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`Case 6:21-cv-00520-ADA Document 36-15 Filed 03/16/22 Page 1 of 156
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`EXHIBIT 5-2
`EXHIBIT 5-2
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`Docket No.: 0107131.00696US2
`Filed on behalf of Intel Corporation
`By: Haixia Lin, Reg. No. 61,318
`Wilmer Cutler Pickering Hale and Dorr LLP
`1875 Pennsylvania Avenue, NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: haixia.lin@wilmerhale.com
`grant.rowan@wilmerhale.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`Intel Corporation
`Petitioner
`
`v.
`
`ParkerVision, Inc.
`Patent Owner
`___________________________________________
`
`Case IPR2020-01302
`____________________________________________
`
`DECLARATION OF VIVEK SUBRAMANIAN, PH.D.
`U.S. PATENT NO. 7,539,474
`CHALLENGING CLAIMS 1, 3, 4, 7, 9–12
`
`INTEL 1002
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`TABLE OF CONTENTS
`INTRODUCTION ............................................................................... 1
`I.
`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE ................... 1
`III. MATERIALS CONSIDERED............................................................... 4
`IV. LEGAL PRINCIPLES.......................................................................... 6
`A. Anticipation ............................................................................... 6
`B. Obviousness ............................................................................... 7
`C.
`“Means-Plus-Function” Claim Elements ...................................... 10
`LEVEL OF ORDINARY SKILL IN THE ART ..................................... 11
`V.
`VI. TECHNICAL BACKGROUND .......................................................... 12
`A. Wireless Communication Signals: Modulation.............................. 12
`1.
`Amplitude modulation ...................................................... 15
`2.
`Phase Modulation ............................................................ 16
`“Up-Conversion” and “Down-Conversion” .................................. 17
`B.
`I/Q Signal Processing ................................................................ 21
`C.
`D. Other Background Concepts ....................................................... 24
`VII. OVERVIEW OF THE ’474 PATENT .................................................. 29
`A.
`The Alleged Invention of the ’474 Patent ..................................... 29
`B.
`Relevant Prosecution History ..................................................... 38
`VIII. CLAIM CONSTRUCTION ................................................................ 39
`A.
`“combining module” (Claim 1) ................................................... 40
`IX. OVERVIEW OF THE PRIOR ART REFERENCES .............................. 43
`A.
`Larson and Butler ..................................................................... 43
`1.
`Larson ............................................................................ 43
`2.
`Butler ............................................................................. 46
`B. Arpaia ..................................................................................... 49
`SPECIFIC GROUNDS OF INVALIDITY ............................................ 55
`Ground I: Claims 1, 3, 4, 7, and 9–11 are anticipated by Larson ..... 55
`Claim 1 .......................................................................... 55
`Claim 3 .......................................................................... 72
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`A.
`
`X.
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`1.
`2.
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`i
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`B.
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`Claim 4 .......................................................................... 74
`Claim 9 .......................................................................... 75
`Claim 10......................................................................... 76
`Claim 11......................................................................... 78
`Ground II: Claims 1, 3, 4, 7, and 9–11 are rendered obvious by
`Larson and Butler ..................................................................... 80
`Claim 1 .......................................................................... 80
`Claim 3 .......................................................................... 92
`Claim 4 .......................................................................... 92
`Claim 7 .......................................................................... 92
`Claim 9 .......................................................................... 95
`Claim 10......................................................................... 96
`Claim 11......................................................................... 98
`Ground III: Claim 12 is anticipated by Arpaia.............................. 98
`Claim 12......................................................................... 98
`XI. AVAILABILITY FOR CROSS EXAMINATION ............................... 127
`XII. RIGHT TO SUPPLEMENT .............................................................. 128
`XIII. JURAT ........................................................................................... 128
`
`
`C.
`
`3.
`4.
`5.
`6.
`1.
`2.
`3.
`4.
`5.
`6.
`7.
`1.
`
`ii
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`I, Vivek Subramanian, declare as follows:
`
`I.
`
`INTRODUCTION
`1. My name is Vivek Subramanian. I am a Professor of Microtechnology
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`at the École polytechnique fédérale de Lausanne (EPFL) (also known as the Swiss
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`Federal Institute of Technology in Lausanne) in Switzerland. Until recently, I was
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`also a professor of Electrical Engineering and Computer Sciences at the University
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`of California, Berkeley. As of July 1, 2020, I have become an adjunct professor at
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`UC Berkeley upon completion of my move to EPFL.
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`2.
`
`I have been retained as an expert in this proceeding by counsel for Intel
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`Corporation. I have been asked for my expert conclusions regarding the validity of
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`claims 1, 3, 4, 7, and 9–12 of U.S. Patent No. 7,539,474 (the “’474 Patent”) (Ex.
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`1001-’474). For the reasons set forth below, it is my conclusion that claims 1, 3, 4,
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`7, and 9–12 of the ’474 patent are invalid.
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`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
`3. My qualifications are stated more fully in my curriculum vitae, which
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`is attached as Exhibit A. Below is a summary of my education, work experience,
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`and other qualifications.
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`4.
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`I received a bachelor’s degree summa cum laude in electrical
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`engineering from Louisiana State University in 1994. I received M.S. and Ph.D.
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`degrees in electrical engineering, in 1996 and 1998, respectively, from Stanford
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`University.
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`5.
`
`Throughout the course of my education, including my B.S., M.S., and
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`Ph.D. degrees, I was involved in designing and implementing wireless and high-
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`speed analog systems. For example, during my PhD, I designed RF CMOS radios,
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`including the transistor level design, simulation, layout, and characterization of the
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`same.
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`6.
`
`After completing my Ph.D., I held multiple appointments
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`simultaneously between 1998 and 2000. I served as a Consulting Assistant Professor
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`in the Electrical Engineering Department of Stanford University. I also served as a
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`Visiting Research Engineer in the Department of Electrical Engineering and
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`Computer Sciences at the University of California, Berkeley, where my research
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`focused on 25nm metal oxide semiconductor field effect transistor (MOSFET)
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`design and fabrication. I worked on technologies for high-performance transistor
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`processes, and I published several papers as a direct outcome of this technology
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`development.
`
`7.
`
`In 2000, I became an assistant professor at the University of California,
`
`Berkeley in the Department of Electrical Engineering & Computer Sciences. In
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`2005, I was promoted to the position of tenured Associate Professor, and in 2011, I
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`was promoted to full Professor. In 2018, I became a full Professor of
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`2
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`Microtechnology at EPFL in Switzerland, where I lead the Laboratory for Advanced
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`Fabrication Technologies (LAFT). The lab focuses on the development and
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`application of advanced additive fabrication techniques for realizing precision
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`microelectronic and electromechanical systems. As of 2020, I have completed my
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`move to EPFL and have therefore converted to an adjunct appointment at Berkeley.
`
`8. My research has maintained a large effort on RF systems. Specifically,
`
`throughout my many years at Berkeley, I maintained a regular research focus on
`
`RFID systems, including designing both readers and RFID tags.
`
`9.
`
`Starting in 2004, I was a founding technical advisor for Kovio. Under
`
`my leadership, Kovio re-focused on RFID and RF anti-theft systems. I led the
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`development of Kovio’s first commercial RFID tag product, including the design of
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`both the tag and the reader. My involvement with Kovio ended with Kovio’s
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`acquisition by Thin Film Electronics ASA, but Kovio continues to focus on this area.
`
`10.
`
`I co-founded Locix Inc. in 2014. Locix develops and sells a range of
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`wireless-enabled products, including proprietary Wi-Fi-based RF localization
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`systems and sub-GHz low-power wireless sensor networks. As CTO of Locix, I led
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`the development of the entire Locix RF product portfolio. I continue to be involved
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`with Locix on a regular basis.
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`11.
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`I have authored or co-authored over 200 technical papers in
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`international journals and conferences and have been named an inventor or co-
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`inventor on more than 50 patents, many of which cover aspects of RF circuits.
`
`12.
`
`I am being compensated for my time at my ordinary hourly rate of $650.
`
`My compensation is not dependent on the outcome of these proceedings or the
`
`content of my opinions. To the best of my knowledge, I have no financial interest
`
`in either party or in the outcome of this proceeding.
`
`III. MATERIALS CONSIDERED
`13.
`In preparing this declaration, I have reviewed the claims, specification,
`
`and file history of the ’474 patent. I understand that the ’474 patent issued on May
`
`26, 2009 from U.S. Patent Application No. 11/059,536 (filed February 17, 2005).
`
`The ’474 patent states that it is a continuation of U.S. Patent Application No.
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`09/526,041 (filed March 14, 2000). The ’474 patent also claims priority to
`
`provisional application 60/129,839 (filed on April 16, 1999).
`
`14.
`
`I have reviewed and understand the references and exhibits cited in this
`
`Declaration, including the following:
`
`Exhibit
`
`Description
`
`1001
`1003
`1004
`
`U.S. Patent No. 7,539,474 (“’474 patent”)
`’474 patent File History
`U.S. Patent No. 6,879,817 (“’817 patent”)
`
`4
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`
`
`1005
`
`1006
`1007
`1008
`1009
`1010
`1011
`1012
`1013
`1014
`1015
`1016
`1017
`1018
`1019
`1020
`
`1023
`
`1024
`
`1025
`
`1026
`
`Lawrence E. Larson, RF and Microwave Circuit Design for
`Wireless Communications (Artech House 1996) (“Larson”)
`U.S. Patent No. 4,603,463 (“Butler”)
`U.S. Patent No. 6,192,225 (“Arpaia”)
`U.S. Patent No. 4,639,619 (“Baldwin)
`U.S. Patent No. 4,712,070 (“Clark”)
`U.S. Patent No. 5,796,304 (“Gentzler”)
`U.S. Patent No. 5,263,196 (“Jasper”)
`U.S. Patent No. 6,014,054 (“Kawakita”)
`U.S. Patent No. 5,621,323 (“Larsen”)
`U.S. Patent No. 5,430,893 (“Myer”)
`U.S. Patent No. 6,230,000 (“Tayloe”)
`U.S. Patent No. 4,705,967 (“Vasile”)
`U.S. Patent No. 5,818,243 (“Wakamatsu”)
`E.U. Patent No. 1,016,209 (“Ferris”)
`Chris Bowick, RF Circuit Design (1982) (“Bowick”)
`Richard B. Curtin, Technique for Measuring Electric Field
`Signals Using a Differential Antenna System, IEEE
`TRANSACTIONS ON ELECTROMAGNETIC COMPATIBILITY (Mar.
`1967) (“Curtin”)
`ParkerVision v. Intel Corp., No. 6:20-cv-108, D.I. 24 (June 26,
`2020) (“Trial Setting Order”)
`ParkerVision v. Intel Corp., No. 6:20-cv-108, D.I. 25 (June 26,
`2020) (“Markman Setting Order”)
`Patent Owner’s Preliminary Infringement Contentions,
`ParkerVision v. Intel Corp., No. 6:20-cv-108 (June 26, 2020)
`Asad A. Abidi, Low-Power Radio-Frequency IC’s for Portable
`Communications, PROCEEDINGS OF THE IEEE, Vol. 83, No. 4
`(Apr. 1995) (“Abidi”)
`
`5
`
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`1027
`
`1028
`
`1029
`1030
`
`Asad A. Abidi, Direct-Conversion Radio Transceivers for Digital
`Communications, IEEE JOURNAL OF SOLID-STATE CIRCUITS, Vol.
`30, No. 12 (Dec. 1995) (“Abidi2”)
`David H. Shen, et al., A 900-MHz RF Front-End with Integrated
`Discrete-Time Filtering, IEEE JOURNAL OF SOLID-STATE
`CIRCUITS, Vol. 31, No. 12 (Dec. 1996) (“Shen”)
`U.S. Patent No. 6,438,366 (“Lindfors”)
`Jim Williams, Application Note 47, High Speed Amplifier
`Techniques, LINEAR TECHNOLOGY, (Aug. 1991) (“Williams”)
`
`
`IV. LEGAL PRINCIPLES
`15.
`I am not an attorney. For the purposes of this declaration, I have been
`
`informed by Intel’s counsel about certain aspects of the law that are relevant to my
`
`opinions, as stated in the following paragraphs. I have applied these legal principles
`
`in arriving at my conclusions expressed in this declaration.
`
`A. Anticipation
`16.
`I have been informed and understand that a patent claim is invalid if it
`
`is “anticipated” by prior art. For the claim to be invalid because it is anticipated, all
`
`of its requirements must have existed in a single device or method that predates the
`
`claimed invention, or must have been described in a single publication or patent that
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`predates the claimed invention. A patent claim may be “anticipated” if each element
`
`of that claim is present either explicitly, implicitly, or inherently in a single prior art
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`reference. I have also been informed that, to be an inherent disclosure, the prior art
`
`reference must necessarily disclose the limitation, and the fact that the reference
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`might possibly practice or contain a claimed limitation is insufficient to establish
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`that the reference inherently teaches the limitation.
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`B. Obviousness
`17.
`I have been informed and understand that a patent claim is invalid if it
`
`would have been obvious to a person of ordinary skill in the art (POSITA) at the
`
`time of the alleged invention. This means that, even if all of the requirements of a
`
`claim are not found in a single prior art reference, the claim is not patentable if the
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`differences between the subject matter in the prior art and the subject matter in the
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`claim would have been obvious to a POSITA at the time of the alleged invention.
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`18.
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`I have been informed and understand that a determination of whether a
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`claim was obvious should be based upon several factors, including, among others:
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`(1) the level of ordinary skill in the art at the time of the alleged invention; (2) the
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`scope and content of the prior art; (3) the differences, if any, that existed between
`
`the claimed invention and the prior art; and (4) any objective considerations of
`
`nonobviousness.
`
`19.
`
`I have been informed and understand that when determining any
`
`differences between the invention covered by the patent claims and the prior art, one
`
`should not look at the individual differences between the patent claims and the prior
`
`art in isolation, but rather consider the claimed invention as a whole and determine
`
`whether or not it would have been obvious in light of all of the prior art.
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`20.
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`I have been informed and understand that a single reference can render
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`a patent claim obvious if any differences between that reference and the claims
`
`would have been obvious to a POSITA. Alternatively, the teachings of two or more
`
`references may be combined in the same way as disclosed in the claims. I have been
`
`informed and understand that when deciding whether to combine the various items
`
`described in the prior art, the relevant question is whether the prior art combination
`
`would have been obvious to a person with ordinary skill in the art at the time of the
`
`invention. I have been further informed that it can be important to identify a
`
`teaching, suggestion, or motivation, in either the prior art or the knowledge of
`
`persons skilled in the art, that would have prompted a person of ordinary skill in the
`
`relevant field to combine the elements in the prior art in the way the claimed
`
`invention does.
`
`21.
`
`In determining whether a combination based on either a single
`
`reference or multiple references would have been obvious, it is appropriate to
`
`consider, among other factors:
`
`(cid:120) whether the teachings of the prior art references disclose known concepts
`
`combined in familiar ways, and when combined, would yield predictable
`
`results;
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`(cid:120) whether a POSITA would implement a predictable variation, and would
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`see the benefit of doing so;
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`(cid:120) whether the claimed elements represent one of a limited number of known
`
`design choices, and would have a reasonable expectation of success by a
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`POSITA;
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`(cid:120) whether a POSITA would have recognized a reason to combine known
`
`elements in the manner described in the claim;
`
`(cid:120) whether there is some teaching or suggestion in the prior art to make the
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`modification or combination of elements claimed in the patent; and
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`(cid:120) whether the innovation applies a known technique that had been used to
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`improve a similar device or method in a similar way.
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`22.
`
`I have been informed and understand that one of ordinary skill in the
`
`art has ordinary creativity and is not an automaton. I have been informed and
`
`understand that in considering obviousness, it is important not to determine
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`obviousness using the benefit of hindsight derived from the patent being considered.
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`I have been informed and understand that a patent composed of several elements is
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`not proved obvious merely by demonstrating that each of its elements was
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`independently known in the prior art.
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`23.
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`I have been informed and understand that to show a motivation to
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`combine, one is not required to show how the references would be physically
`
`combined to render a claim obvious. The analysis is not focused on whether the
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`features of one reference can be physically incorporated into the structure of another
`
`reference, but rather whether a person of ordinary skill in the art would have been
`
`motivated to combine the teachings of the references to achieve the claimed
`
`invention. For example, a person of ordinary skill in the art would understand how
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`predictable variations of known concepts could be combined and would recognize
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`that where multiple tools were available in a toolbox, any could be chosen.
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`C.
`24.
`
`“Means-Plus-Function” Claim Elements
`I have been informed and understand that a “means-plus-function”
`
`claim term is a term that recites a certain function but does not recite sufficient
`
`structure for performing that function. I understand that means-plus-function terms
`
`are limited to the function recited in the claim term and the specific structure
`
`disclosed in the patent’s specification for performing that function and structures
`
`that are equivalent to the disclosed structures.
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`25.
`
`I have been informed and understand that for means-plus-function
`
`limitations, a prior art reference or combination of references must disclose the
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`identical function in the claim limitation and must disclose a structure that performs
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`the function that is either identical to or the equivalent of the structure in the
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`specification of the challenged patent that performs the claimed function. I
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`understand that a structure can be equivalent if (a) the prior art element performs the
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`identical function specified in the claim in substantially the same way, and produces
`
`substantially the same results as the corresponding element disclosed in the
`
`specification; (b) a person of ordinary skill in the art would have recognized the
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`interchangeability of the element shown in the prior art for the corresponding
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`element disclosed in the specification; or (c) there are insubstantial differences
`
`between the prior art element and the corresponding element disclosed in the
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`specification.
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`V. LEVEL OF ORDINARY SKILL IN THE ART
`26.
`I have considered the ’474 patent from the perspective of a POSITA at
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`the time of the alleged invention. A person of ordinary skill in the art for the ’474
`
`patent would have had at least the equivalent of a bachelor’s degree in electrical
`
`engineering or a related subject and two or more years of experience in the field of
`
`radio frequency (RF) circuit design. Less work experience may be compensated by
`
`a higher level of education, such as a master’s degree, and vice versa. At the time
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`of the claimed invention, I would have qualified as a POSITA under this standard.
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`VI. TECHNICAL BACKGROUND
`27.
`I discuss below various technical concepts that are relevant to
`
`understanding the ’474 patent and the prior art. All of the concepts in this section
`
`were well-known long before the time of the ’474 patent.
`
`A. Wireless Communication Signals: Modulation
`28. Wireless devices (e.g., cellular phones) exchange information by
`
`transmitting and receiving electromagnetic signals. Prior to transmission,
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`information, such as telephone voice information, is encoded as a “baseband signal,”
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`which has a relatively low frequency. Because baseband signals have low
`
`frequencies, they cannot be effectively transmitted through the air between wireless
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`devices. Instead, baseband signals must be “imprinted” onto a higher “radio
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`frequency” (or “RF”) signal. That signal is referred to as a “carrier” signal, which
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`can carry the information wirelessly to another device. The process of “imprinting”
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`one signal onto another signal is referred to as “modulation.”
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`29. When a baseband signal is transmitted wirelessly, the baseband signal
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`is modulated onto a higher frequency signal (i.e., the carrier wave) that oscillates at
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`a particular frequency, as indicated below.
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`30. As shown above, the “amplitude” of the signal corresponds to how
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`much the signal oscillates between its “zero” or equilibrium value to its maximum
`
`or minimum values. The signal’s “phase” refers to the position of the signal within
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`its cycle as it oscillates. A full cycle of a signal is conventionally defined as spanning
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`360 degrees (or 2(cid:652)(cid:3)(cid:85)(cid:68)(cid:71)(cid:76)(cid:68)(cid:81)(cid:86)). For instance, as shown above, the signal begins at 0
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`degrees and peaks at 90 degrees ((cid:652)(cid:18)(cid:21)(cid:3)(cid:85)(cid:68)(cid:71)(cid:76)(cid:68)(cid:81)(cid:86)(cid:12). The signal crosses zero at 180 degrees
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`((cid:652)(cid:3)(cid:85)(cid:68)(cid:71)(cid:76)(cid:68)(cid:81)(cid:86)(cid:12), and the signal completes its cycle at 360 degrees (2(cid:652)(cid:3)(cid:85)(cid:68)(cid:71)(cid:76)(cid:68)(cid:81)(cid:86)(cid:12).
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`31. The analog signals shown below have the same frequency and
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`amplitude but have phases that are shifted with respect to each other by 90 degrees
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`((cid:652)(cid:18)(cid:21)(cid:3)(cid:85)(cid:68)(cid:71)(cid:76)(cid:68)(cid:81)(cid:86) or 0.25 cycles).
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`32. As another example, the two signal waves shown below are 180 degrees
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`((cid:652)(cid:3)(cid:85)(cid:68)(cid:71)(cid:76)(cid:68)(cid:81)(cid:86) or 0.5 cycles) out of phase. Because these two signals are essentially
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`“opposite” to each other, they are considered to be “inverted” with respect to each
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`other.
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`33. Encoding a lower frequency baseband signal onto a higher frequency
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`carrier signal is referred to in the art as “modulation.” To perform modulation, the
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`frequency, phase, and/or amplitude of the carrier signal can be modified (or
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`“modulated”) based on the frequency, phase, and/or amplitude of the baseband
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`signal. Some well-known examples of modulation are described in more detail
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`below.
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`1.
`Amplitude modulation
`“Amplitude modulation” refers to modifying the amplitude of the
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`34.
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`carrier signal based on the amplitude of the baseband signal, as shown below. Here,
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`the modified carrier signal is referred to as an “amplitude modulated signal,” which
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`can be transmitted over the air to a wireless device’s receiver.
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`35. The receiver “knows” the amplitude of the unmodulated carrier signal
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`ahead of time. When the receiver receives the amplitude modulated signal, it
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`therefore can recover the original baseband signal from the amplitude modulated
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`signal by comparing the amplitudes of the modulated signal and unmodulated carrier
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`signal.
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`2.
`Phase Modulation
`36. A baseband signal can also be sent over the air to another device using
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`phase modulation. In this example, the “phase” of the carrier signal is modified
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`based on the phase of the baseband signal, as shown below.
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`In this example, the modified carrier signal is called a “phase modulated
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`37.
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`signal,” which is transmitted to a wireless receiver. As in the case of amplitude
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`modulation, the receiver knows the phase of the carrier signal beforehand and can
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`obtain the baseband signal from the modulated carrier signal by comparing the
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`phases of the modulated signal and unmodulated carrier signal.
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`38. Both amplitude and phase modulation were well-known before the ’474
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`patent.
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`B.
`“Up-Conversion” and “Down-Conversion”
`39. Modulating a high-frequency carrier signal with a low-frequency
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`baseband signal to produce a high-frequency modulated signal is called “up-
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`conversion.” After the high-frequency modulated signal is transmitted to a device’s
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`receiver, the receiver needs to convert the modulated signal back down to a lower-
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`frequency signal that can be demodulated to recover and process the information
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`signal. This is achieved using a “down-conversion” method. Claims 1, 3, 4, 7, and
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`9–12 of the ’474 patent relate to down-converting a modulated RF signal. Down-
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`conversion methods have been well-known in the art long before the ’474 patent.
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`40. Generally, regardless of the methodology used, down-conversion shifts
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`the RF signal to a frequency called an intermediate frequency (IF), which has a lower
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`frequency than the RF signal. In some instances, the IF may be at “zero frequency,”
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`which indicates that the IF signal is a baseband signal. In other instances, the IF
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`signal may be at a non-zero frequency, in which case the signal generally will need
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`to be down-converted again until it reaches zero frequency (i.e., baseband). When
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`an IF signal is directly down-converted to a zero frequency, it may be referred to as
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`homodyne down-conversion. When an IF signal is first down-converted to a non-
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`zero frequency and then subsequently down-converted to a zero frequency, it may
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`be referred to as heterodyne down-conversion.
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`41. One well-known down-conversion structure—including the structure
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`disclosed in the ’474 patent and Larson—comprises a switch coupled to a capacitor
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`and to ground. (See, e.g., Ex. 1005-Larson, Fig. 5.36, 276-277; Ex. 1029-Lindfors,
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`Fig. 5, 7:54-56, 2:63-66, 8:9-15; Ex. 1026-Abidi, Fig. 22, 563; Ex. 1027-Abidi2,
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`Fig. 16, 1408; Ex. 1028-Shen, Fig. 7, 1947-48.)
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`42. The following are illustrations of well-known down-conversion
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`structures that comprise a switch coupled to a capacitor and to ground.
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`(Ex. 1005-Larson, Fig. 5.36.)
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`(Ex. 1029-Lindfors, Fig. 5.)
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`(Ex. 1026-Abidi, Fig. 22.)
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`(Ex. 1027-Abidi2, Fig. 16.)
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`(Ex. 1028-Shen, Fig. 7.)
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`C.
`I/Q Signal Processing
`43. Baseband signals may be generated and processed in the form of “I/Q
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`signals,” which are more convenient when using advanced modulation. “I/Q
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`modulation” or “I/Q signal processing” is a well-known technique to generate high
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`frequency modulated signals. I/Q signal processing was well known before the ’474
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`patent, and I/Q signal processing was commonly utilized by 3rd generation (3G) and
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`4th generation (4G) cellular standards. An example of a protocol implementing the
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`3G standard is Universal Mobile Terminal Communications Service (UMTS), and
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`an example of a protocol implementing the 4G standard is Long Term Evolution
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`(LTE).
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`44.
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`I/Q signal processing involves converting a digital baseband data signal
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`into two components: (1) an “in-phase” or “I” component of the signal, and (2) a
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`“quadrature” or “Q” component. The up-conversion process f