:23-107:3-9 and 111:4-114:22. In particular, I was informed that the district
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`court previously explained to the parties that the phrase “baseband processing
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`module operable to…” is not a means-plus-function element under §112, ¶6
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`because the district court agreed with Patent Owner that “a baseband processing
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`module” was a known and recognizable structure. EX1020, 111:4-114:22; 116:18-
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`118:5 (“THE COURT: … I don’t see this as a 112, 6 issue. This is a known
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`processing baseband processing module.”). Additionally, I was informed that the
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`district court indicated there was no need for a formal construction of the phrase
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`“decompose the estimated transmitter beamforming unitary matrix (V) to produce
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`the transmitter beamforming information” under the Phillips standard because the
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`plain and ordinary meaning of the claim language was recognizable without
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`adoption of any formal construction. EX1020, 104:23- 105:2, 106:20-25, 107:3-9
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`(“Assume the Court will not construe that claim any further, that that language of
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`‘transmitter beamforming information’ is what it is and that a person of skill in the
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`art would understand that is the result of the decomposition of the estimated
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`transmitter beamforming matrix”). I also understand that in a different proceeding
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`13
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`in the Southern District of Florida, a third party argued that the claim term “a
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`plurality of Radio Frequency (RF) components” (claim 9) is a means-plus-function
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`term under § 112(6) with the function of “receiving an RF signal and converting
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`the RF signal to a baseband signal” but without corresponding structure and
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`therefore indefinite. Ex1023, 8. Patent Owner there contended that the plain and
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`ordinary meaning applied without needing construction, but, alternatively, if
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`§ 112(6) applies the structure “includes one or more antennas and includes one or
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`more amplifiers, one or more intermediate frequency, one or more mixers and RF
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`filters.” Id. I do not offer an opinion on the proper construction of this claim
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`element. Regardless, my analysis below shows that under both of Patent Owner’s
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`alternative constructions, the prior art discloses or renders obvious claim 9.
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`22.
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`I also understand that the words of the claims should be interpreted as
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`they would have been interpreted by a POSITA at the time the alleged invention
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`was made (not today). Because I do not know at what date the alleged invention
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`was made, I have used the date of July 13, 2005, for reasons explained in ¶19
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`(above) and ¶¶47-49 (below). However, the plain meanings/interpretations that I
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`employed in my analysis below would have also been correct if the date of
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`invention was anywhere within the early to mid 2000s.
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`IV. PERSON OF ORDINARY SKILL IN THE ART
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`14
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`23. Based on my knowledge and experience in the field and my review of
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`the ’862 patent and its file history, I believe that would have had Bachelor’s degree
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`in Electrical Engineering, Computer Engineering, Computer Science, or a related
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`field, and at least 2 years of experience in the field of wireless communication, or a
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`person with equivalent education, work, or experience in this field. Additional
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`education could substitute for some of the experience, and substantial experience
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`could substitute for some of the educational background. My analysis and
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`conclusions as expressed herein are thus based on the perspective of a person of
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`ordinary skill in the art having this level of knowledge and skill at the time of the
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`alleged invention of the ’862 patent.
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`24. Because I do not know at what date the alleged invention as claimed
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`was made, I have used the filing date of the earliest application to which the ’862
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`patent claims priority that supports each element of the challenged claims 9-12 as
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`the point in time from which my analysis from the perspective of one of ordinary
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`skill in the art is based. Again, as I explain in Section VI.C, that date was July 13,
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`2005. However, my analysis of the prior art and the conclusion herein would also
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`apply even if the date of the alleged invention as claimed was anywhere within the
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`early to mid 2000s (e.g., refer to the earlier publication or filing dates of Exhibits
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`1004, 1005, 1006, 1007, 1008, 1009).
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`V. MATERIALS CONSIDERED
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`15
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`25. My analyses set forth in this declaration are based on my experience
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`in the field of wireless communication devices and associated technologies. Based
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`on my above-described experience in the field of wireless communication devices,
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`I believe that I am considered to be an expert in the field. Also, based on my
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`experiences, I understand and know of the capabilities of persons of ordinary skill
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`in this field during the early to mid 2000s and specifically during the time before
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`the alleged priority date (July 13, 2005) for the ’862 patent, and I taught,
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`participated in organizations, and worked closely with many such persons in the
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`field during that time frame.
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`26. As part of my independent analysis for this declaration, I have
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`considered the following: the background knowledge/technologies that were
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`commonly known to persons of ordinary skill in this field during the time before
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`the alleged priority date for the ’862 patent; my own knowledge and experiences
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`gained from my work experience in the fields of electrical engineering and
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`wireless communication devices generally; my experience in teaching and advising
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`others in those subjects; and my experience in working with others involved in
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`those fields. In addition, I have analyzed the following publications and materials:
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`• U.S. Patent No. 8,416,862 to Aldana et al. (“the ’862 patent”) (EX1001)
`• Prosecution History of the ’862 patent (Serial No. 11/237,341) (EX1002)
`• U.S. Pat. No. 7,236,748 to Li et al. (“Li ’748”) (EX1004)
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`16
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`• U.S. Pub. No. 2008/0108310 to Tong et al. (“Tong”) (EX1005)
`• U.S. Pat. No. 7,312,750 to Mao et al. (“Mao”) (EX1006)
`• U.S. Pub. No. 2006/0092054 to Li et al. (“Li ’054”) (EX1007)
`• Yang et al., Reducing the Computations of the Singular Value
`Decomposition Array Given by Brent and Luk, SIAM J. MATRIX
`ANAL. APPL., Vol. 12, No. 4, pp. 713-725, Oct. 1991 (“Yang”)
`(EX1008)
`• U.S. Pat. No. 7,710,925 to Poon (“Poon”) (EX1009)
`• U.S. Provisional Application Serial No. 60/673,451 (“the ’451
`provisional”) (EX1010)
`• U.S. Provisional Application Serial No. 60/698,686 (“the ’686
`provisional”) (EX1011)
`• U.S. Provisional Application Serial No. 60/614,621 (“the ’621
`provisional”) (EX1012)
`• U.S. Provisional Application Serial No. 60/619,461 (“the ’461
`provisional”) (EX1013)
`• U.S. Patent Application Serial No. 11/168,793 (“the ’793 application”)
`(EX1014)
`• Plaintiff Bell Northern Research, LLC’s Patent Rule 3-1 and 3-2
`Disclosure of Asserted Claims and Infringement Contentions Against the
`Huawei Defendants in Bell Northern Research, LLC, v. Huawei Device
`(Dongguan) Co., Ltd., Huawei Device (Shenzhen) Co., Ltd., and Huawei
`Device USA, Inc. (Case No. 3:18-cv-1784) (S.D.Cal.) (EX1015)
`• Defendants’ Invalidity Contentions in Bell Northern Research, LLC, v.
`Huawei Device (Dongguan) Co., Ltd., Huawei Device (Shenzhen) Co.,
`Ltd., and Huawei Device USA, Inc. (Case No. 3:18-cv-1784) (S.D.Cal.)
`(EX1016)
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`17
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`• Defendants’ Joint Opening Claim Construction Brief in Bell Northern
`Research, LLC, v. Huawei Device (Dongguan) Co., Ltd., Huawei Device
`(Shenzhen) Co., Ltd., and Huawei Device USA, Inc. (Case No. 3:18-cv-
`1784) (S.D.Cal.) (EX1017)
`• Plaintiff’s Opening Claim Construction Brief in Bell Northern Re-search,
`LLC, v. Huawei Device (Dongguan) Co., Ltd., Huawei De-vice
`• (Shenzhen) Co., Ltd., and Huawei Device USA, Inc. (Case No. 3:18-cv-
`1784) (S.D.Cal.) (EX1018)
`• Defendants’ Memorandum of Points and Authorities in Support of Their
`Joint Motion for Summary Judgement on Indefiniteness in Bell Northern
`Research, LLC, v. Huawei Device (Dongguan) Co., Ltd., Huawei Device
`(Shenzhen) Co., Ltd., and Huawei Device USA, Inc. (Case No. 3:18-cv-
`1784) (S.D.Cal.) (EX1019)
`• Transcript of Claim Construction Hearing, Day Two, Volume Two,
`Pages 1-122 in Bell Northern Research, LLC, v. Huawei Technologies
`CO., LTD., Huawei Device (Hong Kong) CO., LTD., and Huawei
`Device USA, Inc. (Case No. 3:18-cv-1784) (S.D.Cal.) (EX1020)
`• Declaration of Sylvia Hall-Ellis (EX1021)
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`• Joint Claim Construction and Prehearing Statement, Bell Northern
`Research LLC v. HMD North America, Inc. et al (Case No. 1:22-cv-
`22706-RNS) (S.D. Fla) (EX1023).
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`27. Although this declaration refers to selected portions of the cited
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`references for the sake of brevity, it should be understood that these are examples,
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`and that one of ordinary skill in the art would have viewed the references cited
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`herein in their entirety and in combination with other references cited herein or
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`18
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`cited within the references themselves. The references used in this declaration,
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`therefore, should be viewed as being incorporated herein in their entireties.
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`VI. BACKGROUND OF THE ’862 PATENT
`Subject Matter Overview
`A.
`28. The’862 patent is titled “Efficient Feedback of Channel Information in
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`a Closed Loop Beamforming Wireless Communication System,” and it is generally
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`directed to a “receiving wireless device” that performs a “method for feeding back
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`transmitter beamforming information … to a transmitting wireless communication
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`device.” EX1001 at Abstract. The ’862 patent states that “[i]n order for a
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`transmitter to properly implement beamforming (i.e., determine the beamforming
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`matrix [V]), it needs to know properties of the channel over which the wireless
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`communication is conveyed,” so “the receiver must provide feedback information
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`for the transmitter to determine the properties of the channel.” Id. at 3:14-19. In
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`order to send “feedback from the receiver to the transmitter,” the receiver may
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`“determine[s] the channel response (h) and [] provides it as the feedback
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`information.” Id. at 3:19-22. However, “[a]n issue with this approach” was that
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`“the size of the feedback packet [was] so large that, during the time it takes to send
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`it to the transmitter, the response of the channel has changed.” Id. at 3:22-25. To
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`try to “reduce the size of the feedback,” one conventional approach was for the
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`receiver to “decompose the channel using singular value decomposition (SVD)”
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`
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`19
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`
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`using the equation H=UDV* and to “send information relating only to a calculated
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`value of the transmitter’s beamforming matrix (V) as the feedback information.”
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`Id. at 3:26-33. However, feedback size was still a problem for MIMO wireless
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`communication. Id. at 3:33-35. The ’862 patent conclude that “[t]herefore, a need
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`exist[ed] … for reducing beamforming feedback information for wireless
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`communications.” Id. at 3:49-51.
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`29. FIG. 1 (reproduced below) shows “a communication system 10 that
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`includes a plurality of base stations and/or access points 12, 16, a plurality of
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`
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`20
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`
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`wireless communication devices 18-32 and a network hardware component 34.” Id.
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`at 4:24-27.
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`
`
`
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`Id. at FIG. 1.
`30. FIG. 2 (reproduced below) is a block diagram of “a wireless
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`communication device that includes the host device 18-32 and an associated radio
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`60.” Id. at 5:4-6.
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`31. The ’862 patent explains that the “[w]ireless communication devices
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`18-32 may be laptop computers 18 and 26, personal digital assistant hosts 20 and
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`30, personal computer 24 and 32 and/or cellular telephone 22 and 28.” Id. at 4:29-
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`34. In order to communicate with other devices, “each of the base stations or
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`access points 12-16 has an associated antenna or antenna array.” Id. at 4:52-55.
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`“Typically, base stations are used for cellular telephone systems and like-type
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`systems, while access points are used for in-home or in-building wireless networks
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`(e.g., IEEE 802.11 and versions thereof, Bluetooth, and/or any other type of radio
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`frequency based network protocol).” Id. at 4:63-67. In any case, each device
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`“includes a built-in radio and/or is coupled to a radio.” Id. at 5:67-5:3.
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`32. FIG. 3 (reproduced below) is a block diagram of “a wireless
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`communication device that includes [a] host device 18-32 and an associated radio
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`60.” Id. at 7:21-27. As shown in FIG. 3, “the host device 18-32 includes a
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`processing module 50, memory 52, radio interface 54, input interface 58 and
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`
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`21
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`
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`output interface 56.” Id. at 7:28-30. According to the ’862 patent, “[t]he radio
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`interface allows data to be received from and sent to the radio,” and “[f]or data
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`received from the radio 60 (e.g., inbound data), the radio interface 54 provides the
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`data to the processing module 50 for further processing and/or routing to the output
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`interface 56.” Id. at 7:36-40. The radio interface 54 then “provides data from the
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`processing module 50 to the radio 60.” Id. at 7:43-44.
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`
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`
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`Id. at FIG. 3.
`33. The radio 60 “includes a host interface 62, a baseband processing
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`
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`module 100, memory 65, a plurality of radio frequency (RF) transmitters 106-110,
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`
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`22
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`
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`a transmit/receive (T/R) module 114, a plurality of antennas 81-85, a plurality of
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`RF receivers 118-120, a channel bandwidth adjust module 87, and a local
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`oscillation module 74.” Id. at 7:51-56. Using “operational instructions stored in
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`memory 65,” the baseband processing module 100 “executes digital receiver
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`functions and digital transmitter functions, respectively,” which include “but are
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`not limited to, digital intermediate frequency to baseband conversion,
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`demodulation, constellation demapping, decoding, de-interleaving, fast Fourier
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`transform, cyclic prefix removal, space and time decoding, and/or descrambling.”
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`Id. at 7:56-64. Digital transmitter functions include “encoding, scrambling,
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`interleaving, constellation mapping, modulation, inverse fast Fourier transform,
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`cyclic prefix addition, space and time encoding, and digital baseband to IF
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`conversion.” Id. at 7:64-8:1. The baseband processing module is “implemented
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`using one or more processing devices,” such as “a microprocessor, micro-
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`controller, digital signal processor, microcomputer, central processing unit, field
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`programmable gate array, programmable logic device, state machine, logic
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`circuitry, analog circuitry, digital circuitry, and/or any device that manipulates
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`signals (analog and/or digital) based on operational instructions.” Id. at 8:1-9.
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`34. The “baseband processing module 100, based on the mode selection
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`signal 102 produces one or more outbound symbol streams 104 from the outbound
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`data 94.” Id. at 8:46-48. “Depending on the number of outbound streams 104
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`
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`23
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`
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`produced by the baseband module 10, a corresponding number of the RF
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`transmitters 106-110 will be enabled to up convert the output symbol streams 104
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`into outbound RF signals 112.” Id. at 8:56-59. The RF transmitters 106-110 may
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`include “a digital filter and upsampling module, a digital to analog conversion
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`module, a frequency up conversion module, a power amplifier, and a radio
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`frequency bandpass filter. Id. at 8:60-64. To transmit an RF signal, the “RF
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`transmitters 106-110 provide the outbound RF signals 112 to the transmit/receive
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`module 114, which provides each outbound RF signal to a corresponding antenna
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`81-85.” Id. at 8:64-67.
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`35.
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`In a receive mode, “the transmit/receive module 114 receives one or
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`more inbound RF signals 116 via the antennas 81-85 and provides them to one or
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`more RF receivers 118-122.” Id. at 9:1-4. Then the RF receiver uses “settings
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`provided by the channel bandwidth adjust module 87” in order to “down convert[]
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`the inbound RF signals 116 into a corresponding number of inbound symbol
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`streams 124.” Id. at 9:4-7. Then the baseband processing module 100 “converts the
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`inbound symbol streams 124 into inbound data 92, which is provided to the host
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`device 18-32 via the host interface.” Id. at 9:9-12.
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`36. Figure 5 (reproduced below) is a block diagram o