UNITED STATES PATENT AND TRADEMARK OFFICE
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`Patent No. 8,311,582
`Issue Date: November 13, 2012
`Title: ASYMMETRICAL BEAMS FOR SPECTRUM EFFICIENCY
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`PETITION FOR INTER PARTES REVIEW OF
`U.S. PATENT NO. 8,311,582
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`COMMSCOPE TECHNOLOGIES, LLC
`Petitioner,
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`v.
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`COMMUNICATIONS COMPONENTS ANTENNA INC.,
`Patent Owner
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`

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`U.S. Patent No. 8,311,582
`Petition for Inter Partes Review
`
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`TABLE OF AUTHORITIES ................................................................................... iii
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`TABLE OF CONTENTS
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`LISTING OF EXHIBITS ........................................................................................... v
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`I.
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`INTRODUCTION ........................................................................................... 1
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`II. GROUNDS FOR STANDING PURSUANT TO 37 C.F.R. § 42.104(A) ...... 2
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`III. OVERVIEW OF THE ‘582 PATENT AND PRIOR ART ............................. 2
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`A. Overview of the ‘582 Patent .................................................................. 2
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`B. Overview of the admitted prior art of the ‘582 Patent .......................... 5
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`C. Overview of Patent Owner’s Assertions Regarding Asymmetry ......... 9
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`D. Overview of Yea and the Metawave Website ..................................... 11
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`E.
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`F.
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`Overview of The Asymmetric Beam Prior Art ................................... 18
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`Overview of Mouly ............................................................................. 21
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`G. Overview of the Smith ‘935 Patent ..................................................... 21
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`H. Overview of CSA Antennas, Johansson and Ebine ............................ 22
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`I.
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`J.
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`Overview of Wästberg......................................................................... 22
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`Overview of Derneryd ......................................................................... 23
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`K.
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`Person of Ordinary Skill in the Art ..................................................... 23
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`IV.
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`IDENTIFICATION OF CHALLENGE PURSUANT TO 37 C.F.R. §
`42.104(B) ....................................................................................................... 24
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`A.
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`B.
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`Claims For Which Inter Partes Review Is Requested ......................... 24
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`The Prior Art And Specific Grounds On Which The Challenge To The
`Claims Is Based ................................................................................... 24
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`C.
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`Claim Construction ............................................................................. 25
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`D. How The Construed Claims Are Unpatentable ................................... 32
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`i
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`Petition for Inter Partes Review of U.S. Patent No. 8,311,582
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`E.
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`Supporting Evidence ........................................................................... 32
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`V.
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`THERE IS A REASONABLE LIKELIHOOD THAT AT LEAST ONE
`CLAIM OF THE ‘582 PATENT IS UNPATENTABLE ............................. 33
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`A.
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`B.
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`C.
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`Claim 1 is anticipated by Yea ............................................................. 35
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`Claim 1 is obvious in view of Yea and the Metawave Website and/or
`the Asymmetric Beam Prior Art.......................................................... 39
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`Independent Claims 13 and 20 are anticipated by Yea, or are obvious
`in view of Yea in combination with the Metawave Website and/or the
`Asymmetric Beam Prior Art ............................................................... 44
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`D. Dependent Claims 2, 6, 7, 9, 11, 12, 14, 15, 18, 19, 21, 22, 24, and 27
`are anticipated by Yea or are obvious in view of Yea and the
`Metawave Website .............................................................................. 47
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`E.
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`F.
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`Dependent Claims 3-5 are obvious in view of Yea and Mouly .......... 53
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`Dependent Claims 8, 16, and 23 are obvious in view of Yea and the
`Smith ‘935 Patent ................................................................................ 56
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`G. Dependent Claim 10 is obvious in view of Yea and CSA Antennas;
`and Dependent Claim 28 is obvious in view of Yea, the Metawave
`Website, Johansson and Ebine ............................................................ 58
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`H. Dependent Claims 17 and 25 are obvious in view of Yea in
`combination with Wästberg; and Dependent Claim 26 is obvious in
`view of Yea in combination with Derneryd ........................................ 60
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`VI. MANDATORY NOTICES PURSUANT TO 37 C.F.R. § 42.8(A)(1) ......... 63
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`A.
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`B.
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`C.
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`C.F.R. § 42.8(b)(1): Real Party-In-Interest ........................................ 63
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`C.F.R. § 42.8(b)(2): Related Matters ................................................. 63
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`C.F.R. § 42.8(b)(3) and (4): Lead and Backup Counsel and Service
`Information .......................................................................................... 63
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`VII. CONCLUSION .............................................................................................. 64
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`ii
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`Petition for Inter Partes Review of U.S. Patent No. 8,311,582
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`TABLE OF AUTHORITIES
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`Page(s)
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`Cases
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`Graham v. John Deere Co.,
` 383 U.S. 1 (1966) ................................................................................................. 33
`
`In re Am. Acad. Sci. Tech. Ctr.,
` 367 F.3d 1359, 1364 (Fed. Cir. 2004) .................................................................. 26
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`KSR Int’l Co. v. Teleflex, Inc.,
` 550 U.S. 398 (2007) ............................................................................................. 33
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`Microsoft Corp. v. Proxyconn, Inc.,
` 789 F.3d 1292 (Fed. Cir. 2015) ............................................................................ 25
`
`Other Authorities
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`Laird Technologies, Inc. v. Graftech International Holdings, Inc.,
` IPR2014-00023, Paper 1 (Petition) (Oct. 24, 2013) ............................................. 10
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`Rules
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`35 U.S.C. § 102(b) ................................................................................................... 33
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`37 C.F.R. § 42.104(A)................................................................................................ 2
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`37 C.F.R. § 42.104(B) .............................................................................................. 22
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`37 C.F.R. § 42.104(b)(3) .......................................................................................... 23
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`37 C.F.R. § 42.104(b)(4) .......................................................................................... 30
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`37 C.F.R. § 42.104(b)(5) .......................................................................................... 30
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`37 C.F.R. § 42.8(A)(1) ............................................................................................. 60
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`iii
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`Petition for Inter Partes Review of U.S. Patent No. 8,311,582
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`C.F.R. § 42.8(b)(2) ................................................................................................... 60
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`C.F.R. § 42.8(b)(3) ................................................................................................... 60
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`C.F.R. § 42.8(b)(4) ................................................................................................... 60
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`iv
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`Petition for Inter Partes Review of U.S. Patent No. 8,311,582
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`Exhibit 1001:
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`Exhibit 1002:
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`Exhibit 1003:
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`Exhibit 1004:
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`Exhibit 1005:
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`Exhibit 1006:
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`Exhibit 1007:
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`Exhibit 1008:
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`Exhibit 1009:
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`Exhibit 1010:
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`Exhibit 1011:
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`LISTING OF EXHIBITS
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`U.S. Patent No. 8,311,582 (“‘582 Patent”)
`
`Constantine A. Balanis and Panayiotis I. Ioannides,
`Introduction to Smart Antennas, Morgan & Claypool, (2007)
`(“Smart Antennas”)
`
`Valerio Palestini, Alternative Frequency Plans in Hexagonal-
`Shaped Cellular Layout, Proceedings of the 3rd International
`Symposium on personal, Indoor and Mobile Communications,
`IEEE, (1992)
`
`Michel Mouly, The GSM System for Mobile Communications,
`(1992) (“Mouly”)
`
`Digital Cellular Telecommunications system (Phase 2+);
`Mobile Radio Interface Layer 3 Specification (GSM 04.08),
`(December 1995)
`
`Mingbo Xiao, et al., Resource Management in Power-
`Controlled Cellular Wireless Systems, Wireless
`Communication and Mobile Computing, (2001)
`
`Juha Korhonen, Introduction to 3G Communications, Second
`Edition, Artech House, Boston/London, 2nd edition (2003)
`
`Ben Allen and Mark Beach, On the Analysis of Switched-Beam
`Antennas for the W-CDMA Downlink, IEEE Transactions of
`Vehicular Technology, Vol. 53, No. 3, (May 2004)
`
`John Litva and Titus Kwok-Yeung Lo, Digital Beamforming in
`Wireless Communications, Artech House, (1996) (“Litva
`Book”)
`
`Brian Collins, Base Station Antenna Design, Wireless Design &
`Development, (USA), June 1996)
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`U.S. Patent Application No. 12/094,299 Prosecution History
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`v
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`
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`Petition for Inter Partes Review of U.S. Patent No. 8,311,582
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`TenXc's Amended Complaint in Indian Litigation (“Indian
`Suit”)
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`Indian Patent No. 240893 (“Indian Patent”)
`
`Brian Collins Slides
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`Internet Archive Affidavit of Christopher Butler
`
`Ji-Hae Yea, Smart Antennas for Multiple Sectorization in
`CDMA Cell Sites, RF Design (April 2001) (“Yea”)
`
`Brian Collins, Asymmetry measurements
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`U.S. Patent 6,608,591, issued to Wästberg, et al. on August 19,
`2003 (“Wästberg”)
`
`U.S. Patent 6,104,935, issued to Smith, et al. on August 15,
`2000 (“Smith ’935 Patent”)
`
`Brian Collins, Description of Microsoft Excel spreadsheet for
`computation and the spreadsheet of radiation patterns of a 4-
`element linear broadside array
`
`Anders Derneryd and Bjorn Johansson, Adaptive base-station
`antenna arrays, Ericsson Review No. 3, (1999) (“Derneryd”)
`
`B. Christer V. Johansson and Sara Stefansson, Optimizing
`Antenna Parameters for Sectorized W-CDMA Networks, IEEE
`VTC (2000) (“Johansson”)
`
`Yoshio Ebine and Masaki Ito, A Dual Beam Base Station
`Antenna for Land Mobile Communication – 60° Beam Width in
`Horizontal Plane, Antenna and Propagation, 4-7 (April 1995)
`(“Ebine”)
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`Declaration of Brian S. Collins
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`vi
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`Exhibit 1012:
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`Exhibit 1013:
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`Exhibit 1014:
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`Exhibit 1015:
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`Exhibit 1016:
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`Exhibit 1017:
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`Exhibit 1018:
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`Exhibit 1019:
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`Exhibit 1020:
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`Exhibit 1021:
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`Exhibit 1022:
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`Exhibit 1023:
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`Exhibit 1024:
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`I.
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`Petition for Inter Partes Review of U.S. Patent No. 8,311,582
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`
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`INTRODUCTION
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`The Petition demonstrates that claims 1-28 of United States Patent No.
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`8,311,582 (Ex. 1001, “the ‘582 Patent”) are anticipated and/or obvious by the prior
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`art discussed herein. The claimed invention is directed to increasing network
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`capacity in a cellular communications system. The Patent Owner said the
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`invention does so by replacing conventional sector base station antennas with
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`multibeam base station antennas having asymmetrical beams that reduce overlap
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`with neighboring sub-sector coverage areas while maintaining the critical coverage
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`area of the replaced sector antenna. As shown herein, however, this was already
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`known in the prior art expressly, as well as inherently. The most pertinent of the
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`prior art was not considered by the Patent Office, including prior art that discloses
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`the precise grounds relied on by the Examiner in the Notice of Allowability.
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`Petitioner also provides declaratory evidence from Mr. Brian S. Collins
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`(“Collins Decl.” or Ex. 1024), which corroborates that a person of ordinary skill in
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`the art (“POSA”) would have understood these prior art references disclose the
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`subject matter of claims 1-28, including that it would have been obvious to a
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`POSA to combine certain of the references that render obvious the claims
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`challenged on obviousness grounds. Mr. Collins has worked in the field of cellular
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`communications systems for over 25 years and has extensive experience in antenna
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`system design, development, and manufacture, as well as on-site experience in
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`1
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`

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`Petition for Inter Partes Review of U.S. Patent No. 8,311,582
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`
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`installing, commissioning, and maintaining such systems. As explained herein,
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`there is a reasonable likelihood that at least one claim of the ‘582 Patent is
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`unpatentable under the identified grounds, and Petitioner requests that the Board
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`institute an inter partes review proceeding.
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`II. GROUNDS FOR STANDING PURSUANT TO 37 C.F.R. § 42.104(A)
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`Petitioner certifies that the ‘582 Patent is available for inter partes review
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`and that Petitioner is not barred or estopped from requesting this review
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`challenging the patent claims on the grounds identified herein.
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`
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`III. OVERVIEW OF THE ‘582 PATENT AND PRIOR ART
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`A. Overview of the ‘582 Patent
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`The ‘582 Patent (Ex. 1001) was filed November 18, 2008, as U.S. Patent
`
`Application No. 12/094,299 (“the ‘299 application”) and claims priority to PCT
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`Application No. PCT/CA2007/000434 filed March 19, 2007, and Canadian Patent
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`Application No. 2540218, filed on March 17, 2006. The ‘582 Patent issued
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`November 13, 2012, with 28 claims, of which Claims 1, 13, and 20 are
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`independent. Id.
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`The ‘582 Patent is directed to increasing network capacity in a cellular
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`communications system. Id., Abstract. According to the ‘582 Patent, there were a
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`number of technical limitations in wireless communications systems, including
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`“[a] first limitation is that the frequency spectrum is a scarce resource.” Id., 1:12-
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`2
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`Petition for Inter Partes Review of U.S. Patent No. 8,311,582
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`14, 17-32. A second limitation of prior art wireless communication systems was
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`their “finite communications range.” Id., 1:33-37.
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`The ‘582 Patent states that “[t]o overcome these two limitations, the cellular
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`concept has been introduced for wireless systems. To cover a large area, the
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`available resources are used for a small coverage area, called a cell, and repeated
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`for other cells. The expected number of subscribers that can be served by a
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`network will increase in proportion to the number of cells in the network.” Id.,
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`1:38-43. However, this gives rise to another set of challenges attributable to
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`increased risk of interference. Id., 1:44-50, 1:51-2:13. The Patent explains that it
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`was known in the prior art that capacity could be increased by replacing an omni-
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`directional antenna with a plurality of directional antennas. Id., 2:14-21.
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`According to the ‘582 Patent, however, “practical deployment
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`considerations will generally limit this. . .” because increasing sectorization greater
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`than three does not provide “optimal coverage” due to either “excessive overlap
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`between beam patterns or . . . [causing] an excessive number of conditions for
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`handover. . . [or] coverage holes [that] could result in handover failures.” Id.,
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`2:30-52.1
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`1 As a subscriber moves between sectors and cells, a call is automatically
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`transferred, a process known as “handover” (or “handoff”). Ex. 1024, ¶ 26.
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`3
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`Petition for Inter Partes Review of U.S. Patent No. 8,311,582
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`The ‘582 Patent explains that “alternative means of increasing network
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`capacity are under investigation, such as deploying antennas with optimized beam
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`patterns,” and that “it is desirable to provide an antenna with beam patterns that are
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`tailored for specific sector coverage.” Id., 3:6-13. The ‘582 Patent summarizes its
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`alleged invention: “In the present invention . . . an existing antenna is substituted
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`with a new one, which has substantially the same coverage area as the fixed cell
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`sector being replaced, but divided into a plurality of complementary asymmetrical
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`separate beams or sub-sectors.” Id., 4:32-38 (emp. added). Figure 3 of the ‘582
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`Patent (reproduced below) shows “a polar plot showing a single pair of
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`asymmetrical sub-sector beams overlaying a conventional tri-sector coverage
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`region,” and Figure 5 of the ‘582 Patent (reproduced below) shows “a cartesian
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`plot of a tri sub-section beam pattern overlying a conventional beam pattern
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`according to an embodiment of the present invention.” Id., 4:4-6 and 11-13.2
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`2 The shape of antenna beams is shown with “radiation patterns,” which may be
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`drawn in polar format or in Cartesian (X/Y) format. These formats represent the
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`same data and are both used by antenna engineers. Ex. 1024, ¶¶ 36-37.
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`4
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`Petition for Inter Partes Review of U.S. Patent No. 8,311,582
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`B. Overview of the admitted prior art of the ‘582 Patent
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`The ‘582 Patent describes conventional “pairs of symmetrical sub-sector
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`beams” as shown in the polar plot of Figure 1. Id., 3:66-67 and Fig. 1.
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`
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`The ‘582 Patent states: “Heretofore, antenna beam patterns have
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`consistently been symmetrical, such as in FIG. 1 . . . Such a coverage pattern
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`creates very large overlap regions between pairs of sub-sector beams (e.g. 130,
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`
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`5
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`

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`Petition for Inter Partes Review of U.S. Patent No. 8,311,582
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`131), and between a sub-sector beam from two adjacent sectors, e.g. 131, 110 (at
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`113).” Id., 4:61-67 (emp. added).
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`According to the ‘582 Patent, if such symmetrical beam patterns were
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`adjusted in order to ensure substantially similar handover treatment from the sub-
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`sectors defined by the new antenna to adjacent unmodified sectors and vice versa,
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`“the new beams would introduce excessive overlap as between themselves. On the
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`other hand, adjusting the beam patterns for the new sub-sectors so that the
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`handover between sub-sectors is manageable could result in coverage holes within
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`existing sectors.” Id., 5:1-9
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`The ‘582 Patent then compares “FIG. 2 [reproduced below], which shows 3
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`mirror-imaged pairs (210, 211), (220, 221), (230, 231) of asymmetrical sub-sector
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`beams to replace a traditional 3 sector configuration with a 6 sub-sector
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`configuration. . .” Id., 5:10-14 (emp. added).
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`6
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`Petition for Inter Partes Review of U.S. Patent No. 8,311,582
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`The ‘582 Patent states that “the use of asymmetrical beams ensures
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`handover region reduction by means of low overlap 212 of adjacent pairs of sub-
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`sector beams 210, 211 and between sub-sector beam 211 of a first pair and a sub-
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`sector beam 220, of a second pair, shown at 223.” Id., 5:13-18 (emp. added). The
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`‘582 Patent further states: “In both FIGS. 5 and 6, it may be seen that the
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`introduction of asymmetrical beams allows close approximation of the coverage
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`area of the conventional sector antenna being replaced, with small side lobes and
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`minimal overlap.” Id., 5:61-64 (emp. added).
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`When challenged independent claims 1, 13, and 20 are compared to the prior
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`art discussed in the ‘582 Patent, it is apparent that the only difference is the
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`independent claims require asymmetrical sub-sector beams that reduce the
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`handover regions by means of low overlap between adjacent pairs of sub-sector
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`beams and between the beams of a sub-sector while allowing close approximation
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`7
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`Petition for Inter Partes Review of U.S. Patent No. 8,311,582
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`
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`of the critical coverage area of the sector antenna being replaced. Regarding
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`alleged inventiveness, in order to gain allowance, the patentee amended the
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`independent claims and asserted during prosecution:
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`By using asymmetric beams, the overlapping areas between sub-
`sectors can be reduced so that the area not including the overlapped
`areas will be substantially equivalent to the coverage area of the
`replaced sector. . . Claims 1, 10 and 30 have been amended to recite
`“wherein said at least one asymmetrical sub-sector coverage area
`reduces overlap with said neighbouring sub-sector coverage area
`thereof while maintaining the critical coverage area of the replaced
`antenna.”
`Ex. 1011, at 42-43 (emp. original). The Applicants and Examiner agreed
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`that the amendment to Claims 1, 10 and 30 to recite the “wherein” limitation
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`“would overcome the prior art of record.” Id., at 43; Ex. 1024, ¶ 110.
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`In response, the Examiner issued a Notice of Allowability stating:
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`The prior arts Gilhousen, D1, Newman, Smith, and a thorough search
`discloses various aspects and features of applicant’s claimed invention
`but fail to explicitly or implicitly teach or disclose wherein said at
`least one asymmetrical sub-sector coverage area reduces overlap
`with said neighboring sub-sector coverage area comparing to overlap
`of the replaced antennae while maintaining the critical coverage
`area of the replaced antenna.
`Id., at 21 (emp. added).
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`8
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`Petition for Inter Partes Review of U.S. Patent No. 8,311,582
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`Notwithstanding the eventual allowance of the ‘582 Patent, replacing sector
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`antennas with sub-sector antennas having asymmetrical beams having reduced
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`overlaps compared to the overlaps of the replaced sector antenna while maintaining
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`the critical coverage area of the replaced antenna was already well-known in the
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`prior art as described herein. Moreover, this prior art was not before the Examiner
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`during examination of the ‘582 Patent. Ex. 1024, ¶ 112.
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`C. Overview of Patent Owner’s Assertions Regarding Asymmetry
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`On January 2, 2014, Patent Owner filed an amended suit in India against a
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`subsidiary of Petitioner, Andrew, Inc. (“Andrew”), in the High Court of Delhi at
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`New Delhi (“Indian Suit”) alleging that Andrew infringes Indian Patent No.
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`240893 (“Indian Patent”). Ex. 1012, Indian Plaint and Ex. 1013, Indian Patent No.
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`240893. The Indian Patent is a counterpart patent to the ‘582 Patent.3
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`
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`In the Indian Suit, Patent Owner accuses Andrew’s HBXX-3817TB-VTM
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`antenna (“Andrew Antenna”) of allegedly infringing the Indian Patent. 4 Ex. 1012,
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`¶¶ 21-22. As in the ‘582 Patent, the claims of the Indian Patent require that the
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`3 The Indian Patent and the ‘582 Patent claim priority to the same patent
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`application, have identical specifications, and two nearly identical independent
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`claims (1and 13) except that corresponding claims of the Indian Patent (1 and 10)
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`do not include the “wherein” clause in the independent claims of the ‘582 Patent.
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`4 Andrew and Petitioner deny that the Andrew Antenna infringes the Indian Patent.
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`9
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`Petition for Inter Partes Review of U.S. Patent No. 8,311,582
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`
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`beams of the replacement split-sector antenna include at least one “asymmetric
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`beam.” Id., ¶ 22; Ex. 1013, claims 1 and 10. Patent Owner further asserted that it
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`has an antenna product covered by the Indian Patent, the TenXc W65. Ex. 1012,
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`¶ 22. According to Patent Owner, visual observation of radiation patterns of the
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`TenXc W65 antenna and the Andrew Antenna show that the antennas allegedly
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`have “asymmetric beam patterns.” Id. Patent Owner stated that it further
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`established the alleged asymmetry “by deducting the asymmetricity of the beams
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`of [Andrew’s] products based on the beam pattern depicted in the figures [of the
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`TenXc W65 and Andrew Antenna], below (id.):
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`“Following is a table which establishes clearly that the beams emitted by
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`Defendant’s product are asymmetric for various levels of attenuation” (id.):
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`10
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`Petition for Inter Partes Review of U.S. Patent No. 8,311,582
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`D. Overview of Yea and the Metawave Website
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`At least as early as 2001, Metawave Communications Corp. (“Metawave”)
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`began publishing extensively on its SpotLight 2000 smart antenna system.5 This is
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`the system described in J. Yea, “Smart Antennas for Multiple Sectorization in
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`CDMA Cell Sites,” RF Design, at 28-38 (April 2001) (“Yea”) (Ex. 1016) and the
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`Metawave Website as it existed in 2001 (Ex. 1015, at 1-45), which included pages
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`publishing (1) a “Case Study”; (2) a “Seminar”; (3) a “Technology Brief”; (4)
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`“Key Features”; and (5) a “Sitesculptor” description. These pages are collectively
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`5 In Yea and the Metawave Website, references to the SpotLight 2000 smart
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`antenna system appear variously as “SpotLight”, SpotLightTM, and SpotLight®.
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`For ease of reference, all reference to the system herein are to “SpotLight.”
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`11
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`Petition for Inter Partes Review of U.S. Patent No. 8,311,582
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`referred to herein as the “Metawave Website.”6
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`Yea and the Metawave Website disclose the identical problem and solution
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`of the ‘582 Patent. Yea expressly discloses increasing subscriber capacity in a
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`sectorized cellular communications wireless network by replacing one or more
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`sector antennas with a split-sector antenna that generates a plurality of
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`asymmetrical sub-sector coverage areas that reduce overlap with neighboring sub-
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`sector coverage areas compared to overlap of the replaced antenna while closely
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`approximating the critical coverage area of the replaced antenna, as discussed in
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`the following paragraphs. Ex. 1024, ¶ 114.
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`The author of the Yea reference was a senior RF network engineer at
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`Metawave. Ex. 1016, at 17. Yea discloses results of a field trial of the SpotLight
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`2000 system. Id., at 5 (under “Case Study” section) and at Figs. 4 and 8 showing
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`radiation patterns from the tested SpotLight 2000 system. Id., at 9, 15. Yea
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`discloses that there was a need in the cellular communications network industry to
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`provide increased subscriber capacity. Ex. 1016, at 3. Yea discloses that
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`“increasing the number of sectors in a CDMA cell is a good way to increase
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`capacity. [But] [a]s the number of sectors increases, the total area of the softer
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`6 Ex. 1015 contains a Declaration from the Internet Archive for the Metawave
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`Website. Laird Technologies, Inc. v. Graftech International Holdings, Inc.,
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`IPR2014-00023, Paper 1 (Petition), at 16, 35-36 (Oct. 24, 2013).
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`handoff zones between sectors increases, which in turn increases the ‘handoff
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`overhead’ of the cell.” Id. Yea further discloses that increasing the sectorization
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`of a cell also increases interference and is expensive. Id. Yea discloses that
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`Metawave’s SpotLight 2000 system solved these problems by replacing three
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`sector antennas with three split-sector antennas to provide six-sectors. Id., at 28,
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`30. Yea further discloses that “[s]mart antenna systems make six-sector a practical
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`proposition. They do so in three principal ways: by reducing handoff overhead, by
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`easing the implementation burden and by facilitating successful optimization.” Id.,
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`at 3, 5. Ex. 1024, ¶ 116.
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`Yea further discloses that the field test “site was originally configured in
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`three-sector using conventional antennas and a Nortel Networks CDMA Metro
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`Cell base station . . . . Subsequently, a smart antenna system was installed . . .
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`[and] the site was taken to six-sector. Before and after ERP plots of the two
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`configurations are shown in Figure 4.” Id., at 30. ERP is a standard acronym for
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`Effective Radiated Power. Ex. 1024, ¶ 117.
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`Figure 4 of Yea shows the before and after polar ERP plots of the antenna
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`patterns of the conventional three-sector configuration (left) and the SpotLight
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`2000 six-sector configuration that replaced the three-sector antennas (right) (id., ¶
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`118):
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`Yea discloses that after replacement of the conventional three-sector
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`antennas with the SpotLight 2000 split-sector antennas, there was a “significant
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`increase in cell capacity [that] can be attributed to the control of handoff overhead.
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`Figure 8 compares Ec/I0 polar plots for the baseline three-sector configuration with
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`conventional antennas and the smart antenna six-sector configuration. [Ec/I0 is the
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`signal to interference ratio]. The size of the inter-sector softer handoff regions –
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`and thus the amount of handoff overhead – is indicated by the darker shaded
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`areas.” Ex. 1016, at 9; Ex. 1024, ¶ 120.
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`As is readily seen from Figs. 4 and 8, the split-sector antennas (right side of
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`Figs. 4 and 8) had a coverage area that closely approximated the coverage area of
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`the replaced three-sector antennas (left side of Figs. 4 and 8) but with reduced
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`overlap of beams between neighboring sub-sector coverage areas (darker shaded
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`areas of Fig. 8). Ex. 1016, at 9-15. Yea discloses that “[t]he main purpose of the
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`six-sector deployment was to provide increased site capacity. Metawave’s smart
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`antenna system delivered on that promise.” Id., at 9; Ex. 1024, ¶ 121.
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`Mr. Collins also measured Figs. 4 and 8 of Yea which further confirmed that
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`the six beams of the split-sector antennas of the SpotLight 2000 system are
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`asymmetrical, with Fig. 4 having 5° - 12° of asymmetry per beam and Fig. 8 having
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`2° - 9° asymmetry per beam. Ex. 1017; Ex. 1024, ¶ 122.
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`Mr. Collins also overlaid the radiation patterns of the split-sector antennas
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`from the right-side of Figs. 4 and 8 onto the radiation patterns of the replaced 3-
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`sector antennas from the left-side of Figs. 4 and 8, which are shown below with the
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`overlay of the radiation patterns from Fig. 4 on the left, and the overlay of the
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`radiation patterns from Fig. 8 on the right (Ex. 1024, ¶ 124):
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`300°
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`285°
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`270°
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`255°
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`240°
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`345°
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`0°
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`15°
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`330°
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`315°
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`30°
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`45°
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`345°
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`0°
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`15°
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`330°
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`315°
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`30°
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`45°
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`60°
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`75°
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`90°
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`105°
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`120°
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`300°
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`285°
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`270°
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`255°
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`240°
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`60°
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`75°
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`90°
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`105°
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`120°
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`225°
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`210°
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`195°
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`180°
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`165°
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`135°
`Slide 5: Radiation patterns 
`of replaced sectors and
`150°
`pairs of sub‐sectors
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`225°
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`210°
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`195°
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`180°
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`165°
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`135°
`Slide 10: Superposition of 
`right hand and left hand
`plots of Yea Fig 8.
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`150°
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`The overlaid images from Yea show that the six-sector radiation patterns are
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`asymmetrical with reduced overlap of beams between neighboring sub-sector
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`coverage areas comparing to the overlap of the replaced antennas while
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`maintaining the critical coverage area of the replaced antennas. Ex. 1024, ¶ 125;
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`Ex. 1014, Slides 5 and 10.
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`The Case Study page of the Metawave Website discloses that the field trial
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`of the SpotLight 2000 six-sector configuration increased capacity and that “the
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`operator was able to maintain the baseline 3-sector coverage footprint.” Ex. 1015,
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`at 13; Ex. 1024, ¶ 126.
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`The Seminar page of the Metawave Website also discloses: “Three
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`multibeam panel antennas [of the SpotLight 2000] replace the conventional
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`antennas on the tower, and rack-mounted equipment interfaces with your new or
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`existing base station equipment through standard RF input/output ports . . . .
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`SpotLight 2000 allows the user to craft custom antenna patterns based on 12
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`narrow beams produced by the three panel antennas . . . .” Ex. 1015, at 33. As
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`shown in the Seminar, the coverage of the SpotLight 2000’s twelve 30º narrow
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`beams can be sculpted by adjusting the per-beam gain and the per-beam phase of
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`each antenna, and to optimize softer handoff regions (id., at 39, 42; Ex. 1024, ¶
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`128):
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`The Technology Brief teaches that “SpotLight 2000’s Sector Synthesis
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`technology allows precise and flexible customization of CDMA antenna radiation
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`patterns . . . . SpotLight 2000’s software-controlled multibeam antennas display
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`much sharper sector rolloff than do conventional antennas . . . Additionally, Sector
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`Synthesis gives the operator the ability to reposition handoff zones from high-to
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`low traffic areas, further reducing handoff overhead.” Ex. 1015, at 16. The
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`Technology Brief discloses an “ERP plot of a SpotLight 2000 antenna pattern
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`shows ability to retract or extend coverage footprint” (id.; Ex. 1024, ¶¶ 130-132):
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`The Key Features page of the Metawave Website discloses: “The SpotLight
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`2000 smart antenna system . . . fill[s] in coverage gaps and improve[es] call quality
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`. . . . [The SpotLight 2000] reduce[s] antenna count and tower loading with
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`SpotLight’s three-panel antenna.” Ex. 1015, at 20. The multi-beam planar array
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`antenna panels of the system are shown (Ex. 1024, ¶ 133):
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`The Sitesculptor page discloses: “You can increase the capacity of a CDMA
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`cell site by using SpotLight 2000 to create custom antenna patterns that balance
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`sector traffic loads and minimize handoff overhead . . . . Select a pre-defined
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`sector