Ericsson, Inc. and
`Telefonaktiebolaget LM Ericsson
`v.
`Intellectual Ventures II LLC
`
`
`
`___________
`
`
`
`
`
`
`
`
`
`
`IPR2014-01185
`U.S. Patent No. 7,269,127
`___________
`
`
`
`
`
`
`
`
`
`
`Patent Owner’s Demonstratives
`
`
`
`
`
`
`
`________________
`
`
`
`
`
`Exhibit IV 2012
`IPR2014-01185
`
`
`Telefonaktiebolaget LM Ericsson
`v.
`Intellectual Ventures II LLC
`
`
`
`___________
`
`
`
`
`
`
`
`
`
`
`IPR2014-01185
`U.S. Patent No. 7,269,127
`___________
`
`
`
`
`
`
`
`
`
`
`Patent Owner’s Demonstratives
`
`
`
`
`
`
`
`________________
`
`
`
`
`
`Exhibit IV 2012
`IPR2014-01185
`
`
`
`
`The ’127 Patent
`
`The ’127 Patent
`
`2
`
`
`
`U.S. Patent No.
`7,269,127
`to
`Mody et al.
`
`(Ex. 1001, ’127 Patent)
`
`3
`
`
`
`The ’127 Patent
`
`(‘127 Patent, FIGs 1-3 combined; POPR, pp. 4-5; POR pp. 5-6)
`
`4
`
`
`
`Claim 1
`A transmitter of a communication system, the transmitter comprising:
`
`
`
`an encoder having a pilot/training symbol inserter, the pilot/training
`symbol inserter configured to insert pilot symbols into data blocks and to
`combine training symbols with the data blocks;
`
`
`
`at least one modulator, each modulator having an inverse discrete
`Fourier transform ([I]DFT) stage and a cyclic prefix inserter, each modulator
`outputting a frame structure comprising a preamble structure and a data
`structure, the preamble structure comprising at least one training symbol
`and an enhanced training symbol; and
`
`
`
`at least one transmit antenna, each transmit antenna corresponding to
`a respective one or the at least one modulator, each transmit antenna
`transmitting the frame structure output from the corresponding modulator,
`wherein the enhanced training symbol is a single symbol.
`
`(’127 Patent, Claim 1)
`
`5
`
`
`
`The ’127 Patent: Transmitter
`
`(‘127 Patent, POR pp. 5-6)
`
`6
`
`
`
`The ’127 Patent – Time Domain Frame Structure
`
`(‘127 Patent, 3:51-54)
`
`(‘127 Patent, 7:32-39)
`
`(‘127 Patent, FIG 6; POPR, p. 7; POR, p. 9)
`
`7
`
`
`
`Claim 1
`A transmitter of a communication system, the transmitter comprising:
`
`
`
`an encoder having a pilot/training symbol inserter, the pilot/training
`symbol inserter configured to insert pilot symbols into data blocks and
`to combine training symbols with the data blocks;
`
`
`
`at least one modulator, each modulator having an inverse discrete
`Fourier transform ([I]DFT) stage and a cyclic prefix inserter, each modulator
`outputting a frame structure comprising a preamble structure and a data
`structure, the preamble structure comprising at least one training symbol
`and an enhanced training symbol; and
`
`
`
`at least one transmit antenna, each transmit antenna corresponding to
`a respective one or the at least one modulator, each transmit antenna
`transmitting the frame structure output from the corresponding modulator,
`wherein the enhanced training symbol is a single symbol.
`
`(’127 Patent, Claim 1)
`
`8
`
`
`
`Construction of “pilot symbol”
`
`Board’s
`Construction
`
`“the broadest reasonable construction is apparent
`from the context of the claims and specification”
`
`(Institution Decision, p. 8)
`
`Petitioner’s
`Construction
`
`“a symbol located in the data structure and used for
`performing synchronization”
`
`(Petition, p. 23)
`
`Patent Owner’s
`Construction
`
`“frequency domain symbol for refining the
`calibration of a receiver to a transmitter”
`
`(POR, p. 12)
`
`9
`
`
`
`“pilot symbol” is a frequency domain symbol
`
`See Hartogs Declaration ¶¶ 41, 42, 43
`
`(‘127 Patent, 7:26-28)
`
`(POR, pp. 13-15)
`
`10
`
`
`
`A “pilot symbol” Refines the Calibration of a
`Receiver to a Transmitter
`
`Petitioner’s Expert
`Dr. Haas
`
`(Ex. 2011, 57:11-68:13; POR, p. 18)
`
`11
`
`
`
`Petitioners’ Interpretation: “insert pilot symbols into data blocks”
`
`(Petition, p. 14)
`
`(Petition, p. 29)
`
`12
`
`
`
`Petitioners’ Interpretation: “insert pilot symbols into data blocks”
`
`(Ex. 2011, 29:16-20)
`
`(Motion for Observations, pp. 4-5)
`
`13
`
`
`
`Petitioners’ Interpretation: “insert pilot symbols into data blocks”
`
`(Ex. 2011, 14:10-18)
`
`(Motion for Observations, pp. 3-4)
`
`14
`
`
`
`Petitioners’ Interpretation: “insert pilot symbols into data blocks”
`
`(Ex. 2011, 31:6-14)
`
`(Motion for Observations, p. 5)
`
`15
`
`
`
`Petitioners’ Interpretation: “insert pilot symbols into data blocks”
`
`(Reply, p. 10)
`
`16
`
`
`
`Claim 1
`A transmitter of a communication system, the transmitter comprising:
`
`
`
`an encoder having a pilot/training symbol inserter, the pilot/training
`symbol inserter configured to insert pilot symbols into data blocks and
`to combine training symbols with the data blocks;
`
`
`
`at least one modulator, each modulator having an inverse discrete
`Fourier transform ([I]DFT) stage and a cyclic prefix inserter, each modulator
`outputting a frame structure comprising a preamble structure and a data
`structure, the preamble structure comprising at least one training symbol
`and an enhanced training symbol; and
`
`
`
`at least one transmit antenna, each transmit antenna corresponding to
`a respective one or the at least one modulator, each transmit antenna
`transmitting the frame structure output from the corresponding modulator,
`wherein the enhanced training symbol is a single symbol.
`
`(’127 Patent, Claim 1)
`
`17
`
`
`
`Patent Owner’s Interpretation: “insert pilot symbols into data blocks”
`
`Pilot symbols inserted
`into data blocks
`
`(‘127 Patent, 7:26-32)
`
`(POR, p. 20)
`
`18
`
`
`
`
`
`Instituted Grounds
`
`
`19
`
`
`
`Instituted Grounds
`
`• Claims 1, 2, 3, and 5 of the ’127 patent as
`obvious under 35 U.S.C. § 103 over Schmidl
`and Arslan;
`
`• Claims 4 and 6–10 of the ’127 patent as
`obvious under 35 U.S.C. § 103 over Schmidl,
`Arslan, and Kim; and
`
`• Claim 17 of the ’127 patent as obvious under
`35 U.S.C. § 103 over Schmidl, Arslan, Kim, and
`Heiskala.
`
`(Institution Decision, p. 21)
`
`20
`
`
`
`Claims 1-3 and 5
`Schmidl and Arslan
`(Ground 1)
`
`21
`
`
`
`The Encoder of Schmidl and Arslan Does Not
`“insert pilot symbols into data blocks”
`
`Arslan’s pilot
`portions are
`inserted between
`data blocks
`
`The claimed pilot
`symbols are
`inserted into
`data blocks
`
`(POR, pp. 23, 25, 26)
`
`22
`
`
`
`The Encoder of Schmidl and Arslan Does Not Include a
`“pilot/training symbol inserter”
`
`No “pilot/training
`symbol inserter” in
`Schmidl’s encoder
`
`(POR, p. 27)
`
`23
`
`
`
`The Encoder of Schmidl and Arslan Does Not Include a
`“pilot/training symbol inserter”
`
`No detail in Arslan’s transmitter – No
`“pilot/training symbol inserter”
`
`(POR, p. 27)
`
`24
`
`
`
`Claims 4 and 6-10
`Schmidl, Arslan and Kim
`(Ground 2)
`
`25
`
`
`
`Dependent Claims 4, 6-10
`4. The transmitter of claim 3, wherein each data block has a number of samples N, each
`training block of the at lease one training symbol has a number of samples NI, and the
`training block of the enhanced symbol has a number of samples NI, whereby NI=N/I, where
`I is an integer.
`
`6. The transmitter of claim 5, wherein J equals 4.
`
`7. The transmitter of claim 3, wherein the cyclic prefixes have a number of samples such
`that G=N/I, where I is art integer.
`
`8. The transmitter of claim 1, wherein the enhanced training symbol comprises a cyclic
`prefix and a training block, the cyclic prefix having a number of samples G, the training
`block having a number of samples NI, whereby NI =N/I, where N is equal to the number of
`samples of data blocks of the data structure and I is an integer, and whereby G NI /4.
`
`9. The transmitter of claim 8, wherein the training block is divided into four sections, each
`section having a number of samples NI/4.
`
`10. The transmitter of claim 9, wherein the cyclic prefix and each of the four sections
`comprises the same sequence.
`
`(’127 Patent, Claims 4, 6-10) 26
`
`
`
`Kim Is Directed Generally to a “timing and frequency
`offset estimation method for OFDM”
`
`Kim does not mention the use of
`“pilot symbols” and therefore
`cannot overcome the
`deficiencies of Schmidl and
`Arslan
`
`
`(POR, p. 28)
`
`27
`
`
`
`Claim 17
`Schmidl, Arslan, Kim and Heiskala
`(Ground 3)
`
`28
`
`
`
`Dependent Claim 17
`
`The transmitter of claim 8, wherein the number of modulators
`and transmit antennas is two, a first training block
`corresponding to a first transmit antenna being divided into four
`sections, each section having a number of samples NJ4, and a
`second training block corresponding to a second transmit
`antenna being divided into four sections, each section having a
`number of samples NI/4.
`
`(’127 Patent, Claim 17) 29
`
`
`
`Heiskala Is Directed Generally to “estimation of two
`propagation channels in OFDM”
`
`Heiskala does not mention the use
`of “pilot symbols” and therefore
`cannot overcome the deficiencies
`of Schmidl, Arslan, and Kim.
`
`
`(POR, p. 28)
`
`30
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