UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________
`MEDIATEK INC.,
`Petitioner,
`v.
`PARKERVISION, INC.,
`Patent Owner.
`___________________
`
`PTAB Case No. IPR2024-00150
`Patent No. 7,292,835
`_____________________
`
`DECLARATION OF DR. LAWRENCE E. LARSON
`
`MEDIATEK EX. 1003
`
`

`

`TABLE OF CONTENTS
`
`I.
`II.
`III.
`IV.
`V.
`
`Introduction ...................................................................................................... 1
`Qualifications ................................................................................................... 2
`Summary of Opinions and Materials Considered ........................................... 7
`Level of Skill in the Art ................................................................................... 9
`Background Technology ................................................................................ 11
`A. Wireless Communications Signals ...................................................... 11
`B. Modulating Signals for Wireless Communications ............................ 12
`1.
`Amplitude Modulation .............................................................. 13
`2.
`Phase Modulation ...................................................................... 14
`3.
`Quadrature Amplitude Modulation ........................................... 15
`VI. Overview of U.S. Patent No. 7,292,835 ........................................................ 19
`A.
`Description of the Specification .......................................................... 19
`B.
`Prosecution History ............................................................................. 23
`VII. The Challenged Claims of the ’835 Patent .................................................... 24
`VIII. Claim Construction ........................................................................................ 26
`A.
`Cable modem (claim 1, preamble) ...................................................... 27
`B.
`Storage module (claim 1) .................................................................... 29
`Legal Principles ............................................................................................. 31
`A.
`Burden of Proof ................................................................................... 31
`B.
`Priority ................................................................................................. 31
`C.
`Prior Art ............................................................................................... 32
`D.
`Obviousness ......................................................................................... 33
`Overview of Cited Prior Art References ....................................................... 36
`A.
`U.S. Patent No. 4,682,117 to Gibson (Ex. 1004) ................................ 36
`B.
`U.S. Patent No. 5,339,459 to Schiltz (Ex. 1005) ................................ 38
`C.
`J. Crols & M. Steyaert, A Single-Chip 900 MHz CMOS Receiver
`Front-End with a High Performance Low-IF Topology, 30 IEEE
`JOURNAL OF SOLID-STATE CIRCUITS 1483 (Dec. 1995) (Ex. 1006) .... 41
`
`IX.
`
`X.
`
`i
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`MEDIATEK EX. 1003
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`

`

`D.
`
`L. Goldberg, MCNS/DOCSIS MAC Clears a Path for the Cable-
`Modem Invasion (Ex. 1007) ................................................................ 46
`U.S. Patent No. 6,011,548 to Thacker (Ex. 1008) .............................. 48
`E.
`ITU-T J.83 Recommendation (April 1997) (Ex. 1009) ...................... 48
`F.
`Applicant Admitted Prior Art (“AAPA”) ........................................... 49
`G.
`XI. Comparison of the Cited Prior Art References to the Challenged Claims of
`the ’835 Patent ............................................................................................... 50
`A.
`Gibson In View Of Schiltz Renders Obvious Claims 1-5 .................. 50
`1.
`Motivation to Combine ............................................................. 52
`2.
`Independent Claim 1 ................................................................. 58
`3.
`Claim 2 ...................................................................................... 79
`4.
`Claim 3 ...................................................................................... 81
`5.
`Claim 4 ...................................................................................... 91
`6.
`Claim 5 ...................................................................................... 93
`Crols Renders Obvious Claim 1-5 ...................................................... 95
`1.
`Motivation to Combine – Cable Modem References ............... 95
`2.
`Independent Claim 1 ...............................................................100
`3.
`Claim 2 ....................................................................................124
`4.
`Claim 3 ....................................................................................126
`5.
`Claim 4 ....................................................................................136
`6.
`Claim 5 ....................................................................................137
`XII. Conclusion ...................................................................................................139
`
`B.
`
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`EXHIBITS REFERENCED IN DECLARATION
`
`No.
`
`EX-1001
`
`EX-1002
`
`EX-1004
`
`EX-1005
`
`EX-1006
`
`EX-1007
`
`EX-1008
`
`EX-1009
`
`EX-1010
`
`EX-1011
`
`EX-1016
`
`EX-1021
`
`Description
`
`U.S. Patent No. 7,292,835 (“’835 patent”)
`
`Excerpts of prosecution file history for U.S. Patent No.
`7,292,835
`
`U.S. Patent No. 4,682,117 (“Gibson”)
`
`U.S. Patent No. 5,339,459 (“Schiltz”)
`
`J. Crols, A Single-Chip 900 MHz CMOS Receiver Front-
`End with a High Performance Low-IF Topology, 30
`IEEE JOURNAL OF SOLID-STATE CIRCUITS 1483
`(Dec. 1995) (“Crols”)
`
`L. Goldberg, “MCNS/DOCSIS MAC Clears a Path for
`the Cable-Modem Invasion,” Electronic Design; Dec. 1,
`1997; 45, 27; Materials Science & Engineering
`Collection pg. 69 (“Goldberg”)
`
`U.S. Patent No. 6,011,548 (“Thacker”)
`
`ITU-T J.83 Recommendation (April 1997) (“ITU-T
`J.83”)
`
`Declaration of Brenda Ray
`
`Declaration of June Munford
`
`Claim Construction Order, ParkerVision, Inc. v. Intel
`Corp., No. 6:20-cv-00108 (W.D. Tex. Jan. 26, 2021)
`(ECF 75)
`
`J. Crols, A 1.5 GHz Highly Linear CMOS
`Downconversion Mixer, 30 IEEE JOURNAL OF
`SOLID-STATE CIRCUITS 736 (July 1995)
`
`iii
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`MEDIATEK EX. 1003
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`I, Dr. Lawrence E. Larson, declare as follows:
`
`I.
`
`INTRODUCTION
`1.
`I have been retained by Petitioner MediaTek Inc. ( “MediaTek”) to
`
`serve as an independent expert consultant in Inter Partes review proceedings
`
`regarding U.S. Patent No. 7,292,835 (“the ’835 patent”) (EX-1001). I have been
`
`asked to consider the validity of claims 1-5 of the ’835 patent (the “Challenged
`
`Claims”). My opinions are set forth below.
`
`2.
`
`I am being compensated at my normal rate of $600/hour for all
`
`services rendered. My compensation is not dependent, in any way, on the nature of
`
`my findings, the content of my testimony, or the outcome of this proceeding or any
`
`other proceeding.
`
`3.
`
`4.
`
`I have no other interest in this proceeding.
`
`My analysis of the materials provided in this proceeding is ongoing
`
`and I will continue to review any new materials that are provided. This declaration
`
`is indicative of only those opinions that I have formed to date. I reserve the right
`
`to amend, revise, and/or supplement my opinions stated herein based on any new
`
`information that may become available to me or my continuing analysis of the
`
`materials already provided.
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`II. QUALIFICATIONS
`5. My qualifications for forming the opinions in this report are
`
`summarized here and explained in more detail in my Curriculum Vitae (“CV”),
`
`which is attached as Appendix A to this declaration.
`
`6.
`
`I hold a Ph.D. in Electrical Engineering from the University of
`
`California, Los Angeles (“UCLA”) (1986), as well as a M.B.A. degree from
`
`UCLA (1996), and Master of Engineering and Bachelor of Science degrees in
`
`Electrical Engineering from Cornell University (1980 and 1979, respectively).
`
`7.
`
`I am currently Professor of Engineering at the School of Engineering,
`
`Brown University. I have also held the positions of Interim Provost of Brown
`
`University, as well as Sorensen Family Dean and Founding Dean of the School of
`
`Engineering. I held the position of Dean beginning in 2011, during which time I
`
`oversaw a large expansion in the number of tenure-track engineering faculty,
`
`substantial increases in external research funding, the creation of new graduate
`
`programs, and the construction of a state-of-the-art research and teaching facility.
`
`8.
`
`I have over 40 years of experience in the design of high-performance
`
`circuits for RF communications and other applications, both in industry and
`
`academia. Those include but are not limited to the following work experience.
`
`9.
`
`From 1980 to 1988, I was a Member of Technical Staff at Hughes
`
`Aircraft and Hughes Research Laboratories, where I was responsible for the
`
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`
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`development of CMOS and III-V analog and digital integrated circuits, modeling
`
`and characterization of MESFETs and HEMTs and the development of improved
`
`III-V process techniques. During my tenure, among other things, I helped
`
`developed the first high-performance GaAs switched-capacitor circuits with clock
`
`rates in excess of 100 MHz, demonstrated the first use of low-temperature buffer
`
`GaAs MESFET technology with digital integrated circuits, setting a record for
`
`digital divider performance (22 GHz), and developed GaAs MESFET operational
`
`amplifier with record GBW (10 GHz).
`
`10. From 1988 to 1992, I was an Adjunct Associate Professor at UCLA,
`
`where I was responsible for senior level digital and analog integrated circuit design
`
`courses and a graduate analog MOS integrated circuit design course.
`
`11. From 1992 to 1994, I was an Assistant Manager for the DARPA /
`
`Hughes MIMIC Program, where I was responsible for Program Management of the
`
`Advanced Technology Portion of DARPA/Hughes MIMIC Program, with a budget
`
`of approximately $8M/yr. In that capacity, I was responsible for the technical and
`
`program direction of GaAs HBT and PHEMT efforts. I also directed insertion of
`
`advanced GaAs-based technology into next generation communication and radar
`
`systems.
`
`12. From 1988 to 1996, I was also a Manager in the HEMT Technology
`
`Department, Microwave Devices and Circuits Laboratory, at Hughes Research
`
`3
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`
`Laboratories, where I directed research in high-speed III-V materials, devices, and
`
`circuits, and was responsible for approximately $4M/yr. in Corporate IR&D and
`
`Government Research Contracts. In that capacity, I helped develop the first space-
`
`qualified InP low-noise millimeter wave HEMT. This effort was awarded the 1996
`
`Lawrence Hyland Award – the highest technical achievement award at Hughes
`
`Electronics. I also helped develop the first micromachining (MEMS) switch and
`
`tuner applications for RF and microwave applications (1991). This technology has
`
`now become an extremely active area of worldwide research and development. I
`
`also helped demonstrate the first InP-based HEMT low-noise and high- power
`
`MMICs from 2– 60 GHz, with world record noise figures and power-added
`
`efficiencies. I further helped establish a state-of-the-art InP HEMT MMIC foundry
`
`at HRL, developed the first low-power/high-speed InP HEMT digital IC
`
`technology with ring oscillator delays of 4.2 pS, and directed the research program
`
`that demonstrated HEMTs with record fT’s and fMAX’s above 300 GHz (1993),
`
`which produced the highest frequency room temperature integrated circuit ever
`
`reported – a 210 GHz VCO (IEDM 1994).–
`
`13. From 1994 to 1996, I was a Manager in the Telecommunications
`
`Technology Department, Microwave Devices and Circuits Laboratory, at Hughes
`
`Research Laboratories, where I directed the research and development of
`
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`integrated circuits for commercial RF and microwave communications
`
`applications, including DBS, cellular telephone, VSAT, and PCS.
`
`14. From 1996 to 2011, I held the CWC Industry Chair Professor in
`
`Wireless Communications, in the Department of Electrical and Computer
`
`Engineering at the University of California, San Diego (UCSD). Among other
`
`things, I helped develop improved integrated circuit techniques and novel device
`
`structures for wireless communications applications. This required development of
`
`high-frequency integrated circuits, devices, and packaging techniques for ultra-
`
`wide bandwidth telecommunications applications, and development of novel data
`
`converter and analog-signal processing architectures that are matched to
`
`communications applications.
`
`15. From 2000 to 2001, while on academic leave from UCSD, I was a
`
`Director at IBM’s West Coast Design Center of Excellence in IBM Research
`
`Division, where I directed development of Radio Frequency Integrated Circuits for
`
`SiGe RFICs for 3rd Generation wireless cellular applications. I was also
`
`responsible for leading the team that developed a complete Wideband CDMA chip
`
`set for several “first tier” cellular telephone providers.
`
`16. From 2001 to 2006, I was the Director of the UCSD Center for
`
`Wireless Communications (http://cwc.ucsd.edu), which is one of the largest
`
`industry-funded University Research Centers in the world. Involving over 20
`
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`professors, and supporting roughly 50 PhD graduate students during my tenure,
`
`with an annual budget in excess of $3M, the CWC conducted research in all areas
`
`of wireless communications, from fundamental devices and materials to software
`
`applications. I was responsible for all aspects of the Center, from new member
`
`development to financial management and establishing the research direction.
`
`17. From 2007 to 2011, I was the Chair of the Department of Electrical
`
`and Computer Engineering at the University of California, San Diego. The ECE
`
`Department at UCSD is the largest graduate program on the UCSD campus. As
`
`Chair, I oversaw the faculty development (hiring, promotion, and tenure process),
`
`educational policy and teaching, successful accreditation review, department
`
`resource allocation, and external relations. I also led the development (with CS) of
`
`the Executive Masters of Advanced Study in Embedded Wireless Systems
`
`program.
`
`18.
`
`I have authored more than 125 refereed journal publications and more
`
`than 250 peer reviewed conference publications. I have also authored and/or
`
`edited 12 books or chapters, and am a named inventor on at least 43 issued patents.
`
`The works that I have authored include the following.
`
`• L. E. Larson, RF AND MICROWAVE CIRCUIT DESIGN FOR WIRELESS
`COMMUNICATIONS (Artech House, Inc., 1996).
`
`• J. Groe, and L. E. Larson, CDMA MOBILE RADIO DESIGN: SYSTEMS,
`ALGORITHMS, AND CIRCUITS (Artech House, Inc., 2000).
`
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`
`• CIRCUITS AND SYSTEMS FOR FUTURE GENERATIONS OF WIRELESS
`COMMUNICATIONS, A. Tasic, W. Serdijn, L. Larson, G. Setti, G.
`(Eds.), 2009, VIII, Springer.
`I have been elected a Fellow of the IEEE. The Fellow is the highest
`
`19.
`
`grade of membership of the IEEE, a world professional body consisting of over
`
`300,000 electrical and electronics engineers, with only one‐tenth of one percent
`
`(0.1%) of the IEEE membership being elected to the Fellow grade each year.
`
`Election to Fellow is based upon votes cast by existing Fellows in IEEE. I have
`
`also served on a number of IEEE Committees and as a Paper Reviewer.
`
`III. SUMMARY OF OPINIONS AND MATERIALS CONSIDERED
`20. All of the opinions contained in this declaration are based on the
`
`documents I have reviewed and my professional judgment, as well as my
`
`education, experience, and professional knowledge. I am not an attorney and I am
`
`not offering any legal opinions in this declaration.
`
`21.
`
`In forming my opinions expressed in this declaration, I have relied on
`
`the ’835 patent (Ex. 1001), the prosecution history of the ’835 patent, excerpts of
`
`which have been filed as Exhibit 1002, the prior art references cited herein, and
`
`other exhibits I have cited in this declaration. Each of these documents is a type of
`
`document that an expert in my field would have reasonably relied upon when
`
`forming their opinion.
`
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`22. My opinions are additionally guided by my appreciation and
`
`understanding of how a person of ordinary skill in the art would have understood
`
`the Challenged Claims of the ’835 patent at the time of the alleged invention. I
`
`understand that while MediaTek does not concede that the Challenged Claims have
`
`an earlier priority than the filing date of the ’835 patent, MediaTek contends that
`
`the earliest possible priority date for the Challenged Claims is January 28, 2000.
`
`For purposes of this declaration only, I have assumed that January 28, 2000 is the
`
`priority date for the Challenged Claims (“Priority Date”). Outside of whether
`
`certain references qualify as prior art depending on the priority date that applies, I
`
`am not aware that my opinions herein are impacted in any other way by the issue
`
`of which priority date applies.
`
`23. Based on my experience and expertise, and for the reasons set forth
`
`herein, it is my opinion that:
`
`• Claims 1–5 of the ’835 patent are unpatentable in view of U.S. Patent No.
`
`4,682,117 (“Gibson”) (Ex. 1004) and U.S. Patent No. 5,339,459
`
`(“Schiltz”) (Ex. 1005);
`
`• Claims 1–5 of the ’835 patent are unpatentable in view of J. Crols, A
`
`Single-Chip 900 MHz CMOS Receiver Front-End with a High
`
`Performance Low-IF Topology, 30 IEEE JOURNAL OF SOLID-STATE
`
`CIRCUITS 1483 (Dec. 1995) (“Crols”) (Ex. 1006); and
`
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`• To the extent that the Board determines that “cable modem” as recited in
`
`claim 1 of the ’835 patent is limiting, then claims 1–5 of the ’835 patent
`
`are unpatentable in view of Gibson and Schlitz in further view of one or
`
`more of L. Goldberg, “MCNS/DOCSIS MAC Clears a Path for the
`
`Cable- Modem Invasion,” Electronic Design; Dec. 1, 1997; 45, 27;
`
`Materials Science & Engineering Collection pg. 69 (“Goldberg”)
`
`(Ex. 1007), U.S. Patent No. 6,011,548 (“Thacker”) (Ex. 1008), ITU-T
`
`J.83 Recommendation (April 1997) (“ITU-T J.83”) (Ex. 1009), and
`
`Applicant admitted prior art (“AAPA”) set forth in the ’835 Patent (Ex.
`
`1001) at column 40, lines 17-35.
`
`IV. LEVEL OF SKILL IN THE ART
`I understand that patent claims are interpreted from the perspective of
`24.
`
`a hypothetical person of ordinary skill in the art (“POSITA”) at the time of the
`
`alleged invention. As noted above, I have assumed for purposes of this declaration
`
`that the Priority Date of the Challenged Claims is January 28, 2000 (“Priority
`
`Date”). As of this date, I was at least a person of ordinary skill in the art of the
`
`technology relating to the ’835 Patent, and I had personal knowledge of the
`
`technologies involved in the ’835 Patent.
`
`25.
`
`I understand that various factors are considered in determining the
`
`level of ordinary skill in the art. I understand that the factors include the types of
`
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`problems encountered in the art, prior solutions to those problems, rapidity with
`
`which innovations are made, sophistication of technology at the time of the
`
`invention, and educational levels and experience of persons working in the field
`
`and capable of understanding the applicable scientific and engineering principles.
`
`I understand that in determining the level of ordinary skill in the art, not all factors
`
`may be present or one or more factors may predominate.
`
`26. Taking these factors into account, a POSITA relating to the
`
`technology of the ’835 patent on or before the date of the alleged invention would
`
`have had at least a bachelor’s degree in electrical engineering or a related subject
`
`and two or more years of experience in the field of RF circuit design, or would
`
`have had at least five years of work experience and training in the design and
`
`development of RF circuits and/or systems. Less work experience could be
`
`compensated by a higher level of education, such as a master’s degree.
`
`27. At least as of the date of the Priority Date of the alleged invention, my
`
`education, experience, and professional knowledge qualify me to be a POSITA for
`
`the ’835 patent. I am qualified to provide opinions on what a POSITA would have
`
`known and understood at the time of the alleged invention (e.g., at least as of the
`
`Priority Date).
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`V. BACKGROUND TECHNOLOGY
`A. Wireless Communications Signals
`28. Wireless devices (e.g., cellular phones) exchange information by
`
`transmitting and receiving electromagnetic signals. These signals are
`
`communicated from one device’s transmitter to another device’s receiver. The
`
`Challenged Claims focus on devices for receiving signals transmitted from another
`
`device.
`
`29. As of the Priority Date (and well before it), a communication device
`
`such as a cellular telephone would generate a signal for transmission (e.g., the
`
`voice information of a telephone call). Prior to the process of transmitting the
`
`signal, the signal would have low-frequency content (like voice) capable of being
`
`manipulated by the circuitry of the communication device. Such a signal was
`
`called a “baseband signal” because it was the signal prior to modulation for
`
`transmission and because the range of frequencies prior to modulation were
`
`relatively low compared to the frequencies used in transmission (hence, the “base”
`
`band).
`
`30. The baseband signal could have been digital or analog, and to transmit
`
`a digital baseband signal wirelessly, the digital signal sometimes required being
`
`converted into an analog signal. As shown below, an analog signal is a
`
`continuously changing signal. For electrical signals (other than direct current
`
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`signaling), an analog signal usually takes the form of varying voltage states over
`
`time. Those voltage states can be understood as a series of waveforms that
`
`oscillates at a particular frequency between maximum and minimum values, as
`
`shown below:
`
`
`
`B. Modulating Signals for Wireless Communications
`31. A wireless communications device ordinarily transmits a signal by
`
`propagating an electromagnetic wave using the frequency, phase, and magnitude of
`
`the underlying signal. Although all propagated electromagnetic signals travel at
`
`approximately the speed of light, “baseband” signals have relatively low
`
`frequencies and so cannot be effectively transmitted through the air between
`
`wireless devices. This is due to several reasons, including the size of the
`
`equipment needed to propagate and receive low-frequency signals, power
`
`requirements for such equipment, and signal interference at low frequencies.
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`32. As a result, to effectively transmit the information content of a
`
`baseband signal through the air, the baseband signal must be “imprinted” on or
`
`“upconverted” to a higher frequency signal—called a “carrier” signal—that can be
`
`transmitted more effectively through the air, including due to reduced equipment
`
`size and power requirements, as well as less signal interference.
`
`33. This “imprinting” process is called “modulation,” and modulation is
`
`usually achieved by altering one or more of the frequency, the phase, or the
`
`amplitude of the carrier signal. The following sections describe amplitude
`
`modulation and phase modulation, pertinent here, in more detail.
`
`Amplitude Modulation
`1.
`34. As shown below, modifying the carrier signal’s amplitude based on
`
`the amplitude of the baseband signal is known as “amplitude modulation.” The
`
`modified carrier signal is called an “amplitude modulated signal.”
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`35. Where such systems are (and were) used, the receiving device uses the
`
`frequency of the unmodulated carrier signal to recover the original baseband
`
`signal. In this way, the receiver extracts the amplitude modulations (or envelope of
`
`the carrier signal) and then uses that information to reconstruct the original
`
`baseband signal.
`
`Phase Modulation
`2.
`36. A baseband signal can also be transmitted wirelessly to another device
`
`by altering the “phase” of a carrier signal. This is called “phase” modulation, and
`
`an example of this is shown below.
`
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`
`37. The modified carrier signal is called a “phase modulated signal,”
`
`where the phase shifting represents the information content of the underlying
`
`baseband signal. In a system using “phase modulation” to transmit signals
`
`wirelessly, as in a system using amplitude modulation, the receiving device uses
`
`the frequency of the unmodulated carrier signal to recover the original baseband
`
`signal. In this way, the receiver extracts the phase shifts and then uses that
`
`information to reconstruct the original baseband signal.
`
`Quadrature Amplitude Modulation
`3.
`38. Quadrature amplitude modulation (QAM) was and is a well-known
`
`technique for modulating a carrier signal, using both amplitude and phase
`
`variations. QAM involves two carrier waves of the same frequency that are out of
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`
`
`phase with each other by 90 degrees, a condition known as “quadrature.” The
`
`amplitude of each of the two carrier waves are independently modified in
`
`amplitude to convey information. Often one signal is called the in-phase or “I”
`
`signal, and the other is called the quadrature-phase or “Q” signal. After
`
`modulation of these two carriers waves, the signals are combined and transmitted.
`
`See ’835 patent (Ex. 1001) at 40:35-51. The combined, transmitted wave thus has
`
`variations in amplitude and phase, depending on the information that it conveys.
`
`39. For example, information in a baseband signal may be represented by
`
`different combinations of amplitude and phase modulations, as shown below. In
`
`the example below, if the baseband signal contains the bit string or symbol “0011,”
`
`the QAM modulated wave may have a first amplitude and a first phase as shown
`
`on the top of the figure below. When the baseband signal contains the bit string or
`
`symbol “0101,” the QAM-modulated wave may have a second amplitude and a
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`second phase as shown in the middle of the figure below. And when the baseband
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`signal contains the bit string or symbol “1100,” the QAM-modulated wave may
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`have a third amplitude and a third phase, as shown in the bottom of the figure
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`below.
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`40. As with amplitude modulation and phase modulation schemes, the
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`receiver in a QAM system uses the frequency and phase of the unmodulated carrier
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`signal to recover the original baseband signal from the combined, modulated I and
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`Q carrier signals. In this process, the QAM receiver separates the in-phase
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`modulated signal from the quadrature-phase modulated signal and then recovers
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`the underlying information content using the “known” modulation scheme (e.g., by
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`using the separate, recovered I and Q signals to determine the “combined”
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`amplitude and phase for both signals, which corresponds to a particular symbol).
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`41. Recovery of the transmitted data is further illustrated below using
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`what is known as a “constellation” diagram, on which data symbols are represented
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`as coordinates of the recovered I signal (x-axis) and the recovered Q signal (y-
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`axis).
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`42. The example above is known as “16-QAM” because the combined
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`modulated wave can represent one of 16 symbols (with 4 bits per symbol). For,
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`example, when a receiver detects a wave having the “combined” amplitude and
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`phase corresponding to the green circle on the top right of the diagram, it interprets
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`this as the bit string or symbol “0011.” When the receiver detects a wave having
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`the “combined” amplitude and phase corresponding to the green symbol in the
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`upper left quadrant, it interprets it as the bit string or symbol “0101.” When the
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`receiver detects a wave having a “combined” amplitude and phase corresponding
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`to the green symbol in the lower left quadrant, it interprets this as the bit string or
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`symbol “1100.” And so on. In this way, the receiver can demodulate the QAM-
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`modulated signal and recover the transmitted information (e.g., a transmitted bit
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`string).
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`VI. OVERVIEW OF U.S. PATENT NO. 7,292,835
`A. Description of the Specification
`43. The ’835 patent is titled “Wireless and Wired Cable Modem
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`Applications of Universal Frequency Translation Technology.” ’835 patent (Ex.
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`1001) at (54). The patent provides that it relates to “frequency translation and
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`applications of same” and specifically “cable modem applications.” Id. at
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`Abstract, 1:50–54 (“The present invention is generally related to frequency
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`translation, and applications of same, and more particularly to wireless and wired
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`applications of cable modems using universal frequency translation technology.”).
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`44. As part of the patent’s disclosures, the patent discusses a “QAM
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`modulation mode receiver” that is used to down-convert and demodulate an input
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`signal that is modulated according to QAM. Id. at 42:43–43:57, Fig. 54B. While
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`the patent discusses that the receivers of the invention “may be implemented in
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`cable modems,” id. at 40:52–61, the patent also states that QAM “is a well known
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`technique for modulating digital signals using both amplitude and phase coding,”
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`id. at 40:37–51, and that “cable modem receivers . . . of the present invention may
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`be implemented using a variety of well known devices,” id. at 40:17–35 (listing
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`multiple “Broadcom Corporation” chips, modems, and digital cable tuners). In
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`other words, the described QAM receiver is implemented according to well known
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`modulation conventions in conventional equipment.
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`45. Additionally, the specification and the Challenged Claims do not
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`describe more than a basic, known structure for performing QAM down-
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`conversion, and have nothing specific related to “cable modems” Particularly.
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`Figure 54B (annotated below) depicts a modem (5402) receiving a signal (5416).
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`The signal (5416) comprises “two information signals modulated with an RF
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`carrier according to” the QAM modulation technique. ’835 patent at 42:43–43:57.
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`46. The received RF signal (annotated purple) is processed by two
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`modules: a first “UFD [or frequency down-conversion] Module” (5422) (annotated
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`red) and a second “UFD Module” (5424) (annotated green). An oscillator (5426)
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`(annotated pink) generates an in-phase oscillating signal (5434) (also annotated
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`pink), and a phase shifter (5428) (annotated orange) receives the in-phase
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`oscillating signal and outputs a quadrature-phase oscillating signal (5436) (also
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`annotated orange).
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`47. Figures 20A and 20A-1 (annotated below) depict exemplary
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`frequency down-conversion modules having “UFT [or universal frequency
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`translation] Module[s].” In each, the frequency down-conversion module is shown
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`to comprise a “frequency translation module” (e.g., a switch (2008) (annotated
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`blue)) and a storage module (e.g., a capacitor (2010) (annotated brown)).
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`In Figure 54B of the patent, frequency translation module (5422)
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`48.
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`“samples” the RF signal (5416) at a rate that is a function of the in-phase
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`oscillating signal (5434), creating a down-converted in-phase signal (5438)
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`(annotated yellow). Frequency translation module (5424) samples RF signal
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`(5416) at a rate that is a function of the quadrature-phase oscillating signal (5436),
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`creating a down-converted quadrature-phase signal (5440) (annotated gray). The
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`downconverted “I” and “Q” signals may be “information” signals with “more than
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`two possible states or voltage levels” according to the QAM modulation technique.
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`’835 patent at 43:17–20, 43:32–34.
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`Prosecution History
`B.
`49. The application that resulted in the ’835 patent (Application No.
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`09/770,665) was filed on January 29, 2001. ’835 patent (Ex. 1001) at (22). The
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`patent issued six years later on November 6, 2007. Id. at (45) Outside of a
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`November 30, 2004 restriction and/or election requirement, ’835 Prosecution
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`History (Ex. 1002) at 31–36, the Patent Office never issued an office action
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`rejecting the pending claims. Instead, th