`Case 6:14-cv-00982-KNM Document 147-15 Filed 11/09/15 Page 1of4PagelD#: 1504
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`EXHIBIT 15
`EXHIBIT 15
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`Case 6:14-cv-00982-KNM Document 147-15 Filed 11/09/15 Page 2 of 4 PageID #: 1505
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`Inter Partes Review No.: Unassigned
`Petition For Inter Partes Review
`U.S. Patent No. 8,385,966
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
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`KYOCERA COMMUNICATIONS, INC.
`Petitioner
`v.
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`CELLULAR COMMUNICATIONS EQUIPMENT LLC
`Patent Owner
`
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`Patent No. 8,385,966
`Issue Date: February 26, 2013
`Title: METHOD, APPARATUS AND COMPUTER PROGRAM FOR POWER
`CONTROL RELATED TO RANDOM ACCESS PROCEDURES
`_______________
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`Inter Partes Review No. Unassigned
`____________________________________________________________
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`PETITION FOR INTER PARTES REVIEW
`UNDER 35 U.S.C. §§ 311-319 AND 37 C.F.R. § 42.100 ET. SEQ.
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`4836-7459-5105.3
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`Case 6:14-cv-00982-KNM Document 147-15 Filed 11/09/15 Page 3 of 4 PageID #: 1506
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`Inter Partes Review No.: Unassigned
`Petition For Inter Partes Review
`U.S. Patent No. 8,385,966
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`PUSCH_power = -RX_power + interference_correctoin +
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`offset_power + added_correction + power_ramp_up +
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`PC_correction + PUSCH_RACH_power_offset;
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`This rewritten equation shows that the transmit power for Message 3 is based
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`on f(0), i.e., the sum of the PC_correction (ΔPPC ) and the power_ramp_up value
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`(ΔPrampup). (Ex. 1002, ¶¶[0069]-[0071]).
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`The power_ramp_up variable is used as part of the preamble power and the
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`calculation of f(0). This use of the power_ramp_up value is consistent with the
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`‘966 patent’s use of the terms. (Ex. 1002, ¶¶[0073]-[0076]). Specifically, Claim 5
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`does not initially appear to be consistent with Claim 1. Specifically, Claim 1 notes
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`that the initial transmit power is based on the “preamble power” and f(0). Claim 5
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`recites Ppreamble but does not expressly recite f(0). (Ex. 1002, ¶[0075]). As noted in
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`the International Search Report of the corresponding PCT application, the equation
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`in Claim 5 does not appear to be consistent with the wording of Claim 1. (See, Ex.
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`1013). In the PCT application, Claim 6 as originally filed is the same as Claim 5 in
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`the ‘966 patent. (See Ex. 1014).
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`Claim 5 recites ΔPC_Msg3, which as explained below is equal to ΔPC when
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`calculating the power for Message 3. The formula in Claim 5, however, does not
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`expressly recite ΔPrampup. f(0), therefore, is not found in the equation as written in
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`Claim 5. The missing ΔPrampup, however, can be found in Claim 5 as part of the
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`4836-7459-5105.3
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`Case 6:14-cv-00982-KNM Document 147-15 Filed 11/09/15 Page 4 of 4 PageID #: 1507
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`Inter Partes Review No.: Unassigned
`Petition For Inter Partes Review
`U.S. Patent No. 8,385,966
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`Ppreamble calculation. (‘966 patent, 6:18-26; Ex. 1002, ¶¶[0075]-[0076]). Just as
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`above, the equation in Claim 5 can be rewritten with the Ppreamble variable expanded
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`per Equation 3 from the ‘966 patent. When this is done, Claim 5 recites a formula
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`for calculating a transmit power that depends on both Ppreamble and f(0) = ΔPPC
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`+ΔPrampup. (Ex. 1002, ¶¶[0074]-[0076]). Not allowing ΔPrampup to be considered
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`part of the preamble transmit power and f(0) leads to Claims 5 and 14 that cannot
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`be reconciled with Claims 1 and 11, respectively. (Ex. 1002, ¶[0076]).
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`Qualcomm, therefore, teaches calculating an initial transmit power that depends
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`on the “second power control adjustment state f(0).” (Ex. 1002, ¶¶[0073]-[0076])
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`Further, by calculating the sum of the PC_correction and the power_ramp_up
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`value as part of calculating the RACH power, Qualcomm teaches initializing f(0).
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`(Ex. 1002, ¶¶ [0069]-[0072]).
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`The ‘966 patent defines f(0) as both being calculated with ΔPPC +ΔPrampup and
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`reflecting an “open loop power control error.” (‘966 patent, Claim 1). Open loop
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`power control error can be represented as ΔPPC = P0_UE_PUSCH +f(0) - ΔPrampup. (Ex.
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`1002, ¶[0046] and ¶[0072]). This equation can be rewritten as f(0) = ΔPPC +
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`ΔPrampup - P0_UE_PUSCH. (Ex. 1002, ¶[0046]). Accordingly, the ΔPPC value that is
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`part of f(0) reflects an “open loop power control error.” (Ex. 1002, ¶[0046] and
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`¶[0072]). Qualcomm’s use of the PC_correction value, therefore, also reflects an
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`open loop power control error. (Ex. 1002, ¶¶[0071]-[0072]).
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`4836-7459-5105.3
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